Which Accessibility Law Applies to My Website?

The honest first answer is: probably more than one, and probably not the one you assumed.

Web accessibility law does not follow where your company is registered. It follows where your users are, what sector you operate in, and whether you are public or private. A South African company selling to Irish consumers is subject to Irish law. A Canadian retailer with US customers can be sued in New York. A UK charity delivering a publicly funded service has obligations a UK shop does not.

Here is the map, jurisdiction by jurisdiction, with the version of WCAG each one actually names — because they differ, and that difference matters when someone tells you that you are behind.

European Union

Private sector: the European Accessibility Act. Directive (EU) 2019/882 applies from 28 June 2025 to a defined list of products and services — including e-commerce, consumer banking, e-books, electronic communications and elements of passenger transport. It reaches non-EU businesses selling into the EU. Microenterprises providing services (fewer than 10 employees and turnover or balance sheet not exceeding €2 million) are exempt; microenterprises dealing with products are not, though they get documentation relief.

Enforcement is national and varies substantially: different accessibility statement requirements, different regulators, different penalties. The first court rulings arrived in France in 2026 and went in opposite directions on a national revenue threshold. Our full guide to the EAA covers this in detail.

Public sector: the Web Accessibility Directive. Directive (EU) 2016/2102 has applied to public sector websites since 2020 and mobile apps since June 2021, requires a published accessibility statement following a prescribed model, and puts Member States on a three-year monitoring and reporting cycle.

The standard for both: EN 301 549, currently at version 3.2.1, which incorporates WCAG 2.1 Level AA. A version 4 aligning to WCAG 2.2 is at final draft stage but has not been published or cited in the Official Journal.

United States

The US is the most fragmented jurisdiction, and the most litigious.

Private business — ADA Title III. No federal regulation sets a technical standard for private websites. The obligation is the ADA's general requirement of effective communication, and it is enforced overwhelmingly through private litigation, with courts referring to WCAG without being bound to it. Filing volumes are at record levels — over 5,000 digital accessibility cases in 2025 by one count, with 2026 tracking higher. See website accessibility lawsuits.

State and local government — ADA Title II. The DOJ's 2024 rule adopts WCAG 2.1 Level AA. Compliance dates were extended in April 2026 to 26 April 2027 (populations of 50,000 or more) and 26 April 2028 (smaller entities and special districts) — and that extension is being challenged in federal court. See the ADA Title II web rule.

Federal agencies and their suppliers — Section 508. Still references WCAG 2.0 Level A and AA. If you sell software to the US federal government, this is the standard your Accessibility Conformance Report will be read against — a lower bar than Title II now imposes on state and local government.

State laws. Many states have their own IT accessibility statutes and policies, including Colorado, California, Illinois, Minnesota, Virginia, North Carolina, Oklahoma and others. Colorado's requires WCAG 2.1 AA for state agencies and local government entities, with rules effective from June 2025 — and it was explicitly unaffected by the federal extension.

United Kingdom

Public sector. The Public Sector Bodies (Websites and Mobile Applications) Accessibility Regulations 2018 have applied to all public sector websites since September 2020 and mobile apps since June 2021. The government's published guidance requires WCAG 2.2 Level AA, and the Government Digital Service has monitored against 2.2 since October 2024. A published accessibility statement is mandatory and should be reviewed at least annually. GDS monitors; the Equality and Human Rights Commission enforces.

Private sector. The Equality Act 2010 requires reasonable adjustments for disabled people in the provision of services, and that includes digital services. There is no prescribed technical standard, no deadline and no regulator-set WCAG level — enforcement is by individual claim. WCAG 2.2 AA is the sensible interpretation of "reasonable" in practice.

The EAA does not apply in the UK. UK businesses selling into the EU are caught by it directly.

Canada

Federal — the Accessible Canada Act. This is the significant recent development. New regulations registered in December 2025 set digital accessibility requirements incorporating CAN/ASC – EN 301 549:2024, Canada's adoption of the European standard. They cover web pages, mobile applications and downloadable documents, and require accessibility training, published accessibility statements, conformity assessment in procurement and four-year record retention.

They apply to federal departments, agencies and Crown corporations; large private-sector businesses with 500 or more employees; and medium businesses of 100–499 employees with narrower obligations. Businesses under 100 employees are exempt. Compliance dates run roughly 24 months from registration for public sector web pages and training (around December 2027) and 36 months for private sector web pages, mobile apps and procurement assessments (around December 2028).

Ontario — AODA. The operative web deadline was 1 January 2021: public websites and web content posted after 1 January 2012 must meet WCAG 2.0 Level AA, excluding the live captions and pre-recorded audio description criteria. It applies to public sector organisations and to private and non-profit organisations with 50 or more employees. Accessibility compliance reports are required from organisations with 20 or more employees, with the next filing deadline 31 December 2026. The AODA's statutory goal of a fully accessible Ontario by 1 January 2025 was an aspirational target, and Ontario did not meet it.

Australia

The Disability Discrimination Act 1992 applies to websites, established by a landmark 2000 decision, Maguire v SOCOG, concerning the Sydney Olympics site. The Act names no technical standard; enforcement runs through complaints to the Australian Human Rights Commission. The Commission's guidance, published November 2025, states that organisations should conform to WCAG 2.2 at a minimum of Level AA, and consider selected AAA criteria.

For federal government, the Digital Service Standard and the Digital Experience Policy make accessibility mandatory as policy, with the Digital Inclusion Standard applying to new services from January 2025 and existing services from July 2025.

Everywhere else

Most countries have disability discrimination legislation that a court could apply to a website, even where no digital-specific regulation exists. South Africa's Constitution and Employment Equity Act, for instance, prohibit unfair discrimination on the basis of disability, and SANS 1428 addresses accessibility, but there is no equivalent of the EAA's specific web mandate. The practical position for organisations in such jurisdictions is that domestic enforcement risk is low while export risk is not — the moment you sell into the EU or the US, their law is what matters.

The practical answer

For almost every commercial organisation, the answer to "which standard should we build to" is the same regardless of jurisdiction: WCAG 2.2 Level AA.

It is backward compatible, so it satisfies every law that names WCAG 2.0 or 2.1. It is the current W3C Recommendation and an ISO standard. It is what UK and Australian guidance already require. And it is where the EU and others are heading as EN 301 549 version 4 progresses.

Building to a single modern standard is also far cheaper than maintaining a matrix of jurisdictional variants, because the variation between them is smaller than the effort of tracking it.

Where jurisdiction genuinely does change your work is in the paperwork, not the code: which accessibility statement format you publish, which regulator you name in it, whether you need an Accessibility Conformance Report for procurement, and what records you must retain and for how long. Get the engineering right once, then handle the documentation per market.

*This article summarises published legislation, regulation and government guidance as at August 2026, drawing on EUR-Lex, the US Federal Register, GOV.UK, the Canada Gazette and the Australian Human Rights Commission. It is general information, not legal advice — obligations depend on your specific circumstances, and you should take advice from a qualified lawyer in the relevant jurisdiction.*