Website accessibility is no longer an optional best practice in most major markets. The USA, UK, European Union, Canada, and Australia all have legal frameworks — some explicit, some principle-based — that require websites to be accessible to people with disabilities. The common thread across every jurisdiction is the Web Content Accessibility Guidelines (WCAG), typically at Level AA. Here is a country-by-country summary of what the law requires and what you need to do to meet it.
United States
Primary law: Americans with Disabilities Act (ADA) Title III, with Section 508 applying to federal agencies and contractors.
Standard required: WCAG 2.1 Level AA — confirmed by DOJ final rule (March 2024) for state and local government, and accepted as the practical benchmark for private sector businesses through court decisions.
Who it applies to: All "places of public accommodation" (broadly: businesses serving the public). Courts have applied this to websites, particularly where connected to a physical business. Online-only businesses face increasing litigation risk. Section 508 applies to federal government websites and federally funded programmes.
Enforcement: DOJ enforcement and private litigation. California also has state-level accessibility enforcement through the Unruh Civil Rights Act, which allows statutory damages of $4,000 per violation.
United Kingdom
Primary law: Equality Act 2010 (private sector); Public Sector Bodies (Websites and Mobile Applications) Accessibility Regulations 2018 (public sector).
Standard required: WCAG 2.1 Level AA — explicitly mandated for public sector; effectively the benchmark for private sector under the reasonable adjustments duty.
Who it applies to: All service providers (private sector) under the Equality Act; all public sector bodies under the 2018 Regulations. Public sector compliance is monitored by the Central Digital and Data Office (CDDO) and reported to the European Commission under the legacy EU monitoring requirement.
Enforcement: EHRC enforcement for Equality Act claims; CDDO monitoring and reporting for public sector. Private litigation under the Equality Act is possible but less common than in the US.
European Union
Primary laws: European Accessibility Act 2019/882 (private sector services, from June 2025); Web Accessibility Directive 2016/2102 (public sector).
Standard required: EN 301 549, which incorporates WCAG 2.1 Level AA for web and mobile content. The EAA is rapidly transitioning references to WCAG 2.2.
Who it applies to: E-commerce, banking, media, and other specified digital services (private sector, EAA); all public sector websites and apps (Web Accessibility Directive). Micro-enterprises (fewer than 10 employees AND turnover under EUR 2M) are exempt from the EAA's service requirements.
Enforcement: National market surveillance authorities in each member state, with significant variation in enforcement intensity across the EU27.
Canada
Primary laws: Accessible Canada Act 2019 (federally regulated sectors); Accessibility for Ontarians with Disabilities Act 2005 (Ontario, private sector with 50+ employees); other provincial accessibility legislation.
Standard required: WCAG 2.0 Level AA under AODA (with a transition path toward WCAG 2.1); WCAG 2.1 increasingly referenced in ACA guidance.
Who it applies to: Under AODA: private sector organisations with 50+ employees operating in Ontario must have WCAG 2.0 AA compliant websites. Federal organisations regulated by the ACA include banks, airlines, telecoms, and broadcasters — with progressive accessibility requirements toward WCAG 2.1. Quebec Law 25 requires accessibility considerations in privacy impact assessments for digital services.
Enforcement: AODA Director enforcement for Ontario non-compliance; CASDO (Canadian Accessibility Standards Development Organisation) and Transport Canada / CRTC for ACA sectors.
Australia
Primary law: Disability Discrimination Act 1992 (private sector); Digital Service Standard (Australian Government digital services).
Standard required: WCAG 2.1 Level AA — recommended by the Australian Human Rights Commission as the standard that satisfies DDA obligations. Australian Government websites are required to meet WCAG 2.1 AA under the Digital Service Standard.
Who it applies to: All service providers under the DDA (broad application to websites); Australian Government agencies under the Digital Service Standard.
Enforcement: Complaints to the Australian Human Rights Commission, with potential progression to the Federal Court. No dedicated accessibility regulator for the private sector. Enforcement is complaint-driven.
The practical conclusion
If you operate across multiple of these markets — as most online businesses do — the common denominator is WCAG 2.1 AA, with an eye toward WCAG 2.2 AA as the emerging standard. Building to WCAG 2.2 AA satisfies the legal requirements in all five jurisdictions and positions you ahead of the regulatory curve as standards update.