What are the legal requirements in relation to accessibility: do they differ depending on country?

The amazing @janique_morris gave a brilliant talk at TestBash Autumn on how to advocate for accessibility testing and how to implement it on your teams.
Followed by the talk was a very insightful live Q&A.

One of the questions we didn’t get a chance to ask live was from @paul_pbs:

What are the legal requirements in relation to accessibility: do they differ depending on the country?
E.g. UK based financial company legal compliance requirement?

What about you? What are the legal requirements in your country, if any?


Hey @paul_pbs!

Thank you for your question :smile:

So the short answer is yes, different legal requirements depend on the country and region.

For example:

The European Union has the The EU Web Accessibility Directive, which requires public sector websites and mobile applications to be accessible.

The United Kingdom has the The Equality Act of 2010, which addresses accessibility and discrimination. There is also a regulation called Public Sector Bodies (Websites and Mobile Applications) Accessibility Regulations, which states that public sector websites must also comply with the Web Content Accessibility Guidelines (WCAG).

The United States has the The Americans with Disabilities Act (ADA), which covers a wide range of areas such as public accommodations, employment, transportation, and telecommunications.

There is also a separate one for Canada, Australia, and Japan. They each have their law or act that speaks specifically to Accessibility.

It is important to note that compliance often involves adhering to international standards like the Web Content Accessibility Guidelines (WCAG), which provide a set of guidelines for making web content more accessible. However, the adoption and enforcement of these standards can vary depending on local laws and regulations.

Hope this helps!


Aside from locale conventions which will make your app unusable by locals, pretty much none. If you are not publishing into a regulated industry, there are very few requirements, any app that takes money directly, works in legal, medical or public sector will really fall to the product owner, not to the tester to seek compliance certificates to sell to that sector.

All the requirements we are talking about are not “law” per se, because software is incredibly broad. Industry bodies set out the rules, so it depends entirely on which industry you want to sell to. Yes, a few countries will make it hard to publish for example computer games, but very few do. In America, for example, state judges realised back in the 80’s that some software counts as “entertainment” and sadly, cannot be regulated. Start with your target industry body. In public sector, ADA is really the most interesting, and in my opinion powerful development lately ADA Standards for Accessible Design | ADA.gov

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ADA is more than 30 years old and pre-dates the world wide web! This is why US courts have had so much difficulty applying it to websites over the last 20 years or so. It’s still not fully settled now, with courts in different jurisdictions handing down opposing judgements on cases with the same facts. ADA does not mention any technical standards such as WCAG, although most law suits do refer to non-conformances with it.

The US also has Section 508 legislation, which applies to federal and federally-funded software of all kinds, not just websites. They also have the Communications and Video Accessibility Act (CVAA).

In the UK we have the legislation Janique mentioned, and there is also the Public Sector Equality Duty. The Public Sector Bodies (Websites and Mobile Applications) Accessibility Regulations does indeed mandate conformance with the level AA requirements of the latest WCAG version, but there are exemptions for certain content types such as legacy documents, legacy audio and video content, archives and maps that are not provided for navigation. It’s more complex than that, so you would need to read the actual legislation, which is surprisingly understandable, especially compared with the impenetrable EU and US laws.

The European Accessibility Act 2025
This will finally come into force on 28th June 2025 and will apply to many commercial organisations. It targets specific “essential” sectors such as banking, travel and communications rather than applying to the whole private sector. We don’t yet know if the UK government will adopt it, but I hope they do.

You can read it at EUR-Lex - 32019L0882 - EN - EUR-Lex or you can view a 46-page PDF version at https://eur-lex.europa.eu/legal-content/EN/TXT/PDF/?uri=CELEX:32019L0882.

Since it’s the EU, the act isn’t actually called “The European Accessibility Act 2025” or anything sensible . Believe it or not, it’s actual name is “Directive (EU) 2019/882 of the European Parliament and of the Council of 17 April 2019 on the accessibility requirements for products and services (Text with EEA relevance)”. You couldn’t make it up. But they did.


I’m so glad that as a tester I don’t really need to know much more than “we do WCAG 2.1 AA”.
For Germany and the sector we sell to we have the already mentioned EU accessibility act and BITV 2.0. Both reference WCAG, but BITV adds more sign language and easy German as an additional language option. So even inside the EU there are differences.


Ah, good old European protectionism at work. When I worked in manufacturing, the EU would produce a harmonised standard, then each country except the UK would add their own specific requirements to discourage manufacturers in other countries and protect their local suppliers. Nice to see the Germans now applying the same principles to IT standards.

I work for local public organizations and companies that provide digital public services. I see an increase in them requiring that their websites etc are WCAG compliant AA both for the internal customer support case management sites (admin/back office) and end-user/citizen-facing sites. Accessibility is for all kinds of users! I wrote about it here:

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