Digital accessibility laws in almost every region point to one technical yardstick, WCAG at Level AA, either directly or through a national standard built on it. The law decides who must act and who checks; WCAG decides what an accessible page looks like in code.
This page summarizes the main rules in the United States, the EU, the United Kingdom, Canada and India, names the official source for each, and shows where they overlap. Treat it as orientation, not legal advice: rules shift, every organization differs, and specific questions belong with a lawyer who knows the country involved.
Quick facts
United States
ADA for businesses and local governments, Section 508 for federal agenciesEU
Web Accessibility Directive (public sector) and the EAA, the EU accessibility act for many private services,, both through EN 301 549United Kingdom
Public sector sites must meet WCAG 2.2 AA and publish an accessibility statementIndia
RPwD Act, GIGW 3.0 for government sites, and a SEBI circular for regulated financial entitiesCanada
Accessible Canada Act federally; Ontario's AODA uses WCAG 2.0 AACommon thread
WCAG Level AA, so one well tested site can satisfy several regimes
Digital accessibility laws at a glance
The table gives the short version. The sections below explain each row and link the official text.
| Region | Main rules | Who they cover | Technical standard |
|---|---|---|---|
| United States | ADA Title II and Title III | State and local governments; businesses open to the public | WCAG 2.1 AA |
| United States | Section 508 | Federal agencies and the technology they buy | WCAG 2.0 AA |
| EU | Web Accessibility Directive | Public sector websites and apps | EN 301 549 (WCAG 2.1 AA for web) |
| EU | European Accessibility Act (EAA) | Many private products and services | EN 301 549 |
| United Kingdom | Public sector accessibility regulations, Equality Act | Public bodies; service providers generally | WCAG 2.2 AA for public sector |
| Canada | Accessible Canada Act; Ontario AODA | Federally regulated bodies; Ontario public sector and larger firms | WCAG 2.0 AA under AODA |
| India | RPwD Act, GIGW 3.0, SEBI circular | Government sites; SEBI regulated entities | WCAG 2.1 AA via GIGW |
W3C keeps a longer, country by country list on its web accessibility laws and policies page.
United States: ADA, Section 508, VPAT and ACR
ADA. The Americans with Disabilities Act reaches two groups online: public-facing businesses under Title III, and state and local governments under Title II. A DOJ rule sets WCAG 2.1 AA for Title II web content and apps; the start was pushed back twelve months by an interim final rule, and ada.gov lists the dates now in force. For Title III, judges and settlement agreements tend to measure sites against WCAG 2.1 AA. Our ADA website compliance page goes deeper.
Section 508. This law covers federal agencies and the technology they develop, buy or use. The revised 508 Standards apply WCAG 2.0 AA to web pages and also to documents and software. The official hub is section508.gov.
VPAT vs WCAG. WCAG is the standard; a VPAT is a form; the initials mean Voluntary Product Accessibility Template. A vendor fills it in to report, criterion by criterion, how its product measures up against EN 301 549, Section 508 or WCAG. The completed document is an ACR, an Accessibility Conformance Report. Buyers in government, universities and large companies often ask for one before they sign.
An ACR is only as good as the testing behind it. Ask who tested, which version of the product, and which method they used. A report that marks every row as supported with no remarks deserves a second look.
EU rules: the Directive, the EAA and EN 301 549
Web Accessibility Directive. The EU web accessibility directive covers public sector websites and mobile apps across member states. Public bodies must meet the standard, publish an accessibility statement, offer a way to report problems, and are monitored by national authorities.
The EAA. The European Accessibility Act reaches into the private sector: online shops, banking services, e-books, transport ticketing and more. It has applied since June. Very small service businesses, called microenterprises, are exempt from the service rules. Each member state puts the act into its own national law, so enforcement and penalties differ between countries.
EN 301 549 vs WCAG. EN 301 549 is the EU-wide standard for accessible information and communication technology. It is wider than WCAG: it has chapters for web content, documents, software, hardware and two-way voice and video. Its web chapter matches WCAG 2.1 AA word for word, so a website that meets WCAG 2.1 AA meets that chapter.
Readers in Ireland, Germany and other member states searching for terms like web accessibility laws Ireland or Barrierefreiheit WCAG land in the same place: the national law sits on top of the directive or the act, and the technical test is EN 301 549 and therefore WCAG.
United Kingdom
Public sector bodies in the UK must make their websites and apps meet WCAG 2.2 AA and publish an accessibility statement in a set format, listing known problems and how to get content in another form. The government explains the rules in its guidance for public sector websites and apps. Private companies are covered by the Equality Act, which asks service providers to make reasonable adjustments for disabled people; WCAG is the common way to show you have tried.
Canada and Ontario
The Accessible Canada Act applies to the federal government and federally regulated sectors such as banking, telecoms and air travel, with regulations that set out planning and reporting duties. The province of Ontario has its own law, the AODA, which requires public sector organizations and larger private ones to meet WCAG 2.0 AA on their websites, with some limited exceptions for live captions and audio description. Other provinces are writing their own rules, so check locally.
India: RPwD Act, GIGW 3.0 and the SEBI circular
RPwD Act. The Rights of Persons with Disabilities Act requires accessible information and communication technology, which includes websites and apps.
GIGW 3.0. Government websites follow GIGW 3.0, the official rulebook for Indian government sites, which lines up with WCAG 2.1 AA and adds local needs such as content in several languages.
SEBI digital accessibility circular. SEBI issued a circular on digital accessibility covering the firms it regulates, among them stock brokers, mutual funds, stock exchanges and depositories. It points to WCAG 2.1 and GIGW and asks for accessibility audits and yearly compliance reporting for websites, apps and other digital platforms.
The SEBI deadlines have been extended more than once. Before you plan work around a date, open the newest SEBI circular on sebi.gov.in and confirm with your compliance team.
When several laws apply at once
A company that sells in the US, the EU and India can easily fall under four rule sets. The good news is that they converge.
- Build to WCAG 2.2 AA. Every 2.0 and 2.1 AA criterion sits inside it (apart from the retired 4.1.1), so it covers every standard above. See WCAG 2.2 AA.
- Test properly. Combine automated scans with manual and screen reader checks; an accessibility audit gives you a dated record.
- Write things down. Keep an accessibility statement, a list of known issues with fix dates, and ACRs for your products.
- Check the official source. Dates and scope change; the links on this page go to the regulators themselves.
For help planning the work, see accessibility services and accessibility testing. For a ruling on your own duties, ask a lawyer.
Questions people ask
What is the EU Web Accessibility Directive?
It is an EU law that requires public sector websites and mobile apps to be accessible, using EN 301 549 as the standard. Each public body also posts an accessibility statement and offers users a route to flag problems.
What is the difference between EN 301 549 and WCAG?
WCAG covers web content only. EN 301 549 covers all kinds of ICT, including documents, software and hardware, and its web chapter matches WCAG 2.1 AA. Meeting WCAG 2.1 AA on a website meets that chapter.
What is a VPAT and how does it relate to WCAG?
A VPAT is a template vendors use to report conformance with any of three standards: WCAG, the 508 Standards or EN 301 549. Once filled in, it is called an Accessibility Conformance Report. WCAG is the standard; the VPAT is the way of reporting against it.
Who must follow the SEBI digital accessibility circular?
It is aimed at entities regulated by SEBI, such as stock brokers, depositories, exchanges and mutual funds. Its deadlines have been extended several times, so the newest circular on the SEBI site is the place to confirm scope and timing.
Do digital accessibility laws apply to mobile apps?
Usually yes. The ADA Title II rule, the EU directive and act, and the SEBI circular all mention apps or digital platforms beyond websites. WCAG principles apply to apps, often through EN 301 549.
Is meeting WCAG enough to satisfy these laws?
Meeting WCAG AA covers the technical part in most regions. Some laws add duties such as accessibility statements, feedback routes, reporting or procurement rules. A lawyer can confirm what else applies to you.