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Understanding Accessibility Legislation: EU, UK, and US Perspectives

The accessibility legislation is designed to ensure that all individuals, regardless of their disabilities, have equal access to services, facilities, products, and information. This post discusses essential features of the accessibility legislation and regulations in the EU, UK, and US, with a focus on digital compliance through the Web Content Accessibility Guidelines (WCAG).

Web Content Accessibility Guidelines 

The World Wide Web Consortium created the WCAG set of guidelines to improve the accessibility of web content for individuals with disabilities. 

The four guiding principles of these rules are:
  • Perceivable
    • Provide text alternatives for non-text content.
    • Provide captions and other alternatives for multimedia.
    • Create content that can be presented in different ways, including by assistive technologies, without losing meaning.
    • Make it easier for users to see and hear content.
  • Operable
    • Make all functionality available from a keyboard.
    • Give users enough time to read and use content.
    • Do not use content that causes seizures or physical reactions.
    • Help users navigate and find content.
    • Make it easier to use inputs other than keyboard.
  • Understandable
    • Make text readable and understandable.
    • Make content appear and operate in predictable ways.
    • Help users avoid and correct mistakes.
  • Robust
    • Maximize compatibility with current and future user tools.

Globally, adhering to these guidelines is regarded as best practice and improves accessibility for all users.

EU Accessibility Legislation

Scope of Application

The European Accessibility Act (EAA) aims to improve accessibility to products and services for elderly individuals and persons with disabilities within EU Member States. This directive applies to economic operators both within and outside the EU that provide products or services within the EU.

  • Computers and operating systems
  • ATMs, ticketing, and check-in machines
  • Smartphones
  • Banking services
  • E-books
  • E-commerce
  • TV equipment related to digital television services
  • Telephony services and related equipment
  • Access to audiovisual media services such as television broadcasts and related consumer equipment
  • Services related to air, bus, rail, and waterborne passenger transport

Thus, the EAA encompasses:

  • Products and services sold or used within the EU
  • Foreign-based companies that sell relevant products or services within the EU must comply with the EAA


Annex I, Section III outlines the general accessibility requirements for all services covered by the EAA, including:

  • Making information available through multiple sensory channels
  • Presenting information in a way that is understandable and perceivable by users
  • Providing information content in text formats that can generate alternative assistive formats for presentation in various ways through multiple sensory channels
  • Using fonts of adequate size and suitable shape, with sufficient contrast and adjustable spacing between letters, lines, and paragraphs
  • Supplementing non-textual content with alternative presentations
  • Providing electronic information consistently and adequately by making it perceivable, operable, understandable, and robust
  • Ensuring websites and mobile applications are accessible by making them perceivable, operable, understandable, and robust

Annex V requires service providers to issue an accessibility statement, which should include:

  • A general description of the service in accessible formats
  • Descriptions and explanations necessary to understand the operation of the service
  • A description of how the relevant accessibility requirements set out in Annex I are met


  • By 28 June 2025, Member States must transpose the EAA into national law.
  • A transitional period will be provided until 28 June 2030, during which service providers may continue to use products that were lawfully used to provide similar services before this date.


  • Microenterprises (businesses employing fewer than 10 persons and with an annual turnover or balance sheet total not exceeding EUR 2 million) are exempt from accessibility requirements related to maximizing service foreseeability for persons with disabilities.
  • Service contracts agreed upon before 28 June 2025 can continue without alteration until they expire, but no longer than five years from that date.

UK Accessibility Regulations

Scope of Application

The UK legal framework for accessibility includes the Equality Act 2010, the Accessibility Regulations 2018 (No.2), and the Accessibility (Amendment) (EU Exit) Regulations 2022. These regulations mandate compliance with the Web Content Accessibility Guidelines (WCAG) 2.1 at Levels A and AA. 

  • The Accessibility Regulations primarily address public service bodies.
  • The Equality Act applies to all service providers, ensuring a broad interpretation that includes most entities offering services to the public, whether for payment or not.


Make the Service Accessible

The Equality Act 2010 emphasizes the elimination of discrimination against persons with disabilities and minorities, covering all societal strata, including the young, elderly, pregnant individuals, disabled persons, and ensuring gender protection.

Under Article 29, service providers must:

  1. Not discriminate against persons requiring their services by failing to provide the service.
  2. Provide services fairly without discrimination in terms, termination, or by subjecting individuals to any detriment.
  3. Make reasonable adjustments to accommodate persons with disabilities.

Accessibility Statement

Article 8 of the Accessibility Regulations mandates that public sector bodies provide an accessibility statement for their websites or mobile applications:

  1. The statement must follow the model published by the Minister for the Cabinet Office and be regularly reviewed.
  2. For websites, the statement must be accessible and published on the public sector body’s website.
  3. For mobile applications, the statement must be accessible and available on the public sector body’s website or alongside the application download information.

The accessibility statement must include:

  • An explanation of content that is not accessible and the reasons.
  • Descriptions of accessible alternatives provided.
  • A contact form link to notify of any compliance failures or to request information.
  • A link to the enforcement procedure outlined in Part 5 of the Regulations.

The Accessibility Amendment Regulations also specify that compliance with the accessibility statement must align with WCAG Level A and AA criteria.

Enforcement Date

The requirements are currently in force.


Exemptions are allowed where compliance would impose disproportionate burdens. Such exemptions must be justified within the accessibility statement, detailing the reasons for non-compliance.

US Accessibility Standards

Scope of Application

The Americans with Disabilities Act (ADA) is the primary US law ensuring equal opportunities for people with disabilities. While the ADA originally focused on physical locations, recent legal interpretations have expanded its scope to include digital spaces. 

  • Title III of the ADA applies to private entities considered public accommodations, including but not limited to restaurants, hotels, theaters, retail stores, doctors’ offices, museums, libraries, parks, and amusement parks. This broad definition covers any private entity that offers goods, services, facilities, privileges, or accommodations to the public.
  • Digital Spaces: Recent legal developments suggest that websites should be treated as “places of public accommodation,” requiring them to be accessible to people with disabilities.


Under Title III of the ADA, private entities must ensure that individuals with disabilities have equal access to their services.

Specific requirements include:

  1. Non-discrimination: No individual shall be discriminated against based on disability in the full and equal enjoyment of goods, services, facilities, privileges, or accommodations of any place of public accommodation.
  2. Website Accessibility: Courts and the US Department of Justice (DOJ) increasingly consider websites as places of public accommodation. Websites with access barriers violate the right to equal access.

The DOJ uses the Web Content Accessibility Guidelines (WCAG) as a benchmark for digital accessibility, although specific regulations are still under development. Recommendations by the DOJ’s Civil Rights Division to improve website accessibility include:

  1. Accessibility Statement: Discuss compliance measures and provide contact information for users with accessibility issues.
  2. Color Contrast: Ensure sufficient contrast between text and background.
  3. Text Cues: Use text cues in addition to color for conveying information.
  4. Alt Text for Images: Provide descriptive text alternatives for images.
  5. Video Captions: Include synchronized captions in videos.
  6. Accessible Forms: Use labels, keyboard access, and clear instructions for forms.
  7. Text Size and Zoom: Allow users to adjust text size and use zoom capabilities.
  8. Headings: Use headings for navigation and layout understanding.
  9. Keyboard Navigation: Ensure keyboard access for navigation.
  10. Accessibility Checks: Combine automated accessibility checkers with manual checks.
  11. Reporting Accessibility Issues: Provide a way for users to report accessibility problems.

Enforcement Date

The ADA’s requirements are currently in force.


There are no specific exemptions detailed for digital accessibility under the ADA. However, compliance measures may vary based on the size and resources of the entity, and any undue burden must be justified. 

Websites should include any disproportionate burden justifications within their accessibility statements, explaining why certain accessibility measures may not be feasible.

Common Accessibility Requirements

Across all regions, a prominent requirement is the inclusion of an accessibility statement. This statement should outline the accessibility measures implemented and provide a way for users to report issues. It serves as both a declaration of compliance and a resource for users needing assistance.

Best Practices for Compliance

To meet these international standards, businesses should:
  • Implement the core principles of WCAG and local legislation, across digital content.
  • Regularly update their accessibility statement to reflect current compliance status.
  • Ensure that all new and updated digital content meets these guidelines.
  • Provide training for staff on accessibility best practices and legal requirements.

As digital accessibility becomes increasingly governed by international and national laws, understanding and implementing these standards is crucial for businesses operating across borders. 

By aligning with WCAG and adhering to local legislation, organizations can ensure inclusivity and accessibility for all users.

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