Accessibility Compliance, Jurisdiction by Jurisdiction
Web accessibility is regulated by overlapping laws on both sides of the Atlantic — and most organizations answer to more than one. These guides explain each regime in plain English: who it applies to, which technical standard it references, how it is enforced, and what to do about it. The good news: they all converge on WCAG, so one solid remediation program addresses them together.
Not legal advice. These guides are educational information about accessibility laws and standards, not legal advice. Obligations depend on your jurisdiction, sector, and specific facts — consult a qualified lawyer before making compliance decisions.
Compliance guides
United States
ADA
Americans with Disabilities Act
The US law behind thousands of website lawsuits a year. Titles II and III, the WCAG 2.1 AA rule for state and local governments, and what private businesses must do.
- Private lawsuits + DOJ enforcement
- Title II: WCAG 2.1 AA required
United States · Federal
Section 508
Rehabilitation Act
Binding on federal agencies and every vendor that sells them technology. The 2017 refresh, WCAG 2.0 AA baseline, and how VPATs and ACRs work in procurement.
- Federal agencies + vendors
- WCAG 2.0 AA baseline · VPAT/ACR
European Union
EAA
European Accessibility Act
The EU law covering e-commerce, banking, e-books, transport, and consumer devices — including non-EU companies selling into the EU. Applies since June 28, 2025.
- Applied June 28, 2025
- Reaches non-EU sellers
European Union · Standard
EN 301 549
Harmonized ICT accessibility standard
The technical standard behind EU accessibility law. Chapter structure for web, documents, and software, WCAG 2.1 AA incorporation, and version history.
- Incorporates WCAG 2.1 AA
- Presumption of conformity for EAA/WAD
United Kingdom
United Kingdom
Equality Act 2010 & PSBAR
The outcome-based UK regime: the Equality Act's anticipatory reasonable-adjustments duty for every service provider, PSBAR's mandatory statements for the public sector, and the new statutory Services Code of Practice in force since August 2026.
- Anticipatory duty, no named standard
- GDS monitors against WCAG 2.2 AA
Ireland
Ireland
EAA via S.I. No. 636/2023
Ireland enforces the European Accessibility Act with criminal penalties: fines up to EUR 60,000 and up to 18 months imprisonment on indictment, six sectoral regulators, and personal liability for company officers.
- Criminal offence + officer liability
- Six regulators, CCPC to Central Bank
United States · California
California
Unruh Act & state requirements
The most expensive US jurisdiction for accessibility claims: statutory damages of $4,000 minimum per violation under the Unruh Civil Rights Act, plus state-sector rules.
- $4,000 min. per violation
- Top litigation jurisdiction
United States · New York
New York
State & city human rights laws
The busiest venue for federal web accessibility filings, with state and city human rights laws that extend protections beyond the federal ADA baseline.
- Most federal filings of any state
- State + NYC human rights laws
One standard underneath them all
Every regime above ultimately points at the Web Content Accessibility Guidelines. The ADA Title II rule requires WCAG 2.1 AA, EN 301 549 incorporates WCAG 2.1 AA for the EU, and Section 508 incorporates WCAG 2.0 AA. Because WCAG versions are backwards-compatible, conforming to the WCAG 2.2 AA checklist puts you at or ahead of the technical baseline in every jurisdiction on this page.
| Regime | Who it covers | Technical standard | Key date | How it is enforced |
|---|---|---|---|---|
| ADA Title II (US) | State and local government, including public schools and universities | WCAG 2.1 AA, in regulation since April 2024 | 26 April 2027 for bodies serving 50,000 or more; 26 April 2028 for smaller bodies | Department of Justice, complaints and private lawsuits |
| ADA Title III (US) | Businesses open to the public; websites where courts find a connection to the business | None in regulation; courts and settlements name WCAG 2.0 or 2.1 AA | In force since 1992; no web deadline | Private lawsuits (injunction and fees, no damages) and DOJ; state laws such as California's Unruh Act add damages |
| Section 508 (US) | Federal agencies and the technology they buy or build | WCAG 2.0 AA via the Revised 508 Standards | In force since 18 January 2018 | Complaints, annual agency assessment, procurement |
| European Accessibility Act (EU) | In-scope products and services: e-commerce, banking, transport, e-books, telecoms, computers and their operating systems | EN 301 549, which incorporates WCAG 2.1 AA; v4.1.1 will point at WCAG 2.2 | Applies from 28 June 2025; some existing service contracts run to 2030 | National market surveillance authorities; penalties set by each member state |
| Public Sector Bodies Accessibility Regulations 2018 (UK) | Public sector websites and mobile apps | WCAG 2.2 AA for monitoring, plus a mandatory accessibility statement | 23 September 2020 for websites; 23 June 2021 for apps | GDS monitoring; enforcement by the Cabinet Office and the Equality and Human Rights Commission |
| Equality Act 2010 (UK) | Every service provider, public or private | None named; the duty is to make reasonable adjustments, and it is anticipatory | In force since 1 October 2010 | Claims in the county court or sheriff court; damages including injury to feelings |
For the raw data behind these guides — statutes, penalties, and deadlines across 35+ jurisdictions, plus US litigation trends — see the global accessibility laws tracker and the accessibility lawsuit tracker.
Find out where you stand
A WCAG 2.2 AA audit tells you your exposure under every one of these laws at once — and gives you the remediation roadmap.
Frequently asked questions
Which accessibility law applies to my website?
Usually more than one. A US business open to the public falls under ADA Title III; if it has customers or operations in California or New York, state laws like the Unruh Act add statutory damages on top. Selling products or covered services to EU consumers brings the European Accessibility Act into play, and selling to the US federal government triggers Section 508 procurement requirements. The practical convergence point is WCAG: conforming to WCAG 2.1/2.2 Level AA addresses the technical core of every major regime at once.
What technical standard should I build to?
WCAG 2.2 Level AA is the safest single target today. The DOJ's ADA Title II rule requires WCAG 2.1 AA, the EU's EN 301 549 incorporates WCAG 2.1 AA, and Section 508 formally requires WCAG 2.0 AA — and because WCAG 2.x versions are backwards-compatible, content that meets 2.2 AA satisfies all three baselines. Building to 2.2 AA also covers the criteria newer laws and procurement requirements are starting to reference.
What is the difference between a law and a standard like EN 301 549 or WCAG?
Laws (the ADA, the European Accessibility Act, Section 508, state statutes) create the legal obligation and the enforcement mechanism — lawsuits, regulators, procurement rules. Standards (WCAG, EN 301 549) define the technical test for what 'accessible' means. Laws point at standards: the EAA points at EN 301 549, which points at WCAG 2.1 AA; the ADA Title II rule points directly at WCAG 2.1 AA. You comply with a law by conforming to the standard it references and meeting its process duties, such as accessibility statements and feedback channels.
Where do I start if I'm not compliant with any of these?
Start with an audit of your highest-traffic user journeys against WCAG 2.2 AA — that tells you your real exposure under every regime at once. Fix blocking barriers in core flows first (navigation, forms, checkout, login), publish an accessibility statement, and add automated checks to your development pipeline so regressions get caught. Then work through the jurisdiction-specific duties — VPATs for federal sales, EAA service information for EU markets — from a foundation that is already solid.
Essential Accessibility Resources
Comprehensive tools, checklists, and guides to help you create inclusive digital experiences