The laws
Which accessibility law applies to you
Almost every one of these lands on the same technical standard, WCAG Level AA. What differs is who is covered, when the deadline was, and what happens when you miss it.
This is a plain-English summary, not legal advice. It is accurate to the best of our knowledge and useful for working out whether you have a problem. If you have received a demand letter, talk to a lawyer rather than to a scanner.
European Union
European Accessibility Act
- Who it covers
- Any business selling goods or services to consumers in the EU, including e-commerce, banking, transport and e-books. Micro-enterprises with fewer than 10 staff and under €2m turnover are exempt from most of it.
- What it requires
- WCAG 2.1 Level AA, plus a published accessibility statement.
- Deadline
- Content published after June 2025 must already comply. Everything else has until June 2030.
- What happens if you ignore it
- Enforced by each member state, with penalties set nationally. Products found non-compliant can be ordered off the market.
United States
Americans with Disabilities Act, Title III
- Who it covers
- Businesses open to the public. Courts have applied it to websites for years even though the Act itself predates them.
- What it requires
- No standard is written into the law, which is precisely the problem. Courts and settlements consistently land on WCAG 2.1 Level AA.
- Deadline
- Already in force. There is no grace period.
- What happens if you ignore it
- Private lawsuits. 401 new web accessibility cases were filed in July 2026 alone, and most settle before reaching a courtroom.
United States
ADA Title II
- Who it covers
- State and local government bodies, including public universities and school districts.
- What it requires
- WCAG 2.1 Level AA, written explicitly into the 2024 rule.
- Deadline
- April 2026 for entities serving 50,000 people or more; April 2027 for smaller ones.
- What happens if you ignore it
- Department of Justice enforcement, plus private action.
United States
Section 508
- Who it covers
- Federal agencies and, in practice, anyone selling technology to them.
- What it requires
- WCAG 2.0 Level AA via the Revised 508 Standards.
- Deadline
- In force since 2018.
- What happens if you ignore it
- Procurement. Failing it means losing the contract.
Europe
EN 301 549
- Who it covers
- Public sector bodies across the EU, and referenced by the EAA for private business too.
- What it requires
- WCAG 2.1 Level AA plus additional requirements for software and documents.
- Deadline
- In force.
- What happens if you ignore it
- National enforcement bodies, and exclusion from public tenders.
Canada (Ontario)
AODA
- Who it covers
- Ontario businesses with 50 or more employees, and all public sector organisations.
- What it requires
- WCAG 2.0 Level AA.
- Deadline
- Passed in 2021. Compliance reports are filed periodically.
- What happens if you ignore it
- Fines of up to CAD 100,000 per day for corporations.
United Kingdom
Equality Act 2010
- Who it covers
- Anyone providing goods or services to the public in the UK.
- What it requires
- Reasonable adjustments. No standard is named, but WCAG 2.2 Level AA is the accepted benchmark.
- Deadline
- In force.
- What happens if you ignore it
- Individual claims, and enforcement by the Equality and Human Rights Commission.
Australia
Disability Discrimination Act
- Who it covers
- Anyone providing goods, services or facilities to the Australian public.
- What it requires
- WCAG 2.1 Level AA, per the Australian Human Rights Commission's guidance.
- Deadline
- In force.
- What happens if you ignore it
- Complaints to the Human Rights Commission, and Federal Court action.
One thing worth knowing before you buy anything
None of these laws can be satisfied by installing a widget. Accessibility overlays claim otherwise, and the record does not support it: in 2025 the US Federal Trade Commission reached a $1 million settlement with one overlay vendor over its compliance marketing, and in the first half of that year 456 US lawsuits were filed against sites that already had an overlay running.
Check where your site actually stands