“The power of the Web is in its universality. Access by everyone regardless of disability is an essential aspect.”
So rightly said! Why can't we all be on the same page about accessibility?
Well, Digital first is the outlining ethos of our post-lockdown lives. With people depending on the internet for everything from social engagement to remote work, banking to shopping, education to finding a job; web accessibility has never been that much critical.
It's been long time since we are talking about web accessibility. The US, UK, Canada, Australia, France, Germany, and almost every country is strictly imposing accessibility standards on the organizations and their websites.
Since following the accessibility standards has become obligatory, it will be good to have a handy comparison study of all major international guidelines for web accessibility. Nevertheless, the guidelines keep changing, this article will help you to outline the standards in brief.
So, let's discuss these international accessibility standards and know what is common among them.
International website accessibility standards - Best path for accessibility compliance!
WCAG (Web Content Accessibility Guidelines)
WCAG is the de-facto standard for almost all websites across the world. That implies, if websites are adhering to WCAG standards, they can be assumed as accessible.
Web Content Accessibility Guidelines was created by W3C in 1997 and became ISO standard (ISO/IEC 40500:2012) in 2012.
WCAG itself has three versions as of now, which are - WCAG 2.0, 2.1, and 2.2, out of which, WCAG 2.1 is the most used version. And there are three different conformance levels for each version of WCAG - level A, AA, and AAA.
WCAG is based on four principles: POUR (perceivable, operable, understandable, and robust) and to be compliant with WCAG, every digital product must conform to the below-mentioned conformance levels.
| Conformance level A | Level AA | Level AAA |
|---|---|---|
| Alt text for images | Caption is essential for each audio and video. | Streaming media must have sign language interpretation with audio description. |
| Descriptive transcript for pre-recorded audio and video. | Device orientation shouldn't create any problem. | Background audio is not suggested. |
| Proper headings | Color contrast between text and background must be 4.5:1. | Text and Image contrast should be 7:1. |
| Div and Span are not suggested, instead, usage of real elements is advised. | Table of content is needed for better understanding of content. | Color switcher and text resizer is needed on the website. |
| Meaningful and relevant content is a basic requirement. | Keyboard focus must be highly visible. | For abbreviations, idioms, technical terms, and unusual words, there should be a thesaurus. |
| Dynamic content shouldn't be used if not needed such as automatically played videos. Pause, stop, or hide option must be there for such content. | Web forms should have accurate labels and proper navigation. | Page readability must be easy. |
| Keyboard navigation is important. | Same element on each page should appear in a consistent order. | Self-explanatory hyperlinks. |
Read more about these levels in detail.
Other international accessibility guidelines:
The USA accessibility act - ADA and Section 508
Section 508 is federal law for US government agencies to maintain each government website and make them available for everyone. It is mainly the US Rehabilitation Act of 1973, which was revamped in 2018. Whereas ADA (Americans with Disability Act of 1990) is the civil rights law that restricts the discrimination against people with disabilities in various areas including electronic and information technology.
The Section 508 mainly applicable to government agencies, while the ADA guidelines are applicable to all State and local government agencies, private employers with 15 or more employees, and businesses that operate for the benefit of public. Section 508 covers the accessibility of websites, phones, laptops, computers, multimedia, digital documents, etc. And ADA focuses on information technology, communication, education, etc.
Learn more about the difference between ADA and Section 508.
Accessible Canada Act (ACA)
The Accessible Canada Act (ACA) came into action in 2019. The goal of this act is to make Canada a barrier-free by 2040 in terms of accessibility. The area that ought to adhere to its guidelines are - information and communication technology, employment, design & delivery programs, and services, and many more. Organizations need to proactively identify the accessibility barriers and remove or fix them as soon as possible.
All federal entities must follow ACA to provide accessible solutions to everyone. If a website violates ACA, courts may fine the website up to $250,000. Read more to know more about ACA.
Accessibility for Ontarians with Disability Act (AODA)
AODA has become a law in 2005, which is the first Canadian provincial accessibility law. The act is applicable to public, private, and non-profit organizations. There is a set of defined accessibility standards to ensure ICT products and services accessibility to everyone.
The deadline to file the AODA compliance report was June 2021 and the maximum penalty in case of any violation to the Act:
- For corporations - $100,000 per day.
- Individuals and unincorporated organizations - $50,000 for each day the violation continues.
Australian DDA
Disability Discrimination Act 1992 is a series of disability standards and guidelines. The idea behind this act is to provide equal access to all opportunities to everyone irrespective of their physical abilities. These standards are legally binding regulations set by the Attorney-General under the DDA.
Almost every industry in Australia has to follow DDA such as education, public transport, insurance, banking, entertainment or recreation, and the world wide web. The commission issued an advisory note on world wide web accessibility in 2010. Though initially, the guidelines were influenced by WCAG 2.0 standards however now the Australian government is working to develop a web accessibility national transition strategy to improve digital accessibility level. Explore more information about Australian DDA website accessibility from here.
UK Equality Act (EA)
The Equality Act came into force in 2010, which legally protects individuals from discrimination in the workplace and in every facet of life. The act replaced previous anti-discrimination laws with a single Act, making the law easier to understand. This act made it legal that if an organization supports discrimination, it will be unlawful.
Read detailed guidelines about Equality Act.
Each public and private organization in the UK is abide by these guidelines and the government has declared a deadline to enforce the act into action, which is by 2025.
European web accessibility standard EN 301 549
The act is meant to help organizations to remove accessibility barriers from every digital product. EN 301 549 is applicable to all member states, local and government entities in European Union. Likewise, other laws and standards earlier this act was inspired by WCAG standards. However, its latest harmonized version 3.2.1 has some accessibility requirements that are not mentioned in WCAG.
The Act EN 301 549 is applicable since 2016 and it was expected to apply the standards
- From 2019 to the websites published after 2018.
- From 2020 to all public sector websites.
- From 2021 for all mobile applications.
This blog will help you know more about EN 301 549.
Israel Standard (IS) 5568
This law was scheduled to be introduced in 2015 but it came into action in 2017. The Israel Standard is based on the Equal Rights for Persons with Disabilities (ERPD) Act of 1998. IS 5568 made discrimination against people with disabilities illegal for public services and products.
Similar to other acts, the idea behind this standard is also to protect the dignity and freedom of disabled individuals and offer them equal opportunities to study, work, and participate in other social activities. It covers temporary and permanent physical and cognitive impairments.
The law applies to all government and private institutions. All medium and large companies established after 2017 with annual average revenue of NIS 300,000 or more must be compliant with IS 5568. If small companies also have NIS 300,000 or more revenue, they were also expected to be compliant before 2020.
If a website or other digital properties are found to be guilty of non-compliance, the courts can impose a penalty of up to 50,000 NIS.
German web accessibility act BITV
The German Federal regulation Barrierefreie Informationstechnik-Verordnung or Barrier-free Information Technology Ordinance (BITV) came into action in 2002 for all websites under the German federal. The BITV was conceived on the essence of WCAG 1.0. This act ensures that each website, which comes under the German Federal Government providing public services should be accessible even for people with disabilities.
There was deadline to comply with the standards. All public sector website published before September 23, 2018, was expected to adhere with BITV by September 23, 2020, and mobile applications by June 23, 2021. However, myriad websites still need help to modify their UX/UI as per BITV.
Read the guidelines to improve your website's accessibility.
French web accessibility act RGAA 3
The RGAA includes the details adopted from WCAG 2.0 and technical information to make a website accessible to people with disabilities. The law is modified several times ever since it has come into force to regulate the propagation of digital technology in the public and private sectors. If an organization fails to adhere to RGAA 3, penalties may go up to 5,000 Euros.
California Business discrimination Under Unruh Act
Unruh is a civil rights act to preserve the rights of disabled people of availing equal opportunities by providing more digital accessibility to them. The act is enacted in 1959, modified in 2009 and it applies to all businesses in California. And there is a hefty penalty amount that can be imposed on the organizations failing to adhere to Unruh Act. The amount is a minimum of $4,000 per access violation plus attorney fees.
Comparison of international web accessibility standards
| S.No. | Name of International Accessibility Standard | Country OR State | Year | Accessibility Requirements for a Website | Whom to apply | Legislation |
|---|---|---|---|---|---|---|
| 1 | Section 508 & ADA | USA | ADA - 1990 & Section 508 - 1970 | Both Section 508 and ADA are based on WCAG 2.0 AA level conformance. | All American government federal agencies are expected to adhere with Section 508. Whereas ADA is applicable on all private organizations with more than 15 employees and public sector organizations. | If any organization fails to comply with ADA and/or Section 508, lawsuits and hefty penalty (approx. $50,000 to $100,000 or more than that) can be imposed on those organizations. |
| 2 | Canadian ACA | Canada | 2010 | ACA is based on WCAG standards. | All private, non-profit organizations with more than 50 employees and all public sector organizations must have accessible digital properties under ACA. | Fine for not adhering with accessibility standard is up to $250,000. |
| 3 | AODA | Ontario, CA | 2005 | To comply with Accessibility for Ontarians with Disability Act, a website is expected to follow WCAG 2.0 level AA. So, a website, PDF and other documents must adhere with WCAG/ADA guidelines. | Public, private, and non-profit organizations. | Government can charge up to $100,000 to organizations that are not following accessibility guidelines for their digital products. |
| 4 | Australian DDA | Australia | 1992 | WCAG 2.1 AA is basic requirement to be compliant as per DDA. However, the Australian government is working to build their own local set of guidelines as well. Other than that, As EN 301 549:2020 outlined some requirements for websites including hardware, software, and other technical needs. | Each Australian individual or organization's website must be built under DDA guidelines. | Lawsuits and penalties as per court's decision. |
| 5 | UK Equality Act | England, Scotland, Wales, and Northern Ireland | 2010 | It doesn’t have any specific requirement for a website but to follow WCAG 2.0 AA level, which is a strong recommendation for each public and private sector website. | Public sector bodies - Central government, non-government and local government organizations and charities financed by public funding, and all other organizations in UK. | Lawsuits and fines |
| 6 | EN 301 549 | All EU countries including, Austria, Belgium, Bulgaria, Croatia, Cyprus, Czechia, Denmark, Estonia, Finland, France, Germany, Greece, Hungary, Ireland, Italy, Latvia, Lithuania, Luxembourg, Malta, Netherlands, Poland, Portugal, Romania, Slovakia, Slovenia, Spain, Sweden. | 2016 | Other than WCAG 2.0 standards, this act has some other requirements as well for a website or mobile application. The European Union is working on their own set of rules, and they keep publishing harmonized rules in their official journals. | Each public and private website should be accessible under EN 301 549. | There is legal penalty for inaccessible websites that may harm organization's brand image. |
| 7 | IS 5568 | Israel | 2013 | WCAG 2.0 level AA or POUR principals are all a website ought to follow in order to avoid lawsuits in Israel. | Municipalities, businesses, government agencies, non-profit organizations, etc. | Lawsuits and fines up to NIS 50,000. |
| 8 | German BITV | Germany | 2002 | A website should be POUR to be accessible as per BITV. | All German public bodies and federal agencies, and vendors, partners, and contractors of those agencies. | Lawsuits and colossal fine including court fee |
| 9 | French RGAA | France | 2005 | RGAA says, a website is accessible if it conforms with level A and AA of WCAG and EN 301 549. | All french government agencies and the public institutions. | Fine up to Euros 5000 |
| 10 | California Unruh | California, USA | 1959 | If a website is perceivable, operable, understandable, and robust, then it is accessible under Unruh Act. | All public and government entities in California have to follow Unruh act to improve digital accessibility. | Fine up to $4,000 along with legal expenses. |
The comparison table says it all. More or less, all the international web accessibility standards revolve around WCAG and its four principles. In a nutshell, a website is accessible, if it is:
Perceivable - content and user interface should be designed in a way that everybody can perceive it easily.
Operable - website must be navigable for everyone.
Understandable - web content and its operation should be easy to understand and consume.
Robust - website and other digital products must be interpretable using every device including ATs.
Find out your regional web accessibility regulations and apply the best practices!
Different region may have its own regulations and guidelines regarding website accessibility. Some countries like U.S. and Canada have state or provincial regulations in addition to federal laws. The internet is now a central of our daily lives, and equal access is both a moral imperative and a regular need. The governments are perceiving the positive impact of accessibility guidelines universally; understanding that they require equality in all spaces including digital platforms. Creating persuasive online experience consistently allows everyone to join equally in this digital space is definitely fulfilling the expectations.
As an associate member of International Association of Accessibility Professionals (IAAP), We are a part of Global accessibility community. We are also a member of W3C.
The businesses that are considering remediating websites with full ADA WCAG 2.1 compliance; we provide full website accessibility remediation solution including audit, consulting, remediation, regular maintenance, monitoring, training, and support. It is ideal for websites and digital assets of large enterprises, Federal and state governments. Our solution can make your website compliance with any of these standards - ADA, WCAG 2.1, ATAT 2.0, Section 508, Australian DDA, European EAA EN 301 549, UK Equality Act (EA), Israeli Standard 5568, California Unruh, Ontario AODA, Canada ACA, German BITV, and France RGAA. To request a free quote, please feel free to submit the following form or email us at [email protected].
