If you sell across borders, you are not subject to one accessibility law. You are subject to several at once, and they overlap in ways that are easy to misread. The good news: nearly every major regime points back to the same technical standard, the Web Content Accessibility Guidelines (WCAG). Get WCAG right and you cover most of the map.
This guide lays out the web accessibility laws by country that matter most for global businesses, the EU, the US, Canada, and the UK, in plain English. For each, you will see who it covers, which WCAG version and level it demands, and the concrete things that trip teams up. No legalese, no scare tactics.
The one thing every law agrees on: WCAG
Before the country-by-country tour, understand the anchor. Almost every accessibility law on this list is built on WCAG, maintained by the W3C. WCAG is organized into three conformance levels (A, AA, AAA), and the legal world has settled on Level AA as the practical target. If you build to one standard, build to WCAG 2.2 Level AA.
WCAG 2.2 is the current version, and it matters which one you target. It added six success criteria over 2.1 and removed one:
- 2.4.11 Focus Not Obscured (Minimum, AA): a keyboard-focused element must not be entirely hidden behind sticky headers or cookie banners.
- 2.5.7 Dragging Movements (AA): anything you drag must have a single-pointer alternative like a tap or click.
- 2.5.8 Target Size (Minimum) (AA): interactive targets must be at least 24 by 24 CSS pixels, with spacing exceptions.
- 3.2.6 Consistent Help (A) and 3.3.7 Redundant Entry (A): help and previously entered data behave predictably.
- 3.3.8 Accessible Authentication (Minimum, AA): no cognitive-function test like remembering a password or solving a puzzle without an alternative.
It also removed 4.1.1 Parsing, since modern browsers handle imperfect markup reliably. If your last audit was against WCAG 2.0 or 2.1, those deltas are exactly where new gaps hide. See our plain-English breakdown of the WCAG success criteria, or run a free check at AccessScan to see where you stand today.
European Union: the EAA and the Web Accessibility Directive
The European Accessibility Act (Directive (EU) 2019/882) is the headline change for global business. It applies from 28 June 2025 and reaches private-sector products and services: e-commerce, consumer banking, e-books, ticketing, transport, and more. Its technical baseline is WCAG 2.2 Level A and AA, delivered through the harmonised European standard EN 301 549.
Crucially, the EAA is not limited to EU-based companies. If you offer in-scope services to consumers in the EU, it applies to you, wherever your servers or headquarters sit. A US retailer selling to consumers in Germany is in scope. We cover the details in our European Accessibility Act guide, which also explains how the underlying EN 301 549 standard maps to WCAG.
Don't confuse the EAA with the older Web Accessibility Directive (Directive (EU) 2016/2102). That earlier directive covers public-sector websites and apps, government bodies, and public institutions, also via EN 301 549, and requires a formal accessibility statement in a prescribed format. Private businesses follow the EAA; public bodies follow the Web Accessibility Directive.
United States: the ADA and Section 508
The Americans with Disabilities Act (ADA) is one of the most heavily litigated accessibility laws, and also one of the most ambiguous. It does not name a WCAG version in its text. In practice, courts, settlements, and Department of Justice guidance treat WCAG 2.1/2.2 Level AA as the working benchmark. Build to 2.2 AA and you are on solid ground.
The ADA reaches commercial websites broadly, including foreign companies serving US customers. There is no government certification and no safe-harbor checklist, which is precisely why a documented, tested conformance target matters so much for defending your position.
Section 508 is narrower and more precise. It governs US federal agencies and, by extension, vendors selling to them. The Revised Section 508 standards explicitly adopt WCAG 2.0 Level AA. Because WCAG 2.2 AA is a strict superset of 2.0 AA, meeting 2.2 covers 508 automatically, with margin to spare.
Canada: AODA and the Accessible Canada Act
Canada operates on two levels. The Accessibility for Ontarians with Disabilities Act (AODA) is provincial and requires WCAG 2.0 Level AA for many private and public organizations operating in Ontario. Federally, the Accessible Canada Act (ACA) governs federally regulated entities, banks, telecoms, interprovincial transport, and the federal government, with standards work that draws on WCAG and EN 301 549.
For a business website, the practical takeaway is identical to the US and EU: WCAG 2.2 AA clears AODA's 2.0 AA bar with room to spare, and aligns with where ACA requirements are heading. One technical target, multiple jurisdictions covered.
United Kingdom: post-Brexit but still WCAG
The UK's Equality Act 2010 requires businesses to make reasonable adjustments so disabled people are not put at a substantial disadvantage, which regulators and courts interpret to include websites and apps. There is no UK statute naming a specific WCAG version for the private sector, but WCAG 2.x Level AA is the accepted yardstick.
For public-sector bodies, the Public Sector Bodies (Websites and Mobile Applications) Accessibility Regulations 2018 mandate WCAG 2.x Level AA and a published accessibility statement, mirroring the EU Web Accessibility Directive the UK inherited before Brexit. Again, WCAG 2.2 AA is the safe target.
What this means in practice for a global business
Notice the pattern: five legal regimes across four jurisdictions, and they converge on one standard. You do not need a separate compliance project per country. You need one technical target and one process to maintain it.
- Pick WCAG 2.2 Level AA as your single conformance target. It satisfies the EAA, clears Section 508 and AODA's 2.0 AA requirements, and is the de facto ADA and UK benchmark.
- Watch the contrast basics that fail most automated scans: 4.5:1 for normal text, 3:1 for large text (at least 18pt, or 14pt bold) and for UI components like buttons and form borders.
- Test the things automation cannot fully judge: keyboard operation, focus order, alt-text quality, and form error handling, since these need human review.
- Publish one clear accessibility statement covering your WCAG target, known issues, and a feedback channel. The accessibility statement generator builds it in minutes.
The laws differ in scope and enforcement, but not in what they ask of your front end. Anchor on WCAG 2.2 AA, document it, and keep testing as you ship. That single discipline is what turns a confusing map of web accessibility laws by country into one manageable engineering target.