Accessibility laws, explained in plain English.
Which laws apply to your organization, what they require, and what happens if you do not comply. No legal jargon. Just the facts you need to make an informed decision.
Why this page exists
Accessibility law is no longer just for governments and large corporations. In Canada, the US, the EU, the UK, and Australia, digital accessibility is now a legal requirement for a growing range of organizations, and the rules are tightening every year.
The challenge is that each jurisdiction has its own laws, its own scope, and its own consequences for non-compliance. A business serving customers in multiple countries may be subject to several frameworks at once, and the law that applies in Nova Scotia is not the same as the one that applies in Germany.
This page explains each major framework in plain terms, tells you who it covers, and gives you an honest picture of what happens when organizations do not comply. If you want to know which laws apply to your specific situation, a free 30-minute call and we will give you a clear answer.
Canadian Federal and provincial laws
Accessible Canada Act (ACA)
Federal law, passed 2019. New digital requirements added December 2025.
- Fines Up to $250,000 Per violation. Minor violations start at $250.
- Deadline Dec 2027–28 Depending on organization size
- Requirement WCAG 2.1 AA Via CAN/ASC-EN 301 549
The ACA is Canada’s federal accessibility law, aimed at creating a barrier-free Canada by 2040. It covers websites, mobile apps, software, and digital documents for organizations under federal jurisdiction.
In December 2025, Canada added new specific digital accessibility requirements, with compliance milestones beginning in late 2027. If your organization is federally regulated and has not yet started planning for digital compliance, the window to act proactively is narrowing.
Applies to:
- Federal government departments and Crown corporations
- Banks and financial institutions
- Telecommunications and broadcasting companies
- Interprovincial transportation providers
- Postal and courier services
Excludes:
- Provincially regulated private businesses
- Private businesses with fewer than 10 employees
A note for non-Canadian businesses
If your organization provides digital products or services to Canadian users, the ACA may apply to you even if you are not based in Canada. This includes international e-commerce platforms, SaaS products, and any digital service accessible to Canadians. If you have significant Canadian traffic, it is worth confirming your obligations.
Nova Scotia Accessibility Act
Provincial law, passed 2017. Full compliance target: 2030.
- Scope All sectors Public and private organizations, all sizes.
- Deadline 2030 Full compliance
- Requirement WCAG 2.1 AA Updates expected to align with newer versions
Unlike the ACA, the Nova Scotia Accessibility Act applies to all organizations operating in the province, including small businesses and non-profits. It covers six areas, including information and communication technology, which means websites and digital services are in scope.
If your business operates in Nova Scotia, this law applies to you regardless of how many employees you have or whether you are federally regulated. The 2030 compliance target is approaching, and working toward it gradually is significantly easier than a last-minute effort.
Applies to:
- All public sector organizations in Nova Scotia
- All private sector businesses in Nova Scotia
- Non-profits and community organizations
- Small businesses, including sole traders
Other provincial laws worth knowing about
Ontario’s AODA, Manitoba’s Accessibility for Manitobans Act, and British Columbia’s Accessible BC Act each extend accessibility requirements to private sector organizations within their province. If your business operates across multiple provinces, more than one provincial law may apply to you simultaneously.
United States Accessibility Law
Americans with Disabilities Act (ADA)
Civil rights law, passed 1990. Courts have consistently interpreted it to include websites and digital services.
- Fines Up to $115,250for first violation. Up to $230,500 for repeat offenders.
- Lawsuits 8,000+ filed in 2024.The highest of any jurisdiction globally.
- Requirement WCAG 2.1 AA Referenced by courts in virtually every case.
The Americans with Disabilities Act is the world’s most litigated accessibility law. Originally written before the internet existed, courts and the Department of Justice have consistently interpreted it to include websites, mobile apps, and digital services as places of public accommodation.
Unlike every other jurisdiction on this page, US enforcement is driven primarily by private lawsuits rather than government fines. Any individual with a disability can file a complaint or lawsuit against a business whose website they cannot use. Demand letters from plaintiff’s attorneys are often the first sign a business has that it is in scope.
In 2024, more than 8,000 federal accessibility lawsuits were filed under the ADA, with thousands more in state courts. New York, Florida, and California see the highest volumes, but cases have been filed across all 50 states. The absence of active DOJ enforcement under the current administration has not reduced risk. It has increased private litigation, because individuals and advocacy groups have stepped in where federal enforcement has pulled back.
The ADA has three parts relevant to digital accessibility. Title II covers all state and local government websites, with WCAG 2.1 AA compliance deadlines of April 2027 for larger jurisdictions and April 2028 for smaller ones. Title III covers private businesses open to the public, including e-commerce, healthcare, financial services, and retail. Section 508 applies to federal agencies and organisations receiving federal funding.
Applies to:
- All private businesses open to the public in the US
- E-commerce platforms with US customers
- State and local governments (Title II)
- Federal agencies and federally funded organizations (Section 508)
- Any organization with a website accessible to US visitors, regardless of where it is based
A note for non-US businesses
If your website is accessible to US visitors, you may be in scope for ADA claims even if you are headquartered outside the US. Cases have been filed against international companies serving American customers. If you have significant US traffic, it is worth knowing where you stand.
European Accessibility Laws
European Accessibility Act
In force since June 28, 2025. Applies to any organization serving EU customers.
- Fines €5,000 to €1M+ Varies by country and violation severity.
- Deadlilne June 2025 Deadline for new content. Existing content by June 2030.
- Requirement EN 301 549 Incorporating WCAG 2.1 AA
The European Accessibility Act came into force on June 28, 2025. It applies to any organization providing products or services to customers in the EU, regardless of where that organization is based. A Canadian company selling into France, or an Australian business with EU users, is subject to the EAA.
Because the EAA is a directive rather than a regulation, each EU country has set its own penalty amounts. Germany imposes fines up to €100,000 per violation. France applies fines from €5,000 to €250,000. Spain and Sweden allow penalties exceeding €1,000,000 in serious cases. A business operating across multiple EU markets can face separate enforcement actions in each country simultaneously.
Enforcement began in June 2025. Most countries are starting with notification and a period for corrective action before imposing fines, but complaints from disability advocacy groups are already rising across France, Germany, and Spain.
Applies to:
- Any organization selling products or services to EU customers
- E-commerce platforms serving EU consumers
- Banking and financial services
- Telecommunications
- Transport ticketing and information services
Excludes:
- Microenterprises with fewer than 10 employees and under €2M turnover (only for services, not for products)
A note for non-EU businesses
The EAA is one of the few accessibility laws with explicit extraterritorial reach. If a customer in France, Germany, or Spain can access your website and purchase your product or service, you are in scope, regardless of where your business is headquartered. A Canadian retailer, an Australian SaaS company, or a UK business serving EU customers all fall under EAA requirements. Enforcement is country-level, which means a single non-compliant website could trigger actions in multiple EU member states simultaneously.
UK accessibility law
Equality Act 2010
Applies to all UK service providers, public and private.
- Fines No fixed amount Discrimination claims, court orders, legal costs
- Real-world cost £3,000 to £228,000 Based on documented settlements.
- Requirement WCAG 2.2 AA Practical benchmark for compliance
The UK Equality Act 2010 requires all organizations providing services to the public to make reasonable adjustments so that disabled people are not excluded, including in digital services. It applies to all service providers, from large corporations to small businesses.
Unlike EU countries, the UK does not impose fixed administrative fines for accessibility non-compliance. Instead, individuals who encounter accessibility barriers can bring discrimination claims. Documented settlements range from £3,000 to £228,000, and cases that go to court also carry significant legal costs and reputational damage.
The RNIB and other disability advocacy organizations actively monitor websites and have supported legal actions that resulted in settlements and mandatory remediation. This is not theoretical risk.
Applies to:
- All private sector businesses providing services to the public
- Public sector organizations
- Non-profits and charities
- Educational institutions
- Any organization serving UK customers through digital channels
Public Sector Bodies Accessibility Regulations (PSBAR)
PSBAR, applies specifically to public sector organizations. It requires all public sector websites and apps to meet WCAG 2.2 Level AA and publish an accessibility statement. It covers central and local government, the NHS, universities, and publicly funded organizations. The Government Digital Service actively audits public sector websites and refers non-compliant organisations to the Equality and Human Rights Commission for enforcement.
Applies to:
- Government departments and local councils
- NHS organizations
- Universities and colleges
- Publicly funded charities and organizations
Excludes:
- Private sector businesses (covered by Equality Act instead)
No fixed fine does not mean no risk
The UK Equality Act does not set a specific penalty amount for accessibility non-compliance. This leads some organisations to assume the risk is low. It is not. Any disabled user who encounters a barrier on your website can bring a discrimination claim. Documented settlements range from £3,000 to £228,000, and cases that proceed to court carry legal fees on top of any settlement. The RNIB and other advocacy organisations actively monitor websites and have supported multiple successful claims. The absence of a fixed fine means the financial exposure is unpredictable, not that it is small.
Australian accessibility law
Disability Discrimination Act 1992
Applies to all Australian organizations providing goods or services to the public.
- Enforcement Discrimination claims Via Australian Human Rights Commission
- Requirement WCAG 2.1 AA Referenced in WCAG 2.0 advisory note.
Australia’s DDA prohibits discrimination against people with disabilities in the provision of goods, services, and facilities, including websites and digital services. Like the UK’s Equality Act, it operates through discrimination complaints rather than fixed fines.
The Australian Human Rights Commission has issued advisory notes recommending WCAG compliance as the practical standard for meeting DDA obligations. Complaints are handled through the Commission, and cases that are not resolved can proceed to the Federal Court.
Applies to:
- All organizations providing goods or services in Australia
- Public sector organizations
- Private businesses of any size
- Non-profits and community organizations
Accessibility laws at a glance
| Jurisdiction | Law | Who needs to care | Deadline | What happens if ignored | What it means for you |
|---|---|---|---|---|---|
| Canada (federal) | Accessible Canada Act | Federally regulated organizations (10+ employees) | 2027–2028 (digital requirements) | Fines up to $250,000 per violation | Compliance required soon. Preparation should already be underway |
| Canada (Nova Scotia) | NS Accessibility Act | All organizations operating in Nova Scotia | 2030 (full compliance) | Regulatory enforcement and compliance pressure | Mandatory compliance. Early action reduces cost and risk |
| United States | Americans with Disabilities Act | All businesses open to the public. | Already in effect | Up to $115,231 (first violation). Up to $230,464 (repeat).Plus private lawsuit costs. | Applies globally to companies with US traffic |
| European Union | European Accessibility Act | Any organization serving EU customers (even outside EU) | June 2025 (new) / 2030 (existing) | €5,000 to €1M+ fines depending on country | Applies globally if you have EU users. Eenforcement already starting |
| United Kingdom | Equality Act / PSBAR | All service providers (public & private) | Already in effect | Legal claims and settlements (£3K–£200K+) | Compliance required now. Real legal risk exists today |
| Australia | Disability Discrimination Act | Any organization providing services | Already in effect | Formal complaints and legal action | Compliance expected now. Complaints can happen at any time |
The good news: one audit covers all of them.
Every jurisdiction on this page references the same underlying technical standard: WCAG 2.1 AA or higher. Canada, the EU, the UK, and Australia all point to the same benchmark for what an accessible website looks like.
That means a single, thorough accessibility audit performed to WCAG 2.2 AA will address your compliance obligations across all of these frameworks simultaneously. You do not need a separate audit for each country you operate in.
What varies by jurisdiction is who the law applies to, how it is enforced, and what the consequences are for non-compliance. That is exactly what this page is here to help you understand. And if you are still not sure which laws apply to your specific situation, that is what our free 30-minute call is for.