Digital Accessibility Requirements: Who, What, Where and When

Posted on June 16, 2023
9 min read


What is accessibility?

The design industry defines accessibility in numerous ways, but their essence boils down to creating products that understand and enable people of all backgrounds and abilities. People of a certain age, ability, economic background, education, or geographic location, should all be able to complete life’s tasks with a product or service.

What are accessibility requirements?

Accessibility requirements are often principles and laws which set the standards for how a website, product or service can claim they’re accessible. One thing to note is that while there may be numerous laws around the world stating that accessibility must be included, most laws are based on the Web Content Accessibility Guidelines (WCAG). If these guidelines are adhered to, organizations will be compliant in most situations. compliant in most situations.

Requirements By Region

The Americas

There are numerous accessibility laws in countries like Canada and the US. The Accessible Canada Act was introduced in 2019 as a way of reducing and preventing barriers in technology for those with impairments.In the US, you may have heard of The Americans with Disabilities Act (ADA) and Section 508. ADA is the more general law and applies to public and private businesses, covering aspects like accessibility in the workplace and physical spaces. Section 508 specifically targets technology, covering digital products and services. 

Brazil introduced the Law for the Inclusion of Persons with Disabilities (LBI 13.146/2015) in 2015. The law defines the accessibility guidelines for physical and digital aspects of life, including employer requirements as well as digital services provided by government bodies or commercial companies in the country.Also in South America, Argentina has a law called “Accessibilidad Web” enacted in 2010, a web-only law adhering to WCAG 2.0. This anti-discrimination law focuses on making sure no one faces prejudicial treatment using the product or service. 


The United Nations recognizes 44 countries in Europe, of which 27 are in the EU. While the EU does not dictate laws, there are central directives set by the EU that must be integrated into the laws of its member countries. So, while the laws in EU countries stem from the same place, there may be differences. 

The relevant EU directives are the EU Web Accessibility Directive and the European Accessibility Act. The Web Accessibility Directive targets websites and mobile apps in order to provide people with disabilities better access to digital services in the public sector.

The European Accessibility Act complements this by focusing on products and services in the "internal market" or "single market" (all EU countries). So, while the first directive targets the public sector, the second focuses on making all products and services accessible. 

Table of contents

  • What is accessibility?
  • What are accessibility requirements?
  • Requirements By Region
  • Principles of Digital Accessibility
  • How to use Accessibility Requirements
  • Who requires accessibility
  • Implementing Accessibility Guidelines

Accessibility: Essential for Some, Useful for All - via European Commision

The UK

Despite the UK no longer being a part of the EU, many of the laws remain unchanged. The Equality Act of 2010 requires the public sector to maintain accessible websites and mobile content meeting WCAG Level AA criteria. The act also states that products or services in the private sector cannot discriminate and must make “reasonable accommodations” for impaired users.


The continent of Asia is home to over 4.6 billion people. For perspective, India’s disabled population of 21 million is more than the entire population of its city of Mumbai (20 million). These huge numbers mean that accessibility offers no small return on investment.At the time of writing, India has a population of 1.408 billion people with 2.1% of people who have a disability. Their accessibility is called the Guidelines for Indian Government Websites (2009), which is a mandatory policy stating Government services must conform to WCAG 2.0 guidelines.

China has a staggering population of 1.412 billion people with approximately 85 million (6.2%) people living with a disability. They have two policies on accessibility. First, the Law on the Protection of Persons with Disabilities is a specific accessibility law applying to both the public and private sectors. Second, the Voluntary Web Accessibility Standard is a recommendation issuing the standards for government services to meet WCAG 2.0 guidelines. 

Even in smaller countries like Japan, with a population of 125.7 million, 4.3% of the population has an impairment. There are the Japanese Industrial Standards for both public and private sectors, which requires web services and products to comply with WCAG 2.0 level AA. The law is updated every 5 years and is predicted to include newer WCAG versions. Japan also has an anti-discrimination law stating that government agencies must make accommodations to serve those with impairments.


Australia has one of the earliest laws on this list was introduced in 1986, the Disability Services Act. Since then the laws have been developed further to include accessibility requirements for technology products, services, hardware, and software. Other laws like the Disability Discrimination Act and Procurement Standard Guidance have also been introduced, targeting all sectors. While they’re all not solely focused on digital services, they both reference the WCAG guidelines. 

New Zealand has numerous accessibility laws and guidelines, including the mandatory web-focused policy called Online Practice Guidelines. These guidelines are for all public and non-public services seeking to ensure equal opportunities regardless of factors like disability, race, or religious belief. The New Zealand Government based the policy on WCAG to create The Web Accessibility Standard, which updates when WCAG versions are released.


South Africa, Kenya, Nigeria, and Egypt are the "big four" players of the African tech startup scene. Together these countries make up 75% of total investments across the continent. With an estimated 42.9 million people living with impairments across the four countries, accessibility is no small venture.

To start with, South Africa has an anti-discrimination law called The Equality Act. For us in the tech industry, the act means that we have to ensure our content doesn’t discriminate by being accessible and eliminating obstacles. In addition, the Promotion of Access to Information Act gives the right to access information held by private and public bodies.

Kenya’s very constitution under Article 54 states requires those with a disability to have: the right to access and facilitation in educational institutions, reasonable access to all places, and access to device material. The country then introduced the National ICT Policy in 2019 promising Government services will provide ICT environments that are fully accessible to those with impairments. 

Nigeria introduced the Discrimination Against Persons with Disabilities Act in 2018, following nine years of advocacy by activists. The act finally stated a person with a disability has the right to equal treatment and introduced sanctions and fines for those who contravene the law, including digital accessibility. 

Egypt uses a different definition of accessibility than others. Their Rehabilitation Law defines a person with a disability as any individual who becomes unable to depend on themselves for their own work and remains in that condition. The focus is on the impact of a disability, the inability to perform a task, rather than the condition itself. 

Principles of Digital Accessibility

The WCAG guidelines are divided into four main categories known as the POUR principles. There is additionally a Conformance category in the WCAG guidelines, but this centers around what it means to meet the different criteria levels.

Each criterion is divided into Levels A, AA, and AAA.


Let’s look at the first principle in POUR, "perceivable", which means that users are able to understand the content and distinguish what it is. So, when a user interacts with a component, whether through a mouse, keyboard or other assistive technologies, it should be clear what the component is and behave as expected. 

Perceivable requirements include guidelines like correctly labeled components or text alternatives for images. Whether you’re using a screen reader or have a slow internet connection and the images aren’t loading, you know the information you're missing out on.

Another guideline is that video content includes features like captions or sign language interpreters for those hard of hearing. Perceivable requirements also define how content should be distinguishable via color, contrast, text spacing, and styling of content hover and focus. 


Next is the operable principle, which states that each component and section of content must be able to be used via interactions that a user can achieve. 

Example operable guidelines are navigation through content via keyboard-only methods or designing flash animations in a way that doesn’t trigger seizures. Designs should not be invoking involuntary reactions that prevent the user from operating a website (or risking users’ lives).

It also defines what "enough time" is when it comes to security timeouts so that users can read the content and complete tasks. For example, users must have the ability to pause stop, and hide auto-scrolling or auto-updating information as well as delay a timeout that is likely to cause permanent data loss. 


The third POUR principle is understandable. Those among us who have heard screen-readers announce content with an incorrect or missing language tag will know how important this principle is.

If not, picture an assistive technology voice set with an Australian English accent. If the content is in another language, like Spanish, but the language isn’t communicated to the assistive technology, it will still read Spanish words in its Australian accent. It makes for some interesting pronunciations and an unusable experience.

Content should also be predictable to help make it understandable. Navigation and identification should be consistent with existing mental models and interaction patterns. For example, all buttons within the same website are declared in the same ways and navigated and triggered in the same ways. Those creating design systems know all too well that websites can have 50 implementations of the same component. 


Finally, the Robust principle. This principle centers around the flexibility and adaptability of using assistive technologies.

The robustness of digital products is often determined by the code itself. For example, every component must have a name, role, and value declared within the HTML. Many HTML features are accessible by default and so by including HTML and programming best practices, you target many assistive technologies and accessibility needs.

How to use Accessibility Requirements

Knowing the applicable laws, what your users need, and what your users need is essential for any business to be successful.

Designers, developers, and product owners alike need to be aware of all the laws they need to comply with, whether accessibility, security, or payment. Knowing who you’re targeting means you can start to prioritize guidelines and explore what accessibility means in your product’s context. These accessibility guidelines thoroughly define what needs to be considered in designs but not how the solution looks.

The most effective way of going about accessibility is by including it in the process. Accessibility, like other non-functional requirements, must be considered as early as possible in the process. Include the requirements in the acceptance criteria when writing a ticket.

Conduct research early to incorporate accessibility into designs. Test with impaired users to ensure it works for them. The code has a huge impact on how accessible software is, so training developers and quality analysts is vital to ensure accessibility requirements are met.

Who requires accessibility

Some laws are mandatory for Government services, the public sector, or the private sector. What’s good to know is that when a law says it ‘only targets the Government sector’, if you’re in the private sector but your client or product is offered through the Government sector, then those laws apply to you by extension.

Let’s say you are a private company building a tax calculator offered through the Government. As the end users are Government users, all the accessibility rules that apply to the Government, apply to you too. 

Implementing Accessibility Guidelines

The POUR principles are a first step to grasping what’s required to build accessible designs. It’s these principles that underpin the majority of laws and policies. But these principles don’t help narrow down the size of the challenge when first introducing accessibility into the company, processes, and designs.

Understanding accessibility guidelines, particularly the legal requirements, is not an easy feat. Resources and guidelines provide success criteria but not what needs to happen to fulfill said criteria. This makes sense as impairments are a spectrum and not clear-cut.

As most laws are non-discriminatory and non-prescriptive of what to do, it can be difficult to understand if you’re meeting the requirements. It’s important to build compatibility and flexibility so people can use things in the ways they need. WCAG Level AA is a consistently referenced source and a great way to get started in looking at what’s needed. Finally, talk to users. Talk to those with impairments to understand them, their needs, and their wants. 

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