Most people have heard of WCAG. Some people know that AA is usually the target. Fewer people know which version of WCAG applies in which country, whether it applies to public sector bodies only, or whether private businesses are also in scope. And that’s where things get tricky.
Accessibility laws don’t work the same way everywhere. In some countries, the law names WCAG directly. In others, the law refers to a national or regional standard that is based on WCAG. In others, accessibility is handled through anti-discrimination law, meaning WCAG becomes the clearest benchmark for avoiding legal risk rather than a single neat statutory checklist.
So, let’s break it down.
First, what are WCAG levels?
WCAG stands for Web Content Accessibility Guidelines. It’s the international standard used to make websites, apps and digital content more accessible to people with disabilities. WCAG has three conformance levels: A, AA and AAA. Level A is the minimum, Level AA includes A and AA requirements, and Level AAA is the highest level. In practice, most laws and policies aim for Level AA because it’s generally seen as the best balance between meaningful accessibility and realistic implementation.
That doesn’t mean AAA is pointless. It just means AAA is rarely the legal baseline. For most organisations, the sensible target is: meet WCAG 2.2 AA where possible, and treat WCAG 2.1 AA as the absolute minimum if that’s what your local law still references.
The short version
| Country / region | Main requirement | Typical WCAG level |
|---|---|---|
| UK | Public sector websites and apps must meet accessibility regulations. UK government services are now expected to meet WCAG 2.2 AA. | WCAG 2.2 AA for public sector |
| Ireland | Public sector bodies follow the EU Web Accessibility Directive through Irish regulations. The European Accessibility Act also applies to certain products and services from June 2025. | WCAG 2.1 AA / EN 301 549, moving with EU standards |
| EU | Public sector covered by the Web Accessibility Directive. Certain private sector products and services covered by the European Accessibility Act. | EN 301 549, broadly WCAG 2.1 AA for web |
| USA | Federal agencies follow Section 508. State and local governments now have a DOJ Title II rule requiring WCAG 2.1 AA. Private sector ADA risk is more case-law driven. | WCAG 2.0 AA for Section 508, WCAG 2.1 AA for state/local government |
| Australia | Disability Discrimination Act applies broadly. AHRC guidance points to WCAG as the accepted standard. | WCAG 2.2 AA is the practical target |
| New Zealand | Government web standards require WCAG 2.2 AA from March 2025. | WCAG 2.2 AA for central government |
| Canada | Federal Accessible Canada Act, plus provincial laws. Ontario’s AODA requires public websites and content to meet WCAG 2.0 AA, with limited exceptions. | WCAG 2.0 AA in Ontario, broader federal requirements evolving |
| Norway | Universal design of ICT is a legal requirement for public and private sector services. | WCAG-based requirements, with different minimums for public and private sector |
| Japan | Public sector guidance uses JIS X 8341-3:2016, a WCAG 2.0 derivative. | WCAG 2.0-derived |
| Brazil | eMAG is the government accessibility model and is based on WCAG principles. | WCAG 2.0-derived |
| South Korea | Law and national web accessibility guidelines apply across public and private sectors. | WCAG-derived / KWCAG |
This isn’t legal advice, and requirements can vary by organisation type, sector and service. But it gives you the practical accessibility target in each market.
UK
In the UK, the clearest accessibility rules apply to public sector bodies. The Public Sector Bodies Accessibility Regulations require public sector websites and mobile apps to be accessible, and GOV.UK guidance says services need to meet WCAG 2.2 Level AA as a minimum, with monitoring for WCAG 2.2 starting from October 2024.
For private businesses, the picture is less tidy. The Equality Act 2010 still matters because inaccessible digital services can create discrimination risk, but it doesn’t simply say “your website must meet WCAG 2.2 AA”. That said, if you’re trying to show you’ve taken accessibility seriously, WCAG 2.2 AA is the obvious benchmark.
Practical target: WCAG 2.2 AA.
Ireland
Ireland follows the EU Web Accessibility Directive for public sector websites and mobile apps through the European Union (Accessibility of Websites and Mobile Applications of Public Sector Bodies) Regulations 2020. Irish public bodies are expected to comply with EN 301 549, which Ireland’s National Disability Authority describes as broadly equivalent to WCAG 2.1 AA.
Ireland has also transposed the European Accessibility Act into Irish law. The EAA came into effect on 28 June 2025 and applies to certain products and services, including areas such as e-commerce, banking, e-books, transport-related digital services and consumer technology.
Practical target: WCAG 2.1 AA at minimum, with WCAG 2.2 AA as the safer forward-looking target.
Europe / EU
Across the EU, there are two major layers.
The first is the Web Accessibility Directive, which applies to public sector websites and mobile apps. The second is the European Accessibility Act, which expands accessibility requirements into selected private sector products and services. The European Commission describes the EAA as setting EU-wide accessibility requirements for products and services that are key to inclusion in the digital world.
The technical standard to know is EN 301 549. It supports the Web Accessibility Directive and can be used to demonstrate compliance. It covers more than websites, including software, mobile apps, hardware and documents.
For web content, EN 301 549 has historically aligned closely with WCAG 2.1 AA. WCAG 2.2 is now an ISO/IEC international standard, which makes wider adoption more likely over time.
Practical target: EN 301 549, with WCAG 2.1 AA as the current core web benchmark and WCAG 2.2 AA as the sensible build standard.
USA
The USA is complicated because there isn’t one single web accessibility law covering every website in the same way.
For federal agencies, Section 508 applies. W3C’s policy overview says the revised Section 508 standards incorporate WCAG 2.0 Level AA by reference for web content.
For state and local governments, the Department of Justice published a 2024 rule under Title II of the ADA. The DOJ says state and local government web content and mobile apps usually need to meet WCAG 2.1 Level AA.
For private businesses, ADA Title III litigation has made accessibility a major risk area, but the legal route is less clean than “the statute says WCAG X”. In practice, WCAG AA is still the standard most organisations use because it’s the clearest, most recognised technical benchmark.
Practical target: WCAG 2.1 AA at minimum. WCAG 2.2 AA if you’re building or redesigning now.
Australia
Australia’s position is rooted in the Disability Discrimination Act 1992. The Australian Human Rights Commission says WCAG is the accepted international standard for web accessibility and notes that WCAG applies to web content, non-web documents, apps, software and digital interfaces.
The AHRC also says meeting the relevant standards and guidelines helps organisations meet their obligations under the Disability Discrimination Act, and that these should be treated as the minimum organisations aim for.
Australian government bodies are also using WCAG 2.2 in practice. For example, the Digital Transformation Agency says its website aims to meet Australian Government web accessibility requirements, including WCAG 2.2.
Practical target: WCAG 2.2 AA.
New Zealand
New Zealand has moved clearly to WCAG 2.2. The Government Chief Digital Officer updated the NZ Government Web Standards to incorporate WCAG 2.2, and public service departments and non-public service departments in the Executive branch must meet the NZ Government Web Accessibility Standard 1.2 from 17 March 2025.
New Zealand guidance also says that PDFs and office documents on public-facing websites must be accompanied by accessible HTML versions that meet WCAG 2.2 Level AA and present the same content and structure.
Practical target: WCAG 2.2 AA.
Canada
Canada has a mix of federal and provincial requirements.
At federal level, the Accessible Canada Act aims to identify, remove and prevent barriers for people with disabilities, with the goal of a barrier-free Canada by 2040. The Act is enforced by the Accessibility Commissioner, alongside the Accessible Canada Regulations.
At provincial level, Ontario is one of the clearest examples. Under the Accessibility for Ontarians with Disabilities Act, public websites and web content posted after 1 January 2012 must meet WCAG 2.0 Level AA, except for live captions and pre-recorded audio descriptions.
Practical target: WCAG 2.0 AA where explicitly required, but WCAG 2.1 AA or 2.2 AA is a better modern standard.
Norway
Norway has legal requirements for universal design of ICT. The Norwegian Digitalisation Agency’s accessibility authority says public sector organisations must follow 48 WCAG requirements, while private sector organisations must follow 35 minimum requirements.
This is a useful reminder that not every country simply says “WCAG AA” in the same way. Some take WCAG and turn it into a local set of legal requirements.
Practical target: Follow Norway’s applicable WCAG-based ICT requirements. WCAG 2.1 AA is a sensible working baseline.
Japan
Japan’s public sector guidance uses JIS X 8341-3:2016, a Japanese Industrial Standard for web content accessibility. W3C lists it as a WCAG 2.0 derivative and describes the scope as public sector web.
Japan’s Digital Agency also references JIS X 8341-3:2016 and WCAG 2.2 as indicators for measuring accessibility progress on its own website.
Practical target: JIS X 8341-3:2016, broadly WCAG 2.0-derived. For modern builds, aim higher.
Brazil
Brazil’s eMAG model is the government accessibility framework. W3C lists eMAG as a mandatory policy and a WCAG 2.0 derivative, while the official eMAG site says accessibility on the internet mainly refers to W3C’s WCAG and, for the Brazilian government, eMAG.
Practical target: eMAG, broadly WCAG-derived.
South Korea
South Korea’s framework includes anti-discrimination law and the Korean Web Content Accessibility Guidelines. W3C lists South Korea’s policy as applying to both public and private sectors and describes the national guidance as a WCAG 2.0 derivative.
Practical target: KWCAG / WCAG-derived requirements.
So what should international organisations do?
The simplest answer is this: don’t build to the lowest legal requirement.
If you’re operating across the UK, Ireland, EU, USA, Australia and New Zealand, WCAG 2.2 AA is the cleanest internal standard to adopt. It won’t automatically solve every legal requirement in every country because some laws include statements, procurement rules, reporting duties or product-specific obligations. But from a web and app delivery perspective, WCAG 2.2 AA puts you in a much stronger position than aiming for older versions country by country.
It also avoids the trap of treating accessibility as a compliance exercise. Because that’s the bit that often gets missed.
At its heart, accessibility is really about whether someone can actually use your website. Can they navigate it with a keyboard? Can they understand the content? Can they complete a form? Can they buy the thing, book the appointment, read the policy, access the service or get support without hitting a barrier that didn’t need to exist?
The law might say WCAG 2.0 AA, WCAG 2.1 AA, WCAG 2.2 AA, EN 301 549, JIS X 8341 or eMAG. But the direction of travel is obvious: digital accessibility is becoming a baseline expectation, not a nice-to-have.
Want to know where your website stands on accessibility? Get in touch with us today to arrange an audit of your site, and start making the world a little bit better.
