Web Accessibility Law Beyond Europe: the US, UK and Canada

If you sell across borders, the European Accessibility Act is only the closest of several laws pointing at your website. The good news: they converge on the same technical target. Meet WCAG Level AA and document it, and you are most of the way to satisfying all of them.

United States — the ADA and Section 508

The Americans with Disabilities Act (ADA) does not name WCAG in its text, but U.S. courts have repeatedly treated consumer websites as places of "public accommodation" under Title III, and thousands of web-accessibility lawsuits are filed each year. In 2024 the Department of Justice issued a rule under Title II adopting WCAG 2.1 Level AA for state and local government websites — a strong signal of the benchmark courts look to.

Section 508 is separate: it requires U.S. federal agencies (and often their vendors) to make electronic content accessible, and the Revised 508 Standards incorporate WCAG 2.0 Level AA. If you sell software to the U.S. government, this is contractual, not optional.

United Kingdom — the Equality Act and PSBAR

Post-Brexit, the UK runs its own regime. The Equality Act 2010 requires "reasonable adjustments" so disabled people are not put at a substantial disadvantage — which case law and guidance treat as covering websites. For the public sector specifically, the Public Sector Bodies Accessibility Regulations 2018 require WCAG 2.1 AA plus a published accessibility statement.

Canada — the ACA and AODA

Federally, the Accessible Canada Act drives federally regulated organisations toward barrier-free digital services. Provincially, Ontario's AODA has for years required designated organisations to meet WCAG 2.0 Level AA for public web content, with other provinces moving in the same direction.

What they share

Different statutes, enforcement bodies and deadlines — but a common core:

• WCAG Level AA is the technical yardstick almost everywhere.
• A published accessibility statement and a feedback channel are increasingly expected, not optional.
• Regulators and courts want evidence of assessment over time, not a one-off claim.

Build to WCAG 2.2 AA, keep a dated record, and you are speaking the language every one of these regimes expects — regardless of which market sends the first letter.

This is general information, not legal advice for any specific jurisdiction. As always: automated testing covers roughly 30–40% of WCAG issues and is not a substitute for manual review.