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Web accessibility standards and legislation

Picture of Karine Simard By  Karine Simard  ·  6 minute read

Accessibility standards

WCAG 2.2: The benchmark for accessible content

The Web Content Accessibility Guidelines 2.2 (Web Content Accessibility Guidelines (WCAG 2.0)) are widely recognized as the reference point for web content accessibility. Most accessibility laws and standards are based on WCAG 2.2, or its predecessors (WCAG 2.0 and WCAG 2.1).

WCAG 2.2 organizes its 88 criteria into 13 guidelines across four key principles: Perceivable, Operable, Understandable, and Robust. Each of these is assigned a level of compliance, in the following order: A, AA, AAA. Each level includes those below it. To meet AA compliance—commonly required by legislation—criteria at both A and AA levels must be met. In addition, compliance with WCAG 2.2 also ensures adherence to the equivalent levels of WCAG 2.1 and WCAG 2.0.

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ATAG 2.0: Accessibility in content creation tools

While less known, the (Authoring Tool Accessibility Guidelines (ATAG)) concentrate on tools used to create and share accessible content. This includes CMS platforms, like WordPress, text editors such as Microsoft Word, and e-learning tools, including Storyline or Moodle.

These standards are divided into two parts. The first set of criteria is to make the tool itself accessible. The second is ensures that the tool supports the creation of accessible content.

Regional accessibility legislation

In Québec: SGQRI 008 3.0

SGQRI 008 3.0 is the accessibility standard published by Québec's Ministère de la Cybersécurité et du Numérique. This standard applies to public organizations and companies of the Québec government, including:

  • Ministries;
  • The various Commissions, Councils, Boards, Institutes, Museums and Societies provided for in the Financial Administration Act;
  • Québec universities and CEGEPs;
  • Public health and social services establishments (hospitals, child and youth protection centers, CHSLDs, rehabilitation centers).

It makes compliance with AA-level WCAG 2.2 standards mandatory, with five exceptions for WCAG 2.1:

  • Two 2.1 AA-level criteria are excluded;
  • Three 2.1 AAA-level criteria are mandatory
  • Consider providing a version in Langue des signes Québécoise (LSQ) for video content, depending on the context
  • Seven WCAG 2.2 criteria, from the three different levels of compliance, are also mandatory.

SGQRI 008 3.0 is applicable to all new web content (or redesigns) from April 29, 2024, and all content or functionalities put online before April 29, 2024, must comply with the previous version of the standard (SGQRI-008 2.0).

Additional information about the SGQRI 008 2.0

SGQRI 008 2.0 is the previous version of the current Québec standard. It essentially consisted of applying AA-level WCAG 2.0, with a few exceptions. It was published on July 17, 2018.

In Ontario AODA

The AODA (Accessibility for Ontarians with Disabilities Act) is a law that was passed by the Ontario government in 2005. It applies to a very large number of companies, in addition to the Ontario government. Indeed, if a company offers goods or services in Ontario, and employs more than 50 people on Ontario territory, it is likely to be subject to this Act.

The law requires compliance with AA WCAG 2.0, with two exceptions. Two AA-level criteria are excluded and do not have to be met:

  • 1.2.4 Subtitles (live);
  • 1.2.5 Audiodescription (pre-recorded).

For organizations subject to this law, it applies: :

  • Since January 1, 2014 for all new content or redesigns (Level A only);
  • Since January 1, 2021 to all content (including old content) (Level AA).

It's also important to note that the Ontario government and public organizations are also subject to the same conditions.

About intranets, extranets and other non-public tools

A company is subject to the AODA and deploys in-house tools, which are only available to employees? The company is not obliged to make them available, unless an employee requests them. We therefore advise you to think about this at the very beginning of the development of these internal tools, since corrective measures can prove costly if they are not included in the initial development.

In Manitoba: Accessible Information and Communication Standard Regulation

The Accessible Information and Communication Standard Regulation in Manitoba came into force on May 1, 2022, under The Accessibility for Manitobans Act (AMA).

This regulation applies to the vast majority of organizations in Manitoba, in both the public and private sectors. In general, any organization that provides goods, services, or information to the public, or that employs people, is required to comply.

Implementation is being phased in:

  • Public sector organizations were required to meet the requirements no later than May 1, 2024;
  • All other organizations (private sector and non-profit organizations) must comply no later than May 1, 2025, which is the full compliance date for the standard.

With respect to websites, web applications, and certain internal digital content (including intranets, employee portals, tools, digital documents, and line-of-business applications), organizations must ensure that:

  • all new web content published;
  • all web content required to access goods and services; and
  • any new web application or application that has been significantly updated

meets, at a minimum, the Web Content Accessibility Guidelines (WCAG) 2.1, Level AA.

It is important to note that the accessibility obligation does not automatically extend to all historical content. However, any content, even if created earlier, that is essential for accessing an organization’s goods and services must be made accessible in accordance with these requirements.

In Canada

Since 2011, the vast majority of federal departments, agencies, branches and public institutions have been required to comply with the Government of Canada's Web Accessibility Standard.

This standard requires compliance with WCAG 2.0 level AA, with four exceptions:

  • Complex diagrams do not have to comply with criterion 1.1.1 Non-textual content;
  • Criterion 1.2.4: Subtitles (live) is excluded;
  • Criterion 1.2.5: Audio description (pre-recorded) is excluded, except where the video provides health and safety information;
  • A period of 10 working days is allowed for the subtitling of pre-recorded video content, from the date of publication.

This standard applies to all departments and agencies subject to it: :

  • From October 1, 2011, on all new web pages;
  • Since July 31, 2013, to all web pages (including old ones).

Bill C-81 (Canadian Accessibility Act)

Coming into force in July 2019, Bill C-81 aims to remove barriers by 2040 in order to make Canada fully accessible for everyone. One of the first concrete actions was the creation of Accessibility Standards Canada, an organization responsible for developing national standards.

This organization is responsible for:

  • developing, reviewing, and recommending accessibility standards;
  • sharing information about these standards; and
  • promoting, supporting, and conducting research projects aimed at eliminating and preventing accessibility barriers.

To date, Accessibility Standards Canada has published the CAN/ASC–EN 301 549:2024 standard. This standard addresses the accessibility of information and communication technologies (ICT) and is harmonized with the European standard EN 301 549.

It applies not only to websites and documents (web or otherwise), but also to software, including internal software used by staff (line-of-business applications, management tools, intranets, and so on).

In general, for web content, digital documents, and software interfaces, compliance with WCAG 2.1 Level AA is a core requirement.

In the United States: ADA and Section 508

The two most important pieces of legislation on accessibility in the United States are the American with Disabilities Act and section 508 of the Rehabilitation Act of 1973. Various other U.S. laws outlaw all forms of discrimination based on disability, or, in a more proactive approach, mandate various measures to promote accessibility.

Section 508

This section of the Rehabilitation Act of 1973, amended in 1998, obliges US federal agencies to make their services accessible to individuals as well as to their employees. This means that U.S. federal government suppliers must also be able to comply with WCAG 2.0 level AA (with a few exceptions) and provide the government with content editing tools enabling compliance with WCAG 2.0 (which follows ATAG).

THE ADA

Enacted in 1990, the purpose of the American with Disabilities Act helps to ensure equal opportunities for all U.S. citizens in every aspect of their lives. This law is often referenced in American civil lawsuits related to accessibility. Any company offering services or employing people in the U.S. should take compliance seriously. Although the ADA does not explicitly mention the WCAG (any version), implementing these guidelines can demonstrate a proactive commitment to digital accessibility.

In Europe: EN 301 549 and the European Accessibility Act (EAA)

The European digital accessibility standard is EN 301 549. It defines accessibility requirements for ICT (Information and Communication Technology) products and services across Europe.

Key aspects of EN 301 549:

  • Alignment with WCAG 2.1: The standard is based on the Web Content Accessibility Guidelines (WCAG) 2.1 from the W3C, specifically levels A and AA.

  • Scope of application:

    • Websites and mobile applications

    • Digital documents

    • Software and user interfaces

    • ICT hardware (computers, payment terminals, ATMs, etc.)

    • Communication and telephony services

Legal obligations:

  • It is mandatory for public services under the European Web Accessibility Directive (2016/2102).

  • Starting June 2025, it will also apply to the private sector through the European Accessibility Act (EAA), which enforces accessibility requirements on companies selling digital products and services within the EU.

The European Accessibility Act (EAA), adopted in 2019, aims to harmonize accessibility requirements for various products and services across the European Union. Its main goal is to remove barriers caused by divergent national regulations, facilitating the internal market and improving access for people with disabilities.

Key changes from June 2025:

  • Implementation of accessibility requirements: From June 28, 2025, EU member states must enforce the provisions of the EAA, making accessibility criteria mandatory for relevant products and services.

  • The EAA relies on recognized standards, such as WCAG 2.1, to define accessibility requirements for web content and mobile applications.

In summary, from June 28, 2025, the European Accessibility Act will introduce uniform accessibility requirements across the EU, impacting a wide range of products and services and enhancing accessibility for all citizens, particularly those with disabilities.

In France: General Accessibility Improvement Framework (RGAA)

In effect since 2005, the RGAA is based on the WCAG 2.1 criteria, level AA.

Starting June 28, 2025, the General Accessibility Improvement Framework (RGAA) will undergo significant changes to strengthen digital accessibility in France. Here is a summary of the main updates:

Expansion of scope

Initially intended for public services, the RGAA will also apply to private companies meeting the following criteria:

  • More than 10 employees

  • Annual revenue exceeding €2 million

Compliance deadlines

  • New services: Any digital service launched after June 28, 2025, must be accessible from the outset.

  • Existing services: Digital services already in place before this date will have additional time to comply, with a final deadline set for June 28, 2030.

Penalties for non-compliance

Failure to meet accessibility requirements will result in stricter financial penalties:

  • A €50,000 fine per non-compliant digital service, renewable every six months until compliance is achieved.

  • An additional €25,000 penalty for failing to publish the required accessibility statement.