Digital Accessibility

In the EU, key laws include the Web Accessibility Directive, which aims to provide people with disabilities with better access to the websites and mobile applications of public services, and the European Accessibility Act (EAA), which from 28 June 2025, sets out minimum accessibility requirements for certain consumers products and services (e.g., e-commerce platforms, e-books, banking interfaces, ATMs – to name just a few!). The accessibility requirements of the EAA aim to ensure that in-scope products and services are accessible to people with disabilities as well as people with other functional limitations, such as the elderly.

One of the driving messages the EU legislature has attempted to manufacturers of digital products or providers of digital services is that the starting point is accessible design; products and services should be designed in ways that make them perceivable, operable, understandable, and robust. This means thinking about accessibility from the outset, for example: ensuring that information is easy to understand by users with a range of impairments and provided in more than one sensory mode. Businesses may need to conduct technical assessments, produce compliance documentation, and in many cases, make accessibility information publicly available.

Although the EAA is not applicable in the UK as it was enacted after Brexit, the UK does have legislation that is wide enough to potentially be interpreted as introducing accessibility requirements for digital products and services. The Equality Act 2010 requires service providers to make “reasonable adjustments” for people with disabilities both online and offline.

Digital accessibility is no longer a regional concern, it’s a priority for regulators around the world.

The EU has introduced more structured requirements through the European Accessibility Act, and “EN 301 549 Accessibility requirements for ICT products and services” is in the process of being revised in support of the EAA, with an updated version expected later in 2026.

Many other jurisdictions are also rapidly advancing their own accessibility laws and standards.

In the United States, the Department of Justice aggressively enforces the Americans with Disabilities Act (ADA) against public accommodations with non-accessible web services and digital offerings, and recently adopted its first binding regulation expressly treating web‑ and app‑based services as ADA‑covered government services. The extent to which the ADA applies to websites operated by in-scope businesses remains unresolved among federal courts across the country. This uncertainty, along with record levels of private ADA lawsuits and a patchwork of state laws, presents U.S. businesses with significant compliance questions.

The U.S. Federal Communications Commission (FCC) has also expanded its digital accessibility regulations, most recently by adopting bold performance objectives for video conferencing services which correspond with existing requirements for other modern communications services and video programming.

Canada’s Accessible Canada Act aims to make Canada barrier-free for persons with disabilities by 2040, and applies to federal regulated organisations, whereas the Accessibility for Ontarians with Disabilities Act has mandated phased compliance for digital communications in government and large private sectors. In Australia, the Disability Discrimination Act is actively enforced for inaccessible digital services, and courts have set strong precedent around equal digital access.

Countries across Asia and the Middle East are also considering integrating accessibility into national strategies, particularly for public services. Digital accessibility standards are also increasingly embedded in procurement policies, ESG frameworks, and investor expectations. Multinational businesses are expected to address global accessibility holistically, keeping vigilant and monitoring the evolving landscape will be key for ensuring overall compliance.

Digital accessibility laws, particularly the European Accessibility Act (EAA), are reshaping expectations for a wide range of consumer-facing products and services.

The EAA, in particular, applies to a variety of products and services, including:

• general purpose computer hardware (and their operating systems) such as laptops and tablets;
• payment terminals and certain self-service terminals such as ATMs, ticketing and check-in machines;
• e-readers and their associated software;
• electronic communications services;
• certain elements of passenger transport services, covering websites, electronic tickets and real-time travel information;
• consumer banking interfaces and mobile apps;
• e-commerce platforms, including websites and mobile shopping apps.

While digital accessibility obligations in the U.S. continue to evolve, the ADA, the Twenty‑First Century Communications and Video Accessibility Act (CVAA), and legacy accessibility laws apply, to varying degrees, to broad categories of businesses and services, including:

• websites, mobile apps, and other public-facing digital services provided by public accommodations, which includes retailers, restaurants, hotels, banks, healthcare providers, and entertainment venues;
• services, platforms, and equipment that provide real-time voice, text, and video conferencing services;
• video programming and streaming platforms;
• digital services provided and used by government agencies.

If your organisation is involved in designing, selling, distributing or integrating these types of products or services, you may need to meet specific accessibility requirements.

Importantly, accessibility may be relevant not only just for product manufacturers and service providers, but also more broadly across the supply chain. Businesses must review the relevant rules and assess whether their offerings are in scope.

With digital accessibility regulations evolving rapidly, businesses need more than a one-off compliance exercise. Ongoing vigilance is essential. To stay compliant and competitive, businesses should consider implementing the following strategies:

• Monitor legislative developments. Laws are not static. The EAA, for example, takes full effect in June 2025 but continues to develop through technical standards and national implementation. Other countries, including the United States, Canada and Australia, are also expanding or clarifying digital accessibility obligations. Legal and compliance teams should regularly review updates across key markets.
• Engage with regulators and industry bodies. Proactive dialogue with regulators, accessibility experts and industry associations can provide early insight into enforcement trends, expectations and upcoming changes.
• Assess whether your products and services fall in scope. The EAA applies to a defined list of products and services, but determining applicability can be complex. Businesses should review offerings against legal definitions, especially when launching new tools, platforms or consumer-facing features.
• Keep an eye on your supply chain. Compliance is not limited to your own operations. Suppliers, developers, third-party platforms and content providers may all impact accessibility outcomes. Contracts and procurement processes should reflect this.
• Plan ahead for future launches. Accessibility should be built into product development and service design from the outset. This not only reduces compliance risk but also improves user experience and market reach.

Remaining informed and engaged is the best way to future-proof your business in an increasingly accessibility-driven regulatory landscape.