Compliance
Landscape

Applies to: Public accommodations, employers, state and local government. Title III covers websites of businesses open to the public.

Standard: WCAG 2.1 AA is the de facto standard enforced by courts and the DOJ.

Applies to: Federal agencies and organizations receiving federal funding. Covers electronic and information technology developed, procured, or used by the federal government.

Standard: The 2018 Refresh incorporated WCAG 2.0 AA by reference.

Applies to: Products and services offered in the EU: e-commerce, banking, e-books, transport ticketing, consumer electronics, and digital communications.

Standard: EN 301 549 is the harmonized EU standard, which references WCAG 2.1 AA.

Applies to: ICT products and services procured by public sector bodies in EU member states. Also referenced by the EAA for private sector compliance.

Standard: Incorporates WCAG 2.1 AA requirements and adds requirements for non-web software, documents, and hardware.

Applies to: All public and private sector organizations with one or more employees in Ontario.

Standard: WCAG 2.0 AA is the required standard. WCAG 2.1 compliance is recommended.

Removes the most severe barriers — content that is completely inaccessible without these fixes. The floor, not the target.

• ▸All images have an alt attribute
• ▸Content is not seizure-triggering
• ▸Pages have a descriptive title
• ▸Keyboard navigation is possible
• ▸Form inputs have associated labels

The legal baseline in most jurisdictions. Covers the broad range of barriers affecting the largest number of users.

• ▸Text contrast ≥ 4.5:1 (normal), 3:1 (large)
• ▸Text resizes to 200% without loss of content
• ▸Focus indicators are visible
• ▸Error messages are descriptive
• ▸Headings and labels are meaningful

The highest level. Not required by any regulation, but reflects best practice for the widest possible audience.

• ▸Text contrast ≥ 7:1 (normal), 4.5:1 (large)
• ▸Sign language for prerecorded audio
• ▸Reading level ≤ lower secondary education
• ▸Context-sensitive help is available
• ▸No timing requirements on any task

• □Written accessibility policy exists and is publicly available
• □Policy names a specific WCAG level target (AA minimum)
• □Policy covers both web content and digital documents
• □Accessibility is included in procurement requirements

• □Content creators receive accessibility training before publishing
• □Developers are trained on ARIA, semantic HTML, and keyboard navigation
• □Reviewers know how to use at least one screen reader for testing
• □Training is repeated when WCAG standards are updated

• □Automated scanning is part of the publishing workflow
• □Manual keyboard navigation testing is performed before release
• □Screen reader testing is performed on all interactive content
• □Color contrast is verified at design time, not just post-production

• □A process exists to receive and respond to accessibility complaints
• □Response time targets are defined (e.g., 5 business days)
• □A remediation backlog is tracked and prioritized by severity
• □Accessibility issues are reviewed in retrospectives or post-mortems

Target's website was inaccessible to blind users — no alt text on product images, no keyboard navigation, inaccessible checkout. The case established that private retailer websites are covered by ADA Title III.

Domino's website and app were inaccessible to screen reader users. The Ninth Circuit held that the ADA requires Domino's to comply with WCAG 2.0, remanding for further proceedings.

Winn-Dixie's website was used in conjunction with physical stores (coupons, pharmacy refills). The court required accessibility because of this nexus — but narrowed the scope to websites directly tied to a physical location.

The Department of Justice issued a final rule under ADA Title II requiring all state and local government entities to meet WCAG 2.1 Level AA. Deadlines range from 2026 to 2027 based on population served.