This posting summarizes some detailed research into the state of government accessibility standards around the world, as of March 2016. Usually these evolve fairly slowly, although the Jodhan vs. Attorney General of Canada case may change that (governments don’t like being successfully sued by their citizens).
In general, these standards apply to government agency websites (and not commercial web sites) with the exception of Australia and Norway where commercial sites are also required to comply. Other countries have disability discrimination laws which cover websites, but these don’t specify the technical standards required to comply with the law.
This table shows government accessibility standards, and relevant legislation, in 18 territories:
Comparison of accessibility standards in 11 countries
Country
Standard
Legislation
Applies to
Australia
WCAG 2 AA
Disability Discrimination Act
All government and non-government websites should comply with WCAG 2 AA by end of 2013
Canada
WCAG 2 AA
Human Rights Act 1977
Common Look and Feel 2.0 required WCAG 1 up till July 2011 for all government websites. The Jodhan vs. Attorney General of Canada ruling requires the Canadian government to update the guidelines to WCAG 2, and this was implemented as the Standard on Web Accessibility on Aug 1, 2011.
EU
WCAG 2 AA
European Parliament Resolution (2002) 0325 †
Required for all EU commission websites - see EUROPA - Web accessibility policy.
France
RGAA 3 (based on WCAG 2)
Law No 2005-102, Article 47
Updated from RGAA 2.2 in April 2015, to take account of new technologies like HTML5 and ARIA. RGAA 2.2 was required for all French central government websites by May 2011. All other French public websites (public services, towns, public research, etc) are required to comply by May 2012.
Germany
BITV 2 (based on WCAG 2)
Federal Disabled Equalization Law (BGG)
BITV 2 came into force on Sept 22, 2011, and is required for all government websites. It is based on WCAG 2, but not identical.
Hong Kong
WCAG 2 AA
WCAG 2 AA became the standard for GovHK websites in March 2012.
India
Guidelines for Indian Government Websites (based on WCAG 2 A)
WCAG 2 Level A became the standard for Indian government websites in February 2009.
Ireland
WCAG 2 AA
The Disability Act 2005
All government websites - Universal Design Guidance for Online Public Services 2.10
Israel
WCAG 2 AA
Equal Rights of Persons with Disabilities Law, 5758-1998
All government websites, and websites of businesses with annual turnover of 500,000 ILS
(approx USD $125,000)
- Israeli Standard 5568
Italy
Technical Rules of Law 4/2004 (updated to WCAG 2 in September 2013)
Law No. 4/2004 (Stanca Law)
Required for all government websites
Japan
X 8341-3:2016 (identical to WCAG 2).
Identical to ISO/IEC 40500:2012, which is itself identical to WCAG 2. Required for all local and central government websites. Commercial websites are also encouraged to use it.
Netherlands
WCAG 2 AA
Government websites must comply with the government web guidelines, which include WCAG 2 AA. There are no requirements for non-government websites.
New Zealand
WCAG 2 AA
Human Rights Amendment Act 2001
Web Accessibility Standard 1.0 (WCAG 2 AA with some exceptions) required for all government web sites.
Norway
WCAG 2 AA (with exceptions)
LOV 2008-06-20 nr 42 Lov om forbud mot diskriminering på grunn av nedsatt funksjonsevne
The law requires all websites to be be universally designed. From July 2013, new websites should follow WCAG 2 AA with some exceptions regarding time-based media and social media.
Ontario
AODA (WCAG 2 AA)
Required for all new Ontario government websites by January 2012, and existing government websites by January 2016.
Quebec
SGQRI 008 (based on WCAG 2)
Standards sur l'accessibilité du Web
Custom made standard based on WCAG 2.0 with specifics covering websites, downloadable documents and multimedia.
Spain
UNE 139803:2012 (updated in 2012 to WCAG 2 AA)
Law 34/2002, Law 51/2003
Required for all government websites. No mandatory requirements on non-government websites.
United Kingdom
WCAG 2 AA
Equality Act 2010
The GDS Service Manual requires WCAG 2 AA as a starting point for UK government web sites. Other UK websites need to comply with the Equality Act and provide equal access, but this doesn't specify technical standards.
USA
Section 508 (subset of WCAG 1 with a few additions)
Section 508 of Rehabilitation Act
US federal agencies' websites must comply with Section 508 guidelines. These are currently being updated and will incorporate WCAG 2 AA - but the update has been subject to continual delays through 2013 and 2014.
† Irony Alert: the European resolution insists web site documents should be clear and simple, but kicks off with 22 paragraphs of incomprehensible bureaucratic text. Here’s an example:
whereas the internet as a part of society is an instrument for society as a whole, so it is fundamental that technologically neutral access to public information is offered for all groups in society…
The key takeaway from this research: adoption of WCAG 2 is progressing steadily and becoming increasingly important:
The governments of Australia, Canada, France, Germany, Hong Kong, India, Italy, Ireland, Israel, Japan, Netherlands, New Zealand, Norway, Spain and the UK have already adopted WCAG 2.
In the US, Section 508 is being (slowly) refreshed to harmonize with WCAG 2.
The European Commission has moved to WCAG 2 as a European government standard.