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Accessibility laws and standards: United States and Europe

The rules differ by region, but almost all of them rest on the same technical standard: WCAG. I test your site once, by hand, and the report speaks to whichever rules apply to you.

The two regions

United States

  • ADA Title III: businesses open to the public, including online stores. Enforced mostly through private lawsuits and demand letters.
  • ADA Title II: state and local government websites. The Department of Justice rule sets WCAG 2.1 AA, with deadlines in April 2027 and April 2028.
  • Section 508: federal agencies and the vendors who sell to them. A VPAT/ACR is the usual proof.

See US lawsuit data and risk by industry

European Union

  • European Accessibility Act (EAA): applies since 28 June 2025 to consumer services such as e-commerce, banking, e-books and transport booking. It also covers businesses outside the EU that sell to EU consumers.
  • Web Accessibility Directive: websites and apps of public sector bodies.
  • EN 301 549: the European standard behind both. Version 3.2.1 is based on WCAG 2.1 AA, and the new version 4.1.1 (September 2026) is based on WCAG 2.2 AA.

See EN 301 549 and EAA audits

How the rules compare

Comparison of US and EU accessibility rules
RuleWhereWho it coversTechnical standardHow it is enforced
ADA Title IIIUnited StatesBusinesses open to the public, including their websitesNo named standard. WCAG is what settlements and courts usually use.Private lawsuits and demand letters
ADA Title IIUnited StatesState and local governmentsWCAG 2.1 AAFederal rule with deadlines in April 2027 and April 2028
Section 508United StatesFederal agencies and their suppliersWCAG 2.0 AAProcurement: buyers ask for a VPAT/ACR
European Accessibility ActEuropean UnionConsumer services such as e-commerce, banking, e-books and booking, including sellers outside the EUEN 301 549National authorities, with penalties set by each country
Web Accessibility DirectiveEuropean UnionPublic sector websites and appsEN 301 549Monitoring by each Member State

This is a general overview, not legal advice. Details change, so confirm what applies to you with a qualified lawyer.

One audit, two markets

Every rule in the table relies on WCAG in some form. I test against WCAG 2.2 AA, the newest version, by hand, and then map each finding to the rules you care about: the ADA and Section 508, EN 301 549 and the EAA, or both.

If you sell in the US and the EU, you don't need two audits. You need one thorough audit and a report that shows how it relates to each market.

Get a free accessibility checkRead: how these rules differ