Website Accessibility Compliance Guide

Legal Disclaimer

Please note that this content is for general informational purposes only and does not constitute legal advice. Merchants should consult their own legal counsel to obtain advice tailored to their specific circumstances.

Overview

As a merchant operating a digital storefront, you may be subject to legal requirements that ensure your website is accessible to people with disabilities. These obligations vary depending on where your business is located and where your customers reside. This guideline provides a summary of key accessibility laws in Europe (EU), the United Kingdom (UK), the United States (US), and Canada that may apply to your online business depending on your operational footprint and customer base. Beyond the jurisdictions covered by this article, website accessibility is also required under several other legal frameworks, we encourage you to assess your store’s accessibility not only for compliance, but also for better user experience and inclusivity.

What is Web Accessibility?

According to theW3C Web Accessibility Initiative (WAI)  ,

“Web accessibility means that websites, tools, and technologies are designed and developed so that people with disabilities can use them. More specifically, they can perceive, understand, navigate, and interact with the Web, and they can contribute to the Web.”

For online merchants, this means ensuring that all customers, including those with vision, hearing, mobility, and cognitive impairments, can access, browse, and complete purchases on your store without encountering barriers.

European Union

• European Accessibility Act (EAA)

Applies to:

The European Accessibility Act (Directive (EU) 2019/882) applies to a range of products and services placed on the EU market after 28 June 2025, including e-commerce services. This means the Directive governs how online services are delivered to consumers in the EU, regardless of where the provider is established.

Therefore, if you are a merchant offering goods or services online to consumers located in the European Union—even if your business is based outside the EU—you are likely covered by this law. Whether you operate a website, mobile app, or platform, if it is accessible to EU consumers, you must ensure that your digital service meets the accessibility requirements laid out in the Directive.

Requirements:

Websites and mobile apps must be perceivable, operable, understandable, and robust, aligning with the WCAG 2.1 Level AA standards, as embedded in EN 301 549, the EU’s harmonized accessibility standard.

Exemptions:

Microenterprises (under 10 employees and <€2 million turnover) may be exempt, but this depends on national laws. However, EU Member States are encouraged to support micro-enterprises by providing guidelines and tools to help them voluntarily adopt accessible design practices.

United Kingdom

1. Equality Act 2010

Applies to:

The UK Equality Act 2010 applies to all service providers—public or private (businesses, non‑profits, schools, etc.). It mandates the legal duty to make "reasonable adjustments" to remove or reduce barriers for disabled persons.

Therefore, if you are a merchant offering goods or services to customers in the UK, either from within or outside the UK, you are expected to ensure your website, app, or online store is accessible.

Requirements:

Under the Equality Act 2010, businesses must make “reasonable adjustments” to avoid disadvantaging people with disabilities, including online. While the Act does not prescribe technical standards, compliance with WCAG 2.1 Level AA is widely recognized as the industry benchmark for meeting legal obligations under the "reasonable adjustments" duty.

2. Public Sector Bodies (Websites and Mobile Applications) Regulations 2018

This regulation does not apply to private merchants. It imposes stricter web accessibility requirements only on public sector bodies, such as government agencies, local councils, the NHS, and educational institutions. Under these regulations, all public sector websites and mobile apps must conform to WCAG 2.1 Level AA, with monitoring of WCAG 2.2 compliance beginning in October 2024.

For merchants and private businesses, this Law serves only as a point of reference for public sector compliance—it does not create direct obligations.

Canada

1. Accessible Canada Act (ACA)

The ACA applies mainly to federally regulated organizations—such as banks, telecoms, airlines, federal government bodies, and parliamentary entities, and does not generally apply to private-sector merchants operating provincially. For merchants and private businesses, this Law serves only as a point of reference for public sector compliance, it does not create direct obligations.

2. Ontario: Accessibility for Ontarians with Disabilities Act (AODA)

Applies to:

The AODA applies broadly to every person or organization in the public and private sectors in Ontario, including the Legislative Assembly of Ontario.

However, with respect to the accessible websites and web content requirements under Section 14 of the Integrated Accessibility Standards Regulation (IASR), the obligations apply specifically to:

• The Government of Ontario and the Legislative Assembly.
• Designated public sector organizations.
• Private and not-for-profit organizations with 50 or more employees.

Therefore, if your business operates in Ontario and has 50 or more employees, you are legally required to ensure your website and web content meet these accessibility standards.

Requirements:

All applicable organizations shall ensure that their internet and intranet websites and web content conform to the Web Content Accessibility Guidelines (WCAG) 2.0.

Organizations with fewer than 50 employees are not subject to the Section 14 website accessibility obligations.

3. British Columbia: Accessible BC Act (2021)

Applies to:

The Accessible BC Act currently applies only to provincial government ministries and prescribed public sector organizations such as municipalities, school boards, public colleges and universities, libraries, and health authorities.

Private-sector businesses, including merchants, are not currently subject to this Act. However, the legislation allows for future expansion through regulation, so merchants operating in B.C. should stay informed as accessibility requirements may be extended to the private sector in the coming years.

Requirements:

Covered organizations must:

• Establish an accessibility committee.
• Publish and update an accessibility plan every three years.
• Maintain a public feedback process on accessibility barriers.

While the Act does not yet mandate compliance with WCAG or specific web standards, digital accessibility should be addressed in organizational accessibility plans. Future regulations may introduce enforceable digital standards.

4. Manitoba: Accessibility for Manitobans Act (AMA)

Applies to:

All organizations in Manitoba, including the public and private sectors. Therefore, if you are a merchant operating in Manitoba, you are subject to the AMA and its accessibility standards.

Requirements:

According to the Regulations, web content must meet or exceed WCAG 2.1 Level AA if it is required to access the organization’s goods or services.

Exemptions:

Organizations do not need to comply if:

• Not technically feasible or technology unavailable.
• Compliance causes undue hardship.
• They lack direct control over the web application.
• Content relates to product labels or other product information.

5. Nova Scotia: Accessibility Act

Applies to:

Prescribed public-sector bodies, including municipalities and regional districts, universities, colleges, public libraries, health authorities, provincial housing agencies, arts and tourism entities.

At this time, the Act does not apply to private-sector businesses, including merchants. However, the legislation is designed to expand in phases. Future regulations may extend accessibility obligations to private businesses, so merchants operating in B.C. should monitor developments to prepare for potential compliance duties.

Requirement:

No standing requirement under the Accessibility Act for organizations to conform to WCAG at this. The Act’s Information & Communication Standard (which will include web/digital content) is still under development and is expected to be introduced between 2028–2029.

United States

Americans with Disabilities Act (ADA)

Applies to:

The ADA applies broadly to:

• Public sector entities (Title II) — including state and local governments
• Private sector entities that are places of public accommodation (Title III) — including retail stores, restaurants, hotels, medical offices, schools, and more, whether physical or online, if they serve the public.

Therefore, if you are a merchant operating a business that serves the public in the U.S, whether in a physical location or through a website or app, you are likely subject to the ADA’s accessibility obligations.

Requirement under ADA Title III:

Although there is no explicit statutory requirement for private businesses to use WCAG, the DOJ consistently recommends WCAG 2.1 AA as the appropriate benchmark. Consequently, it is widely regarded as the de facto standard for ADA compliance in the digital environment.

Consquences of Non - Compliance

Failure to make your online store accessible to people with disabilities can result in significant legal and commercial consequences, regardless of where your business is located. Many jurisdictions treat accessibility as a legal right, not just a best practice — and enforcement is increasing globally. Some likely consequences include:

• Legal claims and lawsuits by individuals or advocacy groups.
• Regulatory enforcement, including fines and mandated changes.
• Injunctive relief or settlement obligations, with legal costs.
• Reputational harm and loss of customer trust.
• Restricted market access in jurisdictions with mandatory standards.
• Lost sales opportunities, as inaccessible sites exclude potential customers.

While some jurisdictions offer limited exemptions for micro-enterprises or have not yet imposed direct obligations on the private sector, small businesses are still strongly encouraged to adopt accessibility practices. This approach not only promotes inclusive access and enhances the overall user experience, but also demonstrates a proactive commitment to compliance and positions the business favourably in increasingly regulated markets.

How We Support You

We support you in building inclusive digital storefronts by partnering with accessibility apps available through our app store. These tools are designed to help ensure your website meets the widely adopted Web Content Accessibility Guidelines (WCAG) standards, which provide detailed criteria to make digital content perceivable, operable, understandable, and robust for users with disabilities. Many of these apps include built-in audit features that monitor compliance and help maintain ongoing accessibility, empowering you to create a better experience for all users while meeting legal requirements.