Global regulation trends: the accessibility rules UK organisations can't ignore

If you work in digital accessibility, it can feel as though the legal landscape is changing almost monthly. New laws are appearing around the world, existing regulations are evolving and regulators are taking a greater interest in how organisations deliver accessible digital services.

For UK organisations, accessibility regulation has historically been mainly an issue for the public sector. This is changing, as accessibility regulation becomes increasingly globalised, while UK regulators take more interest in accessibility for sectors such as financial services. 

The European Accessibility Act has changed the conversation

For many organisations, the European Accessibility Act (EAA) remains the biggest development in digital accessibility regulation.

The Act is now in force and applies to many products and services sold to consumers within the EU, affecting organisations based outside the EU that trade into EU markets. Its reach extends to areas including banking services, e-commerce, e-books, ticketing systems and consumer devices. It goes beyond technical compliance checking.

Covered organisations need to be able to show that relevant products and services meet accessibility requirements, including through accessible design and production, accessible information and instructions, appropriate support services, and documentation demonstrating compliance over time.

While there has not yet been widespread enforcement activity, designated monitoring authorities across Europe are becoming established and organisations should expect their activities to increase over time, as large-scale monitoring is put in place and complaints are followed up. 

Standards and enforcement matter as much as legislation

A common theme across different countries is that legislation has the greatest impact when it is supported by clear technical standards and credible enforcement.

In the US, adding WCAG 2.1 AA (Web Content Accessibility Guidelines) Accessibility as a technical standard to the already existing Americans with Disabilities Act (ADA) Title II Regulations more clearly defined an already existing requirement for accessible communication and has encouraged increased compliance efforts.

In the UK, there are criticisms of the Equality Act (the main UK disability discrimination legislation) such as by Disability Rights UK, that it suffers from a lack of proactive enforcement (due to relying on individuals taking expensive legal action) and requirements that depend on concepts such as reasonableness and proportionality rather than clear standards. 

By contrast, regulations with active oversight may be having a greater practical impact:

• The Public Sector Bodies Accessibility Regulations covering public sector organisations has defined technical expectations (WCAG 2.2 AA) for websites and mobile apps as well as a requirement for accessibility statements and central government monitoring.
• Within financial services, the Financial Conduct Authority's (FCA) Consumer Duty is also proving to be a significant driver. Consumer Duty requires financial service organisations to deliver good outcomes for all customers, including disabled customers and those in vulnerable circumstances. This includes providing accessible communications and support services that are designed and delivered to meet the needs of all customers. 

Similarly, the impact of the EAA is likely to increase when enforcement activity starts to become more visible and when the updated version of EN 301 549 is published (hopefully later this year), providing a clear harmonised standard offering presumed conformance with the relevant EAA accessibility requirements. 

Regulation is expanding globally

Although the EAA has received most attention, countries elsewhere in the world are also strengthening accessibility requirements.

Canada has the Accessible Canada Act, which goes well beyond digital services. Organisations covered by the legislation must publish accessibility plans, report regularly on progress and demonstrate how barriers are being identified and removed. This places accessibility firmly within organisational governance rather than treating it as a one-off compliance exercise.

India is another example that has become increasingly active in accessibility regulation. Recent developments include WCAG-based ICT accessibility standards and accessibility requirements within parts of the financial services sector, including from the Securities and Exchange Board of India (SEBI). 

These developments show that accessibility regulation is no longer just concentrated in the USA and Europe. 

Global regulation doesn’t stop at national borders

One important point for UK organisations is that regulation outside the UK can increasingly affect their accessibility obligations. 

A software company based in Manchester may have customers in Germany, Canada or the United States. A SaaS (software as a service) provider headquartered in London could be selling to local authorities in the US or banks across Europe. In each case, those customers may need software that meets their own legal accessibility obligations.

For example, the ADA Title II changes for US public entities (mentioned above) are driving demand for accessible digital products from suppliers across the world. Similarly, UK companies selling services into the European Union may need to demonstrate compliance with European Accessibility Act requirements to purchasers that are selling on to EU consumers - even if the UK companies consider themselves to be B2B companies rather than B2C, and may therefore have thought that the EAA doesn’t apply to them. 

This means that UK businesses may be increasingly asked accessibility questions during procurement and find they are required to provide evidence such as audit reports or accessibility statements - not because UK law demands it, but due to their customers’ legal obligations elsewhere in the world. 

For organisations with global ambitions, accessibility is becoming a competitive advantage as well as a compliance consideration. Building products to recognised international standards such as WCAG 2.2 and EN 301 549 can make it significantly easier to sell into multiple markets without needing to rework products for different jurisdictions.

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Consumer Duty and Digital Accessibility

AI is becoming part of the accessibility conversation

Another emerging trend is the relationship between accessibility and artificial intelligence (AI).

The EU AI Act is primarily about ensuring AI systems are used safely and ethically, with a strong emphasis on protecting fundamental rights. However, it also reinforces the importance of accessibility.

For higher-risk AI systems, accessibility requirements are aligned to those in the European Accessibility Act and Web Accessibility Directive. More generally, organisations deploying AI should be considering whether systems are understandable, transparent and usable by disabled and older people, while avoiding bias and exclusion.

As AI becomes embedded within customer journeys, accessibility is increasingly becoming part of responsible AI governance rather than a separate consideration.

Global accessibility trends

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Stay ahead of accessibility regulation

New accessibility requirements are emerging across Europe, North America and beyond. Whether you're preparing for the EAA, strengthening Consumer Duty outcomes or improving digital governance, these resources can help you take the next step.

To learn more, these resources are a good place to start:

• Find out what the European Accessibility Act means for your organisation
• Ensure your AI-powered services are accessible and inclusive
• Identify accessibility risks before they become compliance issues
• Build accessibility skills across your entire organisation
• Create a sustainable accessibility strategy and governance framework
• Benchmark your organisation's accessibility maturity and plan your next steps

Looking ahead

Accessibility regulation shows no sign of slowing down. 

Whether through the European Accessibility Act, the EU AI Act, developments in Canada and India, or increasing regulatory focus within the UK, the direction of travel is clear. 

Regulations are moving towards clearer technical standards, stronger governance expectations and more meaningful oversight.

The organisations best placed to respond will be those that embed accessibility across their teams via strong accessibility governance, rather than treating it just as as a technical compliance exercise.