Four markets, four laws, one standard. If you sell digital products in more than one of them, here is the timetable on one page. We update it whenever a date moves.
Last updated 3 October 2026.
In one paragraph. In every market we work in, the legal bar for websites and apps is the same: WCAG 2.1 Level AA. Only the dates and the enforcers differ. The EU has enforced it on consumer products since 28 June 2025 under the European Accessibility Act. The US requires it of state and local government from 26 April 2027, or 26 April 2028 for smaller entities, and Colorado already does. The UAE applies it to federal government services now. India applies it to government through GIGW 3.0 and is extending it to every company through draft rules phased over one to two years. One audit and one compliant design system cover all four.
What are the deadlines?
- EU (incl. Germany), European Accessibility Act / BFSG — Consumer sites, apps, shops, banking, ticketing: 28 June 2025 (in force) · EN 301 549 → WCAG 2.1 AA
- Colorado, HB21-1110 — State and local government, and their vendors: 1 July 2025 (in force) · WCAG 2.1 AA
- United States, ADA Title II web rule — Public entities serving 50,000+: 26 April 2027 · WCAG 2.1 AA
- United States, ADA Title II web rule — Public entities under 50,000, special districts: 26 April 2028 · WCAG 2.1 AA
- UAE, National Digital Accessibility Policy — Federal government websites and apps: In force · WCAG 2.1 AA
- India, GIGW 3.0 — Central and state government websites and apps: In force (STQC audit) · GIGW 3.0 / IS 17802
- India, Draft RPwD (Amendment) Rules 2026 — Every establishment offering digital products in India: 12–24 months after notification (draft, July 2026) · IS 17802 → WCAG 2.1 AA
Is it really the same standard everywhere?
Yes, in practice. The US rule names WCAG 2.1 AA directly. The EU's EN 301 549 incorporates it for web and mobile. India's IS 17802 is modelled on EN 301 549. The UAE design system guides federal entities to it. A product that meets WCAG 2.1 AA meets the technical bar in all four markets. What changes from place to place is the paperwork around it and who can come after you.
WCAG 2.2 is not yet required anywhere on this list. Meeting it satisfies 2.1, and the next EN 301 549 revision is expected to adopt it, so it's the sensible build target.
United States: who has to comply, and when?
ADA Title II covers state and local government: cities, counties, school districts, public universities, transit and courts. In April 2026 the Department of Justice moved its deadlines back a year but left the standard unchanged. Large entities must comply by 26 April 2027 and smaller ones by 26 April 2028. Colorado didn't wait: its own law has applied since 1 July 2025, with a $3,500 fine per violation paid to the person affected.
Private companies are reached two ways. A vendor's product becomes the government's product once the public uses it, so the requirement flows down through contracts and RFPs. Businesses open to the public face Title III lawsuits, which number in the thousands every year. → ADA Title II in Colorado: the deadlines and what to fix first
European Union: what has changed since June 2025?
The European Accessibility Act has applied since 28 June 2025 to consumer e-commerce, banking, transport ticketing, telecoms and e-books. Each member state sets its own penalties. They range from a few thousand euros in some countries to €100,000 in Germany and up to €1 million in Spain, and Italy can fine a share of turnover. Enforcement so far has been complaint-led and corrective first: a barrier is reported, an order to fix it follows, and fines come if the fix doesn't. Micro-enterprises that only provide services are exempt. Pure B2B products are out of scope.
In Germany, competitors can also send an Abmahnung (a formal warning letter) before any authority acts. → BFSG in Munich: who it covers, what it costs, and what to fix first
UAE: what applies in Dubai?
Accessibility obligations in the UAE sit with government. The Cabinet-adopted National Digital Accessibility Policy and the TDRA's UAE Design System guide federal websites and apps to WCAG 2.1 AA, and Dubai entities work under the Dubai Universal Design Code. Anything built for a government client inherits that bar, and in practice it must be bilingual: Arabic and English, right-to-left and left-to-right.
The deadline that worries product teams in Dubai is about privacy rather than accessibility. The federal PDPL, plus separate regimes in DIFC and ADGM, govern the same consent and onboarding screens. → PDPL in Dubai: what's law now and what to design in
India: is digital accessibility mandatory now?
For government, yes. GIGW 3.0 has 88 mandatory checkpoints and an STQC audit before a site is certified. For everyone else it's coming. In November 2024 the Supreme Court (Rajive Raturi v Union of India) struck down the "recommendatory" status of the old rules. Draft amendment rules published in July 2026 make IS 17802 mandatory for every establishment offering digital products to people in India, phased by turnover over twelve to twenty-four months from the date they are notified. The rules were still a draft at the time of writing. The direction is settled; only the dates aren't. → Accessibility in Northeast India: the guidelines just became the law
If you sell in more than one market, what do you fix first?
- Audit once, against WCAG 2.1 AA. Go screen by screen and write every failure as a fix. Automated scanners catch roughly a third of the criteria; the rest needs a person with a keyboard and a screen reader.
- Fix the paths people depend on. Checkout, sign-up, login, payment, applications, contact. A compliant homepage with an inaccessible form is where complaints come from.
- Fix the system, not the page. Put contrast, focus states, labels, language markup and structure into the design tokens and components. Then every market, and every new feature, passes by default.
- Add the local paperwork. Publish an accessibility statement and a way to report barriers (EU, India). Prepare a conformance report or VPAT for procurement (US, and India's draft rules). Do a bilingual pass (UAE) and declare each language in the markup (India).
- Re-check as you ship. Compliance is a state you maintain, not a one-off event. Re-test quarterly as content and code change.
Where Parallax fits
Parallax measures every screen it ships against WCAG 2.1 AA, from studios that work in your hours in Denver, Munich, Dubai and the Northeast. We do the same for products that already exist: audits, remediation inside your codebase without a redesign, accessible design systems, and the statements and conformance reports each market asks for. If you have a deadline on this page, start with the brief.
Questions people ask
Which accessibility standard applies in the US, EU, UAE and India?
WCAG 2.1 Level AA, directly or through a national standard: the DOJ rule in the US, EN 301 549 in the EU, IS 17802 in India, and the UAE Design System for federal government.
When is the ADA Title II deadline?
26 April 2027 for state and local governments serving 50,000 or more people. 26 April 2028 for smaller ones and special districts. The DOJ pushed both back a year in April 2026 without changing the standard.
Is the European Accessibility Act being enforced?
Yes, since 28 June 2025. Enforcement runs through national authorities, mostly on complaints, with corrective orders first and fines for failing to fix. Penalties vary by country.
Is accessibility mandatory for private companies in India?
Not yet in final form. Government sites must meet GIGW 3.0 today. The draft RPwD (Amendment) Rules 2026 would require IS 17802 from every establishment, with deadlines of one to two years by turnover from the date the rules are notified.
Is WCAG 2.2 required anywhere?
Not yet. Every regime here references WCAG 2.1 AA. Building to 2.2 satisfies 2.1 and anticipates the next revision of EN 301 549.
Does one audit cover all four markets?
For the technical standard, yes. Each market then adds its own documents: an accessibility statement, a conformance report or VPAT, bilingual content, or a GIGW certificate. These are written from the same audit evidence.
Sources: ADA.gov — Title II web rule · Mondaq — DOJ extends Title II deadlines by one year · Colorado OIT — HB21-1110 FAQ · Level Access — EAA compliance in 2026 · Clym — EAA fines by country · UAE Design System — Accessibility · WAM — TDRA and the National Digital Accessibility Policy · GIGW 3.0 · Mondaq — Draft RPwD (Amendment) Rules 2026 · W3C — WCAG 2.1
