Disability Rights & Accessibility Laws, Outside the United States

by Cam N. Coulter


Posted on June 28, 2021 accessibility


Universal access icon: a stick figure with a circle around them.

Outside the United States, what rights do people with disabilities have and what laws mandate accessibility?

My last two posts have already partially answered this question:

In this post, I’m going to look at national (or provincial) laws — again, outside the US — that affect disability rights and accessibility. Most laws of this sort fall into one of three categories:

  1. Civil rights laws
  2. Procurement laws
  3. Domain-specific laws

Civil rights laws often take the form of anti-discrimination legislation, making it illegal to discriminate against persons with disabilities and possibly mandating accessible goods and services. These laws often focus more on equal rights for people with disabilities than on providing social welfare, and consequently anti-discrimination laws typically affect both the public and private sectors. Some, but not all, civil rights laws have prescriptive guidelines for measuring accessibility. The growth of civil rights legislation protecting people with disabilities across the world can be linked to the growing influence of the social model of disability, as well as to the Convention on the Rights of Persons with Disabilities. The Americans with Disabilities Act (ADA) in the US is an example of a civil rights law.

Procurement laws require that organizations buy accessible products and services. Procurement laws often target public entities (that is, governments). Section 508 of the Rehabilitation Act in the US is an example of a procurement law. Section 508 requires that federal agencies meet certain accessibility standards when they develop, procure, maintain, or use ICT.

Domain-specific laws affect a specific industry. For example, in the US, the Air Carrier Access Act prohibits airlines from discriminating against persons with disabilities and associated regulations require airlines to have accessible websites.

As we’ll see in a moment, there are lots of different laws across the world that affect disability rights and accessibility, and while it isn’t realistic for any one person to be an expert in all of these, I do think it can be helpful for accessibility professionals to have a basic familiarity with accessibility laws and regulations in other countries. Many of those laws fall into one of these three categories, so I think it’s helpful to have this framework in mind as we talk about these laws. Now, let’s get into it!

Canada

The Canadian Human Rights Act explicitly prohibits discrimination on the basis of ability.

The Accessible Canada Act affects the federal public sector, state-owned enterprises, and certain federally regulated organizations. For more on this act, see “Nothing Without Us and the Accessible Canada Act” by Sheri Byrne-Haber.

Canadian provinces have enacted accessibility legislation, including:

The AODA is the oldest and most well-known of these provincial laws. It sets accessibility standards for both public and private sectors. Additionally, the Ontario Human Rights Code explicitly prohibits discrimination against persons with disabilities.

For more on disability rights and accessibility laws in Canada, I recommend “A Complete Overview of Canada’s Accessibility Laws” by Jennifer Doyle on Siteimprove’s blog.

United Kingdom: Equality Act 2010

The Equality Act 2010 is a broad anti-discrimination act that explicitly protects people with disabilities. Here are some links where you can learn more:

Australia: Disability Discrimination Act

In Australia, the Disability Discrimination Act prohibits discrimination against persons with disabilities, and conformance with WCAG 2.0 is “strongly recommended.”

New Zealand: Human Rights Act

In New Zealand, the Human Rights Act explicitly prohibits discrimination against persons with disabilities.

Government Standards for Accessibility

Even if they don’t prohibit discrimination against people with disabilities or mandate accessibility in the private sector, many countries have set their own public-facing, government standards for accessibility, and those standards often reference WCAG 2.0. Below are some links where you can learn more about those requirements as well as other laws across the world that affect disability rights and accessibility.

Image created by Cam Coulter. Icon by mikion on the Noun Project.


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