Accessibility AA Implementation Checklist

The 15^th Global Accessibility Awareness Day (GAAD) held on May 21 this year serves as a reminder that for many people, digital accessibility(*) remains challenging (one estimate by GAAD puts the total number of people with some form of disability at up to 1 billion). This is a topic that concerns both design and IT teams, who need to balance real usability with more inclusive, accessible design.

(*)Digital accessibility refers to the ability of people with disabilities/impairments to independently consume and/or interact with digital (e.g., web, mobile) applications and content.

While accessibility has been dismissed as being in conflict with design and added in development only as an afterthought, a development process that proactively incorporates accessibility right from the beginning and treats it as an ongoing capability can benefit in several significant ways:

• Lower cost and higher-quality product, as adding accessibility features late in development not only takes up more resources and effort, but results in a worse product that malfunctions with changes like new updates.
• Improved user experience, since thoughtful choices regarding visibility, formatting, etc. can better accommodate a wide range of user needs, leading to a growth in new users and better retention.
• Better conformity to legal regulations, especially in markets with strict regulations for accessibility.

This checklist provides IT and Design Leads with an actionable plan that balances legal expectations, design/development practices, and continuous verification. It is designed to meet Web Content Accessibility Guidelines’ (WCAG) AA standard, the most common accessibility benchmark that websites and services should meet.

Points to Consider: Actual Accessibility & Regulatory Differences

To better plan and understand digital accessibility in practice before starting development, teams should keep the following two aspects in mind.

1. Compliance ≠ Accessibility

In accessibility design, legal conformance and checklists should be treated as a baseline for development, rather than the endgoal. A user flow can technically conform to legal requirements, yet remain inaccessible for many users. For example, an email sent by an application places its direct login link after a six-digit OTP, making it difficult for both visually impared and sighted users to locate.

For IT and Design Leads, accessibility should be built into the overall strategy and not be treated only as a QA concern. In addition to automated audits, teams must have human oversight by conducting manual testing and user research with people with disabilities. Similarly, observation beats assumptions: try navigating the application being worked on with only screen reader enabled.

2. Different Regulatory Contexts

European Union (EU)

The EU’s legal framework for accessibility is based on the Web Accessibility Directive (WAD) and the European Accessibility Act (EAA). The WAD, in effect since 2021, requires accessibility for all public services. Beginning on June 28, 2025, the EAA targets a wide range of private devices (computers, ATMs, etc.) and services (banking, e-book, e-commerce, etc.).

As its application varies across the EU, member states have drawn up their own regulations based on this framework. In particular, France is developing legal requirements for digital accessibiity for private services and softwares, which includes:

• Obligations for an accessibility status on every page, a standardized accessibility declaration, and a multi‑year remediation plan (3 years maximum).
• Widening mandates for the service as a whole, not only a single app, to be accessible. New services must comply starting June 2025, while existing services are expected to do so from June 2028.

Failure to comply in France carries significant penalties. Missing declarations can trigger €25,000 per site per year for large private entities, while other sanctions can start at €7,500 for first violation and €15,000 for repeat offenses, up to service confiscation. Internal tools like CRMs are not exempt either: an inaccessible tool that prevents hiring can be grounds for discrimination, possibly escalating into criminal charges.

Overall, different states in the EU carry different legal requirements for accessibility, which are guided by the overarching WAD and EAA laws. Prior research and planning is essential to avoid incurring costly fines as in France, where enforcement capacity is maturing.

Japan

Japan’s digital accessibility is currently regulated by Japan Industrial Standards JIS X 8341-3:2016, which follows the international WCAG 2.2 standards. This is part of the Act for Eliminating Discrimination against Persons with Disabilities passed in 2013, and provides accessibility benchmarks for public and private services.

According to the Bureau of Internet Accessibility, the JIS X 8341-3 is not strictly enforced, with implementation largely left to the companies’ discretion (although many have taken action towards making their websites and services more accessible). However, businesses are still liable for failing to report their accessibility practices or fabricating claims under the Disabilities Act, with fines of up to ¥200,000 ($1,700 USD).

While digital accessibility is not strictly enforced, it is advisable that measures are taken to accommodate user needs in order to expand the current userbase. This is especially true for Japan, which has an aging population with potentially growing disabilities and other medical conditions.

The Case of Vietnam

In recent years, Vietnam has increasingly recognized the need for digital accessibility. For example, the 2010 Law on Persons with Disabilities states that access to digital services is a right and recommends designing products and services to accommodate users with disabilities, although it does not make this a legal obligation.

More recently, the 2025 Law on Digital Transformation makes several references to digital accessibility, including requirements for both public and private services to account for a variety of users with different needs. Despite this, there are still no clear enforcement mechanisms, and the law itself makes no mention of WCAG standards.

Overall, digital accessibility in Vietnam is a “nice-to-have” rather than “must-have”, giving companies the option to implement or not. However, considering the benefits discussed earlier such as an expanded userbase and a more robust final product that responds well to updates or new regulations, businesses can stand to gain from an early investment in accessibility.

Accessibility AA Implementation Checklist

The provided checklist covers the entire development process from the very beginning until after releasing. In this way, accessibility continues to grow and improve with each new circumstance.

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