Even if they are familiar with the term "web accessibility," many business owners and web managers are unsure of what specifically to do on their own websites. Following the April 2024 revision of the Act on the Elimination of Discrimination against Persons with Disabilities, which made reasonable accommodation mandatory for private enterprises, accessibility is no longer "only a matter for large corporations."
In this article, we outline actionable perspectives covering key legal revisions, international standard WCAG guidelines, and priority action items that small and medium-sized businesses can address immediately.
What is web accessibility?
Web accessibility refers to a state where anyone can use information and services on a website, regardless of age, disability, or usage environment. It is a broad concept encompassing usability, such as whether visually impaired users can have pages read aloud by screen readers, whether individuals with color vision deficiencies can discern information, and whether elderly users can operate websites on smartphones.
Accessibility compliance is not just for persons with disabilities. Accommodations for accessibility improve user experience (UX) for all users, such as when viewing on small smartphone screens, watching videos without audio in noisy environments, or browsing over slow internet connections.
What changed with the 2024 and 2025 legal revisions?
Revision of the Act on the Elimination of Discrimination against Persons with Disabilities and mandatory reasonable accommodation
The revised Act on the Elimination of Discrimination against Persons with Disabilities, enacted in 2021, came into effect on April 1, 2024, making the "provision of reasonable accommodation" mandatory for private enterprises, whereas it was previously an obligation to make reasonable efforts. Reasonable accommodation means taking action without imposing an undue burden when a request is made by a person with a disability.
Examples of reasonable accommodation on websites include the following:
- Adding alternative text to images that cannot be read by screen readers
- Providing subtitles and text transcripts for video content
- Providing text instructions on how to navigate forms
However, web accessibility itself has not been fully mandated by law across the board. What is mandated is the "provision of reasonable accommodation," while compliance with web technical standards (such as WCAG) remains an obligation to make reasonable efforts at present. Penalties are limited to administrative fines (up to 200,000 yen) in the event that false reports are submitted when government authorities request improvement reports.
International trends and the European Accessibility Act
Stricter regulations are progressing overseas. In the EU, the European Accessibility Act (EAA) entered full application in June 2025, requiring web services of businesses operating within the EU to comply with WCAG 2.1 Level AA. Companies expanding globally must also pay attention to this trend.
Digital Agency guidebooks and government initiatives
Japan's Digital Agency published the "Web Accessibility Implementation Guidebook" and released a revised edition in October 2025 featuring an added section on smartphone accessibility. Government websites are required to comply with JIS X 8341-3:2016, which corresponds to WCAG 2.1 Level AA, and private companies also reference it as a de facto standard.
What is WCAG? — The four principles and three conformance levels
WCAG represents the international standard web accessibility guidelines formulated by the W3C (World Wide Web Consortium). Currently, WCAG 2.2, published in October 2023, is the latest version, and Japan's JIS X 8341-3:2016 is a domestic standard standardized based on WCAG 2.0.
The four basic principles
WCAG is structured around the following four principles (POUR):
| Principle | Overview |
|---|---|
| Perceivable | Information and user interface components must be presentable to users in ways they can perceive (visual, auditory, etc.) |
| Operable | User interface components and navigation must be operable via keyboard or switch devices without a mouse |
| Understandable | Text is readable, operation is predictable, and input errors can be prevented |
| Robust | Content must be robust enough to be interpreted reliably by assistive technologies such as screen readers |
Three conformance levels
WCAG success criteria are categorized into three levels according to their importance.
| Level | Positioning | Benchmark |
|---|---|---|
| Level A | Minimum baseline criteria to satisfy | alt attributes, captions, etc. |
| Level AA | Standard targeted by many countries and institutions | Contrast ratios, focus indicators, etc. |
| Level AAA | Higher standard (full conformance not recommended) | Sign language videos, extended audio description support, etc. |
Private enterprises should target Level AA. Because Level AAA is extremely difficult to achieve, the W3C does not recommend requiring full conformance for all content.
10 priority action items for small and medium-sized businesses to address first
While starting accessibility compliance from scratch may seem overwhelming, the key is to tackle areas with wide impact and low modification costs first. The following 10 items are common high-priority examples for most websites.
- Add alternative text (alt attributes) to images — Essential for screen readers to convey image content
- Ensure text-to-background contrast ratio is at least 4.5:1 — Level AA requirement for regular text
- Make all functionality accessible via keyboard alone — Navigation using Tab, Enter, and arrow keys
- Display visual focus indicators — Avoid indiscriminately using
outline: none - Use headings (h1–h6) in a semantic hierarchy — Prioritize structure over visual design
- Avoid generic link text like "here" or "click here for details" — Ensure link purpose is clear from the text alone
- Provide captions and text transcripts for videos — Accommodation for audio-free environments and hearing-impaired users
- Properly associate labels with form inputs — Match
<label for>with the field'sid - Write specific error messages — Use "The email address format is invalid" instead of "Input error"
- Set unique page titles (
<title>) for each page — Enables users to identify content in browser tabs
How to proceed with accessibility compliance
Step 1: Current state audit
First, assess your website's current status. You can use free automated audit tools such as Google Lighthouse or the browser extension axe DevTools. Because automated checks only detect approximately 30% to 40% of all accessibility issues, combining them with manual human reviews is essential.
Step 2: Prioritization
Based on the audit results, create an action list starting with areas that have high impact and low remediation costs. Set high-traffic pages—such as the top page, contact page, and product/service pages—as top priorities.
Step 3: Establishing production guidelines
Establish internal checklists for production and updates to prevent compromising accessibility when creating or updating pages. When redesigning a corporate website, clearly stating accessibility requirements in the specifications prevents misalignments with your production agency (refer also to How to Proceed with a Corporate Website Redesign and Tips for Successful Outsourcing).
Step 4: Publishing an accessibility policy
Many large corporations and government agencies establish an "Accessibility Policy" page to publish their approach, conformance target, and contact point. Publishing this page even as an SME allows you to publicly demonstrate your commitment and serve as an intake point for reasonable accommodation requests.
Step 5: Continuous improvement cycle
Accessibility requires ongoing maintenance even after a site launches. Because new issues can arise with every content update, establishing an operational structure combining annual periodic audits with checklist reviews during updates is ideal. Similar to Core Web Vitals, we recommend managing performance and accessibility as ongoing health metrics for your website (please also see How to Improve Website Page Speed — Practical Guide to Core Web Vitals).
Estimated costs of accessibility compliance
Remediation costs vary significantly depending on site scale, current quality, and target conformance level. Use the following as general benchmarks:
| Scope of work | Estimated cost |
|---|---|
| Self-audit using free tools | 0 JPY (internal labor only) |
| Basic audit by specialized firm | 100,000–500,000 JPY |
| Detailed audit + remediation proposals | 1,000,000–3,000,000 JPY |
| Full remediation + operational workflow setup | 3,000,000 JPY or more |
When SMEs take a practical approach, a phased methodology of self-audit → internal remediation of priority items → specialist support tailored to budget is effective. Incorporating accessibility requirements during new site builds or redesigns is far more cost-effective than remediating retroactively.
Why you should start taking action now
Beyond legal obligations, accessibility compliance delivers tangible business benefits.
- SEO benefits: Optimizing alt attributes, heading hierarchies, and page titles directly aligns with SEO
- Audience expansion: Enables diverse audiences, including the elderly and persons with disabilities, to use your services
- Enhanced brand image: Boosts credibility as an enterprise fulfilling social responsibilities
- Readiness for the EU market: Compliance with the European Accessibility Act is required when eyeing global expansion
Postponing action with the mindset that "it's not mandatory yet" carries the risk of falling behind competitors. Particularly since 2025, public agencies and major enterprises increasingly publish accessibility policies and require compliance from business partners, making accessibility compliance an emerging evaluation criterion in B2B web environments as well.
Conclusion
- The April 2024 revision of the Act on the Elimination of Discrimination against Persons with Disabilities made the provision of reasonable accommodation mandatory for private companies
- The technical standard for web accessibility is WCAG, with most organizations targeting Level AA
- SMEs should begin with high-priority items like alt attributes, contrast ratios, keyboard navigation, and form labels
- Incorporating requirements during new builds or redesigns is the most cost-effective approach
- Compliance delivers clear advantages in SEO, UX, and brand reputation alongside legal requirements
Feel free to contact us for advice on designing, building, and improving websites, including accessibility compliance.
