"Our web development agency told us that web accessibility became legally mandatory in 2024 and failing to comply would violate the law, quoting millions of yen for a full site overhaul. We can't tell whether this is genuinely critical or just an aggressive sales pitch." A retail business owner brought this concern to us. When terms like "mandatory" and "violation of the law" are thrown around, businesses often rush into expensive contracts without verifying the facts.
To state the conclusion first: the claim that "accessibility is mandatory, making non-compliance illegal" is not accurate. What the law actually mandated for private businesses is something else, and web accessibility itself is not a legal requirement accompanied by penalties. However, that does not mean you should do nothing. In this article, we clarify what the 2024 legal revisions actually require and explain, in prioritized order, the essential steps SMB project owners should take while avoiding excessive expenditures.
The exact details of the mandate: What is mandatory and what is an obligation to make reasonable efforts
The starting point is the revised Act on the Elimination of Discrimination against Persons with Disabilities, which took effect on April 1, 2024. Under this revision, providing reasonable accommodation became mandatory for private businesses as well. This part is true, and it applies to all businesses, not just a subset of large enterprises.
However, this is where misunderstandings easily occur. What became mandatory was the "provision of reasonable accommodation," not "making websites accessible" per se. Reasonable accommodation refers to accommodating people with disabilities upon request, provided it does not impose an undue burden. On the other hand, preparing a website so that anyone can use it is legally classified as environmental improvement, which remains an obligation to make reasonable efforts. In other words, simply not complying with web accessibility standards does not carry any penalties in and of itself.
| Common explanation | The reality |
|---|---|
| Web accessibility has become mandatory | What became mandatory is the "provision of reasonable accommodation." Web compliance is environmental improvement (obligation to make reasonable efforts) |
| Non-compliance leads to legal violations and penalties | There are no penalties for web accessibility non-compliance itself |
| Every single page must be completely overhauled | What is required is accommodation within a range that does not impose an undue burden |
As a benchmark for success criteria, JIS X 8341-3 is referenced in Japan, while the WCAG guidelines are referenced internationally. However, these are not "laws you break if you fail to comply," but yardsticks to measure your level of implementation. Simply understanding this distinction helps you avoid jumping to the conclusion that "mandatory equals a complete overhaul."
Why clients should focus on prioritization rather than doing everything
Since the law does not demand a complete overhaul, the right question for clients to ask is not "should we comply or not?" but rather "where should we start, and how far should we go?" Tackling high-impact areas first within a limited budget makes the most sense in terms of cost-effectiveness.
High-priority areas are the parts where many users genuinely encounter difficulties. Issues such as poor color contrast between text and background making content hard to read, missing alt text on images preventing screen readers from conveying information, or unclear form labels hindering input are relatively low-effort fixes with substantial impact. Conversely, adding subtitles to all videos or overhauling an entire website from the ground up incurs heavy costs and shouldn't be your starting point. What is important to note here is that many of these improvements don't just benefit people with disabilities; they directly enhance usability for elderly customers and general users viewing sites on small smartphone screens as well. Accessibility initiatives are actually effective measures to avoid missing out on a wide range of customers.
A community-based retail store we supported was struggling with a high drop-off rate on their e-commerce application form. While they were considering a full overhaul, the actual changes we made were modest tweaks: making input field labels clearer, making error messages stand out, and increasing the contrast between text and background. The cost was a fraction of the initial overhaul estimate, yet form abandonments visibly dropped. Because their market demographic included many elderly customers, "accommodations intended for people with disabilities" ultimately elevated overall usability for their primary customer base. The mindset of turning usability improvements into tangible results is also discussed in our article on avoiding pitfalls in website redesigns.
Seeing through quotes that claim non-compliance is illegal
If you receive a massive quote based on the rationale that "a complete overhaul is necessary because it became mandatory," as in the consultation mentioned earlier, please take a step back. As noted above, non-compliance with web accessibility standards is not inherently illegal. If a web production agency urges a complete overhaul citing legal obligations, their premise is likely inaccurate.
A reputable web agency will provide specific priorities, explaining that "while it is legally an obligation to make reasonable efforts, these specific areas are worth addressing given your customer demographic." Conversely, if they attempt to push for a total overhaul simply by claiming "it's now mandatory," ask for their legal basis and the actual risks of non-compliance. The criterion for decision-making is not "is it legally compelled?" but "does it offer practical value to our customers?" Seeing through excessive proposals follows the exact same perspective discussed in our article on maintaining legacy websites regarding "spotting excessive proposals using change as an excuse."
Integrating accessibility during redesigns or new builds is most efficient
That said, accessibility should not be neglected. The most efficient approach is not rushing to patch an existing site, but incorporating accessibility from the start the next time you rebuild your website. Factoring in color contrast, font sizes, and form structures during the initial design phases costs significantly less than retrofitting them later. If you are planning a new build or a redesign, the smart approach is to include "basic accessibility considerations" in your requirements from day one. You can find our overall framework on production costs summarized in our article on website production price benchmarks.
Whether you want to verify if an agency's explanation about mandatory requirements is correct, need help prioritizing where to start within a limited budget, or want to integrate accessibility alongside a redesign, feel free to contact GleamHub via our web production and redesign consultation. We will help you distinguish legally required scopes from measures that genuinely benefit your customers, designing a balanced, practical path forward.
Sources
- What Is Web Accessibility? A Clear Explanation from Scratch | Government Public Relations Online
- Corporate Website Compliance with the Revised Act on the Elimination of Discrimination against Persons with Disabilities | InfoCreate Co., Ltd.
- [2026 Latest] What Needs to Be Done for Web Accessibility? Relevance to the Revised Act on the Elimination of Discrimination against Persons with Disabilities | Goodpatch Blog
