/kb-legal-compliance-mapping

name: kb-legal-compliance-mapping
description: "Reference data, not a reviewer. Map accessibility audit results to legal frameworks: Section 508, ADA, EN 301 549, EAA, AODA. Generate VPAT 2.5 conformance tables."
license: MIT
disable-model-invocation: true
user-invocable: false
metadata:
  tier: reference
  domain: cross-cutting
  output: none
  effort: low
  title: Legal Compliance Mapping

Legal Compliance Mapping Skill

Maps accessibility legal frameworks across jurisdictions. Used by `compliance-mapping` agent and any agent generating compliance reports.

This is reference data, not legal advice. Facts are dated as of October 2026 (checked 27 October 2026). Laws, compliance dates and harmonised standards change, and several items below are unsettled or under litigation. Every report that uses this table must say it is not legal advice, give the date of the facts it relied on, and tell the reader to confirm with counsel and the primary source before relying on a date.

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Framework Comparison

Each framework, with its jurisdiction, WCAG version, scope and enforcement, as of October 2026.

| Framework | Jurisdiction | WCAG Version | Scope | Enforcement | |-----------|-------------|--------------|-------|-------------| | Section 508 (Revised 508 Standards, 36 CFR part 1194) | US (Federal) | WCAG 2.0 A and AA (E205.4, 702.10.1). No proposed rule to move to 2.1 or 2.2 has been published | Federal agencies and the ICT they develop, procure, maintain or use | Administrative complaints, lawsuits | | ADA Title II (28 CFR part 35 subpart H, 2024 rule) | US (State/Local) | WCAG 2.1 AA | State and local government web content and mobile apps | DOJ enforcement, lawsuits | | HHS Section 504 (45 CFR part 84 subpart I, 2024 rule) | US (recipients of HHS funding) | WCAG 2.1 AA | Web content and mobile apps of recipients of HHS financial assistance | HHS Office for Civil Rights, lawsuits | | ADA Title III | US (Private) | No DOJ web regulation and no WCAG version in law. DOJ's 2022 web guidance says WCAG and Section 508 "provide helpful guidance" and businesses have flexibility; courts and settlements commonly reference WCAG 2.x AA | Public accommodations | Private lawsuits, DOJ enforcement | | EN 301 549 | EU | V3.2.1 (2021-03): WCAG 2.1 AA (Clauses 9-11). V4.1.1 (2026-09): WCAG 2.2 A and AA, published but not yet cited in the OJEU | Public sector ICT (WAD); referenced for EAA products and services | EU member state enforcement | | European Accessibility Act (EAA, Directive (EU) 2019/882) | EU | No WCAG version in the Directive. No harmonised standard cited under the EAA was found; EN 301 549 is the usual technical reference | Private sector products and services (applies from 28 June 2025) | Market surveillance, penalties set by each member state | | AODA (IASR, O. Reg. 191/11, s.14) | Ontario, Canada | WCAG 2.0 AA, excluding 1.2.4 and 1.2.5 | Designated public sector organizations and organizations with 50+ employees | Administrative penalties | | Accessible Canada Act and Accessible Canada Regulations (amended by SOR/2025-255) | Canada (Federal) | CAN/ASC-EN 301 549:2024 (identical to EN 301 549 V3.2.1, so WCAG 2.1 AA), incorporated "as amended from time to time" | Federally regulated entities: web pages (including employee-facing), mobile apps, downloadable documents | Accessibility Commissioner, CRTC or CTA depending on sector; penalties | | Israeli Standard 5568 | Israel | WCAG 2.0 AA | Public websites and apps | Civil lawsuits | | JIS X 8341-3:2016 | Japan | WCAG 2.0 AA. A revision aligned with ISO/IEC 40500:2025 (WCAG 2.2) was being drafted in 2026; check JISC for whether it has been issued | Government websites (recommended) | No enforcement (voluntary) | | Chinese GB/T 37668-2019 | China | Based on WCAG 2.0 | Government websites | Administrative guidance |

ISO/IEC 40500:2025 is WCAG 2.2 (the October 2023 text). ISO/IEC 40500:2012 is WCAG 2.0 and is no longer the latest edition. Some laws still cite the 2012 edition by name.

Additional Non-WCAG Requirements

Some frameworks require more than WCAG conformance:

EN 301 549 Additional Requirements

Each clause, with its requirement and beyond WCAG.

| Clause | Requirement | Beyond WCAG | |---------|-------------|-------------| | Clause 5 | Generic requirements, including closed functionality (kiosks, ATMs) | Yes - no WCAG equivalent | | Clause 6 | ICT with two-way voice communication, including real-time text (RTT) | Yes - no WCAG equivalent | | Clause 7 | Video capabilities (captions, audio description) | Extends WCAG 1.2 | | Clause 8 | Hardware accessibility | Yes - physical product requirements | | Clause 10 | Non-web documents | Maps WCAG to document formats | | Clause 11 | Non-web software | Maps WCAG to native applications | | Clause 12 | Documentation and support services | Accessible help documentation | | Clause 13 | ICT providing relay or emergency service access | Yes - no WCAG equivalent |

European Accessibility Act Additions

• Products: general purpose computer hardware and operating systems, self-service terminals, consumer terminals for electronic communications and audiovisual media, e-readers
• Services: electronic communications, access to audiovisual media, passenger transport elements, consumer banking, e-books, e-commerce
• Microenterprises providing services (fewer than 10 persons and annual turnover or balance sheet total not over EUR 2 million) are exempt from the service requirements
• Applies from 28 June 2025. Products already in use to provide services may continue to be used until 28 June 2030 (Art. 32(1)). Member states may also let self-service terminals lawfully in use before 28 June 2025 continue until the end of their economically useful life, up to 20 years (Art. 32(2): a member-state option, not a general rule)
• Presumption of conformity comes from harmonised standards cited in the OJEU (Art. 15). EN 301 549 V4.1.1 had not been cited as of October 2026

VPAT / ACR Mapping

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