Austria's accessibility regime sits across the BGStG (2006), the WZG (2019, WAD-transposing), and the BaFG (2023, EAA-transposing, in force 28 June 2025). The Equal Treatment Act and Constitution Article 7 backstop both.
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55 jurisdictions
Fifty-five jurisdictions surveyed in 2026 — primary statutes, enforcement bodies, penalty ranges in local currency, technical standards, and the recent case law that defines practical scope. EU EAA + WAD, US ADA, UK Equality Act, Japan's 2024 reasonable-accommodation duty — all mapped.
The five enforcement models that cover every accessibility regime in the world, plus a cross-cutting penalty index. Click any card for the full treatment.
WAD (2018) + EAA (2025)
Every EU member state has implemented WCAG 2.1 AA-equivalent obligations under the Web Accessibility Directive for public bodies and, since 28 June 2025, the European Accessibility Act for the private sector. EEA states (NO, IS, LI) follow through the EEA Agreement.
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ADA + state statutory damages
ADA Titles II and III plus state-level multipliers (Unruh $4K/violation in CA, NYSHRL/NYCHRL in NY) drive the docket. Federal circuit-split on whether websites are public accommodations; DOJ's April 2024 Title II rule mandates WCAG 2.1 AA for state and local government.
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Equality Act + PSBAR (post-Brexit)
Post-Brexit GB reverted to Equality Act 2010 + PSBAR 2018 with retained-EU-law status. No fixed PSBAR fine — enforcement is case-law and Cabinet-Office monitoring. Damages assessed under Vento bands (up to £60,700 for severe injury to feelings).
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Reasonable-accommodation duty
Japan's 2024 amendment making reasonable accommodation a legal duty for the private sector; Korea's 2007 Disability Discrimination Act with strong PRA and active class-action docket; China's 2023 Barrier-Free Environment Construction Law with EAA-style scope; India's 2016 RPwD Act with 21 disability categories.
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Anchored in supreme law
Brazil's LBI with CRPD given constitutional rank under Art. 5 §3; Mexico's LGIPD with 32-state federalism; South Africa's PEPUDA + 2023 SASL constitutional recognition (world-first); Israel's 1998 Equal Rights Law + IS 5568; GCC states under Vision-2030 / Vision-2040 frameworks.
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Penalty ranges, every country
A different cut of the same data: the penalty exposure across every country at a glance. Administrative-fine ranges in local currency, civil-damages framing, procurement-disqualification exposure, EU Commission infringement risk — country by country, normalised for comparison.
Open the penalty index →
Grouped by region. Click any card for the full dossier.
Austria's accessibility regime sits across the BGStG (2006), the WZG (2019, WAD-transposing), and the BaFG (2023, EAA-transposing, in force 28 June 2025). The Equal Treatment Act and Constitution Article 7 backstop both.
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Belgium's accessibility regime is layered: federal Anti-Discrimination Act (2007), federal WAD transposition (2018) plus parallel regional and community decrees, and the 2024 EAA Implementation Act applied from 28 June 2025. Constitution Art. 22ter anchors the system.
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Bulgaria's accessibility regime sits across the Persons with Disabilities Act (EAA-transposed in 2024) and the Law on Electronic Governance (WAD-transposed in 2018). Anti-discrimination and constitutional protections backstop both.
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Croatia's accessibility regime sits across the Anti-Discrimination Act (NN 85/08, 112/12), the 2019 WAD transposition for public-sector websites, and the 2023 EAA transposition for private-sector products and services (NN 75/2023, in force 28 June 2025).
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Cyprus combines a cross-cutting Persons with Disabilities Law (2000) with two EU-driven instruments: L119(I)/2018 transposes the Web Accessibility Directive; L89(I)/2023 transposes the European Accessibility Act, in force 28 June 2025.
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Czechia's accessibility regime spans Act 99/2019 Sb. (WAD, public sector) and Act 424/2023 Sb. (EAA, private products and services). The 2009 Anti-Discrimination Act backstops both; the Charter of Fundamental Rights and Freedoms anchors them constitutionally.
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Denmark's accessibility regime sits across the 2022 EAA-transposing Tilgængelighedsloven and the 2018 WAD-transposing Act (LOV 692/2018), backstopped by the 2018 Disability Discrimination Act and the constitutional anti-discrimination principle.
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Estonia transposes the WAD via 2018 amendments to the Public Information Act (AvTS) and the EAA via the 2022 Products and Services Accessibility Act (TTLS), in force 28 June 2025. The 2008 Equal Treatment Act and Constitution §12 backstop both.
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Finland's regime sits across the WAD-transposing Digital Services Act 306/2019, the EAA-transposing Accessibility Act 102/2023, and the Non-Discrimination Act 1325/2014. Constitution § 6 covers disability; § 17 recognises Finnish and Finland-Swedish Sign Languages.
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France stacks five clean tiers: Loi 2005-102 (Article 47), the 2016 Digital Republic Act, Décret 2019-768 transposing the WAD, the RGAA 4.1 technical reference, and DDADUE 2023 transposing the EAA — in force since 28 June 2025.
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Germany layers a constitutional anti-discrimination clause (GG Art. 3(3)) over the federal BGG/BITV 2.0 public-sector regime, the EAA-transposing BFSG (in force 28 June 2025), the AGG anti-discrimination act, and 16 Länder accessibility laws.
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Greece's accessibility regime sits across Law 4727/2020 (Digital Governance Code, Articles 38–45, transposing WAD), Law 5099/2024 (EAA transposition), and Law 4488/2017 (disability-rights and anti-discrimination framework). Constitutional anchor in Article 21(6).
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Hungary's accessibility regime spans Fundamental Law Art. XV(5), the 1998 Disability Rights Act (Fot.), the 2003 Equal Treatment Act (Ebktv.), the 2018 WAD-transposing public-sector statute, and the 2022 EAA-transposing private-sector act in force from 28 June 2025.
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Ireland's accessibility framework: Disability Act 2005, the WAD-transposing S.I. 358/2020, and the EAA-transposing S.I. 636/2023. Equal Status Acts 2000–2018 backstop with civil discrimination remedies.
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Italy's regime spans the 2004 Stanca Act (the oldest EU digital-accessibility law), D.Lgs. 106/2018 transposing the WAD, and D.Lgs. 82/2022 transposing the EAA in force 28 June 2025. Legge 67/2006 and the CRPD backstop both tracks.
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Latvia's accessibility regime spans the 2010 Disability Law, the 2020 WAD-transposing law on accessibility of information-society services, and the 2023 EAA-transposing Products and Services Accessibility Law. The Constitution (Satversme) and CRPD backstop both.
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Lithuania's regime spans the 2023 EAA-transposing Law on Accessibility of Products and Services (in force 28 June 2025), the 2019 Public Sector Bodies Accessibility Act (WAD), the 1991/2024 Law on Social Integration of the Disabled, and the 2003 Law on Equal Opportunities.
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Luxembourg's accessibility regime sits across the WAD-transposing Act of 28 May 2019 (public-sector digital) and the EAA-transposing Act of 8 March 2023 (private-sector, applied 28 June 2025). The 2006 Equal Treatment Act and Article 10bis backstop both.
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Malta's accessibility regime layers Chapter 614 (Web Accessibility Act 2020, WAD-transposed) and Chapter 627 (Accessibility of Products and Services Act 2023, EAA-transposed) onto the broader Equal Opportunities (Persons with Disability) Act of 2000 (Chapter 413).
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Dutch accessibility law layers the 2003 Equal Treatment Disability Act (WGBH/CZ), the 2018 Tijdelijk besluit transposing the WAD, and the 2024 EAA Implementation Act, on the constitutional equality floor of Article 1 Grondwet.
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Poland's framework combines the 2019 Digital Accessibility Act (WAD), the 2019 Accessibility Act for Persons with Special Needs (cross-cutting public sector), and the 2024 EAA-transposing act on products and services, anchored on Constitution Articles 32 and 69.
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Portugal's accessibility regime layers Decree-Law 83/2018 (WAD, public sector) and Law 35/2024 (EAA, private sector, in force 28 June 2025) over Law 38/2004 and Constitution Articles 13 and 71. LGP recognised constitutionally since 1997.
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Romania's regime sits across Law 448/2006 (disability rights), OUG 112/2018 (WAD), and Law 8/2023 (EAA). The Anti-Discrimination Ordinance (OG 137/2000) and Constitution Articles 16 and 50 backstop both tracks.
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Slovakia stacks Act 71/2023 (stand-alone EAA transposition, in force 28 June 2025) on Act 95/2019 (WAD provisions), with the Anti-Discrimination Act 365/2004 and Severe-Disability Compensation Act 447/2008 as backstops.
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Slovenia transposes the EAA through ZDPS (2023, in force 2025) and the WAD through ZDSMA (2018), layered on ZIMI (2010), ZVarD (2016), and Articles 14, 52 and 62a of the Constitution. Slovenian Sign Language constitutionally recognised since 2021.
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Spain's regime sits on the consolidated LGDPD (RDL 1/2013), RD 1112/2018 transposing the WAD, Ley 11/2023 transposing the EAA, and RD 193/2023. Seventeen autonomous-community accessibility acts run in parallel.
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Sweden's regime: Discrimination Act 2008:567, the 2018 Act on Accessibility of Digital Public Services (WAD), and the 2023 Act on Accessibility of Certain Products and Services (EAA, effective 28 June 2025). Constitution Chapter 1 §2 anchors all three.
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Iceland's framework: Lög 61/2011 (ÍTM recognition), Lög 38/2018 (disability services), Equal Treatment Acts (150/2020, 86/2018), Lög 25/2020 (WAD), and the 2024 EAA-transposition act — EU directives applied via the EEA Agreement.
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Liechtenstein's framework: the 2007 Equality of People with Disabilities Act, the 1999 Equal Opportunities Act, plus WAD (2018) and EAA (2024) transposed via the EEA Agreement. Small jurisdiction, full EU-directive coverage.
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Norway's regime: Equality and Anti-Discrimination Act 2017 (LDL), the ICT Universal Design Regulation (FOR-2013-06-21-732) porting WAD obligations via EEA, and the 2024 EAA-transposing Accessibility for Products and Services Act in force from 28 June 2025.
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Russia's framework rests on Federal Law 181-FZ (1995), the omnibus CRPD-harmonising Federal Law 419-FZ (2014), Article 9.13 of the Code on Administrative Offences, and the GOST R 52872-2019 web-accessibility standard aligned with WCAG 2.0 Level AA.
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Serbia: 2006 Law on Prevention of Discrimination Against Persons with Disabilities, 2009 Anti-Discrimination Act, 2023 e-gov accessibility decree, Constitution Arts. 21 + 81. EU-candidate since 2012; CRPD ratified 2009 with Optional Protocol.
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Switzerland's framework runs on BehiG (2002, in force 2004), the BehiV ordinance, federal web standard P028/eCH-0059 mapped to WCAG 2.1 AA, and Constitution Art. 8. Non-EU; the EAA does not apply, but Swiss exporters to the EU still face it.
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Türkiye's accessibility regime sits on Law No. 5378 (2005), the TİHEK equality act (Law No. 6701, 2016), Labour Law Art. 30 quota, and Constitution Arts. 10/49/50/61. CRPD ratified 2009; EU-accession candidate, with partial WAD/EAA alignment via the 2024–2028 strategy.
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Ukraine's framework: Law 875-XII (1991), the Rehabilitation Law (2005), Combating Discrimination (2012), the Ukrainian Sign Language Law (2024), and Constitution Articles 24 and 49. EU-candidate status (June 2022) drives alignment with the EU acquis including the WAD and EAA.
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Two pillars sit on a treaty floor: the Equality Act 2010 (private-sector and employer reasonable-adjustment duties) and PSBAR 2018 (public-sector WCAG 2.1 AA). Northern Ireland runs a separate regime; the EU Accessibility Act does not apply in Great Britain.
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Canada's regime is a federal + provincial mosaic. The Accessible Canada Act 2019 covers federally-regulated entities; Ontario's AODA (2005), Quebec, Manitoba, Nova Scotia, BC, and Saskatchewan add provincial layers. The Charter and the Canadian Human Rights Act backstop both.
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Mexico's regime layers the federal LGIPD (2011, regulated 2014) and the LFPED (2003) on top of constitutional Articles 1 and 4. NMX-COE-001-SCFI-2018 carries WCAG 2.0 AA as the national technical reference; 32 federal states add parallel provisions.
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Federal floor: ADA (1990) + Rehabilitation Act §§ 504/508 + CVAA + ACAA. State multipliers: California Unruh ($4,000/denial), NYSHRL/NYCHRL, Illinois HRA, and others. Litigation-driven; private right of action is the central enforcement engine.
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China's regime sits across the 1990 Law on the Protection of Persons with Disabilities (amended 2008, 2018) and the 2023 Barrier-Free Environment Construction Law — a cross-cutting accessibility statute structurally similar in scope to the EU EAA.
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India's regime is anchored on the Rights of Persons with Disabilities Act 2016 (replacing the 1995 PwD Act), the RPwD Rules 2017, GIGW 3.0 for government websites, and the National Building Code 2016. Constitution Articles 14, 15, 16, and 21 supply the rights floor.
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Japan's framework sits across the 2013 Discrimination Elimination Act (in force 2016; private-sector reasonable accommodation made a legal duty from 1 April 2024), the 1970 Basic Act, the 1960 Employment Promotion Act, and JIS X 8341-3:2016 (WCAG 2.0 AA).
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South Korea's framework: the 2007 Anti-Discrimination Act (in force 2008), the Network Act Article 32 on ICT-provider duties, the Welfare of Persons with Disabilities Act, and KWCAG 2.2 as the national WCAG conformance standard published by NIA.
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Bahrain's framework: Law 74 of 2006 on Care, Rehabilitation and Employment of Persons with Disabilities; Constitution Arts. 5(c) and 18; Labour Law 36/2012 (private-sector quota); and the iGA's WCAG-aligned web accessibility standards for government services.
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Israel's framework rests on the Equal Rights for Persons with Disabilities Law 5758-1998, the 2013 Accessibility Regulations mandating IS 5568 (Israel's WCAG 2.0 AA equivalent), the 1988 Equal Employment Opportunities Law, and the 2006 Class Actions Law.
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Kuwait's framework rests on Law 8 of 2010 on the Rights of Persons with Disabilities, which established the Public Authority for Disability Affairs (PADA). Constitutional anchor in Article 11, with digital-government accessibility led by CAIT under Kuwait Vision 2035.
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Oman's framework: Royal Decree 63/2008 on the Care and Rehabilitation of Disabled Persons, RD 35/2003 (Labour Law) quota provisions, Article 12 of the Basic Statute, Oman Vision 2040 accessibility commitments, and MTCIT web-accessibility guidance.
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Qatar's framework rests on Law 2/2004 on Persons with Special Needs, the Labour Code's employment quota, the Qatar Web Accessibility Policy (WCAG 2.1 AA), Constitutional Articles 18 and 49, and the Mada Center's national digital-accessibility mandate.
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Saudi Arabia's framework anchors on the Disability Welfare Law 2000 (Royal Decree M/37), the 2017 establishment of the Authority of People with Disabilities, the 2022 Saudi Digital Accessibility Policy aligned to WCAG 2.1 AA, and Vision 2030 accessibility commitments.
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UAE accessibility law layers Federal Law 29/2006 (People of Determination), the 2017 National Policy, the TDRA's WCAG 2.1 AA-aligned Web Accessibility Policy, the Dubai Universal Design Code, and Article 358 of the 2021 federal Criminal Code on anti-discrimination.
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Botswana has historically relied on policy frameworks rather than a stand-alone disability statute, with the National Policy on Care for People with Disabilities (1996) as the lead instrument. That policy was under review during 2024–26, potentially toward a stronger statutory replacement.
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Egypt's framework: Law 10 of 2018 on the Rights of Persons with Disabilities, Law 11 of 2019 establishing the NCPD, and Constitution Articles 53 (equality) and 81 (special State protection). UN CRPD ratified April 2008.
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Ethiopia's framework: the Right to Employment of Persons with Disability Proclamation 568/2008, the Building Proclamation 624/2009 requiring accessible new public buildings, and the 2023 National Disability Policy, all led federally by the Ministry of Labour and Social Affairs.
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Ghana's framework: the Persons with Disability Act 2006 (Act 715), whose ten-year accessibility grace period expired in 2016, alongside the Inclusive Education Policy 2015. A draft amendment bill to strengthen enforcement has been before Parliament across successive sessions.
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Kenya's framework: the Persons with Disabilities Act 2024 (replacing the 2003 statute) on the CRPD social model, Article 54 of the 2010 Constitution, the National Council for Persons with Disabilities, and ICT Authority draft accessibility guidelines tied to WCAG.
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Nigeria's framework: the Discrimination Against Persons with Disabilities (Prohibition) Act 2018, which created the National Commission for Persons with Disabilities and a five-year accessibility transition that expired January 2024. Implementation depends heavily on state-level adoption.
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Rwanda's framework: Law No. 01/2007 on the protection of persons with disabilities and a subsequent ministerial framework, with implementation aligned to the Vision 2050 development strategy and coordinated by the National Council of Persons with Disabilities.
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Senegal's framework: the Loi d'orientation sociale of 2010 on the promotion and protection of the rights of persons with disabilities, brought into force by a 2012 implementing decree and built around the carte d'égalité des chances (equal-opportunity card).
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South Africa's framework: PEPUDA (Act 4 of 2000) on Constitution s.9 equality, the Employment Equity Act (1998), the 2023 constitutional recognition of SASL as the 12th official language, and the 2015 White Paper on the Rights of Persons with Disabilities.
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Tanzania's framework: the mainland Persons with Disabilities Act 2010 (Act No. 9 of 2010), enforced through the Prime Minister's Office, with Zanzibar maintaining its own parallel Persons with Disabilities (Rights and Privileges) Act of 2006.
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Uganda's framework: the Persons with Disabilities Act 2020 (replacing the 2006 statute) on the CRPD social model, with a modernised National Council for Disability mandate and built-environment and public-service accessibility delivered through delegated regulations. Anchored by Constitution Articles 32 and 35.
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Australia's accessibility regime sits on the federal Disability Discrimination Act 1992 (Cth), with Premises and Education Standards as mandatory subordinate instruments, the NDIS Act on the services side, and parallel state and territory equal-opportunity acts running alongside.
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New Zealand's regime rests on the Human Rights Act 1993 (disability as a prohibited ground under sections 21, 53 and 57), the world-first NZSL Act 2006, NZBORA section 19, and the all-of-government Web Accessibility Standard 1.1 for the public sector.
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