Accessibility Stopped Being a Values Question in 2024

I have been in a lot of meetings where accessibility came up. Until recently, almost all of them went the same way. Someone agreed it was important, someone else asked what percentage of users it affected, and it went into the backlog with a note saying phase two.

Those meetings are now happening on the wrong premises. Between April 2024 and June 2025, two separate legal changes moved accessibility out of the values column and into the compliance column, and the second one applies to companies that have never set foot in the jurisdiction that passed it.

I have an interest to declare here. I won an Apple Design Award in 2025 in the Inclusivity category, for accessibility work on Speechify, which people use because reading the normal way does not work for them. So I am not a neutral observer. But the argument below is not a moral one, and I would make it to a CFO.

What changed in Japan

On 1 April 2024, the revised Act on the Elimination of Discrimination against Persons with Disabilities came into force. The change is one word. Providing reasonable accommodation, which had been an effort obligation for private businesses, became a legal obligation.

Public bodies had carried that duty since the law first took effect. Private companies had been asked to try. Now they are required.

Two things about this are widely misunderstood in Japan and I hear both regularly.

The first is that people read it as an employment rule. It is not limited to employees. It covers how you serve the people who use your products and services, which for most companies means the website, the app, the signup, the support channel and the store.

The second is that reasonable accommodation is not the same as meeting a technical standard. Japan's web standard, JIS X 8341-3, has not become mandatory for private companies. What is mandatory is that when a person with a disability asks you to remove a barrier, you engage with them and work out a solution unless the burden is genuinely excessive. In practice, a company whose product is unusable with a screen reader has made that conversation much harder to resolve and much more likely to happen.

What changed in Europe, and why it reaches Tokyo

The one with real teeth is the European Accessibility Act, Directive (EU) 2019/882, adopted in 2019 with a deliberately long runway. Member States had to apply their measures from 28 June 2025.

It covers e-commerce, consumer banking, e-books, transport services, telecoms, and the hardware people use to reach them, including payment terminals and self service machines. In practice, for a website or an app, meeting it means the accessibility outcomes described by WCAG 2.1 Level AA, via the harmonised European standard EN 301 549.

The part Japanese companies keep missing: it is not about where you are established. It applies to products and services placed on the EU market. If you sell to consumers in the EU, you are in scope, and being headquartered in Tokyo or Osaka does not change that any more than it changes your obligations under the GDPR.

There are limits worth knowing before anyone panics. Microenterprises providing services, meaning fewer than 10 people and turnover or balance sheet total at or under two million euro, are exempt from the service side requirements. There is a transitional period to 28 June 2030 for services delivered using products that were already lawfully in use. Service contracts agreed before June 2025 can run to expiry, capped at five years. Self service terminals already in use can run to the end of their useful life, up to twenty years.

Those transitions cover the equipment you already own. They do not cover the new website you are launching next year.

The reason this is an economic argument, not an ethical one

Retrofitting accessibility is close to a rebuild. Designing for it costs almost nothing.

That asymmetry is the whole argument and it is not intuitive, so it is worth being concrete about why.

Most accessibility failures are decided very early and cheaply. Whether your colour palette has enough contrast. Whether form fields have real labels. Whether interactive elements are real buttons rather than styled divs. Whether the page has a heading structure that describes the content. Whether you can complete the main task with a keyboard. Every one of those is a decision that costs nothing at the point it is made, by a designer choosing a colour or a developer choosing a tag.

By the time the product exists, each of those decisions has been made hundreds of times, inconsistently, across a codebase. That is why the remediation quote comes back at a number that makes people angry. They are not being overcharged. They are being asked to pay for a year of small decisions all at once.

The same logic applies to a second language, which is why I always bring these two up in the same conversation. Deciding at the start that the product ships in Japanese and English is nearly free. Adding English two years later means every layout that was built to fit Japanese text now breaks.

What I would actually do this quarter

If you sell into the EU, start with scope. Find out which of your services are in scope, whether the microenterprise exemption applies to you, and whether any transitional provision buys you time. That is a couple of days of work and it tells you whether this is urgent or merely important.

Then audit one thing rather than everything. Take the single path that makes you money, whatever it is, and test it end to end. Keyboard only, no mouse. Then with a screen reader. Then at 200% zoom. You do not need a vendor for this and you will learn more in an afternoon than any report will tell you.

Then fix the decisions rather than the pages. If the contrast is wrong, it is wrong in a token, not on a page. If buttons are not buttons, that is a component. Fixing the source of a class of errors is how the number stops growing while you work.

Then write it into the definition of done for new work, so the backlog stops filling behind you. This is the step everybody skips and it is the only one that changes the trajectory.

And treat the Japanese obligation as a process question, not a code question. Someone has to be able to receive a request, understand it, and answer it. If a customer asks for an accommodation today and the email goes unanswered because nobody owns it, the state of your HTML is not your biggest problem.

One more thing about the market

As of September 2025, 29.4% of Japan's population is 65 or over. That is 36.19 million people and it is the highest share among the 38 countries with populations over 40 million, ahead of Italy at 25.1% and Germany at 23.7%. The design consequences of ageing eyes and hands are almost identical to the ones accessibility work already addresses. Larger touch targets, higher contrast, text that scales, forms that forgive mistakes.

So Japanese companies are in an unusual position. The domestic demographic argument and the European legal argument point at the same work. I do not think many of them have noticed that yet, and I would rather they noticed before somebody sends them an invoice for a remediation project.

References

Cabinet Office of Japan, 令和6年4月1日から合理的配慮の提供が義務化されました, and the official leaflet. The 2021 revision to the Act on the Elimination of Discrimination against Persons with Disabilities took effect on 1 April 2024, changing reasonable accommodation for private businesses from an effort obligation to a legal one.
Directive (EU) 2019/882 of the European Parliament and of the Council of 17 April 2019 on the accessibility requirements for products and services. Application from 28 June 2025 (Article 31), microenterprise exemption for services (Article 4(5)), transitional measures to 28 June 2030 and the contract and terminal provisions (Article 32).
EN 301 549, the harmonised European standard for ICT accessibility, which incorporates WCAG 2.1 Level AA for web content.
JIS X 8341-3:2016, the Japanese Industrial Standard for web content accessibility. It remains voluntary for private sector organisations in Japan.
Statistics Bureau of Japan, 統計からみた我が国の高齢者, 14 September 2025. 36.19 million people aged 65 and over, 29.4% of the total population, the highest share among countries with populations above 40 million.