Carlos Lastres
Carlos Lastres1,274 words

84.9% of Japan's Public Bodies Say They Do Accessibility. 14.6% Show Their Work.

Every year the Ministry of Internal Affairs and Communications asks Japan's public bodies how their web accessibility work is going. The 2025 round closed in January and the summary came out in March 2026. It surveyed 2,092 organisations and got 1,058 back, a response rate of 50.6%, which for a voluntary government survey is respectable.

84.9% said they are working on web accessibility.

Then the survey asks for evidence, and the number moves.

Three questions, three different answers

52.1% have published an accessibility policy for their official site. That figure has not moved in five years. It was 49.8% in 2020, 51.3% in 2022, 53.3% in 2023, and 52.1% now. Flat.

56.8% have run a conformance test against JIS X 8341-3:2016. That one is genuinely improving: 39.3% in 2020, 42.5% in 2022, 49.1% in 2023, 56.8% now. Seventeen points in five years, moving steadily. Somebody is doing the work.

14.6% use the ministry's own evaluation worksheet and publish the result. Another 10.5% use it and keep the result to themselves. 51.7% know it exists and do not use it. 23.3% have never heard of it.

So: 85% say yes, half have written a policy, just over half have tested, and one in seven will show you the outcome. Those are not contradictions. They are four different definitions of doing accessibility sitting inside one word.

I see the same spread in private companies constantly. Ask a product team whether they do accessibility and you get a yes. Ask what they tested, against which criteria, on which pages, and when, and the yes turns into a conversation about roadmap.

The reasons are not what people assume

Only 160 organisations said they are not working on accessibility at all, and the survey asked them why. Multiple answers allowed.

65.6% said people and budget are limited and they cannot invest enough. 59.4% said they have nobody with accessibility expertise or experience. 46.9% said other work takes priority. 46.3% said they lack knowledge of why it matters and what is actually required.

Further down: 24.4% did not know the relevant laws and guidelines existed. 17.5% said the effect of doing it is unclear, so the motivation is weak. 15.0% cited technical constraints in their systems.

Nobody said accessibility is not worth doing. That option is essentially absent from the answers.

This is worth naming clearly, because the advocacy conversation in Japan is still largely about persuasion, and persuasion is not what is missing. A town of eight thousand people with one person handling the entire website alongside three other jobs is not unconvinced. It is unstaffed.

Which changes what actually helps. More posters arguing that accessibility matters will not move a body that already agrees and has nobody to assign. What moves it is an accessible CMS template it can adopt without a project, a procurement clause it can paste into the next vendor contract, and a test it can run in an afternoon without hiring a specialist.

The survey supports this reading from another angle. When asked what they found most useful in the ministry's guideline, 76.2% picked the section explaining the necessity and the legal basis. That is the part that lets a person justify the work internally. The demand is not for the argument. It is for the ammunition to win an argument they are already having.

The standard is changing and most of them do not know

Here is the part with a deadline attached.

JIS X 8341-3, the Japanese standard for web accessibility, is being revised. The Web Accessibility Infrastructure Committee convened its drafting committee on 30 October 2025, after ISO/IEC 40500 was revised in September 2025, and the stated policy is to make the new JIS a conforming standard to ISO/IEC 40500:2025. In practice that means the current Japanese standard, which is technically equivalent to WCAG 2.0, moves to WCAG 2.2.

That is not a cosmetic update. The committee's own material puts 26 new success criteria on the table: 7 at level A, 11 at level AA, and 8 at level AAA, drawn from WCAG 2.1 and 2.2. One criterion, 4.1.1 Parsing, is removed.

Eleven new level AA criteria is the number that matters, because level AA is what public procurement and policy statements in Japan generally point at. A site that conforms today does not automatically conform tomorrow.

Asked whether they know the revision is coming and are doing anything about it, 21.7% said yes. 44.9% said they know and have not started. 33.4% had not heard.

Roughly four in five public bodies in Japan are going to meet this as a surprise or as a scramble.

What I would do if I ran one of these sites

The revision has not been published yet, and the committee is still working. That is exactly the window where cheap preparation is possible, because nothing is mandatory and nothing is late.

The committee says it plainly in its own slides: conformance to JIS X 8341-3:2016 is the foundation, and the criteria added in WCAG 2.1 and 2.2, particularly at levels A and AA, can be adopted ahead of time. It also says the work needs a plan with budget and hours attached, which is the sentence most organisations will skip.

So, in order.

  1. Run the 2016 test if you have never run one. You are in the 43.2% who have not, and everything else is guesswork until you do.
  2. Read the new level A and AA criteria and check your site against them by hand. The AA set covers reflow, text spacing, contrast on non text elements, focus that stays visible, an alternative to dragging, and a minimum target size. The level A set includes keeping help in a consistent place and not making people re enter information they already gave you. These are ordinary interface problems, not specialist ones.
  3. Put the accessibility requirement into your next vendor contract rather than into a remediation project after launch. Retrofitting is the expensive path and it is the one almost everyone takes.
  4. Publish the result, whatever it says. 14.6% do. A public evaluation that admits partial conformance is worth more than a policy page claiming compliance nobody has checked.

The private sector should read this too

None of this is legally binding on a Japanese company selling to consumers. The obligation under the disability discrimination act is reasonable accommodation, which is not the same thing as a conformance level.

But standards travel. Public procurement will require the new JIS, vendors who serve government will build to it, the CMS products in this market will follow, and within a few years it becomes what a competent Japanese web project looks like by default. Meanwhile the European Accessibility Act already applies to anyone selling digital products into the EU, and it points at the same WCAG criteria.

You can treat this as two separate compliance problems arriving from two directions. Or you can notice they are converging on one technical standard and do the work once.

Sources

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