Reasonable accommodation became mandatory in 2024 with no standard attached

On 1 April 2024, the amended Act for Eliminating Discrimination against Persons with Disabilities took effect in Japan. Providing reasonable accommodation, previously an efforts duty for private businesses, became a legal obligation.

More than two years later, few companies have worked out whether their own website or app is in scope. The reason is straightforward. No standard was attached.

Public bodies got a standard, private companies did not

The 2024 edition of Japan's public sector website guidelines requires public bodies to target JIS X 8341-3:2016 conformance level AA and to publish their test results. A target, a way to measure it, and a disclosure duty, as a set.

For private businesses none of that exists. There is an obligation to provide reasonable accommodation and no statement of what satisfies it.

That asymmetry is what produces the confusion in practice. With no standard, nothing can be prioritised internally. With no priority, nothing gets funded.

Accommodation and environmental preparation are different concepts

The law distinguishes two things.

Reasonable accommodation means responding to an individual request, within the limits of undue burden. This is what became mandatory in 2024.

Environmental preparation means removing barriers in advance for an unspecified group of people. This remains an efforts duty.

How a website is built usually falls into the second category. So the argument that it is not mandatory holds up formally.

In practice the distinction is harder to maintain than it looks, because the less prepared the environment, the more individual requests arrive. And individual handling costs more than designing it in.

If your only contact route is a telephone number and a deaf customer makes a request, you handle it case by case, every time. Offer a text based route from the start and the request never arises.

With no domestic standard, borrow one

Since no standard exists for the private sector in Japan, the practical move is to adopt an existing one.

WCAG 2.1 level AA corresponds substantively to JIS X 8341-3:2016. You are voluntarily adopting the same level that public bodies are required to hit.

There is a side benefit. The European Accessibility Act has applied since 28 June 2025 and covers non EU businesses selling into the EU. If you export, you will need an equivalent level regardless.

The four places to look first

You do not have to fix everything at once. These four have the largest effect and are the easiest to verify.

1. Can it be operated with a keyboard alone. Without a mouse, can you reach form submission using the tab key. Wherever you cannot, somebody cannot use that part of the site.
2. Contrast between text and background. At least 4.5 to 1 for body text. If a light grey from the brand palette is being used for body copy, this is where it fails.
3. Alternative text on images. Anything that is not decorative needs a description. Pages heavy with logos and diagrams are affected most.
4. Form labels. Is each input associated with a label. Forms that rely on placeholder text alone lose their meaning when read aloud.

All four can be checked without specialist tooling. Fixing only these four measurably increases the number of people who can complete the task.

Do not treat it as a deadline

Accessibility handled as a deadline driven project does not survive. 1 April 2024 has already passed and most sites are unchanged.

A more durable approach is to add one condition to new work. New pages and features ship only after meeting the four items above. Existing pages get fixed when they are next touched.

That needs almost no additional budget. It needs a decision.