The National Digital Accessibility Policy

The National Digital Accessibility Policy was issued in March 2024 by the UAE Digital Government under the Telecommunications and Digital Government Regulatory Authority. Its purpose is to support an inclusive society in which people of determination and senior citizens can access digital information and services on an equal basis with other users. [2] [3]

The policy addresses governance as well as technology. It covers the obligations of federal entities, awareness, inclusion, employee training, technical solutions, accessibility of websites and mobile channels, service journeys, accessibility statements, compliance monitoring and the role of a Digital Accessibility Officer.

Its definition of digital accessibility concerns the usability of information and communications technology products, information and services by people of determination and senior citizens with a comparable degree of effectiveness and safety. The policy also uses inclusive design as a governing principle, meaning products and services should be usable by as many people as possible without requiring separate designs. [3]

Who the National Policy Applies To

The scope section begins broadly by addressing services provided digitally in the UAE, then identifies several groups with different levels of responsibility. This distinction is important when an organisation assesses whether a requirement is mandatory, connected to a government relationship or recommended as best practice. [3]

• All federal government ministries, authorities and institutions are expressly covered.
• Federal regulatory or supervisory entities are expected to work with the private sector entities they license to support compliance.
• Semi-government entities, consultants, institutions and private companies involved in digital transactions with a government entity are included through the competent authority.
• Partners, contractors and outsourced personnel involved in government digital transactions are included.
• Suppliers that develop websites, digital services, applications, systems or delivery channels for federal entities are specifically addressed.
• Local government, semi-government and private sector entities are told to take the policy into account and exert their best efforts to comply.

These clauses do not support a single blanket statement that every private website has exactly the same federal compliance duty. They do show that accessibility can reach private organisations through licensing, public service delivery, procurement, contracting and the development of government systems. The policy objective also refers to private sector providers of public services, including areas such as healthcare, education and e-commerce. [3]

What Federal Government Entities Must Do

The policy gives federal entities operational responsibilities rather than asking them to rely on a general commitment. Key duties include the following. [3]

• Apply the policy and provide periodic information about implementation and compliance.
• Prepare executive action plans covering accessibility initiatives and projects.
• Allocate the financial and non-financial resources needed for implementation.
• Appoint a Digital Accessibility Officer or assign those responsibilities to an existing department.
• Train employees and provide guidance for users who need accessibility support.
• Review service journeys and customer needs across websites, applications and other delivery channels.
• Publish an accessibility policy or statement that explains the applied standard, known limitations, support channels and measures taken.
• Report on compliance and support annual review through the competent authority’s digital government indicators.

The Digital Accessibility Officer is expected to coordinate implementation, develop roadmaps, support teams, build capability, monitor compliance and help ensure that accessibility standards are applied to products, applications and equipment developed or acquired by the entity. This makes accessibility a governance function, not only a task for the web development team. [3]

Which WCAG Version Applies in the UAE

The clearest formal reference appears in the technical annex to the national policy. It states that all public service sites must comply with WCAG 2.1 Level AA. The policy also requires federal accessibility statements to identify the standard applied, naming WCAG 2.1 as a minimum example. [3]

Current government implementation is moving further. The official UAE Government platform states that it is designed and developed to meet WCAG 2.1 and WCAG 2.2 Level AA as a minimum. The UAE Design System says that it adheres to WCAG 2.2 so that its components can be used by people with visual, auditory, cognitive and motor impairments. [5] [6]

WCAG 2.2 Level AA is therefore the better baseline for new or substantially updated services. It includes the Level A and AA requirements inherited from WCAG 2.1 and adds criteria that address current interaction patterns, including focus visibility, dragging movements, target size and accessible authentication. If a contract, tender, regulator or competent authority names WCAG 2.1 or another standard, that requirement must still be followed. [11]

Digital Accessibility Requirements in Dubai

Dubai has an additional local framework. Law No. 3 of 2022 defines accessibility as making information and digital platforms accessible to persons with disabilities in line with adopted standards. It recognises access to information and data platforms in accessible formats as a protected right. [7]

The implementing bylaw requires the concerned entities to ensure accessibility to digital services, information and telecommunications systems through formats suitable for different disabilities. It gives the Dubai Digital Authority responsibility for developing policies and technical standards for digital channels such as websites and smart applications, and for supervising compliance by the public and private sectors in line with priorities and available resources. [8]

This is a stronger local basis for considering private sector responsibilities in Dubai, but the wording still requires careful application. The bylaw does not state that every private website automatically has an identical WCAG conformance obligation. An organisation should identify the applicable Digital Dubai standard, sector requirement, licensing condition, public service role and enforcement context before making a legal claim.

Dubai’s own city portal aims for WCAG 2.1 Level AA and describes internal assessment, external audits, staff training and an accessibility officer as part of its approach. The Dubai Design System also states that its components are designed with WCAG accessibility in mind. [9] [10]

What the Framework Means for Private Companies

Private companies should not treat accessibility as relevant only to ministries. Several common business relationships can create a direct or practical requirement.

• Supplying a federal or local government entity under a tender, framework agreement or service contract.
• Developing or operating a website, application, portal, kiosk or system for a government entity.
• Providing a public service or operating in a sector overseen by a federal regulator.
• Operating in Dubai where local digital accessibility policies and technical standards apply to the service concerned.
• Accepting accessibility requirements in procurement documents, acceptance criteria or customer contracts.
• Providing employment systems or customer services that require reasonable accommodation and equal access.

A private company with no government relationship may still have legal, sector, contractual and customer service reasons to prioritise accessibility. The appropriate conclusion is not that accessibility is optional until a complaint occurs. It is that the source and scope of the requirement must be identified accurately.

Accessibility Covers More Than Websites

The national policy addresses digital products and services across several channels. Depending on the service and relationship, an accessibility programme may need to cover the following.

• Public websites and customer portals.
• Mobile applications and responsive web services.
• Online forms, authentication, payments and complete service journeys.
• PDF files, Word documents, reports and downloadable forms.
• Videos, audio content, captions, transcripts and instructional media.
• Self-service kiosks, public-facing terminals and other digital interfaces.
• Internal systems and acquired products used by employees or government service teams.

Testing only the home page is therefore insufficient. A service can have accessible navigation while its registration form, identity verification, payment process or downloadable document remains unusable with a keyboard or screen reader.

What Level AA Means in Practice

WCAG Level AA affects design, content, code and interaction. A credible implementation normally includes the following requirements.

• Interactive functions can be reached and operated with a keyboard without trapping the user.
• Focus is visible and follows a logical order.
• Images that convey meaning have appropriate text alternatives.
• Form fields have accessible names, instructions and error identification.
• Text and essential controls have sufficient colour contrast.
• Content remains usable when text is enlarged or the viewport becomes narrow.
• Controls expose correct names, roles, values and states to assistive technology.
• Recorded video has captions and other alternatives where required.
• Headings, landmarks and reading order communicate the page structure.
• Authentication and input processes avoid unnecessary cognitive and physical barriers.

Automated scanning can identify some code-level failures, but it cannot judge every user journey or content decision. Manual testing, keyboard testing and testing with assistive technology are needed to determine whether a service works in practice.

Arabic and Bilingual Services

UAE services frequently combine Arabic and English. Accessibility must therefore be verified in both languages. A compliant English interface does not prove that the Arabic version has the correct language metadata, reading order, focus sequence or component behaviour.

Testing should cover right-to-left layouts, mixed-language labels, Arabic pronunciation in screen readers, form validation, numbers, dates, menus, carousels and bilingual documents. Teams should also confirm that interface changes made for Arabic have not altered keyboard order or separated visible labels from their programmatic names.

Arabic PDFs require their own review. A document may look correct while its tags, headings, tables and reading order are unusable with assistive technology. Exporting a designed document to PDF is not enough to establish accessibility.

Accessibility Is Broader Than a Widget

Accessibility tools can offer useful personalisation features such as text resizing, colour adjustments and reading support. They cannot independently establish WCAG conformance or correct every barrier in a product’s code, structure, content and interaction design.

A tool cannot decide whether alternative text conveys the right meaning, repair a broken keyboard interaction, rewrite confusing instructions, create accurate captions or verify that a complete service journey works with a screen reader. An accessibility widget may support users as one part of a wider programme, but remediation and testing must address the underlying product.

What UAE Organisations Should Do Now

1. Define the applicable framework Map the service to the relevant emirate, sector, regulator, public entity, contract and procurement terms. Separate binding duties from policy guidance and internal targets.
2. Adopt a clear technical baseline Use WCAG 2.2 Level AA for new and substantially updated services unless a competent authority or contract specifies another standard.
3. Assign responsibility Name an accessibility owner and establish decision, reporting and escalation responsibilities across product, design, development, content, procurement and legal teams.
4. Include accessibility in procurement Place measurable accessibility requirements, testing evidence and remediation obligations in briefs, requests for proposal, statements of work and acceptance criteria.
5. Audit representative journeys Test the main templates, high-risk content and complete tasks such as registration, authentication, payment, booking, document download and support.
6. Combine testing methods Use automated checks for repeatable issues, then add expert review, keyboard testing and testing with screen readers and other assistive technologies.
7. Publish an honest accessibility statement State the standard used, current conformance position, known limitations, contact method and continuing improvement process. Do not claim full compliance without evidence.
8. Retest and maintain Verify remediation, monitor new releases and recheck major user journeys. Accessibility is a continuing product responsibility rather than a one-time certification exercise.