Website Accessibility Requirements in the UAE

Website accessibility in the UAE is a hard legal requirement for federal government sites and a strong expectation for everyone else. The National Policy for Digital Accessibility, issued by TDRA in March 2024, requires public service websites to meet WCAG 2.1 Level AA. It also reaches the contractors who build those sites. A private Dubai company is asked to make its “best efforts” rather than ordered to comply. For most businesses the practical target is therefore WCAG 2.1 AA, with 2.2 AA as the sensible build standard for anything new.

Key takeaways

• The UAE National Policy for Digital Accessibility (March 2024) sets WCAG 2.1 Level AA as the bar for public service sites and names TDRA as the enforcing authority for federal entities.
• Private companies that build websites, apps or systems for federal entities are inside the policy’s scope, so an agency bidding for government work inherits the AA requirement.
• Every other private business, including free zone companies, is told to take the policy into account and exert its best efforts. That is guidance, not a penalty regime.
• Dubai Law No. 3 of 2022 counts digital platforms as part of accessibility. Its duty to provide access sits with government entities, but its Article 7 ban on disability discrimination applies to any natural or legal person, with fines capped at AED 100,000.
• Bilingual Arabic and English sites fail in predictable places: missing language attributes, weak contrast on Arabic type, and form fields with no labels.

What the rules require of a private UAE website

We looked for a UAE federal or Dubai law that sets a WCAG level for an ordinary private company website, and as of September 2026 we did not find one. That answer surprises clients in both directions. Some assume there is a fine waiting for them. Others assume accessibility is optional. Neither is quite right.

Article 3 of the National Policy for Digital Accessibility lists who it applies to. Federal ministries, authorities and institutions are bound directly. So are consultants, private companies, contractors and “service providers, particularly in the development of websites, electronic/digital services” for federal entities. Then comes a softer line: local government entities, semi-government entities and private sector entities “should take this document into account, and exert the best efforts in compliance”.

The policy defines private sector broadly, and the definition names free zone authorities alongside private companies. A Dubai Silicon Oasis software firm and a JLT trading company sit in the same bracket. Neither is ordered to comply. Both are expected to try.

There is also a sector route. The policy tells each federal regulator to liaise with the private companies it licenses to check adherence. Healthcare, education and e-commerce are named in Article 2 as sectors where private providers deliver public services. A clinic or a school is therefore more likely to be asked about accessibility by its own regulator than a consultancy is.

The national policy in practical terms

Annex 1 of the policy is the technical part, and its first line is the one that matters: all public service sites must comply with Level AA of WCAG 2.1, and with W3C best practice for mobile. The rest of the annex lists features TDRA expects on government portals. It is a useful checklist even for a private site, though not every item suits a small business.

The features divide into two groups. The first group is ordinary WCAG work that any competent build should include:

• Alternative text on logos, images and signs so screen readers can describe them
• Full keyboard navigation, with Tab moving between links and Enter activating them
• Text that can be enlarged, with screen magnification working
• Colour that is never the only way to tell a link from normal text
• Forms built so screen readers can read every field
• Plain language, with complex medical or legal content offered in an easier version

The second group goes beyond WCAG and is aimed at government service portals: a built-in text reader with MP3 download, sign language translation, speech recognition and even facial recognition. A Business Bay consultancy does not need sign language video on its About page. The first group is where a private site should spend its money.

Article 12 adds one requirement that is cheap to copy. Federal entities must publish a Digital Accessibility statement naming the standard they follow (WCAG 2.1 as a minimum), any content that is not yet accessible, and how users can report a problem. The official u.ae portal’s statement says it is built to WCAG 2.1 and 2.2 Level AA “as a minimum”. A one-page statement on a private site costs almost nothing. It also tells users where to report a problem before that problem becomes a complaint.

WCAG levels without the jargon

WCAG is published by the W3C and organised into three conformance levels. Level A covers the basics that block people completely. Level AA covers the barriers that make a site hard to use. Level AAA is the strictest and is rarely required for a whole site. AA includes all of A, which is why regulators almost everywhere, the UAE included, pick AA.

WCAG 2.2 was first published as a W3C Recommendation on 5 October 2023. It keeps nearly all of 2.1, removes the old 4.1.1 Parsing criterion, and adds new ones, several of them at AA. A site that meets 2.2 AA also meets 2.1 AA, so building to 2.2 costs little extra and covers the UAE bar.

Where Arabic and English sites fail most often

Bilingual sites carry accessibility faults that single-language sites do not, and generic audit tools often miss them because they only check the language they were written for.

Language attributes

The html element on the Arabic version should carry lang=”ar” and dir=”rtl”. One issue we often see is an Arabic page served from an English template that still declares lang=”en”. A screen reader then tries to pronounce Arabic text with English rules, and the page becomes unintelligible to exactly the users the markup was meant to help. Criterion 3.1.2 also covers mixed content: a Latin brand name in an Arabic paragraph, or an Arabic tagline on an English page, should be wrapped with its own lang attribute.

Contrast and size on Arabic type

Arabic letterforms have fine strokes, dots and marks that disappear sooner than Latin characters when contrast drops. The 4.5:1 ratio applies to both scripts, but a design that barely passes in English often reads worse in Arabic at the same point size. A light grey on white that looks refined in a Figma mock-up is the usual culprit. In practice we set Arabic body text a step larger than English and test contrast on the Arabic pages separately.

Mirroring

Right-to-left layouts need the reading order, icons and focus order to mirror correctly. A carousel arrow that points the wrong way is a cosmetic fault. A keyboard focus order that jumps from right to left and back again is a functional one, and it is common when RTL is added with CSS alone rather than built into the component.

Forms and CAPTCHAs

Lead forms are where accessibility and revenue meet. A Dubai real estate brokerage whose enquiry form uses placeholder text instead of labels, and an image CAPTCHA with no audio alternative, is locking out part of its enquiries at the point of conversion. Criterion 3.3.8 in WCAG 2.2 makes a puzzle-only login or verification step a failure at AA.

Why an overlay widget is not compliance

Accessibility toolbars that add a floating icon with font resizing, contrast modes and a read-aloud button are popular with UAE businesses, partly because government portals show similar tools. u.ae lists more than a dozen such options in its accessibility statement.

The difference is that u.ae states the platform itself is built to WCAG 2.1 and 2.2 AA, and the toolbar sits on top of that. On a site with unlabelled form fields, images without alt text and a broken focus order, a toolbar changes how the page looks while leaving those underlying faults in place. From a development perspective the markup is the product, and a widget cannot reliably write a missing form label or know what a project photo shows. Our view is that a toolbar is acceptable as an extra, and never as the fix.

A fix order that fits an SME budget

A full WCAG audit of a large site is a real project. A 15 to 30 page company site can be brought close to AA in a sensible order, starting with the faults that block people completely.

1. Run an automated checker such as the free WAVE tool or axe on the home page, a service page, the contact page and one Arabic page. Automated tools catch only part of WCAG, but they find the obvious faults fast.
2. Fix language and direction attributes on every template, English and Arabic.
3. Add labels to every form field and make error messages specific, such as “Enter a UAE mobile number starting with 05” rather than “Invalid input”.
4. Write alt text for meaningful images and mark decorative ones with an empty alt attribute so screen readers skip them.
5. Correct contrast in the design tokens rather than page by page, so the fix holds across the site.
6. Tab through each template with the mouse unplugged. If you lose the focus indicator or get stuck in a menu, that is a keyboard fault to fix.
7. Publish an accessibility statement naming the standard, known gaps and a contact address.

Steps two to five are mostly template work, which is why accessibility is cheapest during a build and most expensive as a retrofit. If a rebuild or redesign is already on the table, put WCAG 2.2 AA in the brief. The website design brief is the right place to write it down, because a requirement added after sign-off tends to become a change request.

When the stakes go up

Three kinds of UAE business should treat AA as a firm requirement rather than a goal.

The first is any company that builds or runs digital services for a federal entity. The policy brings contractors and development service providers into its scope, so an accessibility gap in a delivered portal is a gap in the contract. Expect the requirement to appear in tender documents and acceptance testing.

The second is regulated sectors with public-facing services. Clinics, hospitals, schools and banks are the obvious cases, since the policy expects each federal regulator to check its licensees. Dubai Law No. 3 of 2022 also lists equal access to banking and to “all sources and platforms of information and data” among the rights government entities must secure. For a healthcare provider, accessibility belongs in the same conversation as the other points in our note on healthcare website design in Dubai.

The third is any UAE e-commerce business selling to consumers in the European Union. The European Accessibility Act, Directive (EU) 2019/882, names e-commerce among the services it covers. A Dubai store shipping to Germany or France should get that question answered by EU counsel. UAE law is not the only rulebook that applies to its checkout.

If you are planning a new site or a redesign, the cheapest moment to get accessibility right is before the templates are built. We build WCAG requirements into web design and UI and UX design projects from the first wireframe, and we are glad to look at an existing site first if you are unsure where it stands.

Policy and standards references were checked against the TDRA National Policy for Digital Accessibility (March 2024), Dubai Law No. 3 of 2022, W3C WCAG 2.2 and the u.ae accessibility statement on 27 September 2026, and rechecked on 28 September 2026. Rules change, and this is general information rather than legal advice. Cover photo: Dubai Blue Line stel 5112 to Creek (52765713036) by Rob Dammers, via Wikimedia Commons (CC BY 2.0).