Translation moves words across languages. Accessibility ensures those words and the experience around them are equally usable for people with disabilities. Yet most translation services translate their words but fail to translate the access. This comprehensive guide addresses the critical intersection of language and accessibility, offering translation buyers a complete framework for ensuring their multilingual content complies with the "Big Four" global accessibility standards: the Americans with Disabilities Act (ADA), Section 508 of the Rehabilitation Act, the Web Content Accessibility Guidelines (WCAG 2.2), and the newly enforced European Accessibility Act (EAA). By understanding these frameworks and their practical implications for translation, your organization can minimize legal risk, expand market reach, and serve the 1.3 billion people with disabilities globally, a demographic representing $13 trillion in annual disposable income.
Introduction: The Intersection of Language and Access
The accessibility landscape shifted dramatically in 2025. The European Accessibility Act became fully enforceable on June 28, 2025, marking the first comprehensive EU-wide accessibility mandate affecting businesses selling to EU consumers. Simultaneously, the ADA Title II web accessibility updates created new compliance requirements for state and local government entities. In the United States, web accessibility lawsuits have reached epidemic proportions, with nearly 4,000 cases filed in 2024 alone, and an average settlement ranging from $5,000 to $20,000 though large enterprises face settlements exceeding $350,000. This urgency extends globally, and any organization offering multilingual services must understand that translation without accessibility is a half-measure that exposes companies to substantial legal and reputational risk.
Consider a Spanish-speaking user with low vision navigating a US healthcare portal. The content has been translated to Spanish, but if the HTML language tag (<html lang="en">) remains set to English, their screen reader will attempt to pronounce Spanish words using an English accent, rendering the translation unintelligible. The page fails not because of translation quality, but because the accessibility infrastructure supporting the translation was ignored. This scenario, repeated thousands of times across websites and applications, illustrates the core problem: translation is not the same as localization, and localization is not the same as accessible localization.
The stakes are equally high for PDF documents. A translated PDF that has not been remediated, a process involving manual re-tagging, reading order verification, and validation with assistive technologies will fail catastrophically for blind and low-vision users. A remediated English PDF becomes inaccessible when translated without re-remediation. Many organizations unknowingly expose themselves to litigation by distributing documents that meet accessibility standards in the source language but fail accessibility requirements in the translated versions.
This 2025 buyer's guide equips translation procurement teams, compliance officers, and digital leaders with the knowledge to select vendors, evaluate compliance, and implement accessible multilingual content. The promise is simple: accessibility is achievable, but only when accessibility is prioritized from the translation RFP forward.
The "Big 4" Compliance Framework: What Every Translation Buyer Must Know
Understanding the Four Pillars of Global Accessibility Law
Compliance with accessibility standards requires understanding four distinct but often overlapping frameworks. Each has different jurisdictions, enforcement mechanisms, and implications for translated content.
2.1 The Americans with Disabilities Act (ADA)
The ADA is a foundational US civil rights law prohibiting discrimination against individuals with disabilities across all areas of public life. For digital translation services, Title II (governing state and local government entities) and Title III (covering private businesses and public accommodations) are most relevant. While the ADA does not explicitly use the word "website," courts have consistently interpreted digital services as falling within the Act's scope, particularly for organizations providing services online. If your organization offers a service or information in English on your website, the ADA implies that providing equal access to that service or information in another language does not override the accessibility requirement; the translated version must function equally for disabled users.
The ADA's "equal access" mandate is not merely a translation requirement; it is a functional accessibility requirement. If a Spanish-language form is accessible on paper but inaccessible on the web for screen reader users, the translated digital version fails the ADA, even if the Spanish language itself is perfectly translated. For healthcare organizations, educational institutions, government agencies, and businesses with a significant customer base that uses other languages, this creates a profound compliance obligation: every language version must be tested for accessibility with real assistive technologies.
Recent ADA enforcement has shifted toward proactive compliance and away from serial plaintiff litigation in some cases, but organizations must not view this shift as a license to deprioritize web accessibility. Instead, the focus should be on meaningful access, ensuring that multilingual content is genuinely usable by people with disabilities in all offered languages.
2.2 Section 508 of the Rehabilitation Act
Section 508 is a federal law requiring US government agencies and their contractors to make Information and Communication Technology (ICT) including websites, software, and digital documents accessible to employees and the public. Unlike the ADA, which broadly applies to public accommodations, Section 508 creates a specific mandate for federal compliance and contractor accountability.
One critical tool in Section 508 compliance is the VPAT (Voluntary Product Accessibility Template), also known as the Accessibility Conformance Report (ACR). The VPAT is a standardized document that describes how a product or service meets Section 508 technical standards. For translation services, this is crucial: if you are translating software, websites, or digital documents for a federal agency or federal contractor, the localized version must have its own VPAT, demonstrating that the translated product maintains accessibility across all supported languages.
Many translation vendors are unfamiliar with the VPAT requirement and fail to account for it in their proposals. A vendor that cannot produce a VPAT or Accessibility Conformance Report is signaling that they do not fully understand the compliance landscape for federal translation work. For healthcare systems, universities, and contractors selling to the US government, Section 508 compliance is non-negotiable, and your translation vendor must demonstrate that they have experience with VPAT documentation.
2.3 Web Content Accessibility Guidelines (WCAG) 2.2
WCAG 2.2 is not a law itself; rather, it is the technical standard that underpins most global accessibility laws. Released in 2023 and rapidly adopted by regulatory bodies worldwide, WCAG 2.2 provides a framework of technical success criteria organized into four principles: Perceivable, Operable, Understandable, and Robust (POUR).
WCAG 2.2 introduces nine new success criteria that directly impact translation work. Most notably, criteria 2.5.7 (Dragging Movements) and 2.5.8 (Target Size) have implications for UI localization. The Target Size criterion requires that clickable elements be at least 24×24 CSS pixels, with proper spacing to prevent accidental activation of adjacent targets. In localization, when text expands due to language characteristics (German, for instance, expands content by ~30%), UI elements can shift out of alignment, violating the Target Size and Reflow criteria.
WCAG 2.2 also clarifies the importance of the lang attribute for multilingual content. The <html lang="es"> tag tells screen readers to use Spanish pronunciation for the page content; if this attribute is missing or incorrectly set, screen readers will mispronounce translated text. For PDFs, language attributes must also be set within the document structure, not merely in the metadata.
Three conformance levels exist: Level A (essential), Level AA (the legal standard for ADA and EAA compliance), and Level AAA (ideal but not legally required). Most compliance obligations require WCAG 2.2 AA, which means your translated content must also meet WCAG 2.2 AA.
2.4 European Accessibility Act (EAA)
The European Accessibility Act, approved in 2019 and fully enforced as of June 28, 2025, represents the EU's first comprehensive accessibility directive. Unlike the ADA, which requires equal access to services, the EAA specifically targets products and services in specific sectors: e-commerce, e-books, banking, ticketing machines, websites, and mobile applications.
The EAA applies to US companies selling to EU consumers. If your organization offers e-commerce, SaaS, or digital services to customers in the EU, EAA compliance is mandatory. Failures to comply result in substantial fines: non-compliance fines range from €5,000 to €20,000 per issue, with daily penalties of up to €1,000 for unresolved violations. Some EU countries impose far more severe penalties: Spain fines up to €600,000, Sweden up to €200,000, and France up to €250,000. For organizations not yet aware of EAA, the June 2025 deadline has already passed, making current compliance a matter of urgency.
A crucial distinction: the EAA references EN 301 549, the European accessibility standard, rather than WCAG, though the standards are substantially aligned. However, for practical compliance, most organizations implement WCAG 2.2 AA, which satisfies both EAA and ADA requirements.
Technical Mechanics of Accessible Translation: How Accessibility Breaks in Multilingual Content
Understanding the legal frameworks is necessary but insufficient. Translation buyers must also understand the technical mechanisms through which accessibility fails when translation is not properly localized.
The Language Attribute Problem
The most common failure point in multilingual accessibility is the HTML <html lang="en"> tag. This single line of code tells screen readers what language to use when pronouncing the page content. When a website is translated to Spanish but the lang attribute remains set to English, screen readers attempt to read Spanish text with English phonetics, producing garbled, incomprehensible output.
The problem extends beyond simple mispronunciation. Screen readers use the lang attribute to:
Select the correct pronunciation engine
Apply language-specific rules for acronyms and abbreviations
Enable spell-check and grammar tools for assistive technology users
For multilingual sites offering content in multiple languages simultaneously, the lang attribute must switch dynamically with the language selection. If your Spanish-language page still declares itself as English, or if your Arabic-language page (which should use dir="rtl" and lang="ar") still uses left-to-right directionality, accessibility fails.
ARIA Labels and the Multilingual Localization Gap
ARIA (Accessible Rich Internet Applications) labels are hidden code that tells screen readers what elements do. A button might be marked aria-label="Close" to indicate its function. ARIA labels are often hard-coded in source code and missed by standard translation proxies. When a Spanish-language website is deployed using an English ARIA label, blind Spanish-speaking users hear the button described in English: "Cerrar" (close) is replaced by "Close," switching languages mid-interaction.
Research has shown that ARIA-based approaches lead to language issues in more than 50% of test cases when not properly localized. The best practice is to ensure that all ARIA labels are translated and tested with native-speaking screen reader users in the target language. This requires closer collaboration between translation vendors and accessibility specialists than traditional translation workflows provide.
The challenge is compounded by the fact that ARIA labels are "invisible" to casual reviewers; they do not appear on the rendered page, only in the assistive technology layer. A translation manager reviewing a Spanish website may see perfect Spanish text but remain unaware that the underlying ARIA labels are still in English.
Text Expansion, Reflow, and RTL Languages
Language characteristics directly impact accessibility compliance. German and Russian expand text by 20–30% compared to English, which can cause text to overflow containers, overlap with other elements, or break WCAG 1.4.10 (Reflow) criteria. When a UI button is sized for English text and the translated text expands, the button's internal text may become illegible or inaccessible to screen reader users.
For right-to-left languages like Arabic, Hebrew, and Urdu, the challenges are even more complex. Not only must text and layout be mirrored, but the focus order in which keyboard Tab navigation moves through interactive elements must be reversed. If a form's tab order remains left-to-right for an Arabic-language page, keyboard users will navigate in a counter-intuitive manner. Additionally, icons with directional meaning (arrows, navigation symbols) must be flipped horizontally.
Complex scripts such as Chinese, Arabic, and Devanagari require larger minimum font sizes than Latin scripts to maintain readability and accessibility for users with low vision. A font size adequate for English may be too small for Arabic or Chinese characters, violating WCAG 1.4.4 (Resize Text) criteria.
Multimedia Accessibility: Subtitles, Captions, and Audio Description
A fully accessible video requires three distinct types of audio/visual content:
Subtitles (for hearing viewers who don't speak the language): Display spoken dialogue and key audio elements.
Captions/SDH (Subtitles for the Deaf and Hard of Hearing): Include all dialogue, speaker identification, and descriptions of sound effects and music (e.g., "[door slams]", "[upbeat music plays]").
Audio Description: A separate audio track describing visual action for blind users.
When translating video, all three must be localized. A translated SDH must identify speakers by their translated names, and the sound-effect descriptions must make sense in the target language and cultural context. Audio Description must be re-recorded by professional narrators in the target language, not machine-generated. Yet many organizations translate only the main dialogue, leaving SDH and Audio Description in the source language, creating gaps in accessibility for deaf and blind users in the translated market.
Format-Specific Guides: PDFs, E-books, and Multimedia
The PDF Accessibility Myth
The most dangerous myth in accessible translation is: "Saving a document as PDF preserves accessibility." It does not. A perfectly accessible Word document can become a completely inaccessible PDF if the PDF is not remediated. A translated PDF that was remediated in the source language must be re-remediated in the target language because translation changes the document structure, reading order, and content flow.
The PDF remediation process involves:
Translation: The source file (InDesign, Word, etc.) is translated, and a new PDF is generated.
Manual Tagging: A human expert must assign semantic tags to headings, paragraphs, lists, images, and tables, creating a logical document structure.
Reading Order Verification: The reading order (the sequence in which a screen reader encounters content) must match the logical flow of the document in the target language. For RTL languages, reading order reversal must be verified.
Alt Text Creation: Every image must have descriptive alt text in the target language, and that alt text must be localized, not merely translated. A mailbox in the US looks different from a UK pillar box.
Validation: The PDF must be tested with PAC 2024 (PDF Accessibility Checker) or Adobe Acrobat Pro, and ideally validated by blind users with screen readers.
Many translation vendors assume they can outsource PDF remediation to a generic document services provider unfamiliar with the source language. This creates gaps: a PDF remediation team working only in English may not understand cultural localization requirements (e.g., ensuring images are appropriate for the target market) or may not catch errors in how the translated text was integrated.
The professional standard is PDF/UA (PDF Universal Accessibility), formally ISO 14289. A PDF/UA-compliant document includes proper tagging, metadata, and structure that enable assistive technologies to parse the document correctly. A translated PDF must meet PDF/UA 1.0 standards in the target language to be considered fully accessible.
E-books and the Accessibility Translation Gap
E-books present a unique challenge: they must be accessible in their native format (EPUB, Kindle, etc.) while also being readable through multiple platforms and devices. An EPUB 3 file can embed video and audio, but when localized, these multimedia elements must be re-recorded or re-subtitled in the target language. Many translation vendors treat e-book localization as simple file translation, missing the necessary accessibility remediation and multimedia localization steps.
The Business Case: Why Accessibility Is Strategic, Not Just Compliance
Market Expansion: The Hidden Demographic
With 1.3 billion people globally living with disabilities 15–20% of the global population, the disability market represents approximately $490 billion in annual disposable income in the US alone, expanding to $13 trillion globally when including families and friends. Yet 97% of websites remain inaccessible, collectively losing $6.9 billion annually to competitors with accessible sites. The market opportunity is staggering, but only for organizations that prioritize accessibility as a feature, not a burden.
Research shows that 83% of people with disabilities limit their online shopping to websites they know are accessible. This means accessible multilingual content is not just a compliance checkbox it is a customer retention and acquisition strategy. Organizations that fail to provide accessible multilingual content are actively pushing away a significant customer segment.
Legal Risk Mitigation: Avoiding Multimillion-Dollar Settlements
ADA web accessibility litigation has become an industry. In 2024, nearly 4,000 ADA website accessibility lawsuits were filed, with an average settlement of $5,000–$20,000 for small businesses and settlements exceeding $350,000 for large enterprises. Target and Domino's have faced multimillion-dollar lawsuits over inaccessible websites. The cost of accessibility compliance is dramatically less than the cost of defending and settling a lawsuit.
However, a shift is occurring: judges are beginning to scrutinize the motives of "serial plaintiffs" who file dozens of nearly identical lawsuits seeking settlements rather than meaningful access. This shift does not mean that accessibility is becoming less important. Rather, it signals that courts expect organizations to take accessibility seriously and implement genuine compliance, not cosmetic overlay widgets or token gestures. Organizations that can demonstrate reasonable, good-faith accessibility efforts face lower settlement exposure than those that ignored accessibility entirely.
ROI and Competitive Advantage
The ROI for digital accessibility investment is dramatic: every $1 invested in accessibility yields up to $100 in benefits, according to research by Forrester. Tesco invested £35,000 in accessibility improvements and saw online sales jump to £13 million annually. In a market where 72% of organizations have formal accessibility policies and 85% perceive accessibility as a competitive advantage, failing to invest in multilingual accessibility puts organizations at a disadvantage.
Additionally, accessible content is cleaner code. Cleaner code is easier for Google's algorithms to crawl, index, and rank. Screen readers, in essence, are like blind users and search engine crawlers: they both rely on well-structured, semantic HTML. When your content is accessible, it is also more likely to be picked up by Google's AI Overviews and featured in search results. This creates a virtuous cycle: accessibility improves rankings, which improves visibility, which increases traffic and conversions.
The Vendor Evaluation Framework: Selecting an Accessible Translation Partner
Selecting a translation vendor capable of delivering accessible multilingual content requires moving beyond standard RFP questions. Translation procurement teams must ask specific questions about accessibility expertise, testing capabilities, and quality assurance processes.
Critical Questions to Ask
1. Do your linguists have formal accessibility training?
A vendor's response reveals whether accessibility is integrated into their workflows or treated as an afterthought. Vendors with accessibility expertise often hold IAAP (International Association of Accessibility Professionals) certification or have partnerships with accessibility specialists. Red flags include: "We've never had that requirement before" or "Accessibility is handled by a separate team after translation."
2. Do you translate ARIA labels, alt text, metadata, and hidden accessibility attributes?
This is the hidden code question. Standard translation proxies and many translation management systems do not access ARIA labels or metadata. A vendor should respond: "Yes, we extract and translate all ARIA attributes, test with screen readers, and provide a detailed accessibility QA report." A response like "We only translate visible text" is a red flag.
3. Can you test translated content with JAWS, NVDA, and VoiceOver screen readers?
Screen reader testing is non-negotiable. JAWS (JAWS for Windows) is the industry standard for Windows accessibility testing; NVDA is a free, widely-used alternative; VoiceOver is built into macOS and iOS. A vendor should offer testing with all three and provide detailed reports documenting how the translated content reads when accessed through assistive technology.
4. Do you have a dedicated PDF remediation team?
This question separates serious accessibility vendors from those offering surface-level compliance. A dedicated PDF remediation team understands PDF/UA standards, manual tagging, reading order verification, and localization-specific challenges like RTL language support and text expansion. Vendors who outsource PDF remediation to generic document services providers often lack the linguistic and accessibility expertise needed for quality results.
5. Do you use native-speaking testers with disabilities?
User testing with people with disabilities is the gold standard for accessibility validation. A vendor should employ or contract with blind, low-vision, deaf, and motor-impaired testers who are native speakers of the target language. This is expensive but essential for catching issues that automated tools miss. A vendor response of "We test with our team of sighted, non-disabled testers" is a red flag; accessibility is best validated by the disability community itself.
6. Can you provide a Letter of Conformance or Accessibility Conformance Report (ACR)?
Professional accessibility vendors should be able to provide formal documentation demonstrating that the translated content meets WCAG 2.2 AA or Section 508 standards. This document serves as legal protection and evidence of good-faith compliance efforts. A vendor unfamiliar with conformance documentation or unwilling to provide one is signaling lack of accessibility expertise.
Red Flags: What to Avoid
Accessibility Overlay Widgets: Vendors that promote accessibility overlay widgets ("accessibility plugins" or "AI-powered accessibility solutions") as a substitute for proper accessibility are selling a false solution. Research has consistently shown that overlays interfere with screen reader functionality and create new accessibility barriers while masking underlying issues. Avoid any vendor suggesting overlays as a compliance path.
Claims of "100% Automated Compliance": Automated tools catch ~60–70% of accessibility issues. The remaining issues require human expertise, manual testing, and user validation. A vendor claiming guaranteed, fully automated compliance is overstating capabilities.
Translation Proxies as the Localization Solution: Translation proxies are technology solutions that intercept traffic and translate pages on-the-fly. They excel at speed but fail at accessibility: they cannot localize non-text content (images, videos), struggle with ARIA attributes, and often produce unpredictable results. For accessibility-critical content, translation proxies are a poor choice.
No Post-Deployment Support: Accessibility is not a one-time project. Websites and apps are continuously updated, which means translated content requires continuous re-testing and re-remediation. A vendor offering only "one-time translation" without ongoing support is not equipped for the modern digital environment.
Frequently Asked Questions (FAQ)
Q: Does Google Translate automatically make my site ADA compliant?
A: No. Google Translate provides machine-generated translations without accessibility remediation. ARIA labels remain in English, the lang attribute is not properly set for all content, and multimedia lacks captions or audio description. Additionally, Google Translate output has been shown to contain errors and cultural misalignments. For legal compliance, professional translation with accessibility review is mandatory.
Q: Do I need to translate my Accessibility Statement itself?
A: Yes. Your Accessibility Statement is a legal document describing your accessibility commitments and processes. It must be available in each language your site supports. A site offering Spanish-language content but only an English Accessibility Statement is signaling to Spanish-speaking users with disabilities that the organization does not take their access seriously.
Q: What penalties does EAA non-compliance carry?
A: Fines range from €5,000 to €900,000+ depending on severity and country, with daily penalties of up to €1,000 for unresolved violations. Some EU countries impose criminal penalties including imprisonment for responsible individuals in cases of severe, repeated non-compliance.
Q: Can I use an "accessibility overlay" to quickly become compliant?
A: Accessibility overlays create a false sense of compliance. They interfere with assistive technologies, introduce new accessibility barriers, and do not address underlying accessibility issues. The web accessibility community and legal experts widely reject overlays as a compliance solution. Courts have begun questioning their effectiveness in legal proceedings.
Q: How do I handle multilingual audio descriptions for video?
A: Audio description must be re-recorded by professional narrators in the target language. The description track should describe visual action, on-screen text, and cultural context in a way that makes sense to local audiences. Machine-generated audio description is not a substitute for professional narration.
Q: What is the difference between captions and subtitles?
A: Subtitles contain only dialogue and are designed for hearing viewers who don't speak the language. Captions (SDH Subtitles for the Deaf and Hard of Hearing) include dialogue, speaker identification, and descriptions of sound effects (e.g., "[phone ringing]") and are designed for deaf and hard-of-hearing viewers.
Practical Implementation Roadmap: A 90-Day Accessibility Localization Plan
Weeks 1–2: Accessibility Audit and Vendor Evaluation
Audit your existing multilingual content against WCAG 2.2 AA standards
Document current accessibility gaps in each language
Use the Vendor Evaluation Checklist (above) to issue RFPs to translation partners
Request accessibility testing samples and references
Weeks 3–4: Vendor Selection and Scoping
Select a vendor based on accessibility expertise, not just price
Define accessibility requirements in writing, including:
WCAG 2.2 AA compliance level
Specific languages and content types (web, PDF, multimedia)
Required testing methodologies (screen readers, manual review, user testing)
Deliverables (conformance reports, test reports, remediated files)
Weeks 5–8: Content Translation and Accessibility Review
Begin translation with accessibility requirements embedded in the workflow
Ensure ARIA labels, alt text, and metadata are included in the translation scope
Conduct parallel accessibility testing as translation proceeds
Weeks 9–10: Quality Assurance and User Testing
Screen reader testing with JAWS, NVDA, and VoiceOver
User testing with real people with disabilities (blind, low-vision, deaf, motor-impaired)
Remediation of any identified issues
Weeks 11–12: Documentation and Deployment
Generate Accessibility Conformance Reports and Letters of Conformance
Update Accessibility Statements to reflect new language support
Deploy with confidence and implement post-deployment monitoring
Conclusion: Accessibility Is a Journey, Not a Destination
The 2025 accessibility landscape is complex, multi-jurisdictional, and rapidly evolving. The ADA, Section 508, WCAG 2.2, and EAA represent different regulatory approaches to a common goal: ensuring that digital content and services are usable by everyone, regardless of disability or language. The intersection of accessibility and translation creates unique challenges hidden code that must be localized, multimedia that must be adapted, and testing methodologies that must account for language-specific variables.
However, the path forward is clear. By understanding the legal and technical frameworks, selecting vendors with genuine accessibility expertise, and prioritizing user testing with the disability community, organizations can build multilingual digital experiences that are both legally compliant and genuinely inclusive. The business case is equally compelling: accessible multilingual content expands market reach, reduces legal risk, improves SEO performance, and builds brand loyalty among the 1.3 billion people with disabilities globally.
For translation buyers, the message is unambiguous: accessibility is not a nice-to-have feature to be bolted onto translation after the fact. It is a core requirement that must be designed into the translation process from day one. The vendors that understand this will become the partners of choice. The organizations that prioritize it will thrive in an increasingly diverse, regulated, and accessible digital marketplace.
Next Steps:
Audit your current multilingual content against WCAG 2.2 AA standards
Use the Vendor Evaluation Checklist to assess your current translation partners
Plan your first accessibility-inclusive translation project with a partner that understands that translation without accessibility is incomplete
The opportunity is now. The cost of accessibility is far less than the cost of litigation, and the market opportunity far exceeds the cost of implementation. Your disabled users in all languages are waiting.
