Website accessibility in South Africa

Website accessibility in South Africa rests on equality law, not on a web-specific statute. The Constitution and the Promotion of Equality and Prevention of Unfair Discrimination Act (PEPUDA) prohibit unfair discrimination on the ground of disability. Neither names a technical standard for websites. The recognised benchmark to work towards is the Web Content Accessibility Guidelines (WCAG) from the W3C.

This article is general information, not legal advice. It does not say what any particular website must do to comply with the law. Ask your own legal counsel about your obligations.

What the law says

The Constitution

Section 9(3) of the Constitution lists disability among the grounds on which the state may not unfairly discriminate. Section 9(4) extends this to private persons: no person may unfairly discriminate against anyone on those grounds. It also requires national legislation to prevent or prohibit unfair discrimination. PEPUDA is that legislation.

PEPUDA

The Promotion of Equality and Prevention of Unfair Discrimination Act 4 of 2000 is the primary source. The points that matter for a website owner are these.

• Who it binds. Section 5 says the Act binds the State and all persons. It does not apply to a person to the extent that the Employment Equity Act applies.
• The general rule. Section 6 says neither the State nor any person may unfairly discriminate against any person.
• Disability. Section 9 prohibits unfair discrimination on the ground of disability. Its examples include denying or removing a supporting or enabling facility that a person with a disability needs to function in society, and failing to eliminate obstacles that unfairly limit or restrict persons with disabilities from enjoying equal opportunities, or failing to take steps to reasonably accommodate their needs.
• Fairness. Section 14 sets out the factors a court weighs when deciding whether discrimination is unfair. One is whether the respondent has taken reasonable steps to address the disadvantage or to accommodate diversity.
• Enforcement. Complaints are heard by equality courts. Under section 21, the orders a court can make include damages, an order directing reasonable accommodation, an audit and an apology.

What the Act does not say

PEPUDA does not mention websites, the internet or WCAG. It does not set a technical standard or a conformance level for digital content. Whether a particular barrier on a particular website amounts to unfair discrimination depends on the facts and is a question for a lawyer or a court.

The practical conclusion is modest. A website is one of the ways a business offers goods, services and information. The law prohibits unfairly excluding people with disabilities and asks for reasonable steps. Removing known barriers from a website is a reasonable step, and WCAG is the standard that defines what those barriers are.

WCAG in brief

WCAG is published by the World Wide Web Consortium (W3C). According to the W3C's WCAG overview:

• WCAG 2.2 was published on 5 October 2023 and updated on 12 December 2024.
• The W3C recommends using the latest version. Content that conforms to 2.2 also conforms to 2.1 and 2.0.
• WCAG 2.2 is also an ISO standard, ISO/IEC 40500:2025.
• WCAG 3 is an early draft and is not a standard to build to yet.

WCAG 2.2 is organised under four principles: content must be perceivable, operable, understandable and robust. Each success criterion has a level: A, AA or AAA. Level AA includes every Level A criterion, and it is a common working target. Version 2.2 added nine success criteria, including Target Size (Minimum), Focus Not Obscured, Dragging Movements, Redundant Entry and Accessible Authentication.

What to check on your website

The list below covers barriers that are simple to find. Most items name the WCAG 2.2 success criterion they come from. It is a starting point, not a full audit.

• Images have text alternatives. Every image that carries meaning has alt text that serves the same purpose. Decorative images are marked so that screen readers skip them. (1.1.1, Level A)
• Video has captions. Prerecorded video with sound has captions. (1.2.2, Level A)
• Text has enough contrast. Body text has a contrast ratio of at least 4.5:1 against its background. Large text needs at least 3:1. (1.4.3, Level AA)
• Text can be enlarged. Text can be resized to 200% without losing content or function. (1.4.4, Level AA)
• The page reflows. Content works at a width of 320 CSS pixels without scrolling in two directions. (1.4.10, Level AA)
• Everything works by keyboard. Menus, forms, sliders, pop-ups and booking widgets can all be used without a mouse. (2.1.1, Level A)
• Keyboard focus is visible. It is always clear which link, button or field is selected. (2.4.7, Level AA)
• Tap targets are large enough. Buttons and links are at least 24 by 24 CSS pixels, or have enough space around them. (2.5.8, Level AA)
• Forms are labelled. Every field has a visible label, and errors are explained in text, not by colour alone.
• Structure is clear. Headings follow a logical order, link text describes where the link goes, and the page language is set.

Third-party parts of a site need the same checks. Booking engines, payment pages, chat widgets and embedded maps are often where barriers remain, and the site owner may have little control over them.

How to test

1. Use the keyboard only. Press Tab through a page. Check that you can reach everything, see where you are and complete a form.
2. Zoom to 200% and narrow the browser window. Check that nothing is cut off or overlapping.
3. Run an automated checker. Tools such as Lighthouse in Chrome or WAVE find missing alt text, low contrast and missing labels. They cannot judge whether alt text is meaningful or whether a process makes sense, so they are a first pass only.
4. Try a screen reader, such as VoiceOver on Apple devices, TalkBack on Android or NVDA on Windows.
5. Ask people who use assistive technology. Their feedback finds problems that tools miss.

Record what you find, fix the barriers that block tasks first, and check again after every redesign or new feature. A site that was accessible at launch can stop being so when content is added.

Where Stryx stands

Stryx builds sites with accessibility in mind and can give guidance against WCAG. It gives guidelines only and makes no warranty that a site complies with any law or standard. Clients should consult their own legal counsel.

Related reading: how Stryx builds websites, the POPIA checklist for websites, the website redesign checklist and technical SEO. To discuss an existing site, get in touch.