Web Accessibility (WCAG 2.2) in Indonesia: New Requirements for Government Websites

FebriJune 23, 202610 min read
Web Accessibility (WCAG 2.2) in Indonesia: New Requirements for Government Websites

Web accessibility is the practice of ensuring websites and applications are usable by everyone, including people with visual, auditory, motor, and cognitive disabilities. The global standard for this is WCAG accessibility — the Web Content Accessibility Guidelines — and its latest version, WCAG 2.2, is now the primary reference for government agencies and state-owned enterprises (BUMN) in Indonesia that want their digital services to be inclusive and legally compliant.

In October 2025, WCAG 2.2 was officially adopted as international standard ISO/IEC 40500:2025. Combined with domestic regulatory momentum through Indonesia's Disability Law and the Electronic-Based Government System (SPBE) agenda, 2026 marks a turning point: accessibility is no longer a nice-to-have but an auditable obligation. This article explains what has changed, who must comply, and the practical steps to get there.

What WCAG 2.2 Is and Why This Version Matters

WCAG 2.2 is a technical guideline published by the W3C on 5 October 2023 and updated in December 2024. It contains 12 guidelines grouped under four core principles known by the acronym POUR: Perceivable, Operable, Understandable, and Robust.

Compared to WCAG 2.1, version 2.2 adds nine new success criteria focused on users with cognitive and motor limitations — for example, a minimum touch target of 24x24 pixels, form-filling assistance so users do not have to memorize information, and keyboard focus that is always visible. Its adoption as ISO/IEC 40500:2025 gives WCAG 2.2 far greater legal weight across many jurisdictions, including as a benchmark for government procurement.

ℹ️ Info

WCAG conformance is generally split into three levels: Level A (most basic), Level AA (the level most often legally required), and Level AAA (most stringent). The majority of regulations worldwide, including Indonesian references, target Level AA.

Indonesia's Digital Accessibility Regulatory Landscape

Indonesia does not yet have a single binding national technical standard specifically for digital accessibility, but its legal framework is clear. Law No. 8 of 2016 on Persons with Disabilities, particularly Articles 122-124, requires the government to facilitate communication and guarantee access to information that is easy to understand for persons with disabilities.

Law No. 14 of 2008 on Public Information Disclosure guarantees every citizen's right to obtain information from public bodies without exception, while Law No. 1 of 2024 (the second amendment to the ITE Law) affirms the principle of non-discrimination in digital spaces. In 2024, BAPPENAS issued a Guideline on Digital-Based Public Communication and Information Services for Persons with Disabilities that explicitly references WCAG 2.2 specifications.

The Electronic-Based Government System (SPBE), running since 2018, initially did not treat accessibility as a mandatory element. However, in October 2025, the Central Information Commission launched a change initiative called ACCESS to push for inclusive digital public services — a strong signal that accessibility audits of government sites will become increasingly real.

Global trends add indirect pressure too. The European Union enforced the European Accessibility Act starting June 2025, the United States enforces Section 508 and the ADA, and various countries treat WCAG Level AA as the official benchmark. For Indonesian companies serving international clients or processing cross-border data, ignoring accessibility means limiting global market opportunities.

ℹ️ Important

Although there is no single ministerial regulation that states 'WCAG 2.2 Level AA is mandatory,' the combination of the Disability Law, the Public Information Disclosure Law, and the SPBE agenda is already legally sufficient to require public bodies to provide accessible digital services. Waiting for more specific regulation is a risky strategy.

Why Accessibility Is Urgent: The Data and Scale of the Problem

According to the Long Form SP2020 results released by Statistics Indonesia (BPS), the number of persons with disabilities in Indonesia reaches roughly 22.97 million people, equivalent to 8.5% of the total population. Most are elderly, and their labor participation rate is only 23.94% — partly due to access barriers, including digital access to public services.

The technical scale of the problem is large too. The WebAIM Million 2025 report, which analyzed the one million most popular homepages worldwide, found that 94.8% of pages had automatically detectable WCAG failures, with an average of 51 errors per page. The most common errors were low-contrast text (79.1% of pages), missing image alt text (55.5%), and skipped heading levels (39%).

Research on Indonesian regional government websites shows a similar pattern: most do not meet WCAG standards, making it difficult for citizens with disabilities to access critical services such as complaints, permits, and public information. This gap is not merely a compliance issue but a matter of citizens' rights.

The Four POUR Principles You Must Meet

Every WCAG compliance effort is rooted in the four POUR principles. Understanding each helps teams set the right remediation priorities.

Perceivable | Required Information must be perceivable by all senses: alternative text for images, captions for video, and a minimum color contrast of 4.5:1 for normal text.

Operable | Required All functionality must be operable with a keyboard alone, touch targets must be at least 24x24 pixels, and no content should trigger seizures from flashing light.

Understandable | Required Content and navigation must be consistent and predictable; form error messages must be clear and suggest corrections.

Robust | Required Code must be valid and compatible with assistive technologies such as screen readers, using semantic HTML and correct ARIA attributes.

💡 Tip

Start with high-impact, low-cost fixes — color contrast, image alt text, and form labels. These three alone resolve the majority of failures most frequently flagged by auditors.

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Who Must Comply: Government, BUMN, and Their Vendors

The strongest accessibility obligations attach to public bodies: ministries, agencies, regional governments, and BUMN that deliver digital public services. Service portals, licensing systems, complaint sites, and government mobile apps all fall within this scope.

Often overlooked: vendors and development agencies share responsibility too. When an agency procures website development, WCAG 2.2 Level AA requirements should ideally be written into the Terms of Reference. Vendors who do not understand accessibility risk delivering products that fail audits and must be reworked at additional cost.

Private sectors serving the broad public — banking, insurance, e-commerce, and healthcare — are also increasingly compelled to comply with WCAG, both due to reputational pressure and to expand their market to the 22.97 million potential users who have so far been excluded.

For procurement managers, the key is to write measurable accessibility requirements from the outset. State the WCAG 2.2 Level AA target in the Terms of Reference, require proof of testing (automated and manual audit reports) as a handover condition, and allocate a dedicated remediation budget. Without clear criteria, procurement outcomes are hard to evaluate objectively and the agency risks accepting a non-compliant product.

The Most Common WCAG Failures and How to Fix Them

Based on WebAIM data and field audit experience, most failures concentrate on a handful of issues that are actually easy to fix. Here are the priorities that deliver the biggest impact.

Low-contrast text | 79.1% of pages Text with a contrast ratio below 4.5:1 is hard for low-vision users to read. Fix: adjust the color palette and test with a contrast checker tool.

Missing alt text | 55.5% of pages Images without an alt attribute cannot be read by screen readers. Fix: write descriptive alt text for informative images and empty alt for decorative ones.

Skipped heading structure | 39% of pages Jumping from H2 to H4 confuses screen reader navigation. Fix: use a logical, sequential heading order.

Missing form labels | common Input fields without labels leave users unsure what data is requested. Fix: associate every input with an explicit label element.

Non-descriptive links | common 'Click here' links are meaningless when read out of context. Fix: use link text that describes the destination.

The Business and SEO Benefits of Accessibility

Accessibility is often viewed as a compliance burden, yet its business benefits are real. An accessible site reaches the 22.97 million persons with disabilities in Indonesia plus a growing elderly population — a market segment that has long been overlooked.

Accessibility practices also overlap with SEO ranking factors. Semantic HTML, image alt text, clear heading structure, and descriptive link text are signals favored by both search engines and assistive technologies. In other words, improving accessibility often boosts search visibility as a bonus.

In addition, accessible sites are generally faster, easier to maintain, and have cleaner code. These benefits apply to all users, not just people with disabilities — a principle known as the 'curb-cut effect,' where features designed for some people end up benefiting everyone.

Practical Steps Toward WCAG 2.2 Compliance

Achieving compliance does not have to happen all at once. The following phased approach works well for teams with limited resources.

1. Initial audit. Run automated scans (such as axe DevTools, WAVE, or Lighthouse) to catch obvious errors, then complement them with manual testing using a keyboard and screen readers like NVDA or TalkBack.

2. Prioritization. Categorize findings by user impact and conformance level (A, AA). Fix Level A blockers first.

3. Remediation and integration. Embed accessibility into design components and the development pipeline so it does not accumulate as technical debt. Accessibility is cheapest when built in from the start, not patched at the end.

4. Testing with real users. Involve people with disabilities in testing. Automated tools catch only about 30-40% of issues; the rest surface only through human testing.

5. Continuous monitoring. Accessibility is not a one-off project. Every new feature release can introduce regressions, so periodic audits should be scheduled.

ℹ️ Info

Automated scanning tools can detect only about one-third of all accessibility issues. True compliance always requires manual testing and, ideally, feedback from users with disabilities.

Frequently Asked Questions

Is WCAG 2.2 legally mandatory in Indonesia?

No single regulation explicitly names WCAG 2.2 as a standalone obligation. However, Law No. 8 of 2016, the Public Information Disclosure Law, and the SPBE agenda collectively require public bodies to provide accessible digital services, and WCAG 2.2 Level AA is the most recognized technical benchmark for meeting that requirement.

Which conformance level should I target?

Level AA is the standard target required by most regulations worldwide and serves as the practical benchmark in Indonesia. Level A is too minimal, while Level AAA is difficult to achieve comprehensively and is usually applied only to specific content.

How long does it take to make an old site compliant?

It depends on the site's size and complexity. An initial audit can be completed in 1-2 weeks, while full remediation of a large-scale government portal may take several months if done in phases.

Are accessibility overlay plugins enough?

No. Automated overlays often fail to fix underlying problems and in many cases actively disrupt screen reader users. Fixing the source code remains the reliable, auditor-recognized solution.

What is the risk of ignoring accessibility?

Risks include public complaints, potential information-disclosure disputes, procurement audit failures, reputational damage, and most importantly, shutting millions of citizens out of public services that are their right.

Building Inclusive Digital Services with JoyCyber

Meeting WCAG 2.2 requires a blend of design, development, and compliance expertise. At JoyCyber, we build accessible sites and applications from the design stage, not as an afterthought.

Learn how our web development services embed accessibility into every project, or see our approach to

UI/UX design that is inclusive and conversion-oriented.

For broader context, read our guide on the cost of professional website development in 2026 and

digital transformation for Indonesian companies.

Ready to ensure your government or corporate site is inclusive and compliant? Contact the JoyCyber team for an accessibility audit consultation and a remediation plan that fits your budget and deadline.

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Febri

JoyCyber Team

Tim ahli JoyCyber yang berdedikasi membantu bisnis Indonesia bertransformasi digital dengan solusi teknologi terdepan.

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