Website and app accessibility in Israel under the Service Accessibility Regulations: the standard, the exemptions, the accessibility statement and the exposure to claims

Internet Law · October 21, 2026 · 10 min read

The short answer

Whoever provides a “public service” as defined in section 19J of the Equal Rights for Persons with Disabilities Law, 5758-1998 – including businesses in the fields listed in the Second Schedule to the Law – must make accessible the website and app through which the service, or information about it, is provided. The binding standard under regulation 35A of the Equal Rights for Persons with Disabilities Regulations (Service Accessibility Adjustments), 5773-2013, is SI 5568 part 1 (September 2023 edition) at level AA, which adopts the WCAG 2.0 guidelines with national deviations. An exempt dealer and anyone whose average annual turnover does not exceed ILS 100,000 are fully exempt (regulation 35F(g)); anyone with turnover up to ILS 1,000,000 is exempt, for three renewable years, only for a site that began operating before 26 October 2017 (regulation 35F(i)). Every obligor publishes an accessibility statement (regulation 35E), and anyone employing at least 25 employees appoints an accessibility coordinator (section 19MB of the Law). A deviation from the standard is not a breach so long as no notice was sent to the obligor and it did not fail to cure within a reasonable time and no later than 60 days (regulation 35A(d)); after that the exposure is to damages without proof of loss under section 19NA(b) of the Law – ILS 50,000 nominal, indexed – and to class actions.

1. Who must make the site accessible

The Law dates from 1998; the accessibility chapter was added to it by Amendment No. 2 in 2005. The duty applies to whoever is responsible for providing a “public service”, defined in section 19J of the Equal Rights for Persons with Disabilities Law: a service provided to the public by a public body or in a public place, or a service of the kinds listed in the Second Schedule to the Law. The Schedule is broad and, as the Commission’s guide summarises it, covers among others commerce, health, education, leisure, tourism and hospitality, culture, communications, banking, credit, insurance and financial services – so that almost every online store and digital service offered to the public falls within it.

Regulation 35 of the Service Accessibility Regulations defines an “internet service” as “content in any format, including text, documents, images or video, transmitted over the internet and displayed to the user by means of websites, documents or applications (apps), designed to provide the user with a public service or information about such a service”. Two clarifications from the Commission’s guide “Website accessibility” (updated 16 March 2026): a purely informational site, such as a news site, that provides no public service is not obliged; and the duty rests on the owner or operator of the site – not on the development company.

2. The standard: SI 5568 part 1 and WCAG 2.0

Regulation 35A(a) of the Service Accessibility Regulations provides: “An obligor shall provide accessibility adjustments in an internet service, except as regards applications (apps) within the meaning of regulation 35C and time-based media, in accordance with the internet accessibility standard and the guidelines set in it, at level AA, and subject to the provisions of this Chapter”. The “internet accessibility standard” is defined in regulation 35 as Israeli Standard 5568 “in its various parts and annexes, as amended from time to time”. The edition of SI 5568 part 1 in force was published in September 2023 (Yalkut HaPirsumim 11720, 22 October 2023) and replaced the May 2021 edition; the standard is open to the public free of charge on the Commission’s website.

The cover of the standard states that it is, “save for the national changes and additions indicated in it, identical” to the Web Content Accessibility Guidelines (WCAG) 2.0 of 11 December 2008. The national changes are these: success criteria 1.2.1, 1.2.2 and 1.2.3 (alternatives for time-based media, captions and audio description for recorded content) were raised from level A to level AA, and are therefore required; criteria 1.2.4 and 1.2.5 (live captions and audio description) were raised from level AA to level AAA, and are therefore not required; criterion 2.4.10 (section headings) was lowered from level AAA to level AA, and is therefore required; and criterion 3.1.2 (language of parts) does not apply. The standard adds that the change in the level for time-based media will be reconsidered in future if automatic tools for adding Hebrew captions become available.

For precision: the W3C has since published later versions of the guidelines – WCAG 2.1 and WCAG 2.2, the latter also adopted as ISO/IEC 40500:2025 – but Israeli law refers to the Israeli standard, and the Israeli standard adopts version 2.0. At the time of writing we have not located a draft standard or revision of SI 5568 adopting a later version, neither on the Standards Institution’s public-review list nor in the official gazette. Publications describing the Israeli standard as based on WCAG 2.1 are inaccurate.

Three supplementary provisions: an obligor that is not a public authority and made adjustments at level A by 25 October 2014 is deemed to have complied with the regulation (regulation 35A(b)); a document prepared from 26 October 2017 onwards, such as a PDF file, and uploaded to the site or app must be accessible under the provisions of the standard dealing with documents (regulation 35A(c)(1)); and regulation 35B relieves the obligor of responsibility for the accessibility of content uploaded by third parties that it neither edited nor produced, provided it supplied an accessible infrastructure for uploading it.

3. Apps and video

Apps are carved out of regulation 35A(a) and dealt with in regulation 35C of the Service Accessibility Regulations: an app must meet an Israeli standard for app accessibility “to the extent such a standard exists”, and in its absence the success criteria of the internet accessibility standard apply “as far as possible”, on at least two common operating systems. An app is exempt if an identical, accessible, mobile-adapted website exists and the app links to it. Regulation 35D deals with video: the duty to caption recorded content (criterion 1.2.2) applies to public authorities and to obligors whose average turnover exceeds ILS 5,000,000, for video content they edit or produce, and under regulation 10(b) of the 2017 amending regulations – only for content uploaded to the internet from 26 October 2017 onwards.

4. The exemptions – regulation 35F

Regulation 35F of the Service Accessibility Regulations gathers the exemptions. “Average turnover” is defined in regulation 35 as “the average of the obligor’s turnover in the last three tax years before the date of examination in which the turnover was not zero”; the amounts in the regulation carry no indexation clause.

Sub-regulation	Who is exempt	Scope and conditions
35F(g)	An exempt dealer as defined in section 1 of the Value Added Tax Law, or an obligor whose average annual turnover does not exceed ILS 100,000	Full exemption from accessibility adjustments under the internet chapter
35F(i)	An obligor whose average turnover is ILS 1,000,000 or less	Exemption only for a site or app that began operating before the commencement of the regulations – a date the Commission reads as 26 October 2017, the commencement of the amending regulations that added the internet chapter (regulation 10(a) of the 2017 amending regulations); provided the contact details for obtaining the service are published accessibly; valid for three years from the end of the last tax year examined, renewable every three years
35F(h)	An obligor with turnover up to ILS 300,000	A transitional exemption that expired on 26 October 2020
35F(a)–(c)	An obligor whose platform or technological interface does not permit a particular adjustment	Exemption from that adjustment only, granted by a certified service-accessibility expert on the basis of a professional opinion; valid for up to three years and renewable for three more, and beyond that – with the Commissioner’s approval for special reasons; the obligor provides alternative accessibility and publishes the exemption and the alternative adjustments in the accessibility statement
35F(d)	A service delivered over a social-network platform	Exemption from an adjustment the platform does not permit
35F(e)	A closed service – access limited to pre-registered users, with no more than 500 concurrent registered participants	Exemption from making the content accessible, unless a person with a disability requests it; in that case the 60-day period in regulation 35A(d)(1) does not apply
35F(f)	Personal documents provided in an area requiring identification	The transitional exemption expired on 31 December 2021; a document prepared from 1 January 2022 onwards must be accessible
35F(j)	Advertisements	The chapter does not apply, provided an accessible alternative exists for the information on the service in the advertisement

A note on the amounts: the Commission’s guide (updated 16 March 2026) cites a full exemption for anyone whose turnover is below ILS 120,000 or who is an exempt dealer for VAT purposes, and the transitional exemption for turnover “between ILS 120,000 and ILS 1,000,000”. The text of the regulation says ILS 100,000 and is not indexed; the ILS 120,000 figure appears to track the exempt-dealer ceiling in the Value Added Tax Law. Since an exempt dealer is exempt in any event, the difference is largely academic – but where in doubt, the text of the regulation is the one to rely on.

5. The accessibility statement – regulation 35E

Regulation 35E of the Service Accessibility Regulations provides that “in addition to regulations 34 and 91(e)” – the duties to publish the accessibility arrangements of the physical service and the coordinator’s details – the obligor shall display “in a prominent place on its website and in the app it operates, if there is such an app”, a statement in accordance with the standard’s guidelines on accessibility statements. The statement must contain:

1. information on the accessibility adjustments made;
2. the details of the accessibility coordinator and how to contact him, where the obligor must appoint one under the Law;
3. details enabling contact for reporting missing accessibility adjustments or requesting accessibility, “including a demand under regulation 35A(d)(1)” – that is, the channel through which the notice that starts the 60-day period will be sent;
4. where an exemption was granted under regulation 35F(a) – the exemption and the alternative adjustments (regulation 35F(c)).

In the Ben Or decision, discussed below, six motions to certify class actions concerned the absence of an accessibility statement, the absence of published accessibility arrangements and the absence of coordinator details – not actual inaccessibility. A deficient statement is thus a cause of action a class-action applicant can identify without any technical examination of the site, as was done in those six motions. The firm’s own accessibility statement is published on this site.

6. The accessibility coordinator – section 19MB

Section 19MB(a) of the Equal Rights for Persons with Disabilities Law provides that “whoever is responsible for providing a public service as defined in Chapter D, and employs at least 25 employees, shall appoint from among its employees a person versed, as far as possible, in the field of accessibility for persons with disabilities, who shall as far as possible be a person with a disability”. The coordinator provides information to the public on the accessibility of the service and advises the organisation on its duties (section 19MB(b)). Two clarifications: the threshold is “at least” 25 employees – not “more than 25”, as is sometimes written – and the coordinator is appointed from among the employees. Anyone employing fewer than 25 employees need not appoint a coordinator, and its accessibility statement will give other contact details.

7. The 60-day rule and the Ben Or decision

Regulation 35A(d)(1) of the Service Accessibility Regulations provides: “A deviation from compliance with the provisions of this Chapter shall not be regarded as a breach of the accessibility provisions unless a notice was sent to the obligor demanding that it be cured and the obligor failed to cure it within a reasonable time and no later than 60 days from receipt of the notice”. Regulation 35A(d)(2) adds that during that period the obligor must make alternative adjustments as soon as possible. The consequence is that an accessibility defect on a site is not, in itself, a wrong: the wrong arises only once the cure period has passed without cure. The provision applies to every claim based on the internet chapter, individual or class.

In Class Action 52621-07-23 Ben Or v. Aviv Investment House Ltd. et al. (Tel Aviv District Court, 22 January 2024) Judge Oded Maor heard six joined motions to certify class actions filed by a single applicant against small businesses, without prior notice, for the absence of an accessibility statement, of published accessibility arrangements and of coordinator details. The court held that although “the Class Actions Law contains no provision requiring prior notice before a class action is filed”, regulation 35A(d)(1) itself requires anyone alleging a breach of regulation 35E to send prior notice to the site owner; and as to causes for which no such provision exists, the court extended the prior-notice requirement on the basis of good faith and fairness, noting that “experience shows that many proceedings end right after the small businesses receive the certification motion and act at once to cure the breaches”, and that the absence of prior notice “may be regarded as an abuse of legal proceedings”. The court held that the motions fell to be dismissed on those causes: one motion was dismissed with costs against the applicant, and in the other five the court approved withdrawal without the agreed award and fees, awarding the applicant and his counsel instead a combined award and fee of ILS 1,000 from each of the five respondents – “a sum equivalent to the effort involved in sending a prior-notice letter”.

The decision should be presented in proportion: it is a reasoned decision of a District Court sitting as a single judge, not binding Supreme Court precedent, and it concerns publication breaches rather than substantive inaccessibility. What binds generally is the text of the regulation: a notice, and a cure period of up to 60 days.

8. Damages, defences and class actions

Section 19NA(a) of the Equal Rights for Persons with Disabilities Law provides that an act or omission contrary to the accessibility chapter is a civil wrong to which the Civil Wrongs Ordinance applies. Section 19NA(b) allows the court to award, without proof of loss, damages “in a sum not exceeding ILS 50,000” for a wrong contrary to a provision made, among others, under section 19L – the section under which the internet regulations were made. In other words: damages without proof of loss of up to ILS 50,000 under section 19NA(b) of the Equal Rights for Persons with Disabilities Law, 5758-1998, indexed from March 2005 (the base index under section 19NA(f) is the index for February 2005, published in March) – about ILS 72,500 as of 2026 by an indexation computation, not an official sum. Section 19NA(f) provides that the sum is updated once a year by the rise in the consumer price index against the base index, but imposes no duty to publish the updated sum in the official gazette; the updated figure is therefore the result of an indexation computation, not an official published sum.

Section 19NA(c) lists defences that exclude damages without proof of loss: the defendant is complying with an accessibility order issued against it for the same omission; it filed an undertaking before the omission and is honouring it; a financial sanction or administrative warning was imposed on it for the same omission beforehand, for the period the Commissioner set for making the adjustments; an earlier claim for the same omission was filed and it is complying with the judgment in it, or the earlier claim was filed less than three months before and it is remedying on a reasonable timetable; or it submitted a query to the Commission a reasonable time before the claim was filed. Section 19NA(e) lists the considerations for setting the sum – among them the number of claims filed against the defendant, the type of service and scale of activity, the nature and cost of the adjustment, and turnover or profit – and section 19NA(d) empowers the Minister of Justice to set conditions, relating to the cost of the adjustment against the defendant’s income, under which damages without proof of loss will not be awarded.

The significant exposure is not the individual claim but the class action, the instrument used in Ben Or. The best practical defence has four components: accessibility to the standard, a complete accessibility statement, an active contact channel, and documented handling of every notice within the 60-day period.

9. Administrative enforcement

Alongside the civil route, the Equal Rights for Persons with Disabilities Law gives the Commission administrative enforcement tools: accessibility orders (section 19MC of the Law) and, under Chapter I of the Law, financial sanctions, administrative warnings and undertakings. The sanctions the Commission published in 2025–2026 – among them a sanction of over ILS 40,000 on the Merhavim Regional Council (18 August 2025) – concern the physical accessibility of places and services. We have not located any financial sanction, accessibility order or administrative warning published in 2025–2026 concerning the accessibility of a website or app; nothing about the future follows from that, since the power exists. At government level, the National Digital Agency’s guideline “Making new digital services accessible to persons with disabilities” (guideline 2.2.24, in force since April 2021; updated version 2.1 in force from 1 January 2026) requires ministries to build new digital services to SI 5568 and, for in-house development, to obtain certification from an accessibility expert before launch (for procured services the certification is recommended only) – a benchmark for what the State demands of itself.

The accessibility statement is one of four documents every website and app needs, alongside the terms of use and the privacy policy; for the consolidated overview see the service page.

Frequently asked questions

Must every website be accessible?

Not every website, but most business websites – yes. The duty applies to whoever provides a “public service” as defined in section 19J of the Equal Rights for Persons with Disabilities Law, including services in the fields listed in the Second Schedule to the Law, through a website or app (regulation 35 of the Service Accessibility Regulations). According to the Commission’s guide, a purely informational site is not obliged, and the duty rests on the site’s owner or operator, not on whoever built it.

Which version of WCAG is binding in Israel?

Regulation 35A of the Service Accessibility Regulations refers to Israeli Standard SI 5568 part 1 at level AA. The edition in force, from September 2023, is identical to WCAG 2.0 of December 2008 save for national deviations, set out in the article. Later versions of WCAG exist, but we have not located a revision of the Israeli standard adopting them.

Who is exempt from making a website accessible?

Under regulation 35F(g) of the Service Accessibility Regulations – an exempt dealer as defined in the Value Added Tax Law, or an obligor whose average annual turnover does not exceed ILS 100,000. Under regulation 35F(i) – an obligor whose average turnover is ILS 1,000,000 or less, but only for a site that began operating before 26 October 2017, for three renewable years and provided its contact details are published accessibly. The Commission’s guide cites ILS 120,000; the regulation says ILS 100,000.

What must the accessibility statement contain?

Under regulation 35E of the Service Accessibility Regulations: information on the accessibility adjustments made; the details of the accessibility coordinator, where the obligor must appoint one; and contact details for reporting missing adjustments or requesting accessibility, including a demand under regulation 35A(d)(1). Where a technological exemption was granted under regulation 35F(a), the exemption and the alternative adjustments are stated too (regulation 35F(c)). The statement is placed “in a prominent place” on the site and in the app.

Can a site owner be sued without prior notice?

Regulation 35A(d)(1) of the Service Accessibility Regulations provides that a deviation from the internet provisions is not a breach unless a notice was sent to the obligor and it failed to cure within a reasonable time and no later than 60 days of receipt. In Class Action 52621-07-23 Ben Or v. Aviv Investment House (Tel Aviv District Court, 22 January 2024) the court held that motions to certify class actions filed without prior notice fall to be dismissed, dismissed one of them and approved withdrawal of the others without the agreed award and fees – a District Court decision, not Supreme Court precedent.

What damages may the court award?

Damages without proof of loss of up to ILS 50,000 under section 19NA(b) of the Equal Rights for Persons with Disabilities Law, 5758-1998, indexed from March 2005 – about ILS 72,500 as of 2026 by an approximate indexation computation, not an official sum. The Law does not require publication of the updated figure, so this is an indexation computation, not an official sum. Section 19NA(c) lists defences, among them a prior query to the Commission.

The above is general information on Israeli law only, current as of the date of publication, and does not constitute legal advice or a substitute for advice on your specific circumstances. Sanction and damages figures are those set in the legislation and in the authorities’ publications at the date of publication and are updated from time to time. Consult a lawyer before acting.

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