WCAG 2.2 Comes to Japanese Standards! JIS X 8341-3 Revision Finally Coming After About 10 Years. Effectively an 18-Year Update?

Hello, I'm Morimoto, CEO of Liberogic.
Today, I'd like to talk about web accessibility.

As you may already know from various articles, Japan's domestic web accessibility standard, "JIS X 8341-3," is expected to be revised for the first time in about 10 years.

With only about six months left in this fiscal year, will the formal revision be completed within this year?
I imagine it's a challenging task, but I sincerely hope the WAIC team will do their best.

Looking at the current title, "JIS X 8341-3:2016," you might assume that the accessibility success criteria were significantly updated in 2016, but that is not actually the case.
The success criteria for web content were already identical to WCAG 2.0 as of the 2010 edition.

The 2016 revision was limited to aligning the JIS with ISO/IEC 40500:2012, which internationally standardized WCAG 2.0, making the body text of the JIS match the international standard.
In other words, rather than new accessibility criteria being added in 2016, it is more accurate to view it as a revision that reorganized WCAG 2.0 as Japan's JIS.

Japan also faced a timing issue.

About two years after JIS X 8341-3:2016 was revised, on June 5, 2018, WCAG 2.1 became a W3C Recommendation, significantly strengthening areas that WCAG 2.0 did not fully cover, such as mobile, touch operation, and low vision.
Since the JIS must also align with international standards, it cannot simply be revised every time W3C updates its guidelines.
As a result, Japan's JIS is heading toward a major update from WCAG 2.0 to a level equivalent to WCAG 2.2, without incorporating WCAG 2.1 as a formal standard.

In short, although it is titled "2016," the foundation of success criteria used in Japan to date is effectively WCAG 2.0, which became a W3C Recommendation in 2008.

The JIS itself is being revised for the first time in about 10 years, but

Measured against the baseline of success criteria, this is roughly an 18-year gap, from 2008 to 2026!

It finally feels like it's being updated.

In September 2025, the international standard ISO/IEC 40500 was revised to match WCAG 2.2 content, and in response, revisions to Japan's JIS X 8341-3 are now underway.
For the background of this revision, the success criteria added in WCAG 2.2, and the responses companies will be expected to take going forward, please refer to the article that the EWM Group has written in great detail.

EWM Group, "2026 Latest JIS X 8341-3 Revision: Key Points and Actions Companies Should Take"

Here, drawing on our experience in web production and accessibility support, we share what we think about this revision.

We have kept evaluating the 2026 web against success criteria from 2008

This isn't to say WCAG 2.0 is outdated and useless.
It contains many important principles that remain at the core of accessibility today, including alt text, keyboard operation, contrast, and heading structure.
However, the web itself in 2008 and in 2026 are vastly different.

Smartphones and tablets, touch operation, responsive design, SPAs, modals, fixed UI, and complex web applications.
Given these usage environments, which are now taken for granted, we have long felt a strong sense of discomfort at continuing to treat success criteria created in 2008 as the "current standard" through 2026.
*This is also what prompted Liberogic to get into accessibility work.

WCAG was subsequently updated to 2.1 in 2018 and 2.2 in 2023.
WCAG 2.2 adds success criteria that better reflect how the web is used today, covering touch operation, dragging, focus, authentication, and input.
Even so, in Japan, "JIS X 8341-3:2016" has for a long time remained the benchmark used in government and municipal specifications, tenders, and accessibility testing.

We evaluate websites and web applications of 2026 mainly against success criteria created in 2008.

Even so, this has been a rather unnatural situation, I think.

No one was "slacking off"

That said, this does not mean the Ministry of Internal Affairs and Communications has done nothing.

JIS X 8341-3:2016 is aligned with the international standard ISO/IEC 40500.
As mentioned earlier, it is not a simple matter of rewriting the content in Japan alone.
WAIC has been preparing for the revision of JIS for some time and has published and updated the Japanese translation of WCAG 2.2. It has also organized how to describe conformance when targeting both the current JIS and WCAG 2.1 and 2.2 at the same time. We always keep a close eye on these developments and use them as a reference.

So this is not a case of "Japan has done nothing for ten years."
I think it simply reflects a large gap in speed between the institutional framework and the evolution of the web.

Government bodies are already moving toward WCAG 2.1 and 2.2

More and more government websites and procurement specifications appear to include not only the current JIS but also WCAG 2.1 and WCAG 2.2.
For example, the Digital Agency has set target conformance for JIS X 8341-3:2016 at Level AA, as well as for those WCAG 2.2 A and AA success criteria that are not included in the current JIS.
Procurement guidebooks also clearly state that WCAG 2.2 conformance is necessary, taking into account today's web environment, including mobile use.

I think this is a positive change.

On occasion, we have helped with government procurement bids, and we have explained to clients, "Not only JIS X 8341-3:2016, but ideally let's also check against WCAG 2.2 AA." However, if it is not written in the specifications, the question becomes who bears the additional effort.

This was a very sensitive issue.

Can we really evaluate accessibility quality amid price competition?

Especially in bids where price carries significant weight, I still have some doubts.
If the specifications state "JIS X 8341-3:2016 AA compliance," meeting that condition comes first.

• Beyond that, checking against WCAG 2.1 and 2.2 as well
• carrying out detailed testing by people
• verifying with assistive technologies

Of course, this requires considerable effort and specialized expertise.
Yet when competing on price,

how carefully accessibility was implemented and how thoroughly it was tested

is still hard to judge, as it varies considerably from project to project.
Simply writing "accessibility compliance" in procurement specifications is not enough. We need to consider which criteria apply, to what scope, through what testing methods, and how that quality will be ensured.

Accessibility testing cannot be completed with tools alone

Checking tools such as miChecker also play an important role.
Note: We also hope the Ministry of Internal Affairs and Communications will continue developing an upgraded version.

The same applies to Lente Scan, which we are developing.

While it is possible to improve the accuracy of automated checks as much as feasible, there are success criteria that can only be judged by a human reviewer.

For example,

• Can the task be completed using only the keyboard?
• Does focus move in an appropriate order?
• Are the name, role, and state of components correctly conveyed to assistive technologies?
• Is there a method of operation available other than drag-and-drop?
• Does the authentication method avoid placing an undue burden on users?

These are the kinds of checks involved.

As WCAG 2.2 adoption progresses, the importance of testing that goes beyond surface-level checks into implementation and operation will only increase.
Reviewing the HTML alone is not enough; some items require inspecting the DOM and ARIA, or using assistive technologies such as screen readers.

Accessibility testing is not simply a matter of ticking items off a checklist.
Manual testing in particular requires not only an understanding of the success criteria but also knowledge of implementation and assistive technologies.
Since the testing is performed by people, oversights by reviewers are inevitable.

Having a clear understanding of each characteristic, I believe it is important to reduce oversights as much as possible.

Rather than aiming for a perfect score, keep getting closer to one.

Maintaining web accessibility at 100% at all times is not easy.

Websites are living things.
Content grows from the CMS, UIs change, and external services are sometimes added.
What matters is not testing once, declaring "compliant," and stopping there, but having a system in place to find issues, improve them, and verify again.

Standards and testing exist to safeguard that state, but if the yardstick itself is outdated, improvements on the ground will inevitably hit their limits.
In that sense, I feel the revision of JIS X 8341-3 this time means more than just "the first standard revision in about 10 years" or "effectively an update after 18 years."

Japan's web accessibility standard, which had been based on 2008 for a long time, is finally catching up to the current web environment!

Rather than doing accessibility work just to meet a standard, we use the standard to reduce the number of people who cannot use the web!

I sincerely hope this revision becomes a turning point.