LBI and NBR 17225: what Brazilian law requires of a website

Yes. If your company has its headquarters or a commercial representative in Brazil, its website must be accessible to people with disabilities. That is what article 63 of the Lei Brasileira de Inclusão (LBI, Brazil's Inclusion Law, Law 13,146/2015) requires, and it also applies to government websites. The law has no technical checklist of its own: it says to follow internationally adopted accessibility guidelines. The W3C's international guidelines are called WCAG and are also an ISO standard (ISO/IEC 40500). Since March 2025, Brazil has had ABNT NBR 17225, a technical standard that adopts WCAG 2.2 and organizes those guidelines into 96 requirements and 50 recommendations. Meeting every requirement is equivalent to WCAG 2.2 levels A and AA.

This article explains the law and the standard as published in October 2026. It is not legal advice. For a specific case, talk to a lawyer. Quotes from Brazilian laws and from NBR 17225, and the names of the standard's items, are our translations from Portuguese.

What article 63 of the Brazilian Inclusion Law says

The LBI, also called the Statute of Persons with Disabilities, was signed into law on July 6, 2015 and, under article 127, took effect 180 days after publication. The main text of article 63 reads:

"Accessibility is mandatory on internet sites maintained by companies with headquarters or commercial representation in the country or by government bodies, for use by persons with disabilities, guaranteeing them access to the information available, in accordance with internationally adopted accessibility best practices and guidelines."

(Law 13,146/2015, art. 63)

"Internet site" is the law's term for a website. Under article 2 of the same law, a person with a disability is someone who has a "long-term physical, mental, intellectual or sensory impairment" that, in interaction with barriers, may obstruct full participation in society. Among those barriers, article 3, IV, "d" includes those that hinder receiving information "through communication and information technology systems". A website that does not work with a keyboard or a screen reader fits that description.

The same article has three more paragraphs:

• paragraph 1 says that "sites must display the accessibility symbol prominently";

• paragraphs 2 and 3 cover community telecenters and LAN houses (internet cafés), with accessible equipment and computers, not websites.

Article 64 adds a practical consequence: the accessibility of the websites covered by article 63 must be observed to obtain public funding, such as tax waivers or incentives, contracts or agreements (art. 54, III). Article 63 sets no fine and no compliance deadline of its own. It creates the obligation and points to international guidelines for how to meet it.

Who has to comply

As article 63 is worded, the obligation applies to websites maintained by:

• companies headquartered in Brazil;

• companies with commercial representation in Brazil, even if headquartered abroad;

• government bodies.

The article makes no distinction by size, industry or revenue. A micro business, an online store and a large portal are in the same sentence.

The law speaks of websites "maintained by" companies and government bodies and does not address how responsibility is split between the client and the developer. Our recommendation for agencies, freelancers and clients: state in the contract which standard and level the delivered site must meet (for example, regular conformance with NBR 17225) and who handles the accessibility of content published after delivery.

What ABNT NBR 17225 is

ABNT (Associação Brasileira de Normas Técnicas) is Brazil's national standards body. NBR 17225 is titled "Accessibility in web content and applications", with the subtitle "Requirements". The details below come from the standard itself, in the launch edition published by Brazil's Chamber of Deputies:

• first edition on March 11, 2025, with 69 pages;

• prepared within the Brazilian Accessibility Committee (ABNT/CB-040), by the Study Commission on Accessibility for Digital Inclusion;

• draft submitted to national public consultation from November 27, 2024 to December 26, 2024.

According to NIC.br, technical coordination was led by Ceweb.br (the Center for Web Technology Studies), the work involved 178 specialists over almost two years, and the full text of the standard was made available free of charge.

The scope says the standard sets accessibility requirements for websites based on international guidelines and that "conformance with this standard aims to meet current legislation". A note in the scope names the reference: WCAG 2.2.

How the standard is organized

Section 5 has 146 items. Each is marked as a requirement or a recommendation: 96 requirements and 50 recommendations, counting the items of the first edition. The items are grouped into 16 topics: keyboard interaction, images, headings, regions, lists, tables, links and navigation, buttons and controls, forms and data entry, presentation, use of color, text content, coding and semantic markup, audio and video, animation, and time.

Each item states the WCAG 2.2 success criterion it is meant to meet and that criterion's level. There are also three informative annexes:

• Annex A, items that are problematic for accessibility: CAPTCHA, facial recognition, content shown only on focus or hover, content inserted via CSS, third-party content, custom components, files, tables used for layout and markup outside the specification;

• Annex B, functional performance: what the site must allow for people who use it without vision, with limited vision, without color perception, without hearing, without speech, with limited strength or reach, with photosensitive epilepsy or with limited cognition;

• Annex C, a checklist with every item, its classification (requirement or recommendation), the WCAG criterion and Yes, No and N/A columns.

Regular conformance and full conformance

Section 4 of the standard defines two types of conformance:

• regular conformance: every requirement met. According to the standard, it is aligned with WCAG 2.2 level AA, and a site in regular conformance also conforms to WCAG 2.2 levels A and AA;

• full conformance: requirements and recommendations met. If any recommendation is left out, a reasonable justification is required.

Some items accept more than one way of complying, separated by "or". The first option is the preferred one, and the following ones work as alternatives for exceptions.

Is the standard mandatory?

Not on its own. The foreword notes that ABNT technical documents "are voluntary and do not include contractual, legal or statutory requirements" and that they may be cited in technical regulations, which then set deadlines. The legal obligation comes from article 63 of the LBI.

A practical reading, not a legal one: the LBI asks for international guidelines, and NBR 17225 states that it follows WCAG 2.2 to meet the legislation. That makes it the most direct Brazilian technical reference for planning the work and documenting what was done.

How NBR 17225 relates to WCAG 2.x

WCAG (Web Content Accessibility Guidelines) is published by the W3C, the consortium that publishes web standards. It is organized into four principles (perceivable, operable, understandable and robust), guidelines (13 in version 2.2) and testable success criteria. A success criterion is the verifiable rule, such as "text with a contrast of at least 4.5:1". Each criterion has a level: A, AA or AAA.

The versions in use, according to the W3C:

• WCAG 2.0, published on December 11, 2008;

• WCAG 2.1, published on June 5, 2018;

• WCAG 2.2, published on October 5, 2023 and updated on December 12, 2024. The October 2023 version is identical to ISO/IEC 40500:2025.

The WCAG 2.2 text says that content conforming to 2.2 also conforms to 2.0 and 2.1. Version 2.2 removed one criterion, 4.1.1 (Parsing). The W3C recommends using the most recent version.

NBR 17225 follows the WCAG 2.2 criteria, with some changes in naming. The mapping is not one to one. Criterion 1.1.1 (Non-text Content), for example, became separate items for content images, functional images, decorative images and complex images. And a single item can cite more than one criterion. What changed from WCAG 2.1 to 2.2 is covered in WCAG 2.2 level AA: what changed and how to check it.

On level AAA, the standard's introduction says it is not advisable to adopt it as a requirement for all content, because it cannot always be met. That is why AAA items appear as recommendations.

Other rules that may apply

Decree 5,296/2004, article 47 (public administration)

Article 47 of Decree 5,296/2004 made accessibility mandatory, within twelve months of publication, "on the portals and electronic sites of the public administration" for people with visual impairments (the decree uses an outdated term for persons with disabilities). Paragraph 2 asks for an accessibility symbol on entry pages. Article 48 requires accessibility of sites "of public interest" to obtain public funding. When we checked the Planalto site (Brazil's official legislation portal) in October 2026, article 47 had no note of repeal.

eMAG (federal government)

eMAG (Modelo de Acessibilidade em Governo Eletrônico, the e-Government Accessibility Model) is a set of recommendations for government websites. The current version is 3.1, from April 2014, and it was prepared with WCAG 2.0 in mind. Ordinance No. 3 of May 7, 2007 institutionalized eMAG within the federal IT resource management system (SISP) and made it mandatory for Brazilian government websites and portals.

The Governo Digital portal already lists NBR 17225 among its accessibility references, and at the standard's launch the Department of Digital Public Services of the Ministry of Management and Innovation (MGI) said that federal staff responsible for official websites would receive training to implement it (MDHC). eMAG was made for government websites. For a private company, the obligation is the one in article 63 of the LBI.

The most common failures and how to check each one

The WebAIM Million 2026 automatically analyzed the home pages of the world's top 1 million websites in February 2026. The most common WCAG failures were:

• low-contrast text: 83.9% of pages;

• images without alternative text: 53.1%;

• form fields without labels: 51%;

• empty links (no text saying where they go): 46.3%;

• empty buttons: 30.6%;

• page language not declared: 13.5%.

The sample is global, not Brazilian, and the report itself warns that finding no errors does not mean a page is accessible. An automated tool will not notice, for example, a menu that only opens with a mouse. That is why the table below combines those failures with items that need manual testing, such as keyboard, focus and headings.

Contrast and forms have their own articles: Color contrast: how to meet WCAG criteria 1.4.3 and 1.4.11 and Accessible forms: labels, errors and keyboard.

When the law does not apply, and what is left out

• A company with no headquarters and no commercial representation in Brazil is not in the text of article 63. Whether another rule reaches it is a legal question, outside this article.

• Article 63 speaks of companies and government bodies. A personal website run by an individual, with no business activity, is not mentioned.

• Article 63 covers "internet sites". For mobile apps, ABNT has a separate standard, NBR 17060 (Accessibility in mobile device applications), cited as a normative reference in NBR 17225.

• Third-party content, such as a video embedded from a platform or a social media post, is outside the control of whoever maintains the site. Annex A of NBR 17225 acknowledges this and recommends choosing sources that follow good practices and telling users when there is no barrier-free alternative.

• Level AAA is not required for regular conformance. In the standard, those items are recommendations.

• The accessibility symbol in paragraph 1 is an extra requirement. The main obligation is still an accessible site.

How to evaluate a website's accessibility

1. Run an automated checker on the home page and on the pages that matter most: contact form, search, cart, checkout and login. It quickly finds contrast problems, missing alt, unlabeled fields and undeclared language.

2. Do the W3C Easy Checks: page title, alternative text, headings, contrast, text resizing, keyboard and focus, forms and errors. The W3C warns that they are not definitive and that a page can pass them and still have serious barriers.

3. Use the site with the keyboard alone, from start to finish of a purchase or a sign-up.

4. Listen to the main pages with a screen reader, such as NVDA on Windows or VoiceOver on Mac and iPhone.

5. Fill in the NBR 17225 Annex C checklist (Yes, No or N/A) and keep the result with the date. For full conformance, record the justification for each recommendation not met.

6. Repeat after every relevant change to the theme, plugins, forms or checkout flow.

The W3C is direct about the limits of tools: they cannot determine whether a site is accessible, they only assist the evaluation, and part of the checking requires human judgment. If the plan is to solve everything with a widget installed on the site, read Do accessibility overlays meet the law? first.

How to check your site

The WebVyze free check, with no sign-up, analyzes the home page and points out accessibility and privacy risks under the law. Other free tools are listed at /free-tools.

On the paid plans, WebVyze monitors your sites, links each problem to the matching law and criterion with a fix guide, and marks a problem as resolved only after checking again. No automated check covers every WCAG criterion, and some of them depend on human review. WebVyze does not certify conformance with the LBI or with NBR 17225.