israeli-accessibility-compliance

What this skill does

# Israeli Accessibility Compliance

## Instructions

### Step 1: Understand the Legal Framework

Israeli web accessibility (negishot) is legally mandatory under the **Equal Rights for Persons with Disabilities Act (Chok Shivyon Zechuyot Le'Anashim Im Mugbaluyot), 1998** and the **Equal Rights for Persons with Disabilities (Service Accessibility Accommodations) Regulations, 2013** (Takanot Negishut LeSherut).

| Regulation | Requirement | Status | Penalty |
|------------|-------------|--------|---------|
| IS 5568 (2017, updated 2020 and 2023) | Israeli accessibility standard, anchored to WCAG 2.0 AA | Mandatory since October 2017; compliance deadline extended to October 2020 for pre-2017 businesses | Up to 50,000 NIS statutory civil damages per violation, without proof of harm |
| Takanat Negishut LeSherut (2013) | Public websites and apps must comply | In effect; covers services provided to the public | Lawsuits + statutory damages |
| Mobile applications | Included in scope per the 2013 regulations; explicitly reaffirmed in later updates | In effect | Same statutory damages |
| Government sites | Must meet IS 5568 Level AA | In effect | Commission oversight + administrative penalty |

**Note on WCAG version.** The statute and regulations reference IS 5568. The dominant reading is that IS 5568, including the September 2023 Part 1 edition, stays legally anchored to **WCAG 2.0 AA**, with WCAG 2.1 alignment being partial or vendor-claimed rather than the legal baseline. Some sources describe IS 5568:2020 as WCAG 2.1 AA, so sources differ. The safe working target is WCAG 2.0 AA plus the Israeli-specific additions below; meeting WCAG 2.1 (and 2.2) criteria on top of that is useful future-proofing but is not the floor the law sets.

**Who must comply:** All public-facing Israeli websites and mobile applications of service providers open to the public, including government agencies, educational institutions, healthcare providers, businesses, and non-profits.

### Step 2: Who Is Exempt

The Service Accessibility Regulations base website-accessibility exemptions on **revenue**, not on employee count. There is no "25 employees" or "300,000 NIS" trigger in the regulations. The exemption tiers are:

| Operator | Exemption |
|----------|-----------|
| Osek patur (VAT-exempt dealer) | Full exemption from website accessibility |
| Average annual revenue under 100,000 NIS | Temporary 3-year exemption, renewable every 3 years as long as average revenue stays at or below 120,000 NIS |
| Average annual revenue 100,000 NIS to 1,000,000 NIS | 3-year exemption for an existing site whose operation began before 26 October 2017; a site built after that date must be accessible |
| Average annual revenue above 1,000,000 NIS | No automatic exemption. The operator must apply to the Commission for Equal Rights of Persons with Disabilities to claim a heavy-burden exemption |

These exemptions (except the heavy-burden application) are automatic and need no approval, but the operator must re-check their revenue every 3 years. Exemption from website accessibility does not exempt the operator from other service-accessibility duties.

### Step 3: Enforcement and Penalties

Two enforcement tracks run in parallel:

- **Civil lawsuit.** A claimant can sue for up to **50,000 NIS in statutory damages without proof of harm**, only needing to show the site is non-compliant. **60-day cure period:** a deviation is not treated as a violation unless the operator was first sent a notice demanding a fix and failed to fix it within a reasonable time, no later than 60 days from receiving the notice. A class-action request for an inaccessible site has no cause of action if no prior fix notice was sent. This is a real defense for operators.
- **Administrative enforcement by the Commission.** Amendment 23 to the Equal Rights Act gave the Commission for Equal Rights of Persons with Disabilities an administrative track: warnings, commitments, accessibility orders, and an **administrative monetary penalty** (izum kaspi). The penalty amount is scaled by the operator's size (micro business up to 2,000,000 NIS turnover, small business up to 20,000,000 NIS, regular business above that or a public authority) and by the cost of the specific accommodation, with a per-day charge while a violation continues. Reductions apply for a clean prior record and for corrective action. This penalty is separate from and on top of the 50,000 NIS civil damages.

### Step 4: The Accessibility Coordinator (Rakaz Negishut)

The Service Accessibility Regulations require a service provider that is a public body, or that employs **25 or more employees**, to appoint one of its staff as an **accessibility coordinator** (rakaz negishut). Note this 25-employee figure is the trigger for the *coordinator appointment*, not for the website-accessibility duty itself, which is universal subject to the revenue exemptions above. The coordinator:

- Gives the public information about the accessibility arrangements of the provider's assets and services.
- Handles accessibility inquiries and complaints from the public.
- Helps the parties responsible for accessibility carry out and maintain the required accommodations.

The coordinator's name and contact details must appear in the accessibility statement (see Step 9).

### Step 5: IS 5568 vs WCAG -- Key Differences

IS 5568 is anchored to WCAG 2.0 AA (sources differ on whether the current edition reaches 2.1) and adds Israeli-specific requirements:

| Area | WCAG 2.0 AA | IS 5568 Addition |
|------|-------------|------------------|
| Language | Declare lang attribute | Must support `lang="he"` with RTL |
| Text direction | Not specified | Must declare `dir="rtl"` for Hebrew content |
| Contrast | 4.5:1 for text | Same, plus contrast check with Hebrew fonts |
| Form labels | Associated labels | Labels must support RTL alignment |
| Error messages | Descriptive errors | Must be in Hebrew for Hebrew sites |
| Accessibility statement | Recommended | Mandatory (Hatzaharat Negishot) |
| Contact info | Not required | Must provide accessibility contact method |
| Bilingual public bodies | Not specified | A government or public body that serves the public in Hebrew and Arabic should make its content accessible in both languages, not Hebrew only |

### Step 6: Set Up Accessible RTL HTML Structure

```html
<!DOCTYPE html>
<html lang="he" dir="rtl">
<head>
  <meta charset="utf-8">
  <meta name="viewport" content="width=device-width, initial-scale=1">
  <title>שם האתר - כותרת הדף</title>
</head>
<body>
  <!-- Skip navigation link (required) -->
  <a href="#main-content" class="skip-link">דלג לתוכן הראשי</a>

  <header role="banner">
    <nav role="navigation" aria-label="ניווט ראשי">
      <!-- Navigation items -->
    </nav>
  </header>

  <main id="main-content" role="main">
    <!-- Page content -->
  </main>

  <footer role="contentinfo">
    <a href="/accessibility-statement">הצהרת נגישות</a>
  </footer>
</body>
</html>
```

Key IS 5568 requirements in this structure:
- `lang="he"` and `dir="rtl"` on the `html` element
- Skip navigation link in Hebrew ("דלג לתוכן הראשי")
- ARIA roles for landmarks
- Hebrew ARIA labels for navigation
- Link to accessibility statement (Hatzaharat Negishot) in footer

### Step 7: Hebrew Screen Reader Compatibility

Test with these screen readers commonly used in Israel:

| Screen Reader | Platform | Hebrew Support | Testing Notes |
|--------------|----------|----------------|---------------|
| NVDA | Windows | Excellent with eSpeak-ng Hebrew | Free, most common in Israel |
| JAWS | Windows | Good with Eloquence Hebrew | Commercial, institutional use |
| VoiceOver | macOS/iOS | Good native Hebrew TTS | Built-in, growing adoption |
| TalkBack | Android | Good with Google TTS Hebrew | Built-in on Android devices |

**Hebrew-specific screen reader patterns:**

```html
<!-- Announce content direction changes -->
<p dir="rtl" lang="he">
  טקסט בעברית עם <span dir="ltr" lang="en