Standards Comparison

    WCAG

    Voluntary
    2023

    W3C standard for accessible web content

    VS

    23 NYCRR 500

    Mandatory
    2017

    NY regulation for financial services cybersecurity

    Quick Verdict

    WCAG provides testable web accessibility guidelines for global inclusivity, while 23 NYCRR 500 mandates cybersecurity controls for NY financial entities. Organizations adopt WCAG for legal defense and UX; NYCRR 500 for regulatory compliance and risk reduction.

    Web Accessibility

    WCAG

    Web Content Accessibility Guidelines WCAG 2.1

    Cost
    €€€
    Complexity
    High
    Implementation Time
    6-12 months

    Key Features

    • POUR principles organize accessibility requirements
    • Testable success criteria at A/AA/AAA levels
    • Technology-agnostic for all web content types
    • Backward-compatible additive versioning model
    • Informative techniques separate from normative criteria
    Financial Services

    23 NYCRR 500

    23 NYCRR Part 500

    Cost
    €€€€
    Complexity
    High
    Implementation Time
    18-24 months

    Key Features

    • Annual CISO/CEO dual-signature compliance certification
    • 72-hour cybersecurity incident notification to NYDFS
    • Qualified CISO with board-level annual reporting
    • Phishing-resistant MFA for privileged and remote access
    • Risk-based third-party service provider oversight policy

    Detailed Analysis

    A comprehensive look at the specific requirements, scope, and impact of each standard.

    WCAG Details

    What It Is

    Web Content Accessibility Guidelines (WCAG) 2.1 is a W3C Recommendation, a technology-agnostic framework for making web content accessible to people with disabilities. Its primary purpose is to provide testable success criteria under POUR principles (Perceivable, Operable, Understandable, Robust), ensuring equal access across visual, auditory, motor, cognitive needs.

    Key Components

    • Four POUR principles with 13 guidelines and 78 success criteria at Levels A, AA, AAA.
    • Normative success criteria; informative techniques, understanding docs, failures.
    • Conformance requires full pages, complete processes, accessibility-supported tech, non-interference.
    • No formal certification; self-assessed claims with optional VPAT/ACR.

    Why Organizations Use It

    • Meets legal benchmarks (ADA, Section 508, EN 301 549, EAA).
    • Reduces litigation risk, expands market to 1B+ disabled users.
    • Improves UX, SEO, conversion; builds reputation.

    Implementation Overview

    Phased program: policy, assessment, remediation via design systems/CI tools, training, audits. Applies to all web publishers; public sector often mandates AA. Ongoing monitoring essential.

    23 NYCRR 500 Details

    What It Is

    23 NYCRR Part 500 is the New York Department of Financial Services (NYDFS) Cybersecurity Regulation, a state-level mandate effective March 2017 with 2023 amendments. It establishes prescriptive, risk-based cybersecurity requirements for financial entities to protect nonpublic information (NPI) and information systems. The approach emphasizes governance, evidence-based outcomes, and phased compliance.

    Key Components

    • 14 core requirements including cybersecurity program, CISO appointment, risk assessments, MFA, encryption, penetration testing, TPSP oversight, and 72-hour incident reporting.
    • Built on risk assessment foundation; annual dual CISO/CEO certification by April 15 with 5-year record retention.
    • Enhanced for Class A Companies (>$20M NY revenue + >2,000 employees or >$1B global revenue) with audits and advanced controls.

    Why Organizations Use It

    • Mandatory for Covered Entities (banks, insurers, licensees in NY); avoids multimillion-dollar fines (e.g., Robinhood $30M).
    • Reduces cyber risk, improves resilience, lowers insurance costs; builds stakeholder trust via robust governance.

    Implementation Overview

    • Phased roadmap: gap analysis, asset inventory, MFA rollout, TPSP contracts, testing; 180 days to 2 years.
    • Applies to NY-licensed financial services; NYDFS exams enforce, no universal certification but evidence repository critical.

    Key Differences

    Scope

    WCAG
    Web content accessibility for disabilities
    23 NYCRR 500
    Cybersecurity for financial info systems

    Industry

    WCAG
    All industries, global web content
    23 NYCRR 500
    NY financial services licensees only

    Nature

    WCAG
    Voluntary W3C technical guidelines
    23 NYCRR 500
    Mandatory NY state regulation

    Testing

    WCAG
    Automated/manual audits, user testing
    23 NYCRR 500
    Annual pen tests, vulnerability scans

    Penalties

    WCAG
    No legal penalties, reputational risk
    23 NYCRR 500
    Fines, consent orders, license actions

    Frequently Asked Questions

    Common questions about WCAG and 23 NYCRR 500

    WCAG FAQ

    23 NYCRR 500 FAQ

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