The English Accessibility Line Does Not Say Which Japanese Word It Came From
A Japanese supplier sends over their accessibility position, and the English reads cleanly:
Level AA conformance in JIS X 8341-3:2016
That is the National Police Agency’s English page. Here is a different organization, the Mitsubishi group’s portal site, describing what looks like the same thing:
… partial compliance with Conformance Level AAA and compliance with Conformance Level AA of the Japan Industrial Standards (“JIS X 8341-3:2016”)
Two English sentences, two vocabularies. Both pages have Japanese counterparts, and in Japanese the phrase in question is identical on both: 適合レベルAAに準拠. The same three characters, 準拠, are behind conformance on one page and compliance on the other.
That is not a small wobble. There are three of these words in Japanese, they are defined against each other, and which one a supplier used is the entire content of what they are telling you.
The three words, and what separates them
The vocabulary comes from a short document published by the Web Accessibility Infrastructure Committee of the Info-communication Access Council. It exists because the standard itself does not provide a way to say this. The committee is direct about the document’s status (our translation from the Japanese, here and throughout):
This guideline is one that the Info-communication Access Council, Web Accessibility Infrastructure Committee, has defined on its own authority, as a method for stating how web content corresponds to JIS X 8341-3:2016.
Three notations are defined: 準拠 (junkyo), 一部準拠 (ichibu junkyo), and 配慮 (hairyo). The document separates them by what testing is behind them, and by what has to be published alongside.
| Notation | Testing | Publishing the test result | Also required |
|---|---|---|---|
| 準拠 | Test conducted; every success criterion for the target level met | Required | Nothing further |
| 一部準拠 | Test conducted; some of the success criteria met | Optional | Future plans; any partial-conformance note |
| 配慮 | Whether a test was conducted, and its result, are not asked | — | The target conformance level, or the list of success criteria referred to |
Publishing an accessibility policy is required for all three.
The third row is the one to sit with. On 配慮 the document says:
“配慮” may be used to indicate that the web content was produced using JIS X 8341-3:2016. Whether a test was conducted, and its result, are not asked. The target conformance level, or the list of success criteria referred to, shall be displayed.
So the distance between the first word and the third is the distance between a published test result and a published target — the level aimed at, or the criteria consulted, with the testing question left open. In Japanese those are different words. A reader who sees 準拠 knows a test exists and has been published, because the notation is not available otherwise. Even the lightest of the three obliges the organization to put something specific on the page.
Which of them is compliance
Now put the English back beside it.
| Japanese | English observed | Where |
|---|---|---|
| 準拠 | conformance | National Police Agency |
| 準拠 | compliance | Mitsubishi |
| 一部準拠 | partial compliance | Mitsubishi, Digital Agency |
| 配慮 | not observed | — |
Two things are happening at once here, and they pull in opposite directions.
The first is that one Japanese word arrives in English as two different words. The second is that one English word is doing two different jobs. Conformance renders 準拠 on the police agency’s page — and on the Mitsubishi and Digital Agency pages, Conformance Level renders 適合レベル, which is the name of the level and carries no claim about testing at all. A reader who meets the word conformance in isolation cannot tell whether it is the claim or the label.
Inside a single organization the distinctions hold. Mitsubishi’s English separates compliance from partial compliance exactly as its Japanese separates 準拠 from 一部準拠. Nothing is lost within the page. What is lost is the correspondence between pages — and a buyer comparing two suppliers is reading across pages, not down one.
The word with no English
The fourth row of that table is blank, and it did not start out blank on purpose.
We looked for an English rendering of 配慮 on the three organizations’ English pages, on NTT West’s English accessibility page, and through one web search. Zero. The one candidate that surfaced, NTT West’s Consideration will be given in the future to…, is ordinary English about future plans and is not rendering 配慮 at all.
The claim here is only that we did not find one in that range. It is not that no organization has ever written one.
But the consequence for a reader holds either way, and it is sharper than it first looks. If you cannot recognize what 配慮 looks like in English, then an English sentence in front of you cannot be ruled out as one. You are not only unable to determine which of the three levels a statement is. You are unable to determine which of the three it is not.
That is the asymmetry worth carrying out of this. The lightest of the three notations — the one that asks nothing about testing — is the one with no observed English form.
What the guideline says has to travel with the word
There is a clause near the end of the document that changes how all of the above should be read. This is the April 2021 edition:
When using a notation defined in this guideline, it shall be stated explicitly, as in the following example. … Where this statement is not made explicit, the general notation is unrelated to this guideline.
The March 2016 edition — the one two of the three organizations below cite — carries the same clause, with the notation called an additional statement and the conclusion prefaced by 当然ながら, as a matter of course.
The words do not carry their definitions by themselves. The citation is what attaches them. Without it, 準拠 is just a common Japanese word meaning roughly in accordance with, and the document disclaims it.
The citation, then, is what has to survive translation. Look at what happens to it.
The police agency’s English names the document as “JIS X 8341-3:2016 Compliance guidelines for web contents (March 2016)”. Mitsubishi’s English names the same document as “Guidelines for JIS X 8341-3:2016 Conformance Levels of Web Content – March 2016 edition”. Both then link to the same URL. The Japanese title of that document is ウェブコンテンツのJIS X 8341-3:2016 対応度表記ガイドライン, and neither English name is the one it uses, because it does not have one.
The Digital Agency’s English page states partial compliance with JIS X 8341-3:2016 Conformance Level A has been confirmed and does not mention the guideline. Its Japanese page does, naming the April 2021 edition. The sentence a reader gets in English is the same sentence in both languages; the thing that makes its central word mean one of three specific things appears only in one of them.
Where the evidence actually is
The police agency’s English page ends its accessibility section with a link, and the link is labeled:
Test result
Web accessibility test result (in Japanese)
Follow it and the Japanese page has what the English does not: which edition of the guideline the notation follows, the scope (pages built through the CMS, with PDFs and video excluded), the page-selection method named by its clause number (JB.1.1 ウェブページ単位, web page unit), and the list of URIs actually tested.
None of that is hidden. It is one click from the English page, and the English page says where it is and marks the language it is in. Across the three English statements, that parenthesis is the only place where a specific linked document is labeled by language.
It still does not close the gap. A reader who follows it arrives at a Japanese page, and the guideline it cites is a Japanese page as well. We looked for an English edition of the guideline on the committee’s own site: the guideline pages for both editions, /en/, two /en/ paths under the document tree, the sitemaps, and the document index. The /en/ route returns 200 but serves a Japanese article. The others do not resolve or contain no English. On those routes there is no English edition.
The committee does publish translations. They run the other way: the W3C’s WCAG documents rendered into Japanese. Translating into the language and translating out of it are separate pieces of work. The second one has not been done here.
That direction is not unusual among the Japanese documents a foreign brand ends up depending on. The style standard for translating into Japanese states the same orientation in its opening line of purpose: it governs translation into Japanese, and the document itself is Japanese.
What is actually being asked of the reader
Set the pieces down in order.
Three notations exist in Japanese, defined against each other by what testing sits behind them. The document that defines them says its definitions apply only where it is cited by name. It has no English edition on the routes we checked. Each organization writing an English statement therefore chooses its own rendering — of the notation, and of the document’s name. Two of the three name the document; they give it two different English names, neither of which the document uses. One does not name it in English at all.
Every one of those choices is defensible, and none of the three organizations has done anything incorrect. Each English page is an accurate rendering of its own Japanese page. The three pages are simply not rendered against each other, because there is nothing to render them against.
No individual sentence is where the problem sits. What a reader wants from these statements is something none of them was ever in a position to carry. A supplier who has done the most work — tested every criterion, published the result, named the edition, listed the URIs — reaches an English-reading buyer as Level AA conformance, which is four words that a supplier who has done considerably less could also write in good faith.
The practical consequence is narrow and worth stating plainly. An English accessibility statement from a Japanese organization is not a document you can grade. It is a pointer to one, and the one it points to is the Japanese page — where the notation, the edition, the scope, and the test result are either present or absent, and where their absence is legible.
The three words are printed above. A buyer who does not otherwise read Japanese can match them against a page, or ask which one applies and be told in a line of email. Nothing is being withheld in any of this — the English format had nowhere to put it, so it went where there was room.
Settling it while a build is still being scoped, rather than after it ships, belongs on the same list as the other decisions a Japan Readiness Sprint works through.
Sources: ウェブコンテンツの JIS X 8341-3:2016 対応度表記ガイドライン, 2016年3月版 and 2021年4月版 (the document publishes no English name, and we have not supplied one). Info-communication Access Council, Web Accessibility Infrastructure Committee. https://waic.jp/docs/jis2016/compliance-guidelines/201603/ and https://waic.jp/docs/jis2016/compliance-guidelines/202104/ — National Police Agency web accessibility policy (English and Japanese test-result pages), Mitsubishi official site accessibility policy (English and Japanese), Digital Agency accessibility statement (English and Japanese). All pages retrieved 10 September 2026. Quotations from Japanese sources are our own translations; the Japanese original is given alongside where the wording is the point.