Global Guide to Disability Employment Incentives and Tax Credits

Overview

Governments around the world offer financial incentives to encourage employers to hire and retain people with disabilities. These programs range from direct tax credits and wage subsidies to grants for workplace accommodations and reduced levies. Yet many employers, particularly small and medium-sized businesses, are unaware of the programs available to them or find the application processes confusing.

This guide provides a country-by-country breakdown of the major disability employment incentive programs, eligibility requirements, and how to access them. Amounts and rules change often — always confirm the current position with the agency named before relying on a figure.

United States

Work Opportunity Tax Credit (WOTC)

The WOTC is a federal tax credit for employers who hire individuals from targeted groups, including people with disabilities.

• Status: The IRS states that the WOTC was authorized until December 31, 2025. Unless Congress reauthorizes it, it is not available for employees who start work after that date — check irs.gov for the current position.
• Disability-related groups: Vocational rehabilitation referrals, SSI recipients, and veterans entitled to compensation for a service-connected disability
• Credit amount: The IRS gives a maximum credit ranging from $1,200 to $9,600 depending on the employee hired and the length of employment; the standard maximum is $2,400 for employees working 400+ hours
• Process: Submit IRS Form 8850 to the designated state agency within 28 calendar days of the employee's start date

Section 44 — Disabled Access Credit

A tax credit for eligible small businesses (gross receipts of $1 million or less, or no more than 30 full-time employees, in the preceding year) equal to 50% of eligible access expenditures that exceed $250 but do not exceed $10,250.

• Covers: Removing barriers, qualified interpreters, accessible formats for people with visual impairments, and acquiring or modifying equipment
• Maximum credit: $5,000 per year
• Form: IRS Form 8826

Section 190 — Barrier Removal Deduction

Businesses can deduct up to $15,000 per year for qualified costs of removing architectural and transportation barriers for people with disabilities. Qualifying small businesses can use it alongside the Section 44 credit.

United Kingdom

Access to Work

A government grant program run by the Department for Work and Pensions (DWP) that helps pay for practical support beyond the reasonable adjustments an employer must legally make.

• Eligible costs: Specialist equipment and assistive software, support workers (such as a BSL interpreter or job coach), travel to work where public transport cannot be used, workplace adaptations, and mental health support
• Maximum grant: £69,260 per person per year (for grants awarded from 8 April 2024)
• Who applies: The employee applies. Employers may have to share some costs if the person has worked for them for more than 6 weeks when they apply.
• Changing jobs: Equipment may transfer to a new employer, but awards for support workers or travel do not transfer automatically — the employee must contact Access to Work about the new arrangements
• Process: Apply online through GOV.UK; a case manager contacts the employer and employee, and a workplace assessment may be arranged

Access to Work will not pay for reasonable adjustments that the employer is legally required to make.

Disability Confident Scheme

While not a direct financial incentive, the Disability Confident employer scheme provides guidance, recognition and a structured route to more inclusive recruitment. It has three levels: Disability Confident Committed (Level 1), Disability Confident Employer (Level 2) and Disability Confident Leader (Level 3).

Germany

Eingliederungszuschuss (Integration Subsidy)

A wage subsidy from the Federal Employment Agency (Bundesagentur für Arbeit) or Jobcenter for employers who hire people with disabilities.

• Amount: Up to 70% of the eligible wage, for up to 24 months for people with disabilities and severely disabled people
• Particularly affected severely disabled people: Up to 70% for up to 60 months — or up to 96 months if they have reached age 55
• Process: Apply through the local employment agency or Jobcenter before employment begins; the award and amount are decided case by case

Ausgleichsabgabe (Compensatory Levy)

Employers with at least 20 workplaces must fill at least 5% of them with severely disabled people. Employers below the quota pay a monthly levy per unfilled position. The rates were raised with effect from 1 January 2025 (first payable by 31 March 2026):

• 3% to under 5% fulfilment: 155 EUR per unfilled position per month
• 2% to under 3%: 275 EUR
• Above 0% to under 2%: 405 EUR
• 0% fulfilment: 815 EUR

Lower rates apply to employers with fewer than 40 or 60 workplaces. Hiring severely disabled employees directly reduces or eliminates the levy.

Workplace support from the Integrationsamt

The Integration Offices (Integrationsämter), which collect the levy, can use it to fund technical work aids and in-work support for severely disabled people, and grants to employers for making workplaces suitable for them.

Netherlands

Loonkostensubsidie (Wage Cost Subsidy)

For employees with an occupational disability who cannot earn the minimum wage, the employer applies to the municipality (gemeente) for a wage cost subsidy.

• Amount: Covers the difference between the employee's assessed wage value (loonwaarde) and the minimum wage, up to a maximum of 70% of the minimum wage
• Fast placement: The municipality can use a subsidy of 50% of the minimum wage for up to the first 6 months
• Key advantage: The employee receives a normal salary while the employer is compensated for reduced productivity

No-riskpolis (No-Risk Policy)

For eligible employees with a disability or illness, the UWV (Employee Insurance Agency) pays a Sickness Act (Ziektewet) benefit to the employer if the employee becomes ill.

• Duration: Usually the first 5 years of employment, and in some cases for as long as the employee works
• Effect: The employer also pays no higher sickness or disability insurance premium for that employee

Loonkostenvoordeel (LKV — Wage Cost Benefit)

The LKV is a wage cost benefit that employers claim through the payroll tax return.

• Occupationally disabled employee (new hire): 3.05 EUR per paid hour, up to 6,000 EUR per year, for a maximum of 3 years
• Employees under the job agreement (banenafspraak): 1.01 EUR per paid hour, up to 2,000 EUR per year, for as long as they remain employed

France

AGEFIPH

AGEFIPH manages the disability employment fund for private-sector employers. Its January 2026 offer includes:

• Hiring aid for apprenticeship contracts: Up to 3,000 EUR for hiring a disabled person on an apprenticeship contract of at least 6 months
• Hiring aid for professionalisation contracts: Up to 3,000 EUR, on the same conditions
• Aide à l'adaptation des situations de travail: Funding for adapting work situations for disabled employees
• Aid for adapting training situations, and other support for integration and career progression

OETH obligation

Private and public employers with 20 or more employees must employ disabled workers for 6% of their workforce. If they do not reach 6%, they pay a contribution to Urssaf or the MSA. Since 1 January 2020, all employers must declare the disabled workers they employ.

Cap emploi

Cap emploi advisers provide individual support to employers and disabled employees, including help to keep someone in work when a health problem puts their job at risk.

Canada

Opportunities Fund for Persons with Disabilities

A federal program that funds projects delivered by third-party organisations across Canada, providing persons with disabilities with skills training, self-employment activities, job placements, and other employment supports. One of its goals is to help employers diversify their workforces by creating inclusive and accessible workplaces.

• Who applies: Organisations apply for project funding
• Funding: Varies by project

Provincial Programs

Provinces run their own disability employment programs in addition to federal funding; check your provincial government for current options.

Canada Revenue Agency — Disability Tax Credit

The Disability Tax Credit is a non-refundable tax credit for people with a severe and prolonged impairment (or a supporting family member). It is an individual benefit rather than an employer incentive, but it can reduce the tax a disabled worker pays.

Australia

Employment Assistance Fund (EAF)

Administered through JobAccess and funded by the Australian Government.

• Covers: Workplace modifications and equipment, Auslan services, and workplace assistance and support services such as disability awareness training
• Maximum amounts: A cap of 64,427 AUD (GST exclusive) per application for workplace modifications and equipment; Auslan Level 1 interpreting for work is capped at 13,467.40 AUD (GST inclusive) in a 12-month period
• Who applies: Employers, employees with disability, self-employed workers with disability, some job seekers, or an employment service provider on their behalf

Inclusive Employment Australia

Inclusive Employment Australia replaced the Disability Employment Services (DES) program from 1 November 2025. Government-funded providers connect employers with candidates with disability and provide ongoing support.

• Wage subsidies: Streamlined wage subsidies with a consistent maximum rate of 10,000 AUD

Comparison Table

Getting Started

1. Identify which programs apply to your country and company size
2. Contact your national employment agency or disability employment service for guidance
3. Factor incentives into your business case for disability hiring
4. Apply early — many programs require applications before or soon after hiring
5. Keep records of all expenditures, certifications, and approvals

Resources

• US: IRS WOTC page (irs.gov), JAN (askjan.org)
• UK: GOV.UK Access to Work
• Germany: Bundesagentur für Arbeit (arbeitsagentur.de)
• Netherlands: UWV (uwv.nl), Rijksoverheid (rijksoverheid.nl)
• France: AGEFIPH (agefiph.fr)
• Canada: Opportunities Fund for Persons with Disabilities (canada.ca)
• Australia: JobAccess (jobaccess.gov.au)