Why This Became Urgent
Accessibility used to be discussed as a matter of good practice. It is now, for a large share of businesses, a matter of law with dates attached. Two things changed. The European Accessibility Act began applying to products and services placed on the EU market from June 2025, bringing e-commerce, banking, transport and digital services within a single enforceable framework. And accessibility litigation in the United States has continued at a volume that makes it a commercial risk rather than a theoretical one, particularly for retail and hospitality.
If you sell only to one domestic market, the picture is simpler. If you sell across borders — which most brands with a website now do — the safe assumption is that at least one regime applies to you, and that it points at the same technical standard.
Which Rules Apply To You
The trigger is almost always where your customers are, not where your company or your developers are.
| Market | Framework | Who it covers |
|---|---|---|
| European Union | European Accessibility Act, via national implementations, referencing EN 301 549 | E-commerce, banking, e-books, transport, telecoms and consumer services offered in the EU |
| United States | Americans with Disabilities Act; Section 508 for federal contexts | Applied by courts to commercial websites as places of public accommodation; formal technical rules exist for public bodies |
| United Kingdom | Equality Act 2010; separate regulations for public sector bodies | A duty to make reasonable adjustments for disabled users |
| Canada | Accessible Canada Act and provincial rules such as Ontario's AODA | Federally regulated organisations and, provincially, larger employers |
| India | Rights of Persons with Disabilities Act 2016 and government GIGW guidelines | Government and public-facing digital services, with rising expectations in the private sector |
Note the convergence: almost all of these reference WCAG Level AA either directly or through a standard that adopts it. You do not need a different website per jurisdiction. You need one that meets WCAG AA.
What Level AA Means In Practice
The specification is long. The failures that generate complaints are few, and they repeat.
The issues found on almost every failing site
- Insufficient colour contrast — light grey body text on white is the single most common failure. Normal text needs a 4.5:1 ratio against its background; large text needs 3:1.
- Missing alternative text — decorative images should carry empty alt attributes; informative ones need a description of the information, not the filename.
- Keyboard traps and unreachable controls — every menu, modal, carousel and form must be operable without a mouse, and it must be possible to leave whatever you entered.
- Invisible focus indicators — the focus outline removed for aesthetic reasons, with nothing put in its place, leaving keyboard users with no idea where they are.
- Unlabelled form fields — placeholder text is not a label. It disappears on entry and is inconsistently announced.
- Heading structure used for styling — headings chosen by size rather than hierarchy, which breaks the navigation method most screen reader users rely on first.
- Video without captions, and audio without transcripts.
- Content that breaks at 200 percent zoom or below 320 pixels of effective width.
- Custom components built from generic elements — a clickable div is not a button and does not behave like one.
Most of this is decided at design and build time. That is the point worth internalising: accessibility is cheap when it is a constraint on the design and expensive when it is an audit finding. Our note on accessible design in premium interfaces covers the craft side of the same problem.
Why Overlay Widgets Are Not The Answer
A category of product promises compliance through a single line of JavaScript that adds a floating accessibility toolbar. The pitch is understandably attractive. The reality is that these tools cannot repair the semantics of the underlying page, they often conflict with the screen reader and magnification software a user has already configured to their preference, and a substantial number of US legal claims have been filed against websites that had one installed at the time.
Disability advocacy organisations have been consistently critical of them. If you have one, treat it as unrelated to your compliance position and audit the site underneath it.
How To Assess Where You Stand
Automated tools detect perhaps a third of issues. They are a useful first pass and a poor final answer.
- Run an automated scan across your main templates using a standard tool. This catches contrast, missing alt text and label problems quickly.
- Test with the keyboard alone. Put the mouse away, tab through your homepage, a product or service page, your contact form and your checkout. Can you reach everything, see where you are, and complete the task?
- Test with a screen reader. VoiceOver is built into macOS and iOS; NVDA is free on Windows. Half an hour is genuinely revealing.
- Zoom to 200 percent and check that nothing overlaps, truncates or requires horizontal scrolling.
- Commission a manual audit if you are within scope of the EAA or selling meaningfully into the US, because the criteria that matter most cannot be automated.
What Remediation Costs
Honestly: it depends almost entirely on how the site was built.
- A new build with accessibility as a stated requirement adds very little — it is largely discipline in design decisions and component choices.
- A well-structured existing site usually needs contrast corrections, focus styles, label fixes and some ARIA work. Days to a few weeks.
- A page-builder or heavily templated site is harder, because the markup is generated and you may not control it. Expect constrained results.
- A site built on inaccessible third-party components — carousels, modals, custom dropdowns — may need those components replaced, which is where costs approach a rebuild.
Budget for an audit first. Remediating without one produces activity rather than conformance.
The Commercial Case, Briefly
Setting the law aside: roughly one in six people worldwide lives with a significant disability, and the overlap between accessibility work and general quality is large. Semantic headings, descriptive link text, keyboard operability, captions and fast readable pages all improve search performance and usability for everyone. Older customers with declining eyesight, users on phones in bright sunlight, and anyone watching a video without sound all benefit from exactly the same fixes.
A Reasonable Order Of Work
- Establish which markets you sell into and therefore which frameworks apply
- Run an automated scan and a keyboard test this week
- Fix contrast, focus indicators and form labels — usually the fastest wins available
- Commission a manual WCAG AA audit if you are in scope of the EAA or trading in the US
- Remediate by priority: anything blocking a purchase, enquiry or account action first
- Publish an honest accessibility statement with a contact route and a date
- Add accessibility acceptance criteria to every future design and build brief
- Re-test after significant releases, because sites regress
We build to WCAG 2.2 AA as standard rather than as an upgrade, and we audit existing sites against it where a rebuild is not what you need. If you want to know where your current site stands before deciding anything, we can run an assessment and tell you plainly. This article is general guidance and not legal advice — take advice from a qualified professional in the jurisdictions you sell into.