Digital marketing

Web accessibility: WCAG 2.2 and the European Accessibility Act

An accessible website works for people who use screen readers, keyboards, voice control or magnification, and for anyone on a small screen in bright sunlight. It is also increasingly a legal requirement, and the changes that help disabled users tend to improve conversion and search visibility for everyone.

What is the European Accessibility Act?

The European Accessibility Act (Directive (EU) 2019/882) has applied since 28 June 2025. It covers a defined list of products and services sold to consumers in the EU, including e-commerce, consumer banking, e-books, electronic communications and passenger transport ticketing and information. It can apply to businesses based outside the EU that serve EU consumers. Microenterprises providing services, those with fewer than 10 staff and an annual turnover or balance sheet of no more than 2 million euros, are exempt from the service requirements.

Enforcement and penalties are set by each member state, so the details vary. If you sell online to EU customers, check your obligations with legal counsel now rather than after a complaint.

WCAG 2.2: the standard behind the rules

The Web Content Accessibility Guidelines are published by the W3C. Version 2.2 became a W3C Recommendation in October 2023 and builds on 2.1 with nine new success criteria. Several matter for nearly every site:

  • Focus Not Obscured: a keyboard-focused element must not be completely hidden, for example by a sticky header or cookie banner.
  • Target Size (Minimum): interactive targets should be at least 24 by 24 CSS pixels, or have enough spacing around them.
  • Dragging Movements: anything done by dragging, such as a slider, must also be possible with a single tap or click.
  • Accessible Authentication: logging in must not depend on a cognitive test like memorising or transcribing a code, unless an alternative such as copy and paste or a password manager is supported.
  • Redundant Entry and Consistent Help: do not make users re-enter information they already gave, and keep help options in a consistent place.

The most common failures we find

  • Low colour contrast between text and background.
  • Images and icon buttons without text alternatives.
  • Form fields without proper labels, and error messages that are not announced to screen readers.
  • Menus, modals and carousels that cannot be used with a keyboard or trap focus.
  • Videos without captions.

A practical way to start

Run an automated scan to catch the obvious issues, but remember that automated tools find only a portion of real problems. Follow it with a manual review of your key journeys, such as finding a product, checking out or submitting a form, using only a keyboard and a screen reader. Fix issues in your design system and components so the fix applies everywhere, publish an accessibility statement with a contact route, and test new features before they ship rather than after.

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