23th of September 2025 is not just any date when it comes to accessibility. At least not in the European Union. Public sector websites published before 23 September 2018 should be compliant by 23 September 2020 (Web Accessibility Directive – WAD), so we are now five years from that important date and let me just reflect on this journey from my experiences.
I like to discuss both the positive and negative to better understand and inform about the overall state. Intention is not to sound grumpy or criticize, but we need honesty and transparency to improve. Promoting just the positive parts can make people forget about things that need to improve and it all makes removing barriers slower or even absent.
Compliance is (still) a unicorn for most…
It seems that the (binary) nature of WCAG 2.X and EN 301 549 makes compliance practically unreachable for most of public sector (and beyond). Even after five years we see websites that ignore accessibility and WAD, at least in most countries. I understand that it’s not easy to be compliant, but I can not understand that new websites and services with obvious lack of focus on accessibility can still be released in 2025.
This drills down to maturity levels, especially of procurement and providers/agencies, but also other stakeholders. A lot could be done to prevent this, mostly requiring accessibility in contracts and also knowing how to test for it – to verify claims (that can often be far from their promises).
Seems that authorities don’t like to enforce WAD
I see that in lot of countries we don’t hear anything about any consequences of being inaccessible in public sector. If we dig in we can quickly see that there are perhaps just a couple of people working with WAD. They need to do a lot of things. Educate, audit, report. And often they seem to be neglected. Powerless. Buried in reports.
Accessibility maturity of country and it’s people is directly reflected here. In countries that understand and have longer experiences with accessibility we quickly notice more dedicated resources, establishing systems and automation. Some are also including organizations of people with disabilities and external accessibility specialist to support them and that should in my opinion be the standard practice. Perhaps even a strict requirement. A couple of people can only do so much…
With WCAG 3, I can already speculate, this will be changed for the better. But it is far from ready and it will take a lot of time before we are there (speaking out of experience as we can see how much can we achieve in 5 years)…
Progress over perfection – it is often not enough
Well, any accessibility progress is good, that can’t be denied. But the speed and range of progress is important as well. In my experience we did make a lot of progress, but pace and scope of progress needs to be faster and wider.
Compliance is mostly unreachable for larger sites (it’s always possible to find issues), but there are some minimal efforts that should just be there automatically. Keyboard support, basic semantics, text color contrasts, responsive design and so on are really so basic that we should not neglected.
Making progress systematically and not just sporadically is a must. Otherwise progress just supports the marketing and not more.
I recognize the economic recession and it’s negative impact on accessibility, but with just some basic knowledge we can do way better and for the same cost. A lot of accessibility barriers can be prevented, we just need to know about them.
WAD makes European Accessibility Act stronger
It’s perhaps obvious to you, but for people that got into accessibility in the summer of 2025 – with European Accessibility Act (EAA) it may not be so obvious. Same agencies that needed to at least try to make things more accessible can now cope better with websites and mobile apps for organizations in scope of EAA and they at least know some basics.
This helps everybody and shows the spill-over effects of WAD that goes beyond geography and not also between sectors.
Accessibility statements from WAD are used in EAA
I’ve noticed that some organizations use same statements for EAA that public sector use for WAD. Some even refer both WAD and EAA in them, even if they actually belong to private sector. Now this can be both positive and negative. As some only copy paste whole statements – probably thinking that they will check the imaginary legal checkbox – and add the EAA just as a keyword.
While others recognized that their local authorities didn’t inform them about what to use and were just practical.
Unfortunately, I still see a lot of accessibility statements that are there just for marketing and potentially legal shield. But when we, for example, use a keyboard on the same site, we quickly see that there are no skip links, no focus outlines and we can’t even get to all interactive elements. This is a hint for all new to accessibility – a simple and quick test that can reveal a lot.
And yes – Artificial Intelligence empowering even more magical overlays
I’ve done some research over the years on the accessibility overlays – because, hey – who wouldn’t want to automatically remove barriers – but was quickly “put back to ground” when I tested them and often experienced even more barriers because of them. And in the last five years (not only because of WAD, to be fair, but also because of it) I’ve seen that a lot of organizations really want to take a shortcut, just use some AI and get over it.
Sure, AI helps with accessibility, if it is used correctly, with proper context, with human “in the loop”, but total automation is (still) not here. I’ve seen use of overlays even in countries with very high accessibility maturity (exceptions) and overlays are still the favorite thing to do in countries with low accessibility maturity.
Seems that WAD (and EAA) needs to make it clear that accessibility overlays are not the solution. They tried a bit, but I miss a joint statement, cross-borders. People are ignoring organizations of people with disabilities, accessibility specialists and others that advocate against overlays and I guess we need a clear and synchronized communication in all member states obviously.
It took five years to get universities onboard
At least it seems like this from where I am. WAD was not something new in 2020. And universities could start implementing accessibility in their programs before 2020. But it took them 5 more years. So now they are finally “signing the intention” to integrate accessibility. Better late than never.
But – let me wrap it up here – imagine if they did that 5 years ago. Or – even better – imagine when they did that when WCAG 2.0 was a recommendation… What would that do for the accessibility maturity? Without doubt we would have way less barriers now!
