I am especially referring to e-commerce and to countries where digital accessibility maturity is still lagging behind. We can see that authorities in some countries needed to react – some reacted because of people complaining loudly (like France) and some reacted because of pro activity and preparedness of authorities (like Sweden), at least from what I have concluded by reading summaries of procedures.
This shows a lack of harmonization on other levels than “just” incorporating the European Accessibility Act (which is a directive) into local legislation. Surely no directive can just magically synchronize accessibility maturity across borders (especially borders in our minds), and we can be optimistic about awareness building due to the act itself, but I cannot get rid of a feeling that digital accessibility maturity between member countries varies too much.
Nevertheless, I wanted to add some numbers to my feeling – and here we go.
Short on methodology
I did a quick inventory of “largest” online commerce per EU country, just a few larger ones that are not global, but local (or at least with headquarters in that country).
Then I checked homepages with automatic accessibility testing tools (and some quick manual tests like skip to content link, valid alternative text and validation errors).
Afterwards I checked if they have accessibility statement or page dedicated to accessibility, when it was updated, which standard they mentioned and if they stated conformance what was it.
Summary
I’ve tested 106 home pages, from 27 EU countries. Major online shops, e-commerce, retailers and similar organizations that are in scope of EAA.
Banking and similar financial sites were not a part of this analysis, deliberately (as financial sector show better understanding of compliance and is often also very systematic with it).
Accessibility issues
All of home pages had issues that were detected by automatic accessibility testing tool and all of them had issues when I did manual quick tests. No surprises here actually, please check WebAIM Million (opens in new window) for more coverage.
Best homepages had 11 WCAG issues on average and worst 247 (detected with automatic tests).
Accessibility statements
Any kind of accessibility statement or page dedicated to accessibility was NOT found on homepages in 13 countries. Only 21 homepages out of 106 (about 20%) had such a page easily available (often in footer of the page).
9 accessibility statements claimed partial conformance and only one claimed non-conformance. Others avoided such claims altogether.
3 statements claimed Disproportionate Burden when it comes to multimedia and PDF documents.
7 statements referred to EN 301 549 and 5 statements didn’t mentioned any standard at all.
Missing accessibility statement is a giant red flag
Even if not in scope of any legislation – having an accessibility statement by itself can be a positive signal (unless it is not worth the bytes and just an template copy pasted from somewhere). If you are in the scope of EAA and a year after you do not have an accessibility statement it is a strong signal.
I will not guess about why we do not see accessibility statements or pages for accessibility in major e-commerce from 13 EU countries a year after EAA, but it is telling by itself.
And some authorities publicly announce they will target such organizations first.
Finding so much automatically detected accessibility issues is telling
Once again – automatic accessibility testing is just a signal – but it is still very telling. And with latest signals from search engines like Google – that embrace accessibility tree for the use of AI agents (like it or not) – I hope we will get some spill-over effect that will make the results better. At the same time I hope even more that they will actually solve accessibility issues for people first, and not just whack-a-mole code to pass the test.
Not mentioning standards in accessibility statements
Again, I can not guess, but some statements mention WCAG, some even mention EN 301 549, while others don’t mention a standard at all. EN 17161 Design for All is not mentioned in any statement.
Claiming any kind of conformance and not stating the standard is probably just a marketing strategy.
Sure, authorities need to educate first, but
Web accessibility guidelines and standards are being updated, but they are not anything new. We need education, that is a fact, especially in countries with lower accessibility maturity that didn’t understand public sector was just the first step.
All countries now have some sort of events and trainings. But is it enough? I don’t follow this closely in all member countries, but we can see some progress with AccessibleEU (opens in new window) and that is great.
Seems that act itself should be a motivator for proper resources as well, after some discussion on the pan-European level, I have read between the lines that lots of programs have very limited resources. Again related to per-country accessibility maturity and existing awareness. And politics, as always (will not go into that now).
To conclude – common responsibility
I think we can clearly see that even directives are not enough when people do not understand. Authorities, stakeholders, media, schools, vendors, content providers, marketing, sales, legal, procurement, organizations of people with disabilities,… we, the people… all have a part in this.
It’s just that many of us still don’t know about it. EN17161 Design for All can be our lighthouse here, besides many other sources, together with accessibility maturity sources.
System needs people and people need systems. Otherwise people can burn out and things still remain the same – or even worse – get negatively amplified when we mass-produce code with biased AI on a large scale. Even when we actually could do better, if we knew and if our tools supported us automatically (which they really should).
