Design & UX

An accessible website is also a better understood website.

The European Accessibility Act has applied since June 2025, Switzerland is revising its Disability Discrimination Act, and 95.9% of home pages still fail automated tests. Accessibility is no longer an optional project.

An accessible website is also a better understood website.

In short

30 seconds
  1. 95.9% of home pages fail automated WCAG tests.
  2. The European Accessibility Act also applies to Swiss companies selling in the EU.
  3. One foundation serves people, search engines and AI agents.

Figures going backwards

Every year, the WebAIM organisation automatically analyses the million most visited home pages on the web. The 2026 edition marks a regression. 95.9% of pages show detectable WCAG errors, against 94.8% a year earlier. The average number of errors per page rises to 56.1, up 10.1%.

The detail is more instructive than the total. Six types of error account for most of the problems, and they have been the same since the study began in 2019: low-contrast text (83.9% of pages), images without alternative text (53.1%), form fields without labels (51%), empty links, empty buttons and undeclared document language.

The deterioration goes hand in hand with growing complexity. A home page now has 1,437 elements on average, 22.5% more in one year. The study also notes that pages using ARIA show on average more errors than the others, a sign of often poorly mastered use.

These automated tests detect only part of the barriers. A page without detectable errors is not necessarily accessible. A page with detectable errors, on the other hand, certainly is not.

What the law says, in Europe and in Switzerland

The European Accessibility Act (Directive (EU) 2019/882) has applied since 28 June 2025. It covers a defined set of products and services, including e-commerce, consumer banking services, e-books, certain passenger transport services and electronic communications. The European standard EN 301 549, which builds on the WCAG, serves as the technical reference. Service micro-enterprises, with fewer than 10 people and annual turnover not exceeding 2 million euros, are exempt.

The text applies to operators offering these products and services on the European market, including when they are established in Switzerland. A Swiss online shop selling in France or Germany is therefore covered for that activity.

In Switzerland, the Disability Discrimination Act (DDA) has applied since 2004 to the services of the Confederation, whose websites must comply with the eCH-0059 standard, aligned with the WCAG. A partial revision, whose dispatch was adopted by the Federal Council in December 2024, notably plans to require private providers of services intended for the public to take appropriate measures to guarantee access to them. The bill is under discussion in Parliament, and organisations of people with disabilities consider it insufficient. Some professional associations mention entry into force in 2027, but the timetable will depend on the parliamentary debates.

Accessibility, search and agents: one foundation

Accessibility is often presented as an additional constraint. It works better as a construction principle, because its requirements overlap with those of other audiences.

A clear heading hierarchy helps a screen reader navigate, and a search engine understand how content is organised. Relevant alternative text makes an image understandable for a blind person, as well as for the systems that index or summarise the page. A properly labelled field lets a person fill in a form with the keyboard, and an AI agent fill it in on a user’s behalf. Google also recommends semantic HTML in its optimisation advice for its generative features, and OpenAI states that the agent in its Atlas browser relies on accessibility information to understand pages.

This finding must not reverse the priorities. Accessibility exists first of all for people with disabilities, around 1.7 million in Switzerland according to organisations in the field. It simply provides one more argument for organisations still hesitating to invest.

The most common errors are also the easiest to fix

The good news in the WebAIM report is that the most widespread errors are also the easiest to avoid, provided they are dealt with in the right place.

Contrast is settled in the design system, with text and background colours validated once and for all and forbidden combinations documented. Alternative texts belong to the CMS and to editorial practice: a dedicated field, a clear instruction on what to describe, the distinction between informative and decorative images. Form labels, button names and document language are guaranteed at the level of components and templates, so that every new page inherits them.

Surface solutions, for their part, do not keep their promises. “Overlays”, those layers that claim to make a site compliant by adding a script, have long been criticised by specialists. In the United States, the Federal Trade Commission sanctioned a vendor of this type of product in 2025 for misleading claims about the compliance it promised.

Building it in rather than catching up

Retrofitting compliance is expensive, because it touches hundreds of pages and components. Building accessibility in from the design stage costs little, because it becomes a property of the system.

In practice, this means defining the target level (WCAG 2.1 AA at minimum, 2.2 preferably) and writing it into the specifications. It then means building it into the design system, testing automatically at every deployment and supplementing with manual tests using the keyboard and a screen reader. Finally, editorial teams need training, and an honest accessibility statement must be published, one that also mentions known limitations.

The WNG view

An accessible website is a better-built website. Clearer for its visitors, more readable for engines, more robust for agents. This convergence changes the status of accessibility, which moves from compliance to quality. With us, the subject runs through all four pillars. It starts in Strategy & experience, with the design of journeys and content. It takes shape in Platforms & technology, at the level of components and the CMS. It is verified in Performance & operations, through continuous checks. Handled this way, it does not slow a project down. It raises its level. If your organisation sells in the EU or is preparing the redesign of a platform, now is the right time to make accessibility a starting criterion rather than an end-of-project fix.

Make complexity work.

This article presents a general framework and does not constitute legal advice.

Frequently asked questions

Is a Swiss company covered by the European Accessibility Act?

Yes, if it offers products or services covered by the directive in the EU, for example e-commerce. Service micro-enterprises are exempt.

What level of accessibility should you aim for?

WCAG level AA is the reference of the European (EN 301 549) and Swiss (eCH-0059) standards. Aiming for WCAG 2.2, published in 2023, lets you anticipate future changes.

Is an automated testing tool enough?

No. It detects part of the errors, often the most frequent ones, but does not replace manual tests with the keyboard and assistive technologies.

Facts checked on 20 October 2026 against the sources below. AI-assisted research; written and proofread by the WNG team.

Sources

  1. [1] WebAIM, “The WebAIM Million – The 2026 report on the accessibility of the top 1,000,000 home pages” (new window)
  2. [2] Directive (EU) 2019/882 on the accessibility requirements for products and services, EUR-Lex (new window)
  3. [3] Federal Bureau for the Equality of People with Disabilities (FBED), overview of current legislative projects (PDF) (new window)
  4. [4] Inclusion Handicap, resolution of the delegates’ assembly, 3 July 2025 (PDF) (new window)
  5. [5] Swiss Retail Federation, “New legal framework for digital accessibility” (new window)
  6. [6] W3C, “Web Content Accessibility Guidelines (WCAG) 2.2” (new window)
  7. [7] OpenAI, “Publishers and Developers – FAQ” (Atlas and accessibility) (new window)
  8. [8] Federal Trade Commission, decision concerning the overlay vendor accessiBe, 2025 (new window)

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