As of 28 June 2025, the European Accessibility Act (EAA) has required digital services to comply with WCAG 2.1 AA, including services provided by companies outside the EU. An early WCAG audit mitigates the risk of fines, legal claims, and reputational damage.
What is the WCAG 2.1 AA standard?
The WCAG 2.1 AA guidelines (Web Content Accessibility Guidelines) define European standards for digital accessibility. Their goal is to make websites, apps, and digital content usable for people with visual, hearing, motor, or cognitive impairments.
The WCAG guidelines are based on four core principles: content must be perceivable, operable, understandable, and robust. Conformance level AA is considered the legally relevant minimum standard for companies and public authorities. It ensures that digital services are not only technically accessible but also practically usable.
The 4 pillars of digital accessibility (POUR)
|
Perceivable |
Operable |
Understandable |
Robust |
|
Sufficient font sizes and colour contrast |
Fully operable via keyboard |
Semantically correct HTML structure |
Compatible with screen readers |
|
Alternative text for images and media |
Visible focus indicator |
Consistent navigation and clear labelling |
Custom controls are clearly identifiable by screen readers |
|
Subtitles for videos and transcripts for audio content |
Quick access to main content and logical keyboard navigation |
Forms with labels, input purposes, and understandable error handling |
Accessible PDFs with correct tagging structure |
|
Reflow and text spacing (readability at 200% zoom) |
Clear link purposes and multiple ways to find content |
Language declaration for pages and individual text sections |
Clean, valid code without technical errors |
|
Overlays and pop-ups do not block content |
Accessibility statement |
Explicit sanctions and legal ramifications for non-compliance
Since 28 June 2025, digital services in the EU must be implemented accessibly – otherwise, stricter enforcement mechanisms and sanctions apply. Non-compliance can have significant financial consequences. In addition, authorities and competitors are increasingly monitoring adherence to these requirements.
Non-compliance may result in:
- Fines in the five-figure range: National authorities can impose administrative penalties, often ranging between €5,000 and €20,000, depending on the severity of the violation and the size of the company.
- Daily fines for ongoing violations: If a company does not remove accessibility barriers promptly, daily fines of up to around €1,000 may be applied to encourage swift updates.
- Short-term corrective measures: Authorities are empowered to issue correction orders or deadlines for removing accessibility barriers. Late fixes under time pressure are usually significantly more expensive than a structured, proactive implementation.
- Restrictions on sales and usage: For persistent violations, authorities may restrict or block the sale or provision of non-accessible digital products or services within the EU.
- Legal claims and warnings: In addition to government sanctions, civil claims or warning letters from competitors, user groups, or associations are possible if accessibility barriers remain.
- Reputational damage: Beyond financial penalties, a lack of accessibility can lead to loss of trust, negative media coverage, and decreased customer loyalty.
Which companies are affected by the WCAG guidelines?
The requirements for digital accessibility affect far more companies than is often assumed:
- Online shops
- Banks and financial service providers
- Telecommunications companies
- Streaming and e-book platforms
- Online ticketing services
- Websites of public authorities and companies with a public mandate
Exemptions only apply to micro-enterprises with fewer than 10 employees or an annual turnover below €2 million. For all others, WCAG compliance is mandatory.
WCAG checklist: Key points to consider
The following WCAG checklist highlights the elements that need to be checked – but in practice, it is often very complex to implement all requirements correctly. Errors can occur in design, front-end, and content creation. Without experience or professional support, important criteria can easily be overlooked, such as hidden barriers in interactive elements or PDFs that are not correctly structured.
A professional WCAG audit ensures that all points are systematically assessed and prioritised. This not only minimises legal risks but also significantly improves user-friendliness.
Advantages of a WCAG audit
A WCAG audit offers far more than mere compliance. In addition to meeting legal requirements, digital accessibility delivers measurable business value and strengthens the quality, reach, and trustworthiness of digital services over the long term.
- Minimising legal and financial risks: A structured WCAG audit reduces the risk of warnings, lawsuits, and regulatory sanctions. Legal requirements are implemented early to help avoid ongoing fines for non-compliance.
- Positive impact on SEO and technical performance: Digital accessibility promotes clean, semantic code, clear site structures, and alternative content. These factors help search engines index content effectively, which leads to measurable improvements in visibility and rankings.
- Higher conversion rates: Accessible digital services are easier to understand and use. This results in longer session durations, lower bounce rates, and better performance across all user groups.
- Strengthening brand, trust, and credibility: Accessible content positions companies as socially responsible and inclusive, enhancing trust among customers, partners, and public-sector clients.
- Effective follow-up to relaunches, redesigns, or SEO projects: An audit prevents existing or new websites and digital products from violating current or new accessibility requirements – particularly valuable as a follow-up after technical or design updates.
- Continuous monitoring and maintenance: Regular re-audits ensure accessibility is maintained for new content, system updates, or design changes. This helps establish stable, long-term compliance and quality standards.
what. – WCAG 2.1 AA audits for digital accessibility
what. helps companies implement digital accessibility efficiently and in full compliance with the WCAG 2.1 AA guidelines.
Technical UX assessment
Our WCAG audit combines automated tools with manual checks performed by experienced accessibility experts. We not only assess technical compliance but also specifically analyse the actual usability for people with impairments. This approach ensures that both formal and practical barriers are reliably identified.
Our services:
- Manual testing (keyboard navigation, screen reader compatibility)
- Automated testing tools (e.g., axe, WAVE, Lighthouse)
- Testing on mobile devices and desktop
- Review of PDF and document content (if relevant)
Compliance report
Companies receive a clearly structured report with prioritisation based on risk and relevance. All deviations from the WCAG 2.1 AA guidelines are documented transparently and assessed from a legal perspective.
Our services:
- Assessment based on WCAG 2.1 AA
- Evaluation of technical implementation
Implementation recommendations
what. provides concrete, actionable milestones for developers, designers, and content teams. The focus is on efficient implementation without unnecessary rework or system disruptions.
Our services:
- Prioritised actions with estimated effort
- Design guidance (e.g., contrast, layout, interactive elements)
Accessibility statement
Based on the results, what. produces a legally compliant accessibility statement that meets statutory requirements and provides transparency for users and authorities.
Our services:
- Legal details (developed in collaboration with our partners)
- Customisable client template
Our clients receive a full compliance report, prioritised recommendations, and a legally compliant accessibility statement – all measures are implemented by our team. what. reduces legal risks, enhances user experience, and makes your digital services accessible to everyone. REQUEST A QUOTE
Frequently asked questions about digital accessibility & WCAG 2.1 AA compliance
What is digital accessibility?
Digital accessibility means that websites, apps, and digital content are accessible to all users, regardless of physical or sensory impairments. This includes, among others, people with visual impairments, users with motor limitations, or individuals with cognitive disabilities.
Which organisations are subject to WCAG 2.1 AA compliance?
The requirements of WCAG 2.1 AA and the European Accessibility Act (EAA) apply to all companies offering digital products or services in the EU, including foreign businesses. Only very small companies with minimal annual turnover are exempt.
When do the new WCAG guidelines apply?
WCAG 2.1 AA compliance has been mandatory for digital services in the EU since 28 June 2025. From this date, companies must ensure their websites, apps, and digital platforms are compliant. Early implementation through audits and structured measures is strongly recommended to avoid fines, legal warnings, and reputational damage.
Which content must be accessible?
Accessibility applies to all digital content and features that users interact with, including:
- Websites and online shops
- Mobile apps
- PDFs, Word, or Excel documents
- Interactive elements such as forms, tables, or booking processes
- Multimedia content (images, videos, audio)
- Email communications and other digital customer services
What is the typical duration of a WCAG audit with what.?
Initial audit: 8 to 16 hours for smaller websites (up to 20 pages), 24 to 40 hours for large, multilingual websites.
Implementation of corrections: The duration depends on complexity and the CMS used (e.g., WordPress, Shopify, Payload) and typically ranges from 4 to 16 hours.