The 2026 State of Digital Accessibility and UX Quality Across European Industries

A cross-industry benchmark of 154 web pages across 53 companies in six sectors, conducted in the six months following the European Accessibility Act becoming enforceable.

Download the full PDF report → state-of-digital-accessibility-2026-eu.pdf

#Executive Summary

Six months after the European Accessibility Act (EAA) took effect, we attempted to audit 198 web pages belonging to 53 companies headquartered in the EU and EEA across six industries. The results are sobering.

88% of pages did not meet basic accessibility thresholds. The average accessibility score across all industries is 15 out of 100. Twenty-four percent of pages scored zero — the audit engine could not identify a single meaningful accessibility measure in place.

33% of pages scored below 50 overall. When we extend the analysis beyond accessibility to include usability, clarity, information architecture, conversion design, semantic markup, and keyboard navigation, the picture improves only slightly.

22% of target sites blocked automated auditing entirely. Forty-four pages across 15 EU-headquartered companies returned HTTP 403 (Forbidden) or 429 (Too Many Requests) to our headless browser — the same class of tool that regulators and compliance teams rely on to verify EAA compliance. E-commerce, the sector facing the most active enforcement, had the highest block rate at 59% — eight of fourteen e-commerce companies we attempted to audit blocked our engine entirely.

This report presents the methodology, cross-industry findings, per-industry analysis, and recommendations for organizations preparing for or responding to EAA enforcement.

#Key Findings at a Glance

#Methodology

#Audit Engine

All audits were performed using the VertaaUX CLI (v0.4.0–0.5.2) in basic mode. The engine runs a headless Chromium browser against each target URL and evaluates the rendered page across seven weighted categories:

Each category is scored 0–100. The overall score is the weighted average.

#Sample

• Geography: EU member states and EEA (Norway). Only companies headquartered in the EU or EEA are included. Non-EU companies (UK, Switzerland, US-headquartered) were excluded to maintain geographic consistency with the EAA's jurisdictional scope.
• Industries: E-commerce, Fintech, Healthcare, SaaS/B2B, Travel, Public Sector
• Companies: 8–14 per industry (including blocked), selected by market position and EU user base, all EU/EEA-headquartered
• Pages per company: 3 (homepage, conversion page, flow page)
• Total target audits: 198
• Successful audits: 154 (78%)
• Blocked by bot protection: 44 (22%)
• Audit period: April 2026

#Limitations

• Only companies headquartered in the EU or EEA (Norway) are included. UK, Swiss, and US-headquartered companies were excluded to maintain jurisdictional consistency with the EAA's scope.
• Audits capture a single point in time. Scores may fluctuate with deployments.
• Basic mode provides broad coverage but not the depth of a manual WCAG audit. Automated tools catch an estimated 30–57% of WCAG issues (Deque, 2021); the remaining issues require manual review.
• Bot protection prevented 44 of 198 audits from completing, creating significant sampling bias in e-commerce (59% blocked) and travel (27% blocked).
• Scores reflect automated analysis only. Manual expert review would identify additional issues.
• Individual company names are anonymized in the public version of this report. Companies included in this study may request a re-audit or submit corrections via research@vertaaux.ai.

#Cross-Industry Results

#Overall Scores by Industry

Public sector leads — likely due to existing government accessibility mandates (EN 301 549, EU Directive 2016/2102). E-commerce trails by 13 points despite being the first industry to face EAA enforcement action.

#Category Scores by Industry

Two patterns emerge:

1. Clarity scores are universally high (78–87). European companies know how to write clear marketing copy and build scannable layouts. This is not where they fail.
2. Accessibility and semantic markup are universally catastrophic (10–24 on accessibility; 11–67 on semantic). Public sector stands out in semantic markup (67) because government sites tend to use proper HTML5 elements. Every other industry scores below 30 on semantic markup and below 25 on accessibility.

#The Accessibility Crisis in Numbers

• 88% of pages scored below 50 on accessibility. In a framework where 50 already indicates significant gaps, nearly nine in ten major European websites did not reach that threshold.
• 24% of pages scored zero. No meaningful ARIA attributes, no alt text, no form labels, no color contrast compliance detected.
• SaaS/B2B scored lowest at 10 average. The companies building tools for other businesses — including productivity, HR, and CRM platforms — had the weakest accessibility scores of any sector.

#Issue Volume

Across 154 pages, the audit engine identified 25,547 issues — an average of 166 issues per page. Some pages exceeded 1,000, driven by repeated patterns like missing alt text on product image grids or unlabeled form inputs across dynamic components.

#The Compliance Paradox: When Security Blocks Accessibility

Of our 198 target audits, 44 returned HTTP 403 (Forbidden) or 429 (Too Many Requests). The sites' Web Application Firewalls (WAFs) — typically Cloudflare Bot Fight Mode or Akamai Bot Manager — blocked the headless Chromium browser used by the audit engine.

This is the same class of tool used by:

• Accessibility compliance auditors
• Automated WCAG testing frameworks (axe-core, pa11y)
• Regulatory enforcement agencies
• Disability rights organizations

#Block Rates by Industry

E-commerce — the sector where French disability rights organizations filed emergency injunctions against four major retailers in November 2025 — has the highest block rate. 59% of the EU e-commerce sites in our sample actively prevent automated accessibility auditing — eight of fourteen companies we attempted to audit returned HTTP 403 before analysis could begin.

#Block Rates by Country

Germany leads in absolute blocking — driven by companies across e-commerce, SaaS, and travel sectors using aggressive WAF configurations.

#The Implication

Bot protection serves legitimate security purposes. But the current default configurations of major WAF providers create a paradox: they block the exact tools that organizations and regulators need to verify accessibility compliance.

Blocking automated audit tools does not alter an organization's obligations under the EAA. It does, however, make independent verification more difficult — for the organization's own compliance teams as much as for external assessors.

#Industry Profiles

#E-commerce — Mean 47.6 | Accessibility 13 | Pages 16 of 39 (59% blocked)

E-commerce is the worst-performing industry in our study and the most actively blocking automated audits. The 16 pages we successfully audited reveal:

• Product grids drive issue counts. Pages with product listings often exceed 500 issues due to repeated missing alt text and unlabeled interactive elements across every product card.
• Clarity is the bright spot (85). These sites know how to communicate value propositions and make CTAs visible — their marketing teams are effective. The failure is in implementation, not intent.
• Semantic markup is nearly absent (11). Few e-commerce sites use proper heading hierarchies, landmark regions, or structured HTML5 elements.

This industry faces the most immediate EAA enforcement risk. France, Sweden, and Norway have already initiated cases against retailers.

#Fintech — Mean 54.7 | Accessibility 21 | Pages 27 of 30

Fintech scores at the overall average despite handling sensitive financial flows where accessibility failures directly impact user trust and regulatory compliance.

• Keyboard navigation is relatively strong (66) — likely because payment and authentication flows require form-level tab ordering.
• Semantic markup is poor (20). Modern JavaScript frameworks (React, Next.js) used by fintechs often output div-heavy markup that lacks semantic structure.
• The gap between homepage clarity (83) and flow page usability varies significantly across companies, suggesting inconsistent design system application.

#Healthcare — Mean 52.3 | Accessibility 12 | Pages 29 of 32

Healthcare has the second-lowest accessibility score — concerning given that health platforms serve users with the highest proportion of accessibility needs.

• Accessibility is the worst category (12). Medical apps and patient-facing portals show minimal ARIA implementation and poor form labeling — exactly the patterns that prevent users with disabilities from managing their health independently.
• Norway's publicly reported daily fines against a major health app with ~500K users demonstrate that enforcement is already active in this sector.

#SaaS/B2B — Mean 54.2 | Accessibility 10 | Pages 30 of 33

SaaS has the lowest accessibility score of any industry at 10 — despite building products used by millions of knowledge workers, including users with disabilities.

• Usability scores are the highest of any industry (73). These teams know how to build usable interfaces. The accessibility gap is a knowledge and priority issue, not a capability issue.
• Keyboard navigation is the weakest of any industry (52). Ironic for tools that power desk-based work.
• Clarity is excellent (87), reflecting the marketing sophistication of SaaS companies.

#Travel — Mean 56.5 | Accessibility 12 | Pages 24 of 33 (27% blocked)

Travel performs above average overall but suffers from the second-highest block rate and complex booking flows that amplify accessibility failures.

• Information architecture is the worst of any industry (47). Travel sites with multi-step booking, search filters, and dynamic pricing create complex navigation that the audit engine flags.
• Semantic markup splits sharply between traditional travel companies (higher) and marketplace startups (lower).

#Public Sector — Mean 61.8 | Accessibility 24 | Pages 28 of 31

Public sector leads overall but the 24-point accessibility score is still a failure — and public sector sites have been legally required to meet accessibility standards since EU Directive 2016/2102 (2018 enforcement).

• Semantic markup is the standout (67) — dramatically higher than any other industry. Government sites use proper HTML5 landmarks, heading hierarchies, and structured content.
• This proves the gap is closable. Public sector demonstrates that when semantic markup is prioritized (even partially), scores improve significantly.
• The remaining accessibility gap is in ARIA implementation, form labeling, and dynamic content — areas where even mandated sites struggle.

#Interpretation: What the Data Suggests About EAA Readiness

The following section reflects the authors' interpretation of the benchmark data. It does not constitute a compliance assessment of any individual company or sector.

The European Accessibility Act became enforceable on June 28, 2025. Based on this benchmark:

#Very few organizations appear ready

• 88% of pages did not meet basic accessibility thresholds
• The best-performing industry (Public Sector) still averages 24/100 on accessibility
• Even companies with strong UX teams (high usability, high clarity) have near-zero accessibility scores

#The knowledge gap appears to be the primary barrier

The data shows a clear pattern: companies that score well on usability (67 average) and clarity (84 average) score poorly on accessibility (15 average). These are not teams that lack design capability. The gap suggests a deficit in accessibility-specific knowledge and tooling in development workflows.

#Enforcement pressure is likely to be asymmetric

• E-commerce and travel appear to face the highest near-term risk — low scores, active enforcement activity, and the highest bot-blocking rates that prevent self-assessment
• SaaS companies may be underestimating exposure — the lowest accessibility scores but minimal enforcement pressure to date
• Public sector has a head start but remains far from threshold despite a 6-year mandate

#Recommendations

#For companies

1. Run an automated baseline audit now. You cannot fix what you don't measure. Automated tools catch 30–40% of WCAG issues — enough to identify the most critical gaps.
2. Start with semantic markup. The data shows this is the single highest-leverage category. Proper headings, landmarks, and HTML5 elements improve scores across multiple categories simultaneously.
3. Integrate accessibility into CI/CD. Manual audits are expensive and instantly stale. Automated quality gates catch regressions before they ship.
4. Review your WAF configuration. If your bot protection blocks accessibility auditing tools, you are preventing your own compliance team — and potentially regulators — from assessing your site.

#For regulators

1. Publish technical guidance on WAF compatibility. Current bot protection defaults conflict with automated accessibility testing. Industry needs clear guidance on allowlisting audit tools.
2. Prioritize e-commerce and healthcare enforcement. These sectors have the lowest scores and the highest user impact.
3. Recognize automated auditing as a necessary compliance tool. Organizations that block automated auditing are not more compliant — they are less auditable.

#For the accessibility community

1. Semantic markup is the wedge. It's the most teachable, most automatable, and most impactful category. Start advocacy here.
2. The usability-accessibility gap is an opportunity. Companies with high usability scores have the design talent to solve accessibility — they need education, not capability.
3. Bot protection is becoming a systemic barrier to the automated testing tools that scale accessibility compliance. This needs industry attention.

#About This Study

This study was conducted by VertaaUX, an automated UX and accessibility audit platform. The audit engine scores websites across seven categories using a combination of rule-based analysis and heuristic evaluation in a real browser environment.

The full dataset (anonymized) is available for research purposes upon request.

• Audit engine: VertaaUX CLI v0.4.0–0.5.2, basic mode
• Data collection: April 2026
• Analysis and report: April 2026
• Download PDF: state-of-digital-accessibility-2026-eu.pdf
• Questions / corrections: research@vertaaux.ai

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This report presents findings from automated analysis and does not constitute legal advice or a compliance assessment regarding the European Accessibility Act. Scores reflect automated heuristic evaluation at a single point in time and should not be interpreted as definitive measures of legal compliance. Organizations should consult qualified accessibility professionals and legal counsel for compliance guidance. Companies referenced in this study may request a re-audit or submit corrections via research@vertaaux.ai.