© Recite Me 2025
INDUSTRY REPORT
Digital Accessibility and the EAA: A Compliance Check on 100 Major Companies Serving the EU
An Evaluation of EU-Market Leading Corporations Against WCAG 2.2 Standards
Prepared: July 2025
Executive Summary
The European Accessibility Act (EAA) came into force in June 2025, making digital accessibility a legal requirement for companies operating across the EU. This represents a historic milestone: accessibility is no longer an optional enhancement, but a fundamental standard for delivering inclusive online services.
To assess readiness, we evaluated the public-facing websites of 100 of Europe’s leading brands across key sectors such as retail, banking, telecom, travel, and technology. Together, these organisations set the tone for how accessibility will be adopted at scale.
Our findings show a mixed picture. While many companies still have progress to make before meeting minimum compliance thresholds, encouraging signs are also emerging. Several brands demonstrated strong accessibility foundations, and across the board we found that most high-impact issues can be addressed quickly with the right tools, training, and governance in place.
The takeaway is clear: accessibility compliance is an achievable goal. With awareness rising, regulations now in effect, and practical fixes within reach, Europe’s biggest brands are in a strong position to lead by example closing the digital equity gap and unlocking better experiences for all customers.
Small changes can make a big difference
Accessibility isn’t about perfection, it’s about steady, sustainable improvement.
Meaningful change is within reach today.
This report offers a clear view of how accessible the top brands selling into Europe really are – highlighting the most common barriers and showing how small steps can lead to big change. With the June 2025 deadline now behind us, organisations must act quickly to ensure compliance and provide equal access for all.
Key Findings
0% of the websites passed WCAG 2.2 AA on their homepage.
The most common failures included low contrast text, missing alt text, and unlabelled form inputs.
68% of websites lacked a fully compliant accessibility statement.
75% of sites scored an “Advanced” reading level, presenting barriers to users with dyslexia, low literacy, or cognitive impairments.
Technology and telecom brands are leading the way
This report details the most common failures, ranks the most accessible companies in our dataset, and provides practical steps businesses can take to meet EAA requirements.
DISCLAIMER
This report provides a benchmark overview of public-facing website home pages of 100 of the top companies selling goods and services into the EU, based on automated scans conducted in July 2025. Results reflect accessibility issues detectable by technology at the time of testing and are intended for informational purposes only. They should not be interpreted as a definitive statement of legal compliance.
See Methodology & Scope for full details.
See Methodology & Scope for full details.
Top 20 Accessible Company Websites
While none of the 100 websites evaluated achieved full compliance, accessibility performance varied significantly between companies and industries. This table highlights the 20 best-performing websites in the dataset, offering a practical benchmark for others working to align with the European Accessibility Act.
| Rank | Company | A errors | AA errors | AAA errors | Readability |
| 1 | Adobe | 1 | 1 | 0 | Easy |
| 2 | IKEA | 4 | 0 | 0 | Intermediate |
| 3 | M Group Services | 0 | 1 | 12 | Advanced |
| 4 | Vodafone (UK) | 3 | 0 | 11 | Advanced |
| 5 | Barclays | 4 | 0 | 30 | Advanced |
| 6 | JCB | 9 | 1 | 5 | Advanced |
| 7 | Imperial Brands | 6 | 2 | 17 | Advanced |
| 8 | Anglo American | 11 | 0 | 18 | Advanced |
| 9 | Collinson | 4 | 3 | 10 | Advanced |
| 10 | RSM International | 24 | 6 | 65 | Advanced |
| 11 | Velux | 36 | 1 | 9 | Advanced |
| 12 | Halma PLC | 46 | 0 | 21 | Advanced |
| 13 | McLaren Group | 7 | 12 | 49 | Advanced |
| 14 | Sainsbury's | 12 | 1 | 13 | Advanced |
| 15 | Zara | 2 | 41 | 0 | Easy |
| 16 | ASDA Stores | 8 | 1 | 7 | Intermediate |
| 17 | Tesco | 37 | 0 | 34 | Advanced |
| 18 | Santander | 6 | 1 | 14 | Advanced |
| 19 | Reckitt Benckiser | 10 | 13 | 35 | Advanced |
| 20 | Vodafone (Group) | 23 | 23 | 20 | Advanced |
These rankings were derived based on a combined score reflecting the number of WCAG errors alongside the readability of on-page content. Readability level was assessed using the following criteria:
Easy: Comparable to a reading age of 11–12 years old. Suitable for the general public, including users with lower literacy or cognitive disabilities.
Intermediate: Reading age of 13–15. Accessible to most users, but may introduce comprehension challenges.
Advanced: Reading age of 16+. Likely to present barriers for users with dyslexia, cognitive impairments, or non-native language proficiency.
Important to note: While the companies listed above performed better than their peers, most still presented critical barriers that would prevent some users from successfully navigating or completing key tasks.
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Key Observations
The top performers signal where progress is happening first, offering valuable lessons for others to follow. But what separates the companies that are getting accessibility right from those that are falling behind?
The best websites combined solid technical foundations with inclusive content and structure, proving that accessibility doesn’t have to come at the expense of brand, innovation, or user experience. Here is an overview of the primary insights we uncovered.
1. Technology and Telecom Brands Are Leading the Way
Companies in the tech and telecom sectors consistently demonstrated accessibility leadership. For example, Adobe and Vodafone UK both appear in the top 4. They stand out for cleaner code, better semantic markup, and more consistent adherence to accessibility basics. And that’s likely no coincidence. These industries tend to have stronger digital governance and mature design systems, which translates into more accessible interfaces. They’re also more likely to serve regulated or infrastructure-critical services, which raises the stakes for inclusion.
2. Multilingual Accessibility Statements Are a Mark of Maturity
Among the highest-ranked companies, we observed a higher frequency of accessible, multilingual accessibility statements. These were not just boilerplate policies, but real-world support solutions that include alternate contact options, keyboard navigation tips, and guidance for assistive tech users. By contrast, many of the bottom-ranked companies offered no accessibility statement at all, or buried it under obscure links or jargon-heavy PDFs.
3. Structured HTML and Keyboard Support Separate the Good from the Bad
Well-structured HTML and keyboard-friendly interfaces were far more common in higher-ranked sites. For example, Adobe, IKEA, and Vodafone (UK) all used semantic markup, skip links, and logical tab ordering to support non-mouse users. In contrast, many high-end retail and travel sites still suffer from visual-first builds featuring modals without focus traps, inaccessible carousels, and navigation menus that break under keyboard use.
4. Readability Is Still a Barrier – Even for the Best
Even among the top 20 performers, a staggering 16 used advanced reading levels that exceed the comprehension of many EU citizens. Over 75% of all websites presented content at an advanced level equivalent to college or university reading standards. This creates invisible friction for users with dyslexia, cognitive disabilities, lower literacy, or non-native speakers.
Compliance Breakdown
The European Accessibility Act doesn’t directly codify WCAG. However, it references EN 301 549, which incorporates WCAG 2.1 Level AA for websites and apps.
For this audit, we used WCAG 2.2 Level AA as the benchmark because it reflects the most current and forward-looking criteria, addressing emerging user needs such as cognitive accessibility and mobile interaction patterns. It also reflects where litigation trends and industry best practices are already heading. In short, if Europe’s largest companies are not already meeting WCAG 2.2 AA, they are not fully meeting the spirit of the EAA.
| Compliance Level | Number of Companies | % of Total |
| A | 0 | 0 |
| AA | 0 | 0 |
| AAA | 0 | 0 |
| Non-Compliant | 100 | 100% |
Despite widespread investment in digital platforms, not a single company in our dataset achieved full compliance with WCAG 2.2 Level AA. Some came close, but accessibility gaps remain systemic, representing significant business risk.
Most Common Accessibility Failures
The 100 websites we audited did not fail randomly. A consistent pattern of recurring accessibility errors emerged — many of which are the same barriers that appear repeatedly across sectors, regardless of company size or digital maturity. These are the most widespread failures we uncovered:
Top 6 Failures Identified Across 100 Corporate Websites
| Issue | WCAG Criterion | % of Sites | Technical Reference |
| Low Contrast Text | 1.4.3 (AA) | 79% | G17, G18 |
| Missing alt text for images | 1.1.1 (A) | 76% | F65, H37 |
| Unlabeled form inputs | 3.3.2 (A) | 68% | F68, H44 |
| Empty Links or Buttons | 2.4.4 / 4.1.2 (A) | 63% | H91, G108 |
| Missing language Attribute | 3.1.1 (A) | 66% | F40 |
| Complex Readability | 3.1.5 (AAA) | 74% | G153, G86 |
These are not edge cases stemming from poor code structure. Most are basic, preventable EAA compliance issues. What’s more, these failures directly undermine user experiences because they interfere with core functionalities. Critically, more than half of the errors listed above can be fixed quickly, underscoring how small improvements could have a major impact on digital inclusion.
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Deep Dive: Critical Issues
While every accessibility issue creates friction, some failures have an outsized impact on both usability and compliance. The following commonly occurring barriers are among those most likely to trigger EAA enforcement or litigation. They also represent fundamental issues that prevent customers from completing essential tasks such as making a purchase, signing into an account, or requesting support.
1. Low Contrast Text
❌ Failure: 1.4.3 (AA)
Text that blends into its background is difficult to read for users with low vision, colour blindness, or anyone in glare-heavy environments (like using a mobile phone outdoors).
Impact on user experience:
Product details, CTAs, and legal disclaimers are often unreadable.
Fix:
Ensure foreground and background colours meet the minimum 4.5:1 contrast ratio.
CSS
color: #222; background: #fff;
2. Missing Alternative Text
❌ Failure: 1.1.1 (A)
Images without alt text exclude screen reader users from vital information.
Impact on user experience:
On retail sites, this often means customers cannot access product descriptions. In finance or telecom, it means icons and navigation graphics provide no context.
Fix:
Add descriptive alt attributes to all relevant images, or use alt=”” for decorative graphics.
HTML
<img decoding="async" src="handbag.jpg" alt="Black leather handbag with gold clasp" />
3. Unlabeled Form Inputs
❌ Failure: 3.3.2 (A)
Forms are central to customer journeys and purchase transactions, but without proper labels or programmatic associations, screen reader users don’t know where to enter what information.
Impact on user experience:
Without programmatically associated labels, screen reader users hear only “edit field”, which provides insufficient context to complete checkout pages, login portals, and applications.
Fix:
Associate <label> elements with each input using for and id attributes.
HTML
<label for="card">Card Number</label>
4. Missing Language Declaration
❌ Failure: 3.1.1 (A)
Without a declared page language, screen readers cannot correctly interpret content. This is particularly damaging in the EU, where multilingual sites are common.
Example:
For example, a French-language page without lang=”fr” may be read with an English pronunciation engine — making it unintelligible.
Fix:
Add a language attribute to the <html> element and declare changes inline where needed.
HTML
<p lang="en">Terms and Conditions (English)</p>
These barriers present repeatedly across the dataset, suggesting that accessibility is still being treated as a bolt-on rather than a built-in. The fact that 11% of companies were only a handful of fixes away from compliance shows that meaningful progress is possible. However, that would require accessibility to be embedded into design, content, and engineering practices, rather than being treated as an afterthought.
Speak to an Accessibility Expert
Don’t wait to build accessible online environments for your customers. At Recite Me our team of accessibility experts can help you create more inclusive digital spaces.Reach out through our contact form to see how we can help you.
Industry Insights
While accessibility gaps were present across all of the websites we audited, specific patterns emerged when comparing industries. The following sector-level trends reveal both where progress is being made and where risk is most acute.
| Industry | Avg A Errors | Avg AA Errors | Avg AAA Errors | Common Issues |
| Technology & Telecom | 12 | 4 | 11 | Readability, unlabeled forms |
| Retail & eCommerce | 26 | 10 | 22 | Missing alt text, low contrast |
| Banking & Finance | 20 | 9 | 24 | Unlabeled forms, dense legal text |
| Travel & Hospitality | 28 | 12 | 25 | Keyboard traps, missing language declarations |
Standout Industry Insights
Technology & Telecom: Leading but Not Perfect
The high-ranking trend across the industry demonstrates that internal digital maturity is a predictor of accessibility success. In other words, companies with robust engineering teams and platform control are outpacing those reliant on legacy CMSs or marketing-first design. However, even so, all fall short of full compliance, often let down by content readability or unlabeled form fields.
Retail & eCommerce: Visual First, Accessibility Last
Most companies prioritise sleek, image-heavy designs that lack alt text or proper keyboard support, leaving entire purchase journeys inaccessible to disabled users. Even mass-market retailers, while slightly stronger, often struggle with contrast issues and complex checkout flows. Structured markup and basic keyboard navigation are often the difference between a usable site and one that locks out entire user groups.
Banking & Finance: Security Without Usability
Banks and insurers in the dataset generally provided secure, robust platforms, but often overlooked accessibility basics. Login and authentication forms were frequently missing labels, while dense legal text made them difficult to read. The result is a series of accessibility barriers for customers who already face challenges navigating financial products.
Travel & Hospitality: A Consistent Weak Spot
Airlines and booking platforms were among the most problematic of websites in our audit. While most offered multilingual options, many were undermined by missing language declarations and complex, modal-heavy booking journeys that were incompatible with keyboard-only navigation. For a sector already covered by stricter EAA obligations, this is a major red flag.
How to Get Started on Easy Fixes
More than half of the accessibility issues we identified could be resolved with small, targeted updates. These are not deep engineering challenges. Rather, they are low-effort improvements that deliver immediate value for millions of users while also reducing compliance risk under the European Accessibility Act.
The table below outlines a focused list of high-impact fixes that can typically be implemented quickly, without requiring a design overhaul or deep backend work.
Fix
Why it Matters
Estimated Effort
Add lang=”en” to <html>
Ensures screen readers apply correct pronunciation rules, especially critical for multilingual EU sites.
Very Low (<1 hour)
Add missing alt text to images
Provides context for product images, navigation icons, and infographics for screen reader users.
Low (1–2 hours)
Improve text contrast
Makes essential content readable for users with low vision, colour blindness, or in glare-heavy environments.
Low (2–3 hours)
Fix empty buttons/links
Prevents assistive technologies from announcing “button” or “link” with no context, improving navigation.
Low (2–4 hours)
Add visible focus indicators
Allows keyboard users to see exactly where they are on a page, essential for checkout and login flows.
Low (2–4 hours)
Label all form inputs
Enables screen reader and keyboard users to complete transactions, logins, and applications.
Medium (half–1 day)
These quick wins can dramatically improve usability for users with visual, motor, or cognitive disabilities. They also enhance overall user experience for all customers, including those browsing on mobile devices or in low-bandwidth conditions. Additionally, addressing these fixes early sets a strong foundation for broader accessibility work, demonstrating proactive compliance momentum, should your website be flagged for review.
Speak to an Accessibility Consultant
Don’t wait to build accessible online environments for your customers. At Recite Me our team of accessibility experts can help you create more inclusive digital spaces. Reach out through our contact form to see how we can help you.
Further Recommendations: A Practical Roadmap for Improvement
Creating an inclusive digital experience for all users doesn’t require a complete rebuild, and most companies are far closer to compliance than they realise. What’s needed is a structured, step-by-step approach that prioritises the highest-impact changes first, embeds accessibility into everyday processes, and maintains momentum over time.
Here’s a practical roadmap businesses can follow to accelerate progress toward full EAA compliance.
STEP ONE
Audit & Prioritise
Conduct accessibility scans of high-traffic areas such as product pages, checkout flows, account portals, and customer service forms.
Identify both WCAG failures and readability challenges.
Prioritise issues that block transactions or essential navigation, as these carry the most significant compliance and business risk.
STEP TWO
Start Fixing What Matters Most
Address high-frequency errors like missing alt text, low-contrast text, unlabeled form inputs, and empty links.
Focus first on shared components (navigation, headers, footers, checkout forms) that affect multiple areas of the site.
Consider deploying assistive tools like the Recite Me Toolbar to provide immediate support for users while remediation is in progress.
STEP THREE
Engage the Right People
Bring together IT, UX, content, compliance, and customer service teams to align accessibility with business goals.
Ensure vendor contracts specify accessibility requirements, so external platforms and marketing tools don’t create new barriers.
Assign clear responsibility for accessibility ownership at both senior and operational levels.
STEP FOUR
Build Internal Knowledge
Train developers, designers, and content creators on WCAG 2.2 best practices and plain language writing.
Integrate accessibility checks into QA and publishing workflows, so new content is compliant by default.
Appoint accessibility champions within departments to drive awareness and accountability.
STEP FIVE
Be Transparent About Your Progress
Publish or update your company’s accessibility statement, outlining current status and timelines for improvement.
Offer accessible feedback channels so customers can report barriers and request support.
Track and publicly share progress to build credibility with regulators, customers, and advocacy groups.
REMEMBER
Accessibility is not about chasing perfect scores. It’s about removing the most damaging barriers first, embedding inclusive practices into everyday workflows, and demonstrating to customers that their needs matter. Businesses that act now not only guarantee EAA compliance. They also stand to win the long-term benefits of a broader, more engaged customer base.
In the last 12 months, British Gas’ website has seen:
175,851
toolbar launches
1,052,760
pages made inclusive
Understanding the EAA
The European Accessibility Act (Directive 2019/882) is the EU’s most ambitious step yet towards digital inclusion. It establishes a harmonised framework for accessibility requirements across all member states, aiming to remove barriers for people with disabilities while ensuring consistency across the single market.
The responsibility of legal enactment and enforcement sits with each member state, meaning national regulators are empowered to set technical standards and apply penalties under their own legal frameworks. That means the specific legal standards may vary by country, but in practice, companies are expected to align with the existing international accessibility standards set out in WCAG.
Crucially, the Act applies to any business selling goods or services into the EU, regardless of where they are physically based. For example, UK companies are no longer EU members, but if they sell into EU markets, their websites, apps, and digital platforms must still meet EAA requirements.
Compliance Deadlines
The European Accessibility Act sets out two key compliance deadlines, one of which has already passed:
DEADLINE
28 June 2025:
All new digital products and services placed on the EU market.
28 June 2030:
All existing products and services that predate the Act must be retrofitted to comply.
Non-compliance Consequences
Companies that fail to comply face a range of potential consequences:
Administrative fines of up to €20,000 per violation.
Ongoing daily fines of up to €1,000 until issues are resolved.
Enforcement actions by national regulators across member states.
Consumer lawsuits and collective actions under disability and equality law.
Restricted access to EU markets via blocks on non-compliant products or services.
Reputational damage.
Procurement barriers (EU tenders increasingly require proof of accessibility).
For companies selling in the EU marketplace, these risks highlight that the stakes are now higher than ever. Businesses that embed accessibility into their products and services now don’t just avoid penalties. They position themselves as leaders in an increasingly inclusive European economy.
Conclusion
The numbers are clear. Not a single one of the EU’s top 100 commercial websites meets WCAG 2.2 Level AA standards. But inaccessible websites don’t just fall short on compliance. They actively block participation in commerce, banking, travel, and communication. That means millions of European customers, including disabled users, older adults, and non-native language speakers, are being excluded from services they rely on every day. In the context of the European Accessibility Act, that exclusion isn’t simply unfair. It’s unlawful.
Every step towards more accessible content reduces risk while also enhancing loyalty, trust, and reach. And the best bit? Accessibility doesn’t require overnight perfection. Many of the issues we identified can be fixed within hours, and more than half can be resolved without major redesigns.
Accessibility is both achievable and overdue. The tools are here, and the standards are clear. The time to act is now.
Methodology & Scope
This report is based on an independent audit conducted by Recite Me using our Accessibility Checker.
- Scope of Review
We evaluated the official homepage URLs of 100 of the top companies selling goods and services into the EU. Homepages were selected because they serve as the primary entry point for residents seeking public services. - Testing Approach
Each homepage was programmatically scanned against the latest Web Content Accessibility Guidelines (WCAG) 2.2, Level A–AAA. Our Accessibility Checker identifies accessibility errors detectable through automated technology such as missing alternative text, low contrast text, and unlabeled form inputs. - Limitations
Automated testing surfaces a significant proportion of common accessibility barriers but does not capture every possible issue. Manual testing methods (e.g., user journeys with screen readers, keyboard-only navigation, or cognitive load assessments) would likely identify additional barriers. For this reason, the results in this report should be seen as a benchmark of technical compliance rather than a full accessibility audit. - Data Integrity
All results reflect the state of each homepage at the time of testing (July 2025). Websites may have been updated since. The analysis is intended to highlight trends, common failures, and areas for improvement not to single out or criticize any specific state.
