European Accessibility Act: keyboard and screen reader use

The rule

Member States had to apply national laws implementing the Directive from 28 June 2025 (Art. 31(2)). The national text is what an authority applies, so check the law of each country you sell into.

What PeekWell checks and how

EU-10 asks one question: can an automated engine find barriers for keyboard and screen reader users on the public pages it visited? The answer comes from the page as the browser renders it.

The scan opens key public pages in a headless browser and runs an accessibility engine, axe-core with Pa11y alongside it, against each one. Every rule that fails is recorded by WCAG success criterion. It looks for missing alt text, form fields without labels, text with too little contrast, missing landmarks, keyboard traps and a missing page language. Separately it notes whether an accessibility statement page exists. The decision comes from the engine’s output, not from a language model.

The check leaves out companies in the micro size band, because of the exemption in Article 4(5).

The scan has limits, and the report says so. It sees the public pages it visited and nothing behind a sign-in, so a basket or an account page is outside it unless it is publicly reachable. It does not sign in or submit forms. An automated engine finds only part of what a person using a screen reader would find: the axe-core maintainers say it finds on average 57% of WCAG issues, and that it returns elements as “incomplete” where it cannot be certain. The accessibility statement is checked for presence only, not for whether its contents are accurate. A Passed means the expected behaviour was observed on the pages scanned. It does not say the site complies.

The same engine runs for UK-12 and US-06; only the law each report points to differs.

Why it matters for a company

The Directive has applied since 28 June 2025 and enforcement is only beginning to show. As of 7 October 2026 no decision by an authority against a named company could be confirmed at the authority’s own page. A French court order of 4 June 2026 against Carrefour France, brought by two associations, is the one court record read, and this section otherwise describes supervision.

Three things follow. Authorities in at least two countries have started with consumer-facing shops. The first step is a request to improve, so a documented plan and visible progress put a company in a different position from one that has done nothing. And Article 13(5) lets an authority ask for “all information necessary to demonstrate the conformity of the service”, so the evidence trail matters as much as the fix.

Smaller companies and larger companies

The size line is the microenterprise exemption: fewer than 10 people and a turnover or balance sheet of no more than EUR 2 million. Above it there is no further threshold, though a documented disproportionate burden assessment under Article 14 can reduce what is expected of a smaller business.

In a small company the site is usually a theme on a hosted shop platform, with plugins added over time. The barriers come from the theme and the content: product photos without descriptions, a newsletter field with only placeholder text, grey text on a pale background, a cookie banner the Tab key cannot reach. Nobody owns accessibility, so nobody has looked. A few template edits can fix a great deal.

In a larger company the work is spread out. The design system, the checkout, the app and the marketing pages belong to different teams and suppliers, and a release in one place can undo a fix in another. Third-party content that the company neither funded, developed nor controls is outside the Directive (Art. 2(4)(d)), but whether an embedded widget falls on that side is a question for an adviser. The likelier gap is process: no tests in the release pipeline, and no record of what was checked and when.

How to fix it

1. Try your own site with the keyboard. Put the mouse away. Press Tab through the home page, a product page and the basket, and note where you cannot reach a control, cannot see where you are, or cannot leave a pop-up. WCAG 2.1.2 asks that focus can always move away, and 2.4.7 asks that the focus indicator is visible.
2. Give every picture and control a name. Meaningful images need a text alternative (WCAG 1.1.1). Form fields need a visible label tied to the field, not only placeholder text.
3. Check contrast. WCAG 1.4.3 asks for a contrast ratio of at least 4.5:1 for normal text and 3:1 for large text. A browser’s developer tools show the ratio for any element.
4. Set the page language. WCAG 3.1.1 asks that the language of each page can be determined by software.
5. Publish the information the Directive asks for. Add a page saying how the service meets the requirements and how to report a problem, next to your terms and conditions (Annex V). If you rely on disproportionate burden for any part, write the assessment down and set a review date (Art. 14).
6. Re-scan. Run a scan after each change. The finding for a rule should disappear once the engine stops reporting it. Then test with a screen reader yourself or with people who use one, because the engine will not catch everything.

<label for="email">Email address</label>
<input id="email" name="email" type="email" autocomplete="email">

Whether a given design meets the national law is a question for your legal adviser, and Peeky reports only what it sees.