Four months into the European Accessibility Act, 33 of 35 big European shop home pages still have findings a machine can see

October 26, 2026

The European Accessibility Act has applied since June 28, 2025. Online shops that sell to consumers in the EU have to meet EN 301 549, which for web pages means WCAG 2.1 AA, unless they are micro-enterprises. National market surveillance bodies enforce it, and each country sets its own penalties. Four months in, I wanted to know what a plain automated pass finds on the front door of the shops that are plainly in scope.

What I ran

I took 91 home pages: large retailers and marketplaces in Germany, France, the Netherlands, the Nordics, Spain, Portugal, Poland, Czechia, Italy and Austria, plus a few UK shops that sell into the EU. I fetched each one the way a crawler does, with no login, and ran the same page checks that sit behind our $149 readiness report: the static accessibility audit, a contrast check against the colour pairs the stylesheets declare, an alt text review and a touch target review.

56 of the 91 did not give me a page worth auditing. Some refused the request, some served a near-empty shell that only builds the page in JavaScript. I left those out and did not count them as passes. That leaves 35 home pages with at least 20 links in the served HTML, a median of 244 links each.

What came back

33 of the 35 had at least one automated finding. The median page had 13 and the worst had 86. The most common ones:

• 17 pages (49%) had no skip link at the top of a page with many links, so a keyboard user tabs through the whole header on every visit.
• 15 pages had links with no text and no accessible name, usually an image or icon wrapped in an anchor.
• 13 pages had icon-only buttons with no label.
• 13 pages had images with no alt attribute, 137 images in total across those pages.
• 12 pages had no h1.
• 8 pages had a text field that relies on its placeholder as the only label.

27 of the 35 had at least one finding rated high, which in our scale means a barrier for someone using a screen reader or a keyboard. Of the 35, 32 had at least one text and background pair in their stylesheets below the AA contrast ratio, 391 pairs in all.

How far to trust it

This is a check of the HTML and CSS a plain request receives. It cannot see what a script adds afterwards, it cannot tell whether a link name is meaningful, and it does not test focus order, screen reader announcements or anything after the home page. The contrast numbers come from declared colours, and in places the tool has to assume the background, so treat that count as a list of places to look. A site with no findings here can still fail an audit, and a site with many may have fixed them in the rendered page.

I am not naming sites. A home page fetched once by one tool is not a verdict on a company, and a list of names would turn this into the wrong conversation. If one of these is yours, you can run the same checks for free.

What I would fix first

Skip link, names on icon-only buttons and image links, alt attributes and a single h1. All four are template changes, so one fix reaches every page. Then run the checks on a product page and the checkout, which is where the Act cares most and where this study did not look.

The free check runs on one page of your site and takes about a minute: allthepossibles.com/report. The full report covers up to ten pages, maps every finding to the EN 301 549 clause and ends with a fix list in the order to do it, and there is a sample if you want to see it before deciding.