Marketing, digital and compliance leads at enterprise, infrastructure and B2B companies whose public website, customer portal or online services are reviewed by customers, procurement teams or regulators.
- WCAG 2.1 Level AA is the standard most regulations and procurement teams now reference for public-facing websites and apps.
- Deadlines are real and some moved recently: the EU Accessibility Act applies from 28 June 2025; US ADA Title II rules for public bodies now run to April 2027 and 2028; HHS Section 504 rules to May 2027 and 2028.
- Most sites are not there yet. WebAIM found detectable WCAG failures on 95.9% of the top million home pages in 2026, averaging 56.1 errors each.
- Procurement increasingly asks for evidence - a conformance report, a recent audit and a remediation roadmap - before a deal proceeds.
- The practical route: audit key templates and journeys, fix shared components first, document conformance, and keep accessibility in the release process.
For many enterprise and infrastructure companies, the public website used to be a brochure: important for reputation, rarely scrutinised for how it works. That has changed. Customers, procurement teams and, in more sectors, regulators now ask directly whether a company's website, portals and online services meet accessibility standards - and they expect a specific answer.
This article explains what is being asked for, which rules currently apply, how procurement reviews treat accessibility, and a practical plan to get your public-facing site ready.
This is general guidance, not legal advice. Confirm your organisation's obligations with legal counsel.
The standard: WCAG 2.1 Level AA
The Web Content Accessibility Guidelines (WCAG), published by the W3C, are the common reference point. Level AA is the practical target: it covers the basics of Level A (text alternatives, keyboard access, no keyboard traps) plus requirements such as text contrast of 4.5:1 for normal text, resizable text, consistent navigation, visible focus and clear error handling. WCAG 2.2 adds a handful of further criteria; designing to 2.2 AA gives you margin over 2.1 AA.
What regulations currently require
Rules differ by country and sector, and several dates changed in 2026. As of September 2026:
| Rule | Who it covers | Standard | Timing |
|---|---|---|---|
| European Accessibility Act | Many consumer-facing products and services in the EU, including e-commerce, banking, transport services and e-books | EU harmonised standards aligned with WCAG | Applies from 28 June 2025; microenterprises providing services are exempt |
| ADA Title II web rule (US) | State and local government entities | WCAG 2.1 AA | April 26, 2027 (population 50,000+); April 26, 2028 (smaller) |
| HHS Section 504 rule (US) | Recipients of HHS federal funding | WCAG 2.1 AA | May 11, 2027 (15+ employees); May 2028 (fewer) |
| GIGW 3.0 (India) | Government websites and apps | WCAG 2.1 Level AA conformity | In force |
Even where a company is not directly covered, its customers often are. A private supplier selling to public bodies, banks or healthcare organisations will be asked about accessibility because the buyer has obligations of its own.
How far most websites are from compliance
The gap is large across the web. WebAIM's 2026 automated analysis of the top one million home pages found detectable WCAG failures on 95.9% of them, with an average of 56.1 errors per page. Automated tools catch only part of the picture, so real conformance levels are lower still.
Source: WebAIM Million, 2026 report
View as table
| Measure | Share of home pages |
|---|---|
| Any detectable WCAG 2 failure | 95.9% |
| Low-contrast text | 83.9% |
| Missing image alternative text | 53.1% |
| Missing form input labels | 51% |
| Empty links | 46.3% |
The encouraging part: WebAIM found 96% of detected errors fall into just six categories - low contrast, missing alt text, missing form labels, empty links, empty buttons and missing page language. These are mostly fixable in templates and components rather than page by page.
What procurement teams ask for
When accessibility appears in a vendor or supplier review, the questions tend to follow a pattern:
| Request | What it is | How to prepare |
|---|---|---|
| Conformance statement | A statement of which WCAG version and level you meet, with known exceptions | Base it on a real audit, not aspiration; date it |
| Accessibility conformance report (ACR) | A detailed, criterion-by-criterion report, often using the VPAT template | Commission or produce one for your main product or site |
| Recent audit evidence | Summary of an independent or internal audit | Keep the report and the fixes it led to |
| Remediation roadmap | Dates for fixing known gaps | Prioritise by user impact and publish internal owners |
| Process evidence | How accessibility is maintained in releases | Show design-system standards, testing and acceptance criteria |
Teams that have built accessibility in answer these quickly. Teams that have not end up retrofitting under deal pressure - slower, more expensive, and usually lower quality.
A practical plan for your public site
- Scope what counts. List public pages, templates, portals, forms, documents (PDFs) and third-party embeds such as chat widgets and booking tools.
- Audit representative templates and journeys. Use automated scanning across the site, then manual keyboard and screen-reader testing on key templates and the journeys that matter: contact, quote request, sign-in, applications, downloads.
- Fix shared components first. Navigation, forms, buttons, colour tokens and page templates fix many pages at once.
- Fix content and documents. Alt text, heading structure, link text, captions, and accessible versions of important PDFs.
- Handle third parties. Check embedded tools; ask vendors for their conformance reports and choose accessible options where you can.
- Document. Publish an accessibility statement, produce a conformance report, and keep a dated remediation log.
- Keep it in the process. Add accessibility to design review, content publishing checklists and QA for every release.
Common traps on enterprise websites
- Overlays instead of fixes. Script-based "accessibility overlays" do not make an inaccessible site conform and can interfere with assistive technology. Fix the underlying code.
- Inaccessible documents. Annual reports, tenders and policies published as scanned PDFs.
- Third-party forms and booking widgets that break keyboard access.
- Brand colours that fail contrast on buttons and links - test them; see our contrast testing walkthrough.
- Carousels and auto-playing video without pause controls.
Across enterprise work, accessibility has moved from "nice to have" to a line item in reviews. On a major banking client's platform, the WCAG A/AA/AAA work I contributed to was not a separate compliance project. It was built into how the product was designed and reviewed, which is what made it sustainable.
The companies that handle procurement questions calmly are not the ones with the most impressive statements. They are the ones that can show a recent audit, a dated conformance report and a design system that keeps new pages compliant by default.
Frequently asked questions
Does an accessibility overlay make our site compliant?
No. Overlays do not fix underlying code problems such as missing labels or keyboard traps, and they can conflict with the assistive technologies disabled users rely on. Fix issues at source.
Is WCAG 2.2 required?
Current US rules reference WCAG 2.1 AA. WCAG 2.2 is newer and backwards compatible in practice; many organisations now design to 2.2 AA to stay ahead.
How often should we audit our website?
After any significant redesign, and at least annually for sites that change often. Automated monitoring between audits catches regressions early.
Do PDFs on our site need to be accessible?
If they are part of how people use your services - forms, reports, policies - yes. Provide accessible versions or HTML equivalents for important documents.
Who should own website accessibility?
A named owner, usually in digital or marketing, supported by design, development, content and legal. Shared ownership without a lead tends to stall.
Procurement or compliance asking about accessibility?
Let's audit your public site and give you a clear, prioritised plan.
Sources
Every statistic in this article links to its original publisher. Figures were checked against these sources on September 29, 2026.
- Understanding SC 1.4.3: Contrast (Minimum) - W3C
- European Accessibility Act - European Commission
- Fact sheet: new rule on the accessibility of web content and mobile apps - US Department of Justice, ADA.gov
- Compliance with Section 504 of the Rehabilitation Act - Alston & Bird health care advisory, updated May 2026
- New features of GIGW 3.0 - Government of India
- The WebAIM Million, 2026 report - WebAIM, 2026
