Written by Rachael Camp
What you might miss and possible implications
The European Accessibility Act came into force in June 2025. It applies to products and services in EU countries, but also those who have customers or clients based in the EU, providing they have 10 or more employees and an annual turnover over EUR 2 million.
It specifically mentions banking services and points of access e.g. ATMs as an example of which services it applies to.
In short, this means it affects Swiss companies too. Even if your website can be accessed within EU countries, then you need to be compliant.
If I am exempt, why should I still aim for compliance?
If you are exempt, you might think you don’t need to do anything. But the earlier you consider accessibility measures, the easier it is to design and build a compliant product or service. If you wait to until you must be compliant and your product is already finished, you will lose time and money trying to fix it.
Neilson Norman Group estimate that changes made after the release of a product can cost up to 100 times more than if they are made before development begins.
Then there are other costs: fines for non-compliance, missed revenue because people are unable to read your website or use your products, and potential legal challenges.
Starting early is always your best option.
Why can’t I just add an overlay or accessibility menu?
Accessibility overlays and menus are becoming increasingly popular. They are a button users can click to change fonts, colours, enhance contrast and other parameters to suit their needs and preferences.
Despite their popularity, they are not recommended by accessibility experts, nor do they satisfy the EU accessibility act. They are essentially a band aid that doesn’t fix underlying problems with the code or design of the product.
Interestingly, an audit by Digital Accessibility Luxembourg in 2024 found that websites using an accessibility menu had lower accessibility scores than websites without. Furthermore, most of the sites with menus or overlays had accessibility issues caused directly by the menu or overlay itself.
Why can’t I ask AI to fix it?
Many believe that AI can solve accessibility challenges, and while it is true that we can use AI to automate part of the process, automated checkers catch only 20-30% of the WCAG 2.2 criteria (a set of accessibility guidelines mandated by the European Accessibility Act).
Another idea is that AI can customise different experiences based on preferences and needs, but the process to do this must be accessible in the first place. Additionally changes that the AI makes often create new issues.
So how can I make accessibility easier and cost effective?
As the Web Content Accessibility Guidelines can be overwhelming to read without context, I put together some points to consider when developing products and services.
Can I complete the action with at least two of my senses (sight, hearing, touch or other movement, smell, taste)?
When you create anything, ensure that people don’t need to rely on one sense alone to use it.
For example:
I can navigate a website using my mouse (sight, movement) or using my keyboard (touch) and a screen reader (hearing). If I cannot use my hands, I could use voice commands, or a hands-free mouse.
When I need to click to close a menu, I need to click an “X”. But I cannot see the “X” and it isn’t labelled, then I am stuck.
When I watch a video: if I cannot hear it, I will not understand speech or sounds, unless I can read closed captions.
Can I still understand if I only use black and white?
If I remove colour from my screen, can I still navigate and complete my task?
If colours are used to indicate something (e.g. a status) then a description of the status should be written next to it to ensure that the context is not lose if another person sees the colours differently. We also can see if we are using enough contrast between elements so that they are legible.
Can an 11-year-old understand it?
The European commission itself uses clear language in its work, so that people with reading or comprehension difficulties or are not fluent in the language can still understand it.
Plain English, a style of writing understood by children aged between 9 and 11, is recommended for services used by the general population, even for complex ideas and legal documents. This is notably used by the UK government.
This style is known as ‘Langage simplifié’, ‘langage facile’ or ‘français facile à lire et à comprendre’ (FALC) in French, ‘Einfache Sprache’ in German and ‘linguaggio chiaro’ in Italian.
Research by Christopher Trudeau at the Thomas M Cooley Law School in Michigan found that 80% of people prefer sentences written in clear English, and this preference only increases with the complexity of the topic.
Can I test with real people?
User tests, even with concepts or mock-ups can bring you valuable insights that help you easily spot accessibility issues. Include people of different ages (younger or older), who have disabilities or don’t have prior knowledge of your product.
Testing with blind people is especially valuable as they quickly find multiple issues and you get a unique insight into their experience and how it differs from your own. Smashing Magazine put together a guide of best practices for running these tests at https://www.smashingmagazine.com/2023/06/testing-sites-apps-blind-users-cheat-sheet/
Conclusion
Despite their perception as slow, costly and restrictive, accessibility considerations and testing prevent costly compliance issues in the long term, especially when you do it early and in collaboration with real people.
About Rachael Camp
Rachael Camp is the Co-Founder at SwissFx, a financial platform for international payments and foreign exchange supporting internationally active businesses. She has extensive experience in design and product, focussing on enterprise UX and accessibility.
