Is your website accessible? WCAG 2.2, the EU Accessibility Act and a practical compliance plan

Accessibility stopped being a design preference and became a dated obligation in two markets at once. The European Accessibility Act (Directive (EU) 2019/882) has applied since 28 June 2025 and covers e-commerce and digital services sold to consumers in the EU, including services offered by companies based outside the EU. In Türkiye, Presidential Circular 2025/10, published in the Official Gazette of 21 June 2025 (issue 32933), requires websites and mobile applications to conform to the Ministry's "Website and Mobile Application Accessibility Checklist - Level A" together with WCAG 2.2. The Turkish deadline for the listed institutions was one year and passed in June 2026. E-commerce service providers under Law 6563 have two years, so June 2027. If you sell in both markets, the practical target is WCAG 2.2 AA, because the EU bar sits at AA and doing the work twice costs more than doing it once.

Who the Turkish circular covers

The one-year deadline applied to public institutions, universities, municipalities, state economic enterprises, municipal companies and subsidiaries, professional bodies with public status, banks, private hospitals, private education institutions licensed by the Ministry of National Education, road passenger carriers under Law 4925, passenger ships, private rail and air passenger carriers, Group A travel agencies licensed by the Ministry of Culture and Tourism, and electronic communications operators with more than 200,000 subscribers. The two-year window belongs only to e-commerce service providers under Law 6563.

The legal basis is not new. Law 5378 on Persons with Disabilities already treats the accessibility of information services and information and communication technology as a legal requirement. What the circular adds is a monitoring machine. A Monitoring Commission chaired by the Minister of Family and Social Services decides which sites and apps get reviewed each year, and an Advisory Commission feeds into that plan. The third body is the one that lands on your desk: every covered organization has to form its own internal Review Commission, examine its sites and apps technically, and submit a report to the Monitoring Commission. Results are announced by the Minister, and organizations found accessible get the right to display an Accessibility Logo for two years.

What Level A asks for, and what it leaves out

The Ministry's checklist is built on the four principles and 31 Level A success criteria of WCAG 2.2. Level A is the floor, not comfort. Text contrast (1.4.3), the 24 by 24 pixel minimum target size (2.5.8) and keeping the focused element from being fully hidden (2.4.11) are all AA criteria, so they sit outside the Turkish requirement. Two of the criteria WCAG 2.2 introduced at Level A are inside it: Consistent Help (3.2.6), which asks you to keep help mechanisms in the same relative place across pages, and Redundant Entry (3.3.7), which asks you to stop making people retype information they already gave you.

WCAG 2.2 became a W3C Recommendation in October 2023. It added nine success criteria and dropped one. Criterion 4.1.1 Parsing was declared obsolete because assistive technology no longer parses HTML directly; it reads the browser's accessibility tree. If a vendor's audit report still lists parsing errors, that report was not rebuilt for 2.2.

The checklist is a work list, not an exam paper

The 2026 revision of the Turkish checklist runs to 126 questions. Single-starred questions mark conditions that must be met, double-starred ones mark situations that must not exist, and the rest are inventory questions that route you to the sections that apply. The rule that decides how much work this is sits in the opening notes: every question has to be answered separately for each web page and each mobile screen, in context.

That single sentence rules out a site-level opinion. You need a page-level and screen-level inventory instead. The questions are specific too. Do informative images have text alternatives that assistive technology can reach? Are decorative images marked so a screen reader skips them, for example with an empty alt=""? Are state and content changes that follow a user interaction reported programmatically? That last one eliminates a lot of hand-rolled components: a tab becoming selected, a dropdown opening and closing, an error message appearing.

Five of the six most common failures are Level A issues

WebAIM's 2026 scan of one million home pages found automatically detectable WCAG failures on 95.9% of them, a regression from 94.8% the year before. The average number of errors per page rose from 51 to 56.1. Six error types account for 96% of everything detected: 83.9% of home pages had low contrast text, 53.1% had images with missing alternative text, 51% had form inputs with no label, 46.3% had empty links, 30.6% had empty buttons, and 13.5% had no document language set.

Read that list through a Level A lens. Alternative text, form labels, empty links, empty buttons and document language all map to Level A criteria. Only low contrast belongs to AA. So the work standing between a typical site and the Turkish threshold is not exotic; it is the same five items on nearly every project. On an e-commerce site you can usually guess where they break: icon-only buttons, the product gallery, the filter panel, the address form, and the lang attribute left behind by a language switcher.

Adding ARIA is not the same as adding accessibility

The uncomfortable finding in the same report: home pages that used ARIA averaged 59.1 errors, while pages without it averaged 42. ARIA attributes grew 27% in a year, past an average of 133 per page. The honest reading is not that ARIA is harmful. ARIA does not replace native HTML semantics; it fills the gaps they leave.

Say you wrote <div role="button"> instead of <button>. You declared the role, and you also took on focus handling, Enter and Space behaviour, and announcing disabled and pressed states. Miss one of those and the component is announced as a button that does nothing, which is worse for the user than no markup at all, because it promises a control that works. The working rule stays simple: reach for the native element first, and use ARIA only for behaviour that has no native equivalent.

Buying a widget is not buying compliance

Overlay widgets look like the short path. In January 2025 the US Federal Trade Commission announced a $1 million order against an overlay vendor, finalised in April 2025, over claims that its product would automatically make websites conform to WCAG 2.1 AA. The claims were found unsubstantiated.

The technical side reaches the same conclusion. If the source has no alt attribute, the widget guesses. It cannot know which label belongs to which input, and it cannot report your component's state changes to assistive technology. The checklist questions look at the source and at the accessibility tree. A script loaded at runtime does not answer them on your behalf.

How far automated testing takes you

Estimates of how much of WCAG can be judged pass or fail by a tool vary, and the range quoted across the field runs from 20% to 40%, so roughly a third. The rest needs human judgement: whether the alternative text describes the function of the image, whether focus order matches the visual flow, whether an error message tells the user what to do next.

The minimum setup a team can put in place this week has three parts. First, park the mouse and complete five key flows with Tab, Shift+Tab, Enter, Space and arrow keys only. Second, listen to the same flows with a screen reader: NVDA is free on Windows, VoiceOver ships with macOS and iOS, TalkBack with Android. Third, and this is the part that lasts, run axe or Lighthouse inside your deployment pipeline and fail the build on newly introduced violations. Without the third part the first two repeat on every release, the same way manual scenarios pile up when test automation has no gate behind it.

Selling into the EU means AA, plus a written statement

Under the EAA, the presumption of conformity comes from the harmonised standard EN 301 549. The version in force, 3.2.1 from 2021, uses WCAG 2.1 AA as the baseline for web content. A draft of the next version, which aligns clauses 9, 10 and 11 with WCAG 2.2, went out for review in November 2025 and is expected to be cited in the Official Journal around autumn 2026. Services get a microenterprise exemption, defined as fewer than 10 employees with annual turnover or balance sheet total not above 2 million euro; products do not. Service contracts signed before 28 June 2025 may continue unchanged, but they have to end by 28 June 2030 at the latest. Enforcement is national, and the amounts are real: Germany's implementing act, the BFSG, sets fines from 10,000 to 100,000 euro depending on the type and severity of the violation. Providers are also expected to publish accessibility information about the service, so plan for a maintained accessibility statement rather than a one-off audit PDF.

Most of what separates A from AA lives in the design system: contrast ratios, target sizes, visible focus styles, and authentication that does not depend on memory or transcription. Fixing those once, in the tokens and the shared components, costs far less than reopening the same screens a year later for a second market.

The circular is not the only source of risk

Türkiye's Human Rights and Equality Institution treats disability as a ground of discrimination under Law 6701 and was issuing decisions before the circular existed. In decision 2024/403 it found that many areas of a bank's internet and mobile banking applications could not be read by screen readers, and held that the prohibition of discrimination on grounds of disability had been violated. In decision 2024/1302 it concluded that a university's internal systems were not accessible. Individual complaints run on their own track, independent of the deadlines in the circular.

The same work pays off twice

Much of what accessibility asks for also tells machines what your content means. A meaningful heading hierarchy, link text that names its destination instead of saying "click here", alternative text that describes what an image does, a correct lang attribute, and forms that work from the keyboard all serve the screen reader and the parser reading your page. The overlap with technical SEO and visibility in AI answers is not a coincidence, since both depend on the same structural markup.

The second payoff is performance. Deeply nested wrappers, fake buttons wired up in JavaScript, and panels that re-render on every interaction produce accessibility failures and site speed problems together. Mobile apps are in scope as well: the Turkish checklist asks the same questions of app screens and platform accessibility APIs, so choosing native or cross-platform changes nothing about the obligation.

Five things worth doing this month

One, build a scope inventory. Which domains, which mobile apps, which user flows. List page templates rather than individual pages, since 400 product pages are one template.

Two, test five key flows with a keyboard and a screen reader: sign-in, search, add to cart, checkout, and the support form. Record where each one breaks. A screen recording moves a developer faster than a written ticket.

Three, sweep the five items: alternative text, form labels, empty links and buttons, document language, focus visibility. That sweep alone clears most of what tools can detect.

Four, put the audit in the pipeline and freeze the threshold at today's count. Block new violations before you try to reach zero, then lower the threshold in steps.

Five, name the owner of the review report. If the internal Review Commission stays a list of names, the report gets written in the final week. A plan that says which fix ships in which release is also the strongest document you can hand to a monitoring body.

Treating accessibility as a layer added at the end makes it one of the more expensive forms of technical debt to carry. Folded into design review and code review, it turns into an ordinary quality item. The deadlines forced that shift; what is left is choosing which template to start with.