TRDigital accessibility in the EEA telecom sector, 2026
An automated WCAG 2.2 assessment of 26 telecom operator homepages across the European Economic Area, after the European Accessibility Act began to apply to electronic communications services.
Telecom is one of the services the European Accessibility Act names outright: since 28 June 2025, operators' websites and apps must be accessible across the EU. We scanned the homepages of 26 telecom operators in the European Economic Area, 14 group corporate sites and 12 consumer sites, against WCAG 2.2 and classified every automatically detected barrier by criterion, principle and level. Every homepage has at least one barrier at Level A or AA, 591 in total. Most are buttons and links a screen reader cannot name, and group corporate sites carry far more barriers than the consumer sites customers use every day.
1Key findings
- 26 / 26
Every operator has barriers. All 26 homepages have at least one A or AA barrier; half of them have 7 or more.
- 17 / 26
Screen reader users get stuck on two in three sites. Unnamed buttons and links account for 410 barriers, 69% of the total.
- 84%
Group corporate sites fare worse than consumer sites. The 14 group sites hold 499 barriers; their median site has 10.5 barriers against 5 on the 12 consumer sites.
- 88%
Barriers are mostly repetition. On 20 of 26 sites, a single error type makes up at least half of the barriers; one fix goes a long way.
- 44%
One site holds 44% of all barriers. 260 barriers sit on a single homepage, and the 7 sites with the most barriers hold 81% of the total.
2Methodology
- STEP 01Select26 telecom operators in the EEA: 14 group corporate sites and 12 consumer sites.
- STEP 02ScanEach homepage against WCAG 2.2 on 5 November 2026, with the same tool version.
- STEP 03ClassifyEvery barrier tagged by criterion, principle and level.
- STEP 04AnalyseResults grouped by topic, site type and sector. No operator is named or ranked.
Scope note. The accessibility data in this report is calculated from each operator's homepage only. Pages behind login, subpages, mobile apps and documents are out of scope; results do not represent an operator's digital channels as a whole.
Standard disclosure
Automated testing in this study detects only a subset of WCAG 2.2 failures. A clean automated result does not mean a site is accessible or conformant. Barriers under the Understandable principle, such as unclear instructions or unhelpful error messages, and the real behaviour of interactive components can only be assessed through manual review, which is outside the scope of this report. Findings describe detectable barriers, not legal compliance.
3Results
3.1 Barriers by WCAG principle
WCAG groups its requirements under four principles. On telecom homepages, nearly half of all barriers are Robust: controls that assistive technology cannot identify.
Robust holds nearly half of all barriers
Share of 591 barriers, with the number of sites affected
83% are Level A
Level A is the most basic level of WCAG
Two issues make up all AA barriers
Composition of the 98 Level AA barriers
3.2 Barriers by topic
Two in three operators have screen reader barriers
Operator homepages failing each topic, shown per 10 sites
Screen readers. 410 barriers on 17 sites are buttons and links without an accessible name, and empty links. A screen reader announces them only as "button" or "link".
Contrast. 70 low-contrast barriers appear on 12 sites. Nine of those sites are group corporate sites; only three are consumer sites.
Images. 42 barriers on 7 sites are images without a text description, and image links a screen reader cannot name.
3.3 Group sites and consumer sites
Group corporate sites carry 84% of barriers
Share of 591 barriers by site type, with the median per site
Every site has barriers; three have more than 50
Number of operator homepages by count of A and AA barriers
of all barriers sit on a single homepage (260 of 591)
of barriers repeat an error already present on the same site
median barriers per 100 elements examined (range 0.2 to 73.7)
4Priorities for remediation
Five targeted fixes cover 583 of the 591 barriers detected. The coverage column shows the cumulative share once each fix is added to those above it.
| # | Fix | Barriers · sites | Who benefits | Cumulative coverage |
|---|---|---|---|---|
| 1 | Give buttons and links an accessible nameWCAG 4.1.2 · 2.4.4 | 410 · 17 sites | Screen reader users | |
| 2 | Fix weak contrastWCAG 1.4.3 | 70 · 12 sites | Low vision, older users | |
| 3 | Add text alternatives to imagesWCAG 1.1.1 | 42 · 7 sites | Blind users | |
| 4 | Code page structure correctlyWCAG 1.3.1 | 33 · 11 sites | Screen reader users | |
| 5 | Make touch targets at least 24 pxWCAG 2.5.8 | 28 · 5 sites | Mobile, motor impaired |
The same fixes pay off beyond compliance: meaningful names and clean structure help search engines and software tools interpret a page, alt text makes device and plan images easier to find, and better contrast improves readability for every customer.
Beyond Level AA
Level AAA is not required by most regulations and is kept out of the main figures. It shows whether a site that passes AA is truly comfortable to use.
sites have touch targets below 44 × 44 px; 1,204 targets in total.
sites have text below the AAA 7:1 contrast ratio.
sites open links in a new tab without warning.
5Regulatory context
Telecom is one of the services the European Accessibility Act names outright. Since June 2025, operators' websites and apps must be accessible across the EU, on top of the equivalent-access duties they already had under the telecom code.
From equivalent access to accessible services
Milestones for digital accessibility in European telecom
- Dec 2018
European Electronic Communications Code (EECC) adopted
- Apr 2019
EU adopts the European Accessibility Act directive
- Dec 2020
EECC equivalent access for disabled end-users applies
- Jun 2022
Deadline for member states to transpose the EAA
- Jun 2025
EAA applies to electronic communications services
- Sep 2026
EN 301 549 v4.1.1 published, moving to WCAG 2.2
- Jun 2030
Transition ends for systems in use before 2025
European Accessibility Act
Electronic communications services are in scope by name: internet access, calls and messaging. Operators' websites and apps must be accessible, and emergency calls to 112 must support real-time text. Penalties are set nationally.
Telecom code
Requires equivalent access and choice for disabled end-users. National telecom regulators supervise these duties, and in some states, such as Ireland, also enforce the EAA for telecom services.
EEA EFTA states
The EAA has not yet been incorporated into the EEA Agreement. Norway already requires private-sector websites to meet WCAG under its Equality and Anti-Discrimination Act, supervised by its universal design authority.
For telecom, scope is not in doubt: consumer services are named in the EAA. Group corporate sites mainly inform investors and the public and may fall outside the consumer-service scope, yet they are the most visible face of each operator. Every homepage in this report has automatically detected barriers at Levels A and AA. This is not a compliance judgement.
6Implications for executives
Measure the customer journeys in scope
The EAA covers the websites and apps used to sell and support telecom services. Measure plan selection, checkout, account and support pages in every market, not only the homepage.
Assign a single owner
Barriers span design, content and engineering. Without an executive owner and a quarterly target, fixes lose to the campaign calendar.
Fix shared components first
88% of barriers are the same error repeated. Unnamed buttons and links in shared components carry most of them; fixing those carries into every page and market.
Bring the group site up to the same bar
Group corporate sites carry 84% of the barriers in this report. They are often run by a separate team and agency; give them the same WCAG 2.2 AA target and checks as consumer sites.
References
- Directive (EU) 2019/882 on the accessibility requirements for products and services. EUR-Lex.
- Directive (EU) 2018/1972 establishing the European Electronic Communications Code. EUR-Lex.
- ComReg. “Obligations on electronic communications service providers under the European Accessibility Act”, ComReg 25/39, 27 June 2025.
- BEREC. Report on measures for ensuring equivalence of access and choice for disabled end-users.
- Lov&Data. “Digital inkludering og EUs tilgjengelegheitsdirektiv (EAA)”, issue 3/2025.
- Uutilsynet (Norwegian Authority for Universal Design of ICT). Regulations.
- AccessibleEU. “The European accessibility standard EN 301 549 has been updated”, 7 September 2026.
- W3C. Web Content Accessibility Guidelines (WCAG) 2.2.
- World Health Organization. Disability and health, fact sheet, March 2023.
EEA telecom sector: digital accessibility report 2026
Complete data, methodology, WCAG criteria table and appendix.
