With enforcement of the European Accessibility Act (EAA) now underway, businesses that sell into Europe face growing regulatory pressure to provide accessible experiences. Yet our research suggests many U.K. retailers aren’t keeping pace with evolving requirements: 84% of homepages for the U.K.’s top 100 retail brands contain critical accessibility issues.
This is not a marginal concern. For retailers selling into the European Union (EU), these accessibility barriers could constitute violations of the EAA, leading to potential fines and penalties. And even for those that only operate within the U.K., poor accessibility can disrupt customer experience, resulting in compromised trust and lost revenue.
In this piece, we explore what our recent analysis of top U.K. retail websites uncovered about brands’ accessibility status. We’ll also unpack the consequences of accessibility gaps for retailers operating within, and outside of, the EU market, and outline steps brands can take to minimize compliance risks and harness accessibility as a strategic advantage.
Accessibility gaps persist across U.K. retail: Key findings from our research
To understand adoption of digital accessibility among U.K. retailers, we performed automated testing on the homepages of the top 100 most popular retail brands in the U.K., including the homepages of their European market sites. We scanned homepages for conformance to the Web Content Accessibility Guidelines (WCAG) 2.1 AA using the Level Access Platform in July of 2025.
We selected WCAG 2.1 AA because this is the web accessibility standard incorporated into EN 301 549, the presumptive standard for EAA compliance.
Our analysis revealed a consistent—and concerning—pattern: Accessibility barriers are widespread, persistent, and severe. Our study found that:
- Eight in 10 homepages had critical accessibility issues (barriers with a major impact on users with disabilities).
- Five homepages had more than 100 high-severity issues each. Four of these belonged to the same retailer, replicated across different markets—showing how accessibility gaps can scale when brands expand internationally.
- No homepage was free of issues. Every single one presented at least one high-severity barrier for users.
Many of the same issues occurred across multiple websites. The most common errors included:
- Links and buttons missing accessible names: Without a name, screen readers can’t announce what a link or button does. So, the purpose of controls like “Add to Cart” or “Play Video” are not communicated to people who can’t see the screen.
- Insufficient text contrast: When text and background colours are too similar, people with low vision or contrast limitations may struggle to read the content.
- Incorrect heading structure: Headings give pages structure. Skipping levels or using them out of order makes it harder for assistive technologies to help users navigate and understand the purpose of each page section.
- Images missing alternative text (alt text): Alt text describes the meaning of an image for people who can’t see it. Without it, screen reader users have no way to understand the purpose of the image.
- Navigation, aside, and other page regions missing accessible names: Navigation structures, sidebars, and other page sections need names so assistive technologies can tell users where they are on the page.
Why accessibility should be every retailer’s priority
If you work for a U.K. retail brand that’s struggling to implement accessibility, these findings may serve as a point of consolation that you’re not alone. However, bear in mind that inaccessibility has consequences—legal, reputational, and financial.
Retailers selling into the EU expose themselves to substantial legal risks when they violate the EAA. Non-compliant brands may face penalties that vary by country, ranging from fines (up to several million euros in some cases), to removal of products or services from sale, or even suspension of trading rights until issues are resolved. Beyond official penalties, regulatory action can tarnish a brand’s reputation, eroding customer trust.
Even if you’re focused solely on the U.K. market, accessibility is critical to providing a positive customer experience and protecting your bottom line. When customers with disabilities are unable to easily browse products or complete a purchase, it’s likely they will take their business elsewhere.
In fact, the combined spending power of households with at least one person with a disability—known as the Purple Pound—is worth an estimated £274 billion annually to the U.K. economy. Failing to consider accessibility from the outset means retailers risk losing out on a market of this size and potential.
The takeaway? Whether or not your business is covered by the EAA, aligning with accessibility standards will help you stay ahead in an increasingly competitive market.
Six steps to improve digital accessibility in retail
The data is clear: U.K. retailers are falling behind on digital accessibility standards, even as regulations tighten and customer expectations rise. If your brand is among the many that have yet to address accessibility gaps, it can be difficult to know where to start. But with a clear, structured approach, you can meet applicable compliance requirements while gaining a competitive advantage.
Here are six steps to put you on the path toward reduced legal risk, stronger customer loyalty, and sustainable growth.
1. Audit your digital channels.
Start by getting a clear picture of your brand’s accessibility. Obtain a professional audit of your websites, mobile apps, and customer-facing systems to identify where barriers exist. A robust audit provides the evidence base needed to prioritise fixes, allocate resources wisely, and measure progress over time.
For the most thorough and reliable results, choose an audit provider that offers functional assistive technology (AT) testing performed by users with disabilities. Testing by native AT users will surface issues that automated scans and even traditional manual evaluations can miss, helping you build experiences that are not only compliant, but usable for everyone.
2. Establish ownership for accessibility.
Accessibility will not advance without clear lines of accountability. Assign responsibility for compliance across e-commerce sites, checkout flows, loyalty portals, and mobile applications. When ownership is explicit, accessibility becomes embedded in everyday operations rather than left to chance.
3. Address high-impact customer journeys first.
Focus initial efforts on the experiences most critical to revenue and reputation. A single inaccessible checkout button or loyalty portal can frustrate customers, cost you sales, and expose your brand to legal risk. Fixing these high-value journeys first delivers quick wins while building momentum for broader improvements.
4. Embed accessibility at the point of creation.
The most efficient way to maintain compliance is to design for accessibility from the outset. Whether launching a new campaign, rolling out a site feature, or updating core templates, proactively incorporating accessibility into design and development prevents costly retrofits and accelerates delivery.
5. Document and communicate progress.
Keep clear records of audits, fixes, and policy updates. Publish accessibility statements and share milestones internally and externally. Internally communicating your progress can help keep teams motivated and aligned, while externally demonstrating your commitment builds trust with customers and regulators alike.
6. Commit to continuous improvement.
Accessibility is not a one-off project, but an ongoing responsibility. Establish regular reviews, refresh staff training, and adapt to evolving standards. Retailers who take this iterative approach create systems that remain compliant, inclusive, and sustainable over time.
Strengthen your brand with a trusted partner.
Across U.K. retail, accessibility gaps remain the norm rather than the exception. Retailers who fix them now will do more than meet legal requirements—they’ll open doors for millions of customers, boost sales, and build digital experiences that welcome everyone.
Level Access equips retailers with the tools, training, and support to help make this happen. From auditing and remediation to governance and reporting, our end-to-end solution gives you the clarity and control to meet compliance obligations and deliver barrier-free experiences across all channels.
Whether you’re starting with a single site or managing accessibility across multiple markets, contact us to move from awareness to action.
More about this analysis: Our methodology
We conducted automated accessibility testing on the homepages of the top 100 most popular retail brands in the U.K., according to YouGov.
Homepages were scanned for conformance with WCAG 2.1 AA using the Level Access Platform in July 2025. We chose WCAG 2.1 AA because it’s the standard incorporated into EN 301 549, the presumptive standard for EAA compliance.
For each brand, we scanned the homepage available to U.K. consumers (typically “.co.uk” or “.com” domains), as well as available regional domains for five EU markets: France, Germany, Italy, Spain, and the Netherlands.
Because the EAA specifically applies to digital services provided to EU consumers, we wanted to understand whether consumers within these major EU markets were provided with accessible experiences—or whether businesses may be at risk. In total, 136 homepages were scanned.
We used a VPN when needed to reach country-specific sites. If sites were redirected elsewhere, unavailable, or unreachable, we tested the page consumers were sent to instead.
All sites were tested at a standard desktop resolution after cookie notices or pop-ups were dismissed to ensure a consistent testing environment.
Frequently asked questions
Does the European Accessibility Act apply to U.K. retailers?
If you sell to EU consumers, the EAA applies to your digital products and services (such as e-commerce, communication, audiovisual media, and consumer financial services) regardless of where your business is based. While the law does not apply to U.K.-only retailers, aligning with EAA standards can help future-proof your business and improve the customer experience.
Are retailers required to publish accessibility statements under the EAA?
Yes. The EAA requires providers to make specific accessibility information publicly available about how their websites, apps, and digital services meet the Act’s requirements. While the law doesn’t mandate a formal “accessibility statement,” publishing one is widely recommended because it offers a clear, centralized way for regulators, customers, and partners to understand your accessibility efforts.
How does early accessibility planning reduce legal risk?
When accessibility is addressed from the outset, retailers can ensure new websites, apps, and features meet accessibility standards before launch, minimizing the risk of legal challenges, reputational damage, and the need for urgent remediation later.