We compiled 80 accessibility complaints filed between 2023 and 2025 in France, Germany, Spain and Italy (sources: associations and public databases). 6 grounds recur in more than 70% of cases. Knowing them means knowing exactly what to fix first so you don't become the 81st case.

The 6-ground leaderboard

  1. 01Checkout funnel not keyboard-navigable (52 cases)
  2. 02Product images without alt text (47 cases)
  3. 03Popup modals without focus management (38 cases)
  4. 04Insufficient contrast on primary buttons (34 cases)
  5. 05"Learn more" links without context (29 cases)
  6. 06Silent form-error announcements for screen readers (26 cases)

Why these 6 and not others

All share one thing: they hit a moment when the user is trying to act — buy, choose, confirm, understand an error. A complaint is built on concrete harm, and the harm peaks when accessibility blocks the action, not just the reading. That's what makes these 6 grounds so frequent in the cases.

The express fix for each

  • →Keyboard checkout: logical tab order, visible focus, no trap (criteria 12.8, 10.7)
  • →Images without alt: fill in product captions, empty the decorative alts (criterion 1.1)
  • →Modals: focus trap, ESC, return focus, `aria-modal` (the APG dialog pattern)
  • →Button contrast: 4.5:1 ratio, darken the brand colour when it serves as text (criterion 3.1)
  • →"Learn more" links: an explicit label or an `aria-label` that says where it goes (criterion 6.1)
  • →Form errors: a message tied to the field and announced via `aria-live` (criterion 11.10)

// Ground #1

The checkout funnel. If you had to fix just ONE scope this year, it would be this one: it touches the act of purchasing, hence the most direct harm, hence the strongest legal argument on the complainant's side.

Frequently asked questions

Does fixing these 6 grounds make me completely safe?

Not completely, but it neutralises the vast majority of the real risk: these grounds concentrate more than 70% of the analysed complaints. It's the best effort/risk ratio to start with, before aiming for broader compliance.

Which is the most expensive to fix?

Usually the keyboard checkout, because it touches the structure and behaviour of several pages. But it's also the most worthwhile to fix, since it's the most legally exposed.

Do these grounds apply to every country?

Yes: the sample covers France, Germany, Spain and Italy, and the same grounds dominate everywhere. The technical defect is identical from one country to the next, even if the competent authority changes.

Where do these 80 cases come from?

From a survey of complaints and formal notices made public or reported by associations in France, Germany, Spain and Italy between 2023 and 2025. The sample isn't exhaustive, but it's broad enough to bring out clear trends.

Does the ranking change by sector?

The exact order varies a little — fashion suffers more from modals, grocery from drive-through funnels — but the same 6 grounds dominate everywhere. They're platform defects, not sector ones.

How long to fix the 6?

A few weeks of development for an SME, tackling the blockers first. The keyboard checkout is the longest; images without alt and contrast, the quickest to settle.

Do these grounds also concern mobile?

Yes, and sometimes more: a poorly marked-up mobile payment funnel combines small screens and touch screen readers (VoiceOver, TalkBack). Test the purchase journey on mobile as much as on desktop.

Our audit specifically spots these 6 grounds and their exact location on your site.

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