Study: AudioEye detects up to 2.5x more issues than other tools
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2026 Digital Accessibility Index
Accessibility has never been harder to get right, or more consequential to get wrong.
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Accessibility risk is compounding, and most programs aren’t built to keep pace
Digital accessibility has never carried more risk. Web accessibility litigation has doubled in the last six years, and the European Accessibility Act is extending compliance requirements to markets that previously had none.
At the same time, AI is changing how websites are built. Teams are using AI to work faster, but the LLMs writing the code were trained on an internet that is largely inaccessible. Sites are changing rapidly, and they’re getting less accessible.
The scale of the challenge is getting bigger, too. Two-thirds of AI search sessions now bypass the home page, sending users to interior pages that manual audits rarely reach. Teams can no longer focus on a few pages and trust that most users will rarely venture elsewhere. Litigation can now come from almost any direction.
Our latest Digital Accessibility Index reflects these pressures. We scanned 160,000+ pages across 6,100+ websites, spanning seven industries and two continents. The average page had 62 accessibility issues, and that number increased on the pages AI now routes most users to.
Key findings
40%
of all issues trace back to five WCAG criteria. The problem is more concentrated than it looks.
21%
of all issues are high-risk. These are the failures that block users and drive most accessibility lawsuits.
10%
more issues per page on the pages AI search routes users to most. The risk footprint is shifting.
25%
more issues per page on EU sites than U.S. counterparts. With the EAA now in effect, that gap has new urgency.
Some organizations are trying to close the gap. In a survey of 400 business leaders, 44% said they managed accessibility in-house, even though 64% said they lacked the expertise to do it well. The programs most organizations have built to address accessibility are ill-suited for the scale of the problem.
That gap has a cost. When organizations receive a claim, the settlement of $25K to $75K is rarely the largest line item. Legal fees, executive time, and retroactive accessibility fixes typically exceed it. The opportunity cost is real, too. People with disabilities control over $2.6 trillion in disposable income(opens in a new tab) across North America and Europe, and 83% limit their shopping to sites they know are accessible(opens in a new tab).
“We’ll get to it” has become the most expensive sentence in most accessibility roadmaps. In the four chapters that follow, we show where issues concentrate, why they persist, and what closing the gap actually requires.
The Digital Front Door Has Moved
Homepages are no longer the primary entry points for users.
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For years, traffic followed a predictable path. Users arrived on your homepage and deliberately navigated through your site. Accessibility programs, understandably, followed the same logic, focusing on the pages users were most likely to reach.
That logic no longer holds.
AI-powered search has fundamentally changed where users enter a site. AI-referred traffic grew 632% year-over-year across nine industries, from retail to financial services (Q4 2024 vs. Q4 2025). And it doesn’t follow the same path as direct or organic search traffic.
Most AI traffic bypasses the homepage entirely, routing users directly to the pages behind it.
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Of the 162,000 non-homepages scanned for this report, the average interior page had 62.4 accessibility issues compared to 56.7 on homepages. Users arriving through AI search are landing on pages with more issues, which means more opportunities to encounter one.
That shift has already shown up in the litigation data. Interior pages are where most users land, and increasingly where most claims originate.
64%
of web accessibility claims in 2025 referenced issues on interior pages
High-intent users. High-issue pages.
Research conducted by Semrush(opens in a new tab) found that the average AI search visitor is 4.4x as valuable as the average visit from traditional organic search, based on conversion rate.
That value is concentrated on the pages with the most accessibility issues.
The complexity data explains why. AI routes users to interior pages: product detail, pricing, services. Those pages carry more elements on average, including more images, links, buttons, and form fields. That complexity creates more surface area for failures on the exact pages where AI traffic now concentrates.
+18%
Non-homepages average 1,251 elements (images, links, form fields, buttons, menus) compared to 1,059 on homepages
For users who rely on assistive technology, the complexity translates directly into friction. On a deep product or industry page, mislabeled form fields, missing heading structures, and inaccessible interactive elements are common.
When users hit those friction points, they leave: 71% of people with disabilities leave a site when they encounter issues(opens in a new tab). With the average page carrying 62 issues, 13 of them high-risk, the damage rarely shows up in a support ticket; it shows up as a lost visitor or abandoned cart.
Every page is the front door
The question is no longer whether your website is accessible. It’s whether the pages users are actually reaching are accessible. Right now, those are two very different answers.
AI-powered search sends users directly to the page that answered their question, not your homepage. These are the pages where decisions get made, and where accessibility issues are most likely to be waiting.
There’s a second force making this worse. The pages users land on are being built faster and with less oversight using AI tools. Researchers at MIT and the Wharton School of Business found AI coding agents have increased the volume of code written by 741%(opens in a new tab).
+741%
more code is being generated by AI coding agents, yet actual software releases have only increased by 20%
These tools learned from an internet that’s largely inaccessible, so every new page inherits those gaps. As the New York City Bar Association noted, AI can’t solve for accessibility it was never trained to recognize(opens in a new tab). Left unchecked, the LLMs that now build and route the web send high-intent users to pages produced too fast for anyone to catch the gaps. Speed isn’t the problem. The missing guardrails are.
Manual audits and periodic reviews can’t keep pace with that volume. The organizations that close that gap use automation plus human expertise to maintain continuous coverage across the full site, because it's the only approach that keeps up with where users are actually landing.
Accessibility has to live across the entire site, not just the front door.
The Five Criteria Almost Every Page Fails
Five WCAG failures account for 40% of all detected issues. They happen to be the building blocks of a working web.
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On the surface, a global e-commerce site and the municipal website for a small town have little in common. Yet the same five WCAG criteria fail on roughly 75% of pages, regardless of industry or region.
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Forty percent of all detected issues came from these five criteria.
When they fail, the impact is immediate. A screen reader user clicking a button with no accessible label has no idea what it does. A keyboard user on a site with no way to skip past the navigation has to tab through every menu item on the page to reach the content they need.
“Accessibility issues have cost a number of companies some decent money because I have to shop elsewhere.”
Chris Preiman, Internet Security Professional
Frequency is only half the story
Every accessibility issue is evaluated by how much it affects users, from lower-impact issues that slow users down to severe issues that stop them outright.
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Of the more than 10 million issues detected across 166,000 pages, roughly 1 in 5 is high-risk. Put another way, the average page has about 13 high-risk issues, the failures that appear most often in litigation.
That ratio is remarkably consistent across industries, varying less than four percentage points from the lowest to the highest.
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No industry is meaningfully ahead of the others, which means no industry has solved it.
Litigation data reflects the same pattern
Web accessibility litigation has doubled in the last six years. The five criteria that fail most consistently are the ones that appear in those cases most often.
Severity ratings describe user impact. They also indicate legal risk. Year after year, plaintiffs target the same set of issues. Forms that can't be completed with a keyboard. Product images with no description for blind shoppers. Links that don't tell screen reader users where they're going.
These failures show up on most sites, and when they end up in court, their impact on users is difficult to dispute. The legal case almost writes itself: the failure is documented, the user impact is measurable, and the standard has been public for decades.
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The failures that block users are the same ones that end up in courtrooms.
When cases settle, the cost typically runs between $25,000 and $75,000, not counting legal fees, the executive time required to manage each case, or the cost of fixing the issues that triggered it. For organizations treating accessibility as a calculated risk, those numbers represent the floor.
Why the same failures persist
If resolving these five criteria would address nearly half of all detected issues and cut legal exposure, why hasn't anyone fixed them?
It comes down to four approaches, each with their own limitation. Most organizations will recognize themselves in one.
Not on the radar
These organizations aren't tracking accessibility at all. The failures on their pages are invisible to them, and so is the risk.
Testing, but not fully
These organizations rely on automated tools that cover only a portion of the page. The issues those tools miss are often the ones that carry the most risk.
Managing it in-house
These organizations manage accessibility in-house. Forty-four percent of leaders we surveyed run programs this way; 64% who do say they lack the expertise to do it well.
Waiting it out
These organizations have seen the litigation data and settlement costs and chosen to take their chances. The calculation is getting harder to justify.
None of these approaches reliably stay ahead of the high-risk issues that drive litigation. The volume and pace of change on most sites make that impossible without automation. The complexity of the failures that matter most make it impossible without human expertise. Most programs are built around one or neither.
The Forcing Function
Accessibility happens when something forces it. The EU has seen this before with GDPR enforcement.
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One year ago, the European Accessibility Act (EAA) went into effect. The expectation was progress.
A year in, our scan found something different. On average, EU sites had 25% more accessibility issues per page than U.S. sites.
That gap showed up across every industry we measured:
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Tech is the exception. EU tech companies are right alongside their U.S. counterparts, not because EU tech organizations care more about accessibility, but because their buyers require it. Enterprise procurement, developer tooling standards, and B2B sales cycles pushed accessibility up the priority stack. The forcing function arrived. The gap closed.
Every other industry in this chart is still waiting for its forcing function.
The 25% gap isn't evidence that EU organizations are behind. It's what any market looks like before a forcing function arrives. And the EU has more visibility into what comes next than any market in history — because it's already watched this play out.
GDPR followed the same pattern
A compliance deadline, widespread unpreparedness, and an enforcement curve that started quietly and compounded fast.
The first two years were quiet; most organizations took the quiet as confirmation that the urgency had been overstated.
It hadn’t.
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That’s not a slow build. €50M in year one, €746M by year three, and €1.2B by year five. GDPR went from “probably fine to wait” to the largest privacy fine in history in less time than most organizations run a compliance program.
But the speed isn’t the lesson. The risk was building through the quiet years; the fines were just the moment the risk became visible.
The organizations that read the early signals correctly didn’t wait for the Meta fine to tell them GDPR was serious. They built ahead of the curve and turned compliance into a competitive advantage. Privacy-first design became a differentiator. Trust became an asset. The organizations that moved early spent less, retained more customer trust, and didn’t have to rebuild their data infrastructure under pressure.
The ‘wait-and-see’ organizations did the work twice. First the rushed fix, then the fine, then the trust they had to earn back.
The EAA is at that same early, deceptively quiet stage. The organizations that recognize this moment have seen it before.
The EAA curve is already bending
EAA enforcement hasn’t produced a headline fine yet. What’s happening instead is messier and more telling: enforcement starting in pieces, across different countries, through different mechanisms on different timelines. Exactly the way GDPR started.
France
Disability rights organizations have filed cases against four major retailers. French law allows fines of €7,500 per infraction, €15,000 for repeat offenses.
Germany
Warning letters began in August 2025, six weeks after the BFSG took effect; fines from market surveillance authorities (up to €100,000 per violation) began earlier this year.
Norway
A healthcare company faces daily fines of NOK 50,000 until accessibility violations are resolved. Fines began in December 2025 after an inspection found 119 errors.
Italy
AGID's Determination No. 84/2026 unified enforcement into a single sanction process, a public complaint platform went live, and the agency declared 2026 the year of enforcement. Penalties reach up to 5% of turnover.
The curve has already started. And unlike the GDPR’s early years, the cost isn’t waiting for the curve to steepen.
The cost is already running
GDPR taught the EU a lesson that goes beyond the fines: the cost of unpreparedness doesn’t start when enforcement arrives. It starts the moment a gap exists. The fine was just the visible cost. The trust erosion was the real one.
The same dynamic is running in EU accessibility right now. Every inaccessible page is a worse experience for users with disabilities, and that cost doesn’t wait for a regulator, a warning letter, or a headline fine to arrive. Users with disabilities who encounter issues don’t convert. They don’t return. They don’t recommend. They route their spending and their loyalty to the organization that serves them.
$2.6 trillion
spending power of the disability community across the U.S., UK, EU, and Canada.
That market is already spending elsewhere. Most EU organizations aren’t set up to capture it.
The forcing function will eventually close the accessibility gap. But the revenue, the loyalty, and the trust in the meantime don’t come back when compliance arrives. The organizations that built ahead of the curve did more than avoid the fine. They captured the trust their competitors couldn’t buy back.
The Failures That Define Each Industry
Every industry is failing. The difference is where.
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Forty-eight issues per page. Across all seven industries, that’s the best average, and it belongs to government sites. Retail sites sit on the other end of the spectrum, with nearly 65 issues per page.
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What the totals don’t show is where the failures concentrate. Every industry has specific actions that can’t fail: the product images a shopper needs to decide what to buy, or the forms someone needs to schedule an appointment.
Which category fails depends on the industry. For professional services, issues cluster in contact forms, where client relationships typically begin. For SaaS companies, they concentrate on product images and links: the screenshots, demos, and documentation buyers need before deciding. For government sites, they land in interactive elements: the buttons and input fields residents use to renew licenses, access benefits, or apply for housing.
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Breaking at the wrong moment
The failures that matter most are the ones that block what users came to do: buy a product, access their health records, apply for a benefit.
In retail, those pressure points are product images and the checkout flow. Non-text content fails on 78.9% of retail pages; form fields lack labels or instructions on 49.1%. For a shopper using assistive technology, that combination can make it impossible to evaluate a product or complete a purchase.
"It's genuinely disheartening. And it's way too common. I could not tell you how many times I've been unable to access my cart, fill out my shipping information, or solve the CAPTCHA."
Chris Preiman, Internet Security Professional
Healthcare's failures land on similar ground, at higher personal cost. Name, Role, and Value fail on 74.8% of healthcare pages, leaving assistive technology unable to identify on-screen components or their functions. Keyboard accessibility fails on 31.3% of pages. On a patient portal, those two failures can make it impossible to schedule an appointment or access lab results without help. For medical records, needing help means someone else is in the room.
“If test results aren’t accessible, I have to wait for someone to help me. Even if they only know the results seconds before me, it’s the principle of the thing. These are my test results.”
Ana Jacob, AudioEye A11iance Member
Many users with disabilities leave and don’t return
The issues on checkout pages, patient portals, and government benefits sites produce the same result. Not a complaint filed, not a call to customer support. Just a closed tab, and a customer gone.
“I run into problems all the time trying to transfer funds or make payments. But I rarely reach out to companies. I just cringe thinking about how I’m going to explain it to people. It feels so daunting.”
Dave Carlson, AudioEye A11iance Member
That silence doesn't register as lost business. It just disappears.
Sixty-two percent of business leaders believe customers have abandoned transactions on their site because of accessibility issues. But sensing it and measuring it are different problems. Accessibility issues don't show up as a stated reason for leaving. Teams see the drop-off rates and abandoned carts. The cause stays invisible. Lawsuits are how the problem finally becomes visible, not where it begins.
62%
of business leaders believe customers have abandoned transactions on their site because of accessibility issues
The same customers who leave when a site fails them come back when it works. People with disabilities who find a site accessible tend to return to it and recommend it. They control over $2.6 trillion in disposable income(opens in a new tab) across North America and Europe, and organizations that get accessibility right earn a disproportionate share of it. The gap between knowing that and acting on it is where that share is lost.
Where To Focus First
Issues across every industry are concentrated and predictable. That also means they're fixable, with the right approach. Here's where to start.
1. Start with your highest-traffic pages.
The failure rates in this report are averages. Your site has its own profile. Traffic to interior pages has grown, and those pages average more issues than homepages. The pages users are landing on first may not be the ones your program prioritizes.
2. Pay attention to where issues concentrate, not just how many there are.
For your site, the question isn’t just the total number of issues. It’s also how they impact users. Some issues create friction. Others create walls. Roughly 1 in 5 issues is high-risk: the kind that stops completion entirely and shows up most often in litigation. Those are the ones worth finding first.
3. Match your approach to what your site actually requires.
The right approach depends on how complex your site is and how often it changes. For most organizations, that means automated technology to handle scale and human expertise for the issues that require human review. Getting that combination right ahead of the regulatory curve reduces legal exposure. It also positions you to earn from $2.6 trillion in disposable income held by people who actively limit their spending to sites they know are accessible.
Curious how your site compares to our scan results? The scanner below is a starting point. It shows you where your issues concentrate, breaks them down by severity, and tells you whether high-risk failures are hiding in plain sight.
Methodology
To evaluate the current state of digital accessibility, AudioEye scanned 166,457 web pages across 6,161 domains, representing seven industries: retail, technology, manufacturing, professional services, finance and legal, healthcare, and government agencies.
Using AudioEye's automated accessibility scanner, we ran more than 207 million element-level tests across 91 rules and 25 WCAG success criteria, tested against Web Content Accessibility Guidelines (WCAG) 2.2 Level A/AA standards. The scan identified more than 10.3 million accessibility issues, with an average of 62 issues per page across all industries scanned.