The verdict in three sentences
A health insurer that lets customers buy, quote or manage a policy online falls within the scope of the European Accessibility Act, applicable across the EU since 28 June 2025. A realistic budget for WCAG 2.2 AA compliance sits between 6,500 and 21,000 EUR including the audit, over 6 to 12 weeks. The most underestimated item is not the website itself but the PDFs (benefit tables, policy documents) and quote forms.
Why a Dublin insurer is in scope
The digital lead of a Dublin health insurer with 60,000 members often assumes accessibility rules only target public bodies. That was true before 2025. Ireland's transposition of the European Accessibility Act extends obligations to e-commerce and consumer banking services: as soon as a journey lets users compare cover, request a quote or sign a policy, it must meet the harmonised standard EN 301 549, which maps to WCAG. Penalties vary by member state; France, for example, sets up to 50,000 EUR per non-compliant service, and Ireland provides for fines and prosecution through its market surveillance authorities.
Beyond legal risk, around 1 in 5 Europeans lives with a disability or long-term limitation, and members over 65 often represent 30 to 40 % of a health insurer's book. A quote form that breaks at 200 % zoom loses sales.
Most failed criteria and their fix cost
Audits of insurance websites in 2025 and 2026 show the same recurring themes. Costs below are 2026 orders of magnitude for an 80 to 150 page site.
| Theme | Typical defect | Observed frequency | Indicative fix cost |
|---|---|---|---|
| Colour contrast (WCAG 1.4.3) | Light grey text on white below 4.5:1 | 80 to 90 % of sites | 800 to 2,000 EUR (colour token redesign) |
| Forms (1.3.1, 3.3.1 to 3.3.3) | Unlabelled fields, unannounced errors | 75 to 85 % | 2,000 to 5,000 EUR (quote tool and forms) |
| PDF documents | Scanned or untagged benefit tables | 70 to 90 % | 40 to 150 EUR per PDF, often 30 to 80 documents |
| Keyboard navigation (2.1.1, 2.4.7) | Menus and modals not keyboard operable | 60 to 70 % | 1,000 to 3,000 EUR |
| Images (1.1.1) | Missing alternatives, decorative images mishandled | 60 to 75 % | 400 to 1,200 EUR |
| Structure (1.3.1, 2.4.6) | Skipped headings, unmarked lists | 50 to 65 % | 500 to 1,500 EUR |
| Media (1.2.2) | Videos without captions or transcripts | 40 to 60 % | 150 to 400 EUR per video |
WCAG 2.2 AA contains 55 success criteria, including 9 added in 2023 such as focus not obscured and minimum target size. A serious audit covers a representative sample of about 20 pages (home, cover pages, quote tool, member area, contact, legal) and produces a compliance rate that underpins the accessibility statement.
The full budget, line by line
| Item | 2026 range | Lead time |
|---|---|---|
| WCAG 2.2 audit on 20 pages | 2,500 to 6,000 EUR | 2 to 3 weeks |
| Front-end and form fixes | 4,000 to 15,000 EUR | 3 to 8 weeks |
| PDF remediation | 1,500 to 8,000 EUR | 2 to 4 weeks, in parallel |
| Validation re-audit | 1,000 to 2,500 EUR | 1 week |
| Accessibility statement and roadmap | 500 to 1,500 EUR | A few days |
| Editor training | 800 to 2,000 EUR per session | 1 day |
When the site is old (a 2018 WordPress theme, a third-party quote tool in an iframe), fixing can cost more than an accessible-by-design redesign. A Kolonell premium redesign costs 2,000,000 to 3,500,000 FCFA, i.e. 3,050 to 5,340 EUR, built on a WCAG 2.2 compliant foundation; PDF remediation and the external audit are priced separately.
Mini case study
Siobhan, digital lead at a Dublin health insurer with 60,000 members, receives a first audit: 48 % compliance, 42 untagged benefit PDFs, a quote tool unusable by keyboard.
Fix option: audit 4,200 EUR, fixes 11,500 EUR, PDFs 42 × 90 EUR = 3,780 EUR, re-audit 1,800 EUR. Total: 21,280 EUR.
Need a professional website?
Kolonell builds websites that attract clients, optimized for the Sénégalese market. Free quote in 2 minutes.
Redesign option: audit 4,200 EUR, premium redesign 5,340 EUR, rebuilt quote tool 4,000 EUR, PDFs 3,780 EUR, re-audit 1,800 EUR. Total: 19,120 EUR, with a brand new site.
If the accessible quote tool wins just 15 extra policies a year at 600 EUR annual premium, i.e. 9,000 EUR, the investment pays back in just over 2 years, before counting the penalty risk avoided.
FAQ
Does the European Accessibility Act really apply to insurers?
Yes, as soon as the insurer sells or manages policies online, which counts as an e-commerce service. Microenterprises with fewer than 10 staff and under 2 million EUR turnover are exempt, which never covers an insurer with 60,000 members.
Do we need 100 % compliance?
The site should aim for full compliance, but the statement can declare partial compliance with a dated remediation roadmap. Below roughly 50 %, regulators treat the site as non-compliant.
How long does compliance take?
Budget 6 to 12 weeks for an 80 to 150 page site. PDFs are often the critical path when there are more than 50 of them.
Is WCAG 2.2 the same as France's RGAA?
France's RGAA 4.1 translates WCAG 2.1 AA into 106 testable criteria. Covering the 9 extra WCAG 2.2 criteria adds 5 to 10 % to the budget and anticipates the next standard update.
Who maintains compliance after the project?
Every new page or PDF can break compliance. Kolonell monthly maintenance (35,000 to 120,000 FCFA, i.e. 50 to 180 EUR) covers technical checks; editor training remains essential.
Let's scope your project. We price the audit, fixes or accessible redesign of your website with a 6 to 12 week schedule and a ready-to-publish accessibility statement. Detailed quote within 48 h via our quote form. WhatsApp +221 77 596 93 33.
Mohamed Bah
Fondateur, Kolonell
Passionate about digital and entrepreneurship in Africa, Mohamed has been helping Sénégalese businesses with their digital transformation since 2020. Founder of Kolonell, he believes every SME deserves a professional and accessible online présence.
