The verdict in three sentences
Since 28 June 2025, the European Accessibility Act has extended digital accessibility duties to many consumer-facing online services, including taking out and managing contracts on a website or app. For a Dublin health insurer with 180,000 members, the work comes to a 2026 ballpark of 20,000 to 45,000 euros for a WCAG 2.2 AA audit on 20 pages, remediation of 60 to 120 issues and the documentation, over 12 weeks. Doing nothing carries real exposure: Irish market surveillance authorities can issue compliance notices and pursue penalties, and older or disabled members file complaints when they cannot claim online.
What the rules require of an Irish health insurer in 2026
The head of communications at a Dublin health insurer runs three digital services: the public site with quotes and online joining, the member portal (claims, certificates, policy documents) and a mobile app. Ireland transposed the EAA through the European Union (Accessibility Requirements of Products and Services) Regulations 2023, which apply to e-commerce services and online contract journeys aimed at consumers. EN 301 549, which maps to WCAG at level AA, is the reference standard. The exact scope depends on your products and size: have your legal team confirm it.
| Requirement | What it means | Status | Risk if missing |
|---|---|---|---|
| WCAG 2.2 level AA | key pages and journeys meet the success criteria | applies now | compliance notice, penalties |
| Accessibility information | describe how the service meets requirements | published and maintained | enforcement action |
| Accessible joining and renewal | quote, purchase and policy changes usable by all | since 28 June 2025 | complaints, enforcement |
| Accessible member portal | claims, documents, login, session timeouts | since 28 June 2025 | complaints, call volume |
| Feedback mechanism | a way to report barriers and get content | ongoing | escalation to regulator |
| Mobile app coverage | the app is a separate service | since 28 June 2025 | separate exposure |
Health insurers have a large share of older members: in many books, more than 30% are over 60. For them, poor contrast or a claim form that cannot be used with a keyboard turns into a call to the contact centre, which costs far more than the fix.
Budget: audit, remediation and documentation
The audit covers a representative sample: home, product pages, quote tool, joining flow, login, member dashboard, claim submission, certificate download, contact, legal pages. Twenty pages usually cover every template. Here are 2026 ballpark figures in Dublin.
| Line item | Scope | 2026 ballpark (EUR, ex VAT) |
|---|---|---|
| WCAG 2.2 AA audit on 20 pages | 55 success criteria, NVDA, JAWS and VoiceOver testing, detailed report | 5,000 to 9,000 |
| Template remediation | components, contrast, keyboard navigation, ARIA | 8,000 to 19,000 |
| Journey remediation | joining and claim forms, PDFs | 5,000 to 13,000 |
| Accessibility statement and roadmap | drafting, publication, 3-year plan | 1,000 to 2,000 |
| Content editor training | accessible writing, alt text, PDFs | 1,000 to 2,000 |
The total lands between 20,000 and 45,000 euros. The remediation share varies mostly with architecture. If the site runs on a shared component library, a fix made once applies everywhere. If every page was built by hand, cost climbs quickly. Plan another 2,000 to 3,500 euros for a validation re-audit if the board wants independent sign-off.
The issues we find almost every time
On a health insurer site, an audit usually finds 60 to 120 issues. They cluster in a few areas, and many can be fixed at template level.
| WCAG area | Typical issue count | Concrete example | Fix effort |
|---|---|---|---|
| Contrast (1.4.3) | 8 to 15 | light grey text on white at 2.8:1 instead of 4.5:1 | low, in the design system |
| Text alternatives (1.1.1) | 10 to 20 | benefit icons with no alt text | low |
| Forms (1.3.1, 3.3.1, 3.3.2) | 12 to 25 | unlabeled fields, errors shown by colour only | medium |
| Keyboard and focus (2.1.1, 2.4.7, 2.4.11) | 6 to 12 | no skip link, hidden focus, illogical tab order | medium |
| Custom widgets (4.1.2) | 8 to 18 | quote calculator unusable by keyboard | high |
| Headings and structure (1.3.1, 2.4.6) | 6 to 12 | H1 to H4 out of order | low |
| Timing and documents (2.2.1) | 5 to 15 | silent session timeout, untagged PDFs | medium to high |
PDFs need special attention: certificates, benefit tables and policy booklets are often generated untagged. Producing them as accessible HTML or tagged PDF from the policy system avoids fixing them one by one. If a redesign is coming, building accessibility into the designs costs far less than retrofitting, as covered in our article on a headless rebuild of a large site.
The 12-week plan runs as follows: weeks 1 to 3 for the audit, 4 to 9 for remediation in batches starting with templates, 10 for documentation and training, 11 and 12 for the re-test and publication of the statement.
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Mini case study
Aoife, head of communications at a 180,000-member health insurer in Dublin, builds the case for the executive team. Budget: audit 7,000 euros, remediation 24,000 euros, documentation and training 2,500 euros, or 33,500 euros.
On the risk side, three services are exposed (public site, member portal, app). On the operations side, the contact centre gets about 1,200 calls a month from members stuck on an online task. Each call costs about 6 euros of agent time. If the fixes remove half of them, savings reach 600 x 6 = 3,600 euros per month, or 43,200 euros per year. The project pays back in 33,500 / 3,600 = 9.3 months, before counting the regulatory risk avoided.
FAQ
Do we need to pass 100% of WCAG 2.2 AA criteria?
Full conformance is demanding and rarely reached in one pass. Fixing all critical journeys and reaching at least 75% of criteria within 12 weeks, with a credible roadmap for the rest, is a defensible path.
Is an accessibility overlay widget enough?
No. Overlays fix neither form code nor keyboard navigation, and they can get in the way of screen readers. They do not deliver WCAG conformance, yet they often cost 500 to 2,000 euros per year.
Is the mobile app in scope?
Yes, it is a service in its own right and needs its own assessment. An app audit usually costs 4,000 to 7,000 euros depending on the number of screens.
How often should we re-test?
After every major release and at least once a year. An annual re-audit on 10 to 20 pages costs about 2,000 to 3,500 euros.
Does WCAG 2.2 differ much from 2.1?
It adds 9 success criteria, 6 of them at levels A and AA, such as focus not obscured, target size of at least 24 by 24 pixels and accessible authentication. Kolonell handles audits and remediation within its cybersecurity and compliance work.
Let's scope your project. List your digital services and your members' key journeys, and we will scope the WCAG audit, the remediation plan and a 12-week timeline. Detailed quote within 48 h. 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.
