The European Union recently adopted a directive called the European Accessibility Act (EAA). Unlike a regulation, a directive gives member states some flexibility in implementing its rules within their own law. As a result, Poland created the Polish Accessibility Act (PAD). It specifies which products and services must meet accessibility requirements and to what extent. Other EU countries have also implemented the EAA through their own national laws, for example, Spain via Ley 11/2023, Italy with Legislative Decree 82/2022, and France through Law 2023-171, so the accessibility requirements apply well beyond Poland. These law concerns entrepreneurs, service providers, digital product creators, and if you’re reading this, there’s a high likelihood you’re in this group.
All of this is also related to WCAG, which stands for Web Content Accessibility Guidelines – a set of international standards to help create digital content accessible to everyone, including people with disabilities. Thanks to these rules, your website, application or e-book can be more useful and inclusive for people with various limitations.
No. However, under the EAA, each EU country transposes the directive into its own national law, often by referencing established technical standards. These typically include compliance with WCAG 2.1 (level AA), in some cases, elements of WCAG 2.2, and the EN 301 549 standard, the EU-wide technical benchmark for accessibility. The law imposes obligations on manufacturers, importers, distributors and service providers for a range of products and services, as shown below.
Products:
Services:
Who does it not apply to? Currently, micro-enterprises that employ fewer than 10 people and have an annual turnover of less than €2 million are excluded from the scope of e-commerce services. This exemption comes directly from the EAA and is reflected in most national laws, not just in Poland. However, beware if you sell products, even as a small company, you may still be subject to accessibility requirements, depending on the type of offer.
However, even if you don’t have to implement anything yet, it’s worth considering digital accessibility now. It’s not only a sign of respect for your customers, but also a way to build a stronger brand and create an internet that everyone can use without barriers.
The key document to know is EN 301 549 (version 3.2.1) – the European technical accessibility standard. This standard specifies what technical accessibility criteria digital products and services in the European Union must meet.
The standard contains detailed guidelines for digital and technological solutions, regardless of whether we are talking about websites, applications, devices, or communication support systems. Its purpose is to harmonize requirements across the EU. Compliance with EN 301 549 is mandatory for entities covered by the EAA (European Accessibility Act) directive, which we mentioned earlier.
Version 3.2.1 of this standard is fully based on WCAG 2.1, which guarantees compliance with global best practices in digital accessibility.
One might ask: “Why all this standardization? Can’t you just say: ‘implement WCAG 2.1’?” Well, not exactly. EN 301 549 extends the scope – it covers not only digital content, but also technological infrastructure, interfaces, and digital services in a broader sense. WCAG is only part of the bigger picture.
Let’s summarize how it connects:
Let’s discuss WCAG in more detail, as we’ve only touched on it lightly so far. We already know that the PAD obliges us to apply WCAG guidelines in version 2.1 (level AA), and partially also 2.2 – especially in the context of good practices and projects currently being implemented or in the future.
Until October 5, 2023, the organization responsible for creating and developing WCAG standards, W3C (World Wide Web Consortium), used version 2.1. On that day, the official extension of WCAG 2.2 was announced, which introduced 9 new success criteria to the existing ones. The change was a response to the growing importance of mobile devices, such as smartphones and tablets, and the development of digital products and content, e.g., e-books.
Ultimately, WCAG 2.2 is a comprehensive set of guidelines aimed at people creating digital products, content creators, decision-makers, as well as all those who are responsible for and participate in creating digital accessibility.
What is the most important difference between versions 2.1 and 2.2? The new guidelines provide even better support for people with low vision, cognitive limitations, and users with physical limitations, e.g., people with large fingers, hand deformities, or motor disabilities who have difficulty operating touch devices.
An example of a new criterion from WCAG 2.2 is “Accessible Authentication” (3.3.7), which eliminates the need to solve CAPTCHA puzzles or remember complex passwords – a huge convenience for people with cognitive disorders.
It is also worth emphasizing that WCAG 2.2, as well as WCAG 2.1 (contained in WCAG 2.2), benefits not only people with disabilities. These standards enhance the usability of content for all users, regardless of their current conditions, environment, or mood, which are often overlooked in designing main and alternative use scenarios.
For example, people with hearing impairments need subtitles for video materials. However, people in a crowded subway who forgot their headphones, or people on the autism spectrum or with ADHD who are currently overstimulated by sound, can also use this feature. Each of them is a potential user, client, or recipient.
Therefore, implementing WCAG 2.2 also brings real business benefits.
Detailed guidelines can be found directly on the W3C website (I encourage you to read them).
User Experience (UX) is a popular term today, often used interchangeably (though incorrectly) with UI, or User Interface. UX is not just about appearance or aesthetics – it’s the entire user experience, which begins much earlier than the moment an application is launched. A good user experience is based on empathy, understanding, and a deep knowledge of the recipient’s needs. It’s a design process that starts by asking: what does the user feel, what challenges do they face, and how can we truly help them?
But UX is not just the domain of designers. It’s a social and life phenomenon. And this is where accessibility comes in. We live in a world designed by a specific group of people – for themselves and by themselves. This is a natural mechanism. The problem arises when everyone else – those who don’t fit the “default” pattern – are excluded.
When we think about accessibility, people in wheelchairs or who are blind most often come to mind. Meanwhile, the group of people at risk of exclusion is much broader – it includes people with visual impairments, hearing loss, or other disabilities of varying severity and also users with any motor limitations, atypical hand structure, larger hands, or age-related limitations.
Increasingly, there is also talk about the needs of neurodivergent people, whose difficulties may be less visible but just as real. This includes people with ADHD, autism, OCD, anxiety disorders, dyslexia, or schizophrenia. Their experience with digital systems can vary significantly, and their needs often go unnoticed in the design process.
There is a whole group of difficulties not visible at first glance, which may result from life situations, mental health, or temporary overload. And that’s why accessibility should be understood broadly – as designing for diversity, not just for the chosen few. As you can see, this is quite a large group of people. According to the World Health Organization estimates, in 2023, there were 1.3 billion people with disabilities worldwide, which constituted 16% of the global population (your potential audience or customers). Of course, that doesn’t mean you need to go to extremes. It is not possible to adapt products for everyone from every angle. That is why the WCAG guidelines are so crucial, as they meet us halfway and make things easier, giving us proven and verified requirements.
Returning to the topic, you can also temporarily be a person with limited access. Imagine you are on the beach, forgot your sunglasses, and your phone screen is almost unreadable, but you need to quickly check your account balance. This is also exclusion, though situational.
What am I getting at? UX is not just a digital product. UX is about caring for every user, in every situation. And accessibility is not a luxury – it’s a sign of respect. That’s why in this section, I will focus on empathy as the foundation of designing experiences that are truly accessible.
To truly understand our users, let’s try to put ourselves in their shoes and imagine it through the lens of transport exclusion.
Let’s say you live in a small village. Your neighbors all have cars – some better, some worse – but you have no means of transportation. What’s worse, public transport in your area simply doesn’t exist because “it’s not profitable for anyone.” As a result, your neighbor from next door can easily go shopping, bring their groceries back, and return, while you have to embark on a walking marathon of your life to do the same. And if you want to get to a bigger city, you are dependent on the goodwill of someone who has a car.
But now imagine someone gives you a bicycle. Maybe it’s not luxurious, but it’s something – you don’t have to walk. Later, someone else gives you an electric scooter – it’s faster, although a bit less comfortable in autumn. And finally, after some time, a group of people from your community decides to take action – and from now on, a bus runs every hour. Although you still don’t have the same opportunities as those with cars, your comfort has significantly increased, and the level of exclusion has clearly decreased.
This is how accessibility works.
It’s not about everyone having the same thing; it’s about everyone having real access to act, participate, and use. Pay attention to ramps for wheelchairs, designated parking spaces for people with disabilities, and audible signals at crossings. All of this happens in the physical world, not the digital one, yet it is also UX – user experience.
Accessibility is essentially about creating a space where more people can participate without obstacles or, at the very least, with less effort.
Let’s move on to the creative process itself, based on empathy and considering accessibility. Of course, we have plenty of design tools to use during the empathizing stage, such as the design thinking methodology. However, I would like to focus on personas because they work well in both design and defining business goals of projects before a project even reaches a designer. According to the CDC (the Centers for Disease Control and Prevention), people with disabilities may experience problems in specific areas: vision, movement, thinking, remembering, learning, communication, hearing, mental health, and social relationships.
It is worth considering the probability of certain limitations when segmenting the target group. For example, if we are designing an application for construction workers, we can assume that some users – due to the nature of physical work – may have calloused or broad fingers. In such a case, a well-designed persona might look like this:
Another example is:
Therefore, it is worth considering – completely independently of WCAG – creating personas that take into account specific limitations from various exclusion groups. Especially if we know that such a group will be a dominant part of our audience.
One can also expand classic UX tools, such as the empathy map, to include the most common limitations. Example questions worth asking:
It can also be helpful to supplement the user journey with typical life situations of our users. An example could be an application aimed at mothers. In such a tool, it is worth considering a scenario where a mother holds a child in one arm, operates the phone with the other hand, and the children are running around. One child is crying, and she needs to quickly access the necessary information. In this case:
Of course, it’s easy to talk about assumptions. But true empathy is born where we are able to listen. That is why it is worth conducting interviews, tests, reading available materials and reports, especially if we are creating a product for a specific target group. The point is to understand their real needs and limitations and introduce dedicated solutions already at the design stage.
Accessibility is not just WCAG. It is a set of guidelines that will not design the information architecture for us, will not build the user experience, and will not tell us where to place a given button. It is we, as designers, researchers, and creators, who are responsible for how we use the information available to us.
Therefore:
It is precisely the combination of empathy and knowledge that leads to the best solutions.
Previously, we talked a lot about accessibility, mainly in the context of users’ physical needs (e.g., vision, hearing, or mobility problems). However, it’s worth looking broader. Cognitive accessibility is increasingly being discussed, which responds to diverse ways of thinking, processing information, and reacting.
And this is where Cognitive Design comes in, which is an approach that considers how the human brain works in contact with a product. In the context of UX/UI, we more often talk about Cognitive UX, which is the implementation of these principles in digital interfaces.
Cognitive Design vs. Cognitive UX
In other words, Cognitive UX is a part of Cognitive Design – it’s practical and specific, but it stems from the same idea: designing in harmony with the capabilities and limitations of the human mind. I encourage you to explore the topic further.
In recent years, we have observed an increase in diagnoses related to cognitive diversity, partly due to changes in the classification of cognitive disorders in ICD-11. Simultaneously, cognitive science is developing, which studies how humans perceive the world, process stimuli, and learn.
Moreover, the concept of neurodiversity (i.e., differences in brain functioning) is gaining social visibility in both design and everyday services.
This can be seen, for example, in public spaces: “quiet hours” in stores, dimmed lights in shopping malls, fewer stimuli – all for sensory-sensitive individuals. Interestingly, neurotypical people do not lose anything, but neurodivergent people gain immensely.
Cognitive design involves creating solutions for people with difficulties in focusing attention, information processing, working memory, and understanding complex structures. We are talking about people with (among other things): ADHD, autism, dyslexia, anxiety disorders, cognitive overload (e.g., due to stress, fatigue, life situations), etc. Therefore, a well-designed interface should be intuitive, simple, uncluttered, and predictable.
Key principles of Cognitive Design:
Not only WCAG, but also Nielsen’s heuristics come to the rescue, which is a set of universal principles that will work in any system. Often falling within the scope of WCAG, they allow for managing feedback, supporting user memory, assisting in decision-making and strengthening the sense of control. Below, we will list and describe all 10 of them.
The system should continuously inform the user about its current state in the context of a specific process.
Examples:
Such feedback gives a sense of control and reduces cognitive anxiety.
Icons, buttons, components, and layouts should be understandable because they reflect known standards, both from the internet and the physical world. For example, play/pause icons resemble those from tape recorders, MP3 players, or YouTube. This is not a coincidence, but conscious design consistent with the user’s mental model.
Language is equally important. Texts should appeal to the recipient’s natural context and be understandable to them.
The user should:
It is also important to anticipate and support users’ mental models – time and budget permitting.
The system is a whole; when designing, let’s not focus solely on individual screens. Inconsistencies, such as different fonts, colors without justification, or sudden style changes, can disrupt the rhythm. It’s like someone building a single-family house in the middle of a housing estate with apartment blocks, which surprises and disrupts the consistency of the space.
Exception: You can consciously break consistency to highlight something – but it should be done tastefully and for a specific purpose.
Before the user fills anything in:
The goal is to minimize the possibility of making a mistake before it happens.
Don’t make the user remember everything; create “trustworthy” systems that:
This is enormous support for people with memory impairments, cognitive overload, or difficulty concentrating.
Each of us functions differently – due to environment, habits, and even the devices we use, which influences the diversity with which we interact with products. A well-designed system should:
This is particularly important in the context of cognitive accessibility.
Avoid overwhelming the user with excessive information, colors, and other stimuli unless necessary. The rule is: the more options and distractions, the harder the decisions (the so-called paradox of choice). Therefore:
Curiosity: well-known leaders (e.g., presidents, CEOs) often minimize daily choices (eating the same food, wearing the same clothes) to save cognitive resources for important matters. It works similarly with digital systems.
Feedback is crucial. Lack of feedback = frustration, and we want to avoid that. If the user makes a mistake, they should:
Not everything can be designed intuitively, especially in complex systems (e.g., government portals, engineering applications). In such cases:
We already know what cognitive UX is, what its assumptions are, and why it’s worth using. But how does this translate into the real challenges of specific individuals?
After all, just as someone with larger fingers needs bigger buttons, and a person with impaired vision needs stronger contrast, neurodivergent people have different needs that are not always obvious.
People with ADHD often have difficulties with:
Distractions such as pop-ups, animations, and flashing elements can effectively pull them away from their goal.
How to help them?
For people on the autism spectrum, challenges can include:
How to help them?
For people with dyslexia, the biggest problems are:
How to help them?
Of course, this is a very broad and diverse group, so treat these examples as a starting point, not a complete study. My goal is to highlight the topic and demonstrate how it translates into practical design. This is just scratching the surface, but even at this level, we can start designing more consciously. If you want to learn more about the topic, these articles will help you:
We have listed only a few examples, and the topic is much more complex, just as the number of variables is immense. However, even such a general approach allows us to understand the challenges faced by people with different ways of processing information, and where our role as designers begins. It will certainly be helpful to familiarize yourself with the concept of cognitive load.
Ultimately, these small changes make users more willing to return to your product. Cognitive design is not just about caring for diversity; it is about designing with empathy, which improves a person’s psychological well-being and their relationship with technology. And that is what good UX is all about.
As I mentioned earlier, UX and UI are closely related, but they cannot be equated. Therefore, let’s now focus on what we can do in the UI area for better digital accessibility.
Of course, the most important are the WCAG guidelines, which every designer should know and implement. But merely meeting their technical requirements does not yet guarantee a friendly and accessible user experience.
Take, for example, colors or content layout – even if WCAG-compliant, they can be unreadable or disorienting if design intuition is lacking. That’s why aesthetics and clarity, clear content hierarchy, and conscious use of animations and microinteractions are crucial. A good UI designer should therefore combine knowledge of standards (like WCAG, cognitive design) with empathy, understanding of the target group, and practical experience.
What should you pay attention to when designing an accessible UI?
Ensure that all texts and interface elements have adequate contrast – not only because of WCAG, but simply for convenience. Remember that color cannot be the sole carrier of information – for example, do not mark errors only in red without text or an icon.
Every button, link, or form field should have clear states so that users relying on keyboards or screen readers can easily navigate the page.
A loader, a change in button state after clicking, and a message after saving – all these elements assure the user that the system is working. A lack of such signals often leads to frustration.
Divide content into sections, use visual hierarchy, and avoid too many options at once. Help the user focus on what is important at a given moment.
The interface must work and look good on both a phone and a large monitor – not only visually, but also functionally. Ensure that the content is readable with high zoom and that the layout does not break.
Beyond technique, the Gestalt principles can be a huge help for designers. These are rules derived from the psychology of perception. They describe how the human brain perceives the arrangement and meaning of visual elements.
We don’t look at an interface as a collection of independent dots, lines, and blocks; we see them as an organized whole. And it is on this basis that you can build an intuitive UI.
Here are the most important Gestalt principles in the context of UI:
Fortunately, you don’t have to do everything from scratch. In the work of a UI designer, the following will be useful:
I encourage you to explore your software, design system documentation, and ready-made UI kits, which will speed up your work.
Creating an accessible UI is not just about meeting WCAG requirements. It is primarily about designing with people in mind: their limitations, habits, and emotions. Combining technical knowledge, the psychology of perception, and empathy will allow you to create solutions that are not only correct, but simply good and useful.
Moreover, accessibility is not just about UX; it’s about the entire Customer Experience. Inclusive design doesn’t end with WCAG compliance; it begins where a designer’s and a company’s conscious intention emerges to truly open up to diverse users. It’s worth remembering that accessibility today is not just a formal requirement, but also:
And most importantly… As designers, product managers, or business owners, we should view accessibility not as an obligation, but as an opportunity. An opportunity to:
Accessibility is designing for real people – like you, me, and your loved ones. A sustainable digital product that meets their needs will always defend itself, also commercially.
