WAD for healthcare: requirements, priorities, and audit checklist

FAQ

Frequently asked questions

Cited answers. Sourced. Updated as standards and case law change.

• Does WAD apply to healthcare websites?

  The EU Web Accessibility Directive (Directive (EU) 2016/2102) requires public-sector bodies in all EU member states to make their websites and mobile apps accessible per EN 301 549, with mandatory accessibility statements and a complaints mechanism — operative since September 2018 for new sites and September 2020 for all sites.

• What are the most common WAD failures in healthcare sites?

  Patient portal logins without screen-reader-accessible MFA Telehealth video without captions or sign-language interpreter integration Symptom checkers built as inaccessible single-page apps

• What conformance level should a healthcare site target?

  WCAG 2.2 Level AA is the consensus target for legal compliance and the level referenced by virtually every national accessibility law.

• What does HHS Section 1557 require for accessibility?

  The May 2024 final rule requires entities receiving federal financial assistance from HHS — virtually all hospitals, clinics, and insurers — to conform to WCAG 2.1 AA for web content, mobile apps, and kiosks. Compliance deadlines stagger from May 2025 through May 2027 based on entity size.

• Can a healthcare site use an accessibility widget?

  Widgets are problematic in healthcare for two reasons: (1) WCAG conformance must be at source level, not via overlay; (2) HIPAA-covered information transmitted to a third-party overlay vendor may itself create a breach. Most healthcare CISOs disallow third-party overlay widgets.

• Does WCAG 2.1 cover telehealth video?

  Yes — Criterion 1.2.4 requires real-time captions for live audio content, which includes telehealth visits. 1.2.6 (Sign Language, AAA) is recommended for healthcare emergency content.