Booked, but not for everyone
Since June 2025, selling rooms online to guests in the EU has come with accessibility rules. We scanned the booking sites of 98 hotel groups and chains in Türkiye and Europe, from the home page to the first booking step. Nearly all of them have barriers that can stop a guest who uses a screen reader, a keyboard or a zoomed-in screen.
A hotel's booking site is a shop. Guests pick dates, compare rooms, enter their details and pay. Under the European Accessibility Act, every one of those steps has to work for people who can't see the screen well, can't use a mouse or need to zoom in. Sixteen months after the rules came into force, we wanted to know how far hotel groups have got. So we took 100 groups and chains, scanned every site we could, and are publishing the numbers without naming anyone.
The rules cover the whole booking, not only the payment.
The European Accessibility Act (Directive 2019/882) has applied since 28 June 2025. One of the services it covers is e-commerce, and selling a hotel room online to a consumer is e-commerce. What counts is who the service is sold to, not where the company is based: a hotel group in Antalya that sells rooms from its own site to a guest in Germany or the Netherlands is in scope. Microenterprises that provide services, those with fewer than ten people and no more than €2 million in turnover, are exempt, which is why we only looked at groups and chains.
The technical yardstick in Europe is the harmonised standard EN 301 549, which takes its web requirements from WCAG 2.1 level AA. That is what we measured against. A failure against WCAG is a barrier for a guest. Whether it is also a breach of the law is for national authorities and a hotel's own lawyers to judge, and we don't make that call for anyone.
Nearly every site has the same handful of problems.
We scanned up to three pages per site: the home page, a room page and the first booking step, each on a desktop screen and on a phone. The median site failed five different WCAG rules. Most of the list below is the basics: text people can read, links and buttons with names, pictures with descriptions, form fields with labels.
| ≥1 serious barrier | Median rules failed | Links a statement | |
|---|---|---|---|
| Turkish hotel groups | 29 / 30 | 4 | 1 / 30 |
| European hotel groups | 28 / 29 | 5 | 9 / 29 |
| International chains | 11 / 13 | 5 | 6 / 13 |
The international chains do a little better on serious barriers and much better on accessibility statements, which suggests a central team with a written policy makes a difference. Turkish and European groups are almost level on barriers; on statements, the European groups are well ahead.
Where it matters most, it's no better.
You might expect the booking step to get the most care, since that is where the money changes hands. It doesn't. Of the 29 booking steps we could open directly, 27 had at least one serious or critical barrier, and 22 had a control with no name: a date button, a guest-count selector or a "continue" link that a screen reader announces only as "button" or "link". A sighted guest sees a calendar icon. A blind guest hears nothing that tells them which button opens the dates.
On at least 9 of the 72 sites, the "Book" button takes the guest to a booking engine on another company's domain, and many more run an engine on a subdomain of their own. Either way, the guest believes they are booking with the hotel, and the hotel is the one selling the room. That's why accessibility belongs in the contract with the engine provider, together with a test the provider has to pass.
- 1“button”
- 2“button”
- 3“button”
- 4“link”
- 1“Previous month, button”
- 2“15 October, available, button”
- 3“Remove an adult, 2 adults, button”
- 4“Show availability, button”
A widget isn't a fix. A statement is a start.
5 of the 72 sites load an accessibility overlay, a widget that promises to make a site accessible with one line of code. 4 of those 5 still had serious or critical barriers in our scan. That matches what accessibility practitioners have said for years: an overlay changes how a page looks for people who find and use the widget, but it doesn't fix the code underneath, and that code is what a screen reader reads.
The EAA asks service providers to publish how their service meets the accessibility requirements, and a linked accessibility statement is the usual way to do it. 16 of the 72 sites link one from the home page: 6 of 13 international chains, 9 of 29 European groups and 1 of 30 Turkish groups. A statement doesn't make a site accessible. But writing an honest one makes a team find out where it stands.
Start with the path to the booking, not the whole site.
None of this needs a new website. Most of it is a few weeks of focused work on the pages a guest passes through.
user-scalable=no and maximum-scale out of the page.Our checklist for hotel booking sites goes through these steps one by one, with a test you can run in an afternoon. If you'd rather have someone else look, that's what our Compliance Check is for.
How we did it, and what we didn't do.
Everything below is fixed and repeatable. The anonymised data and the scan script are public.
Automated checks find roughly a third of real accessibility barriers, so these numbers are a floor. A site with no serious barrier in our scan isn't necessarily accessible, and this first part didn't include keyboard or screen-reader testing; that is part two. The sample was chosen, not drawn at random, so the results describe these 72 sites, not the whole industry. And a barrier is not a verdict: whether a hotel meets the EAA depends on national law, its size and its contracts.
[1] Directive (EU) 2019/882, the European Accessibility Act: Art. 2(2)(f) e-commerce services, Art. 4(5) microenterprises, Art. 13(2) and Annex V information on services
[2] ETSI EN 301 549 V3.2.1 (2021-03), clause 9: web content, with WCAG 2.1 level AA as the requirement
[3] W3C, Web Content Accessibility Guidelines 2.1 and 2.2
[4] Deque Systems, axe-core 4.14.0 rules and impact levels
[5] UK Government Digital Service (2017), what automated tools found on a page with known barriers
[6] Overlay Fact Sheet, a statement by accessibility practitioners on overlay widgets · overlayfactsheet.com