Regulatory context
Healthcare services intersect with the EAA in several ways. While 'healthcare' is not a standalone EAA category, many healthcare digital services fall within scope as e-commerce services (online pharmacies), electronic communications (telemedicine platforms), or through public sector obligations under the Web Accessibility Directive (public hospital websites, national health portals). EN 301 549 incorporating WCAG 2.1 Level AA is the applicable standard. Additionally, EU medical device regulations (MDR 2017/745) reference usability and accessibility for software classified as medical devices. National health authorities across EU member states are increasingly mandating accessible digital health services as part of healthcare digitalisation strategies.
Common issues Lumi finds in healthcare websites
Patient portal and health record access
Patient portals providing access to medical records, test results, prescriptions, and care plans frequently have inaccessible data displays. Lab results in tables without proper headers, medication lists without clear structure, and clinical documents in inaccessible PDF format all create barriers to patients managing their own health.
Appointment booking systems
Online appointment booking for GP visits, specialist referrals, vaccinations, and diagnostics commonly uses date pickers, time slot selectors, and provider search interfaces that lack keyboard support and screen reader compatibility. Multi-step booking flows with conditional questions compound the problem.
Telemedicine and video consultation interfaces
Video consultation platforms must be accessible for patients using screen readers, switch devices, or voice control. Pre-consultation questionnaires, waiting room interfaces, in-call controls (mute, camera, screen share), and post-consultation summaries all need to be fully accessible.
Medical document and letter accessibility
Discharge summaries, referral letters, consent forms, and patient information leaflets are frequently published as scanned PDFs or generated from clinical systems without accessibility tagging. Patients must be able to read and understand their own medical documents independently.
Prescription and pharmacy interfaces
Online prescription management, repeat prescription ordering, and pharmacy services involve medication lists, dosage information, and interaction warnings that must be accessible. Drug names, dosages, and instructions need clear labelling - errors in understanding medication information have serious health consequences.
Health assessment forms and symptom checkers
Online symptom checkers, pre-appointment questionnaires, and health risk assessments use multi-step forms with conditional logic, body diagrams, and pain scales. These interactive tools need text alternatives for visual elements and full keyboard and screen reader support.
Healthcare-specific challenges
Healthcare digital services face acute accessibility challenges because the consequences of inaccessible health information are severe - patients may miss appointments, misunderstand medication instructions, or be unable to access their own medical records. Older adults and people with disabilities are disproportionately high users of healthcare services, making accessibility especially critical in this sector. Clinical systems and electronic health record (EHR) platforms often generate patient-facing content that development teams cannot easily modify. Telemedicine adoption has grown rapidly, but many platforms were built for speed-to-market rather than accessibility. Strict data protection requirements (GDPR, national health data laws) add complexity to authentication and consent flows that must remain accessible.
Compliance timeline
Public healthcare providers (NHS equivalents, public hospitals, national health portals) are already required to comply with the Web Accessibility Directive since 2018-2021. Private healthcare services that fall within EAA scope must comply from 28 June 2025 for new services and 28 June 2030 for existing ones. The EU Health Data Space regulation (proposed) may introduce additional digital accessibility requirements for health data platforms.
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Frequently asked questions
Does the EAA apply to healthcare websites?
It depends on the service type. Public healthcare sites are covered by the Web Accessibility Directive. Private healthcare services may fall within EAA scope if they constitute e-commerce (online pharmacies), electronic communications (telemedicine), or other in-scope service categories. Regardless of direct EAA applicability, EN 301 549 is the standard increasingly referenced by national health authorities.
Do patient portals need to be accessible?
Yes. Patient portals provided by public health services must comply with the WAD. Those provided by private organisations are increasingly subject to accessibility requirements through the EAA, national health regulations, and medical device regulations. Patients have a fundamental right to access their own health information independently.
Are telemedicine platforms covered by accessibility law?
Telemedicine platforms that provide electronic communications services fall within EAA scope. Public health telemedicine services are covered by the WAD. The platform must be accessible end-to-end - from booking through the consultation interface to accessing post-consultation documents and prescriptions.
What accessibility standards apply to health apps?
EN 301 549 applies to health apps within EAA or WAD scope, covering WCAG 2.1 Level AA for web content and additional software-specific requirements. Health apps classified as medical devices under MDR 2017/745 must also meet usability requirements that include accessibility considerations.
Related resources
Last reviewed: April 2026. Content is reviewed quarterly for accuracy.