1. Focus order: the banner is not a modal window

Most banners behave like a modal window: as soon as the page loads, they grab keyboard focus, lock scrolling and cover the content. For someone using a keyboard or a screen reader, that means they can only reach the page they actually came for once they've dealt with the banner somehow. That's the wrong order of priorities: cookie consent is not why they came.

A correctly built banner is a region with its own heading, placed early in the document, right after the skip links, but it never moves focus onto itself. A keyboard user finds it after three presses of Tab; a screen reader user sees it in the list of regions and, on top of that, hears one polite sentence saying the banner exists and where it is. The whole page stays usable even before a decision is made, because until someone decides, nothing beyond the essential is stored.

A modal window only makes sense when you genuinely cannot proceed without a decision. That doesn't apply to cookies: without consent, the analytics and marketing scripts simply don't load. Anyone who insists on a modal window is admitting they want to force consent.

2. It can always be closed, and rejecting is exactly as easy as accepting

Two requirements, one technical and one ethical. Technical: the banner must be closable with the Escape key, and its content must not be a keyboard trap (criterion 2.1.2). Closing it without a decision counts as rejecting non-essential cookies; that follows from the requirement for consent to be freely given and active.

Ethical: the "Accept all" and "Reject non-essential" buttons must be equally visible and equally close together. A greyed-out "Reject" hidden behind a "Settings" button and three clicks away is a dark pattern, which European supervisory authorities — including the Slovak Office for Personal Data Protection and the European Data Protection Board — repeatedly flag as invalid consent. For a user with reduced attention or a cognitive impairment, it's not just an inconvenience, it's a barrier.

Closing also means the banner must not obscure the focused element (criterion 2.4.11 in WCAG 2.2). A banner pinned to the bottom of the window covers every button a keyboard user reaches at the end of the page. The fix is simple: while the banner is showing, it writes its height into the document's scroll-padding, and the browser scrolls the focused element above it automatically.

3. The right to change your mind

Consent that can't be withdrawn as easily as it was given is not consent. In practice that means a permanent link or "Change cookie settings" button, typically in the footer of every page, which opens the same banner with the current choice already set. On closing, focus returns to the button the user came from, exactly as with any other disclosure widget.

Two small things people tend to forget. First, remembering a rejection needs no cookie at all; the browser's local storage is enough. Second, the stored choice should carry a version: when a new category or a new tool is added, you bump the version and the banner asks again, instead of the new tool quietly hiding behind old consent.

Why not to use a plugin

This isn't dogma; it's experience from audits. Consent management platforms (plugins) regularly have these problems:

• They load third-party scripts before consent is given. The plugin itself is often a script from someone else's domain, carrying its own cookies and its own tracking. Cookie consent ends up being collected by a tool that breaches it itself.
• Generic ARIA instead of semantics. A window with no heading, buttons built from div elements, toggles with no labels, aria-hidden slapped on the whole page and forgotten after closing. For a screen reader, the site goes silent.
• A focus trap. Focus gets locked inside the banner, but Escape doesn't work and the only way out is to give consent.
• Content gets covered, with zero support for zooming. At 400% zoom the banner fills the whole screen and can't be scrolled away.
• It can't be checked or fixed. The code changes without your knowledge, an accessibility evaluation is only valid until the next update, and any bug you find, you can't fix.
• Legal risk stays yours. The duty to obtain consent under Article 5(3) of the ePrivacy Directive (2002/58/EC) as transposed by national law (in Slovakia, § 109(8) of Act No. 452/2021 Coll. on Electronic Communications) and the GDPR's conditions for consent rests with the website operator, not the plugin vendor.

A banner you build yourself is a few dozen lines: a region with a heading, three buttons, one group of toggles, and storing the choice. If you need to manage consent for dozens of tools, what you actually need is fewer tools.

What this looks like in practice

The accessible component patterns page has a banner that meets everything above, complete with a keyboard map, screen reader announcements and code to copy. This website doesn't use cookies at all, so the banner is just a demonstration — which makes it all the easier to try out.

Checklist

• The banner is a region with a heading, placed early in the document, with no focus moved onto it after loading.
• The page is usable without a decision; nothing non-essential loads before consent.
• Escape closes the banner and counts as rejection; keyboard focus can always get out of it.
• "Accept" and "Reject" are equal buttons; no categories are pre-checked by default.
• The banner doesn't obscure the focused element; the content behind it can still be scrolled into view even at 400% zoom.
• The choice can be changed from any page; closing returns focus to the button.
• The choice carries a version, and the banner asks again when the categories change.
• After saving, a status message sounds, which a screen reader reads without interruption.

Don't panic…

First of all, check whether the European Accessibility Act (EAA) applies to you. But, very briefly: if you run an e-shop, a mobile application, or a website where you offer any kind of service, or if you send electronic invoices to end consumers, the EAA applies to you. If you're not sure, check with our test. B2B is not covered by the EAA, but if you offer a service that your partners then offer on to their own customers – end consumers – you're simply passing the problem on to them, and either you'll lose those partners, or they'll start passing the responsibility back to you. Take your pick of which is worse… If you also offer services or goods abroad, you'll need to check the local legislation too, since in some countries the EAA may have been implemented more strictly than it has been here.

Why does accessibility matter? Listen to the podcast Denník N recorded with us. We also most recently talked about accessibility for Basta Digital.

Accessibility Doctors

What all needs to be accessible?

In short? Everything. But step by step. It's important to look at the whole spectrum of the service you provide and your communication with customers. Besides your website, mobile application, payment processes and so on, don't forget:

• published documents, especially contractual or business terms and other legally binding content,
• electronic invoices,
• instructions or manuals for the products and services you sell,
• accessible help and customer support,
• electronic communications such as newsletter emails or social media posts,
• promotional or informational videos and podcasts.

How do I check accessibility myself?

You don't need a PhD in information science (although we do have one :-)). To check basic accessibility, all you need to do is… put your mouse aside / turn off the touchpad. It takes some getting used to, but can you reach all the services and functions on your website using only the keyboard? Can you complete the checkout process without a mouse, or send a question through a chat bot? And does the way you move around the page without a mouse make logical sense? Congratulations – you've just checked two very important points: keyboard operability and a meaningful order.

It's only the beginning, but if you've passed this test, the rest will be easier. For example, the WAVE extension can help you quickly spot:

• contrast errors,
• missing text alternatives for images (unless they're purely decorative or illustrative graphics),
• missing labels for form fields,
• certain elements that can't be operated using the keyboard.

For more thorough testing, you can try Accessibility Insights, which walks you through selected points from the WCAG guidelines (the Web Content Accessibility Guidelines – we also helped produce an unofficial Slovak translation of them). However, no automated tool checks more than 20–30% of the current requirements, and none of them can check accessibility against the EU's applicable standard, EN 301 549 (PDF, 2.2 MB). They won't verify whether the text alternatives used are accurate, whether users have sufficient instructions before and during form completion and are alerted to errors in a clear and accessible way, whether the reading order through the content is genuinely meaningful, and so on. Just as they miss plenty of real issues, they also frequently report many false positive findings, especially if you use images and background graphics inserted via CSS.

The ultimate test, of course, is using assistive technology, such as NVDA for Windows, or VoiceOver for macOS. Linux also has its own tool, called Orca.

To check the accessibility of PDF documents, you can use either the paid version of Adobe Acrobat Pro, or the free PDF Accessibility Checker PAC 2026 (Windows only).

Is this all too much? Get in touch and we'll take a look at it together!

When deciding what will or won't be implemented, it's worth also considering the benefits accessibility can bring to a business. There are, in fact, numerous benefits that can turn accessibility into added value for a company and improve its competitiveness.

Accessibility helps you win more customers and strengthen your brand

More accessible digital solutions mean a larger customer base, since persons with disabilities, older people, or people with temporary limitations (such as a broken arm or a short-term deterioration in eyesight) will find it easier to use the services and products on offer. By removing barriers, we win their trust and their satisfaction with our products and services. Companies that adapt to the new requirements in good time minimise the risk of legal disputes and sanctions, including financial penalties, while also building a positive image as a socially responsible brand.

Accessibility improves the user experience for everyone

Accessibility isn't just about meeting requirements for persons with disabilities – it improves the overall user experience (UX) for everyone. When a website, mobile application or digital product is designed with an emphasis on simplicity, intuitiveness and usability, all users benefit. What specific improvements does accessibility bring?

• Clearer navigation – A clear, consistent menu, a logical content layout, and the ability to operate the site by keyboard or voice command make it easier for everyone to use, not just for persons with disabilities.
• Better colour contrast and readability – Properly set colour contrast, sufficiently large text and clear typography reduce eye strain and improve the readability of content for older people and people with temporarily reduced eyesight (for example, tired eyes when working at night), as well as on screens exposed to direct sunlight or when projected onto a large screen, where poor colour contrast can significantly reduce readability.
• Simpler forms and interactions – Well-designed forms with clear labels, properly flagged errors and the ability to auto-fill data improve efficiency and reduce user frustration.
• Clearer content – Using plain language, short sentences and well-structured text helps not only people with cognitive impairments, but also all users reading on mobile devices or who aren't native speakers of the site's language.
• Adaptability across devices – Accessible design is responsive, meaning it displays correctly on mobiles, tablets and desktops alike. This leads to better user comfort and prevents visitors from leaving the site. Responsive design is also important for SEO, since, from 5 July 2024, the Google crawler only indexes websites that are responsive.

Accessibility and SEO: better visibility in search engines

One of the less-discussed but very important benefits of accessibility is its positive impact on SEO (search engine optimisation). When a website is accessible, it often also meets key SEO requirements that improve its position in organic search results. How exactly does accessibility affect SEO?

• Better content structure – Using correctly marked-up headings (H1, H2, H3, etc.), a logical hierarchy of information and well-organised sections help search engines better understand the page's content and increase its relevance.
• Text alternatives for images – Search engines can't "see" images, but they can read their text alternatives. Correctly written text alternatives help not only blind users, but also how the page is displayed in search engines.
• Faster page loading – Optimising for accessibility often involves removing unnecessary elements, which speeds up page loading. Google treats loading speed as an important factor when ranking pages in search results.
• Mobile accessibility = higher Google ranking – Since Google enforces mobile-first indexing (ranking based on the mobile version of the page), responsive design and accessibility for touch devices can significantly affect your SEO score.
• Clearer, more understandable text – Using plain language and short paragraphs improves readability not only for users, but also for search engines, which can then better understand the page's content.
• Meaningful hyperlinks, even out of context – Descriptive and unambiguous link text (e.g. "Read the overview of WCAG 2.2 changes" instead of "Click here") improves orientation on the website and helps search engines better understand the connections between pages.

Getting ready for the future of the digital market

With the EAA's effective date approaching, it's essential for organisations to start adapting their digital solutions as soon as possible. Implementing accessibility measures requires thorough planning, testing and a gradual roll-out of changes, especially for large digital platforms. The sooner companies begin this implementation, the easier and more cost-effective it will be for them to adapt to the new standards.

Thorough preparation not only enables companies to meet legal requirements, but also to gain a competitive advantage and support innovation in the digital environment. This allows businesses to set themselves apart from the competition and contribute to building a more inclusive digital society, where everyone has equal access to information and services.

We can help you prepare and plan the implementation of accessibility requirements – read more in our Services section.