Digital accessibility in Europe and in Lithuania is gaining increasing momentum. In 2026, new European Accessibility Act requirements come into force, and WCAG in Lithuania becomes not a recommendation but a legal obligation for all public-sector organisations. In this article, we will discuss what changed in 2025–2026, which standards apply, what penalties are possible for non-compliance and how to achieve WCAG compliance in practice.
What is WCAG and why does it matter?
WCAG (Web Content Accessibility Guidelines) — these are international web content accessibility standards developed by W3C (World Wide Web Consortium). These standards define how web content should be presented so that everyone can use it, including people with disabilities.
WCAG in Lithuania became legally binding back in 2019, when EU Directive 2016/2102 on the accessibility of websites and mobile applications of public-sector bodies was transposed. However, in 2025–2026 the requirements were significantly expanded.
The four WCAG principles
All WCAG requirements are based on four main principles:
- Perceivable — information and user interface components must be presented in ways users can perceive. This includes alternative text for images, captions for videos, and sufficient colour contrast.
- Operable — interface components and navigation must be operable. The entire website must work with a keyboard, without a mouse, and allow enough time for interaction.
- Understandable — information and interface controls must be understandable. Text should be clear, and the interface consistent and predictable.
- Robust — content must be built robustly enough that it can be interpreted by a variety of technologies, including assistive technologies (screen readers, etc.).
What changed in 2025–2026?
The European Accessibility Act (EAA)
On 28 June 2025, the European Accessibility Act (European Accessibility Act, EAA) came into force, significantly expanding the scope of accessibility requirements. Key changes:
- Expanded scope — accessibility requirements now apply not only to the public sector, but also to the private sector: e-commerce websites, banking services, transport information systems.
- Mobile applications — all public-sector mobile applications must meet WCAG 2.1 AA standards.
- Intranet systems — newly developed internal systems must also be accessible.
- Documents — documents published via the website (PDF, Word, Excel) must be accessible.
WCAG 2.2 standard requirements
Although WCAG 2.1 AA is still officially required in Lithuania, the WCAG 2.2 standard, published in October 2023, is becoming a new benchmark. WCAG 2.2 adds new criteria:
- Focus visible — keyboard focus must be clearly visible (2.4.11, 2.4.12).
- Dragging alternatives — functions requiring dragging (drag-and-drop) must have alternatives (2.5.7).
- Minimum target size — interactive elements must be at least 24×24 pixels (2.5.8).
- Consistent help access — help mechanisms must be consistently provided throughout the page (3.2.6).
- Redundant entry — the system must avoid asking the user to re-enter information they have already provided (3.3.7).
Stricter supervision in Lithuania
The Communications Regulatory Authority (RRT), responsible for supervising website accessibility in Lithuania, has increased the scope of inspections since 2025. Now not only main websites are checked, but also their subsystems, electronic services and mobile applications.
What penalties are possible for WCAG non-compliance?
WCAG non-compliance in Lithuania may lead to:
- Administrative fines — the Communications Regulatory Authority may impose fines on public-sector organisations.
- Orders to remove breaches — a deadline is set by which the website must be brought into compliance.
- Public disclosure — organisations that do not comply are published publicly, creating reputational risk.
- Legal disputes — people with disabilities may go to court on grounds of discrimination if the website is not accessible.
Under the European Accessibility Act, Member States must set effective, proportionate and dissuasive sanctions. In Lithuania, the specific fine amounts depend on the scale of the breach and the size of the organisation.
Practical steps to achieve WCAG compliance
1. Carry out an accessibility audit
The first step is to assess the current state of the website. An accessibility audit includes:
- Automated testing using tools (WAVE, axe, Lighthouse).
- Manual testing with a keyboard and screen reader.
- Testing with real users with disabilities (if possible).
To find out how much it would cost to adapt your website, use our pricing calculator.
2. Prioritise issues
After the audit, you will receive a list of issues. Prioritise them according to:
- Critical issues — those that completely block use of the website (e.g. keyboard navigation not working, images without alt text on main pages).
- Major issues — those that make use significantly more difficult (e.g. insufficient contrast, unclear labelling of terms).
- Moderate and minor issues — those that cause inconvenience but do not prevent use of the website.
3. Fix systematically
Accessibility fixes should be carried out systematically:
- Start with the HTML structure — correct heading levels, semantic elements.
- Add alternative text to all images.
- Check and correct colour contrast.
- Ensure keyboard navigation — focus visibility, tab order.
- Add ARIA labels where additional context is needed.
- Check forms — labels, error messages, instructions.
- Add captions to video content.
4. Automated vs manual testing
It is important to understand that automated tools detect only about 30–40 % of accessibility problems. The rest require manual testing. An effective strategy combines both methods:
- Automated testing — fast, repeatable, good for the first line. Use WAVE, axe DevTools, Lighthouse.
- Manual testing — essential for detecting more complex issues. Test with a keyboard, screen reader (NVDA, VoiceOver), zoom.
- User testing — the best way to assess real accessibility. Include people with disabilities in the testing process.
5. Accessibility statement
Public-sector organisations must publish an accessibility statement. It must include:
- The level of compliance (fully compliant, partly compliant, non-compliant).
- A description of inaccessible content and the reasons.
- A feedback mechanism — how to report accessibility issues.
- A link to the enforcement procedure.
How can Tobalt help?
Our team specialises in public-sector website accessibility. We offer:
- A comprehensive WCAG accessibility audit.
- Accessibility fixes in line with WCAG 2.1 AA (and 2.2) standards.
- New website development with accessibility built in from the start.
- Staff training on accessibility topics.
Find out more about our WCAG adaptation service and how we can help your organisation meet the latest standards.
Conclusions
WCAG in Lithuania in 2026 is not a future vision, but a current reality. Public-sector organisations must ensure that their websites are accessible to all residents, regardless of their abilities. The European Accessibility Act and stricter supervision mean that non-compliance will cost more and more — both financially and reputationally.
Start with an accessibility audit, prioritise issues and fix them systematically. And if you need help — contact us, and together we will find the best solution for your organisation.
Want to find out whether your website meets WCAG requirements? Get a free accessibility and contrast report — Tobalt will check your website and provide specific recommendations to ensure compliance.