The accessibility gap in pharma digital
Most pharma brand teams only think about web accessibility when legal flags it. By then, the site is live, the design system is locked, and remediation becomes a line item that nobody wants to own. We see this pattern repeatedly. Across the sites our team has audited this year, including properties from J&J/Janssen, GSK, Amgen, AbbVie, Takeda, BMS, and MSD, the dividing line is almost always the same: was accessibility in the original brief, or was it bolted on?
The WebAIM Million 2025 report found that 95.9% of websites fail to meet WCAG 2.2 Level A/AA standards, averaging 51 errors per page. Pharma is not an outlier in that number. If anything, the regulated nature of our content, with mandatory legal copy, PI documents, and risk statements, tends to make the problem worse. More PDFs, more locked templates, more legacy components.
MSD's hpvinfo.be is one of the clearer counterexamples we have audited. It is not perfect. But it is on the right side of the gap, and the reasons are instructive for any brand team planning a patient site in 2025 or 2026.
How do you audit a pharma website for WCAG 2.2 AA compliance
A proper WCAG 2.2 AA audit is not a scanner run. Automated tools, the ones that produce a tidy PDF in ten seconds, detect only 30 to 40% of accessibility issues. The rest, including meaningful alt text, logical heading order, keyboard trap detection, focus visibility, and cognitive-load criteria introduced in WCAG 2.2, require manual expert evaluation.
Our methodology on hpvinfo.be followed the same process we use across pharma brands:
- Automated scan to flag the obvious failures (contrast ratios, missing labels, ARIA misuse).
- Manual keyboard-only walkthrough of the primary user journeys, in this case the HPV information path a parent or teenager would actually take.
- Screen reader pass using NVDA and VoiceOver on the key content pages.
- Heading and landmark structure review against the semantic HTML spec.
- PDF accessibility check on any downloadable patient materials.
- Scoring against the 50 WCAG 2.2 AA success criteria, weighted by user impact.
Most pharma sites we audit score below 40 out of 100 on a first pass. HPV info scored materially higher. The reason was not heroic remediation after launch. It was a build that respected the spec from the start.
Why does accessibility matter for public health patient websites
For a transactional pharma site, poor accessibility is a legal and reputational risk. For a public health site, it is an editorial failure. HPV vaccination information needs to reach parents making a decision for their twelve-year-old, teenagers reading on their phone, and caregivers supporting someone with low vision or a cognitive condition. If the site is unusable with a screen reader, or if the keyboard focus disappears halfway through the FAQ, the information does not land.
This is where accessibility stops being a compliance exercise and starts being a communications question. At Promedia we design patient engagement journeys across digital and traditional channels, and the single most consistent lesson from patient feedback is that comprehension and reach are inseparable. A patient information brochure revised based on survey insights is the offline equivalent of a site that passes a keyboard test. Both ask the same question: can the person who needs this actually use it?
MSD's commitment on hpvinfo.be reads differently in that light. The intent is visible in the code, not just in an accessibility statement page. Heading structure holds up. Alt text on informative visuals is present. Keyboard navigation works on the main journeys. That is rare, and for a public health topic it matters more than for almost any other category of pharma content.
What are the most common accessibility failures on pharma websites
Across the audits we have run this year, the same handful of failures show up repeatedly. None of them are exotic. All of them are fixable at design stage for a fraction of the retrofit cost.
- Contrast failures on secondary UI elements: pagination arrows, breadcrumb separators, disabled button states, footer links against brand-coloured backgrounds.
- Untagged PDFs. Patient leaflets, PI documents, and risk minimisation materials are often uploaded straight from Word with no structural tags, making them opaque to screen readers.
- Missing or decorative alt text on informative visuals. Mechanism-of-action diagrams and infographics are frequent offenders.
- Keyboard traps in cookie banners, consent modals, and video players, often introduced by third-party scripts.
- Weak or invisible focus states, especially on sites with custom-styled buttons that override browser defaults.
- Heading structure that follows visual design rather than document outline, with H1s skipped or H3s used for styling reasons.
HPV info was not immune to all of these. Contrast on a few secondary elements needs work. Some PDFs still need proper tagging. Focus states could be sharper in places. But the gap between a site built with accessibility in the brief and one where it was retrofitted at the end is measured in weeks of remediation work, not months. HPV info sits in the first category.
How does the European Accessibility Act affect pharmaceutical companies
The European Accessibility Act came into force in June 2025.
The minimum legal standard referenced by the EAA is WCAG 2.1 AA, but WCAG 2.2 is increasingly the recommended benchmark. WCAG 2.2, released by the W3C in October 2023, added nine new success criteria focused on users with cognitive disabilities, low vision, and mobile users. Building to 2.2 now avoids a second remediation cycle in eighteen months when regulators formally move the floor.
The operational implication for brand and digital teams: accessibility needs to move from the end of the project plan to the start. It belongs in the design brief, in the component library acceptance criteria, in the CMS template specification, and in every third-party vendor contract. Retrofitting a non-accessible site to WCAG 2.2 AA typically costs between fifteen and thirty percent of the original build budget. Designing it in from the start adds closer to five.
