When a website is flagged as inaccessible, most people think of technology first: contrast values, focus indicators, ARIA attributes. In practice the larger share of barriers sits in the copy and in the way that copy was built into the page. A heading that is merely larger and bolder stays plain body text as far as a screen reader is concerned. A link labelled “learn more” leads nowhere in a list of links. Opening hours uploaded as an image do not exist at all for assistive technology. And a form field labelled “subject 2” is a riddle for people without any impairment too. This article is the editorial counterpart to the technical view of accessibility law: it sets out which writing decisions determine access, what an editorial checklist looks like, and how a read-aloud test lets you hear in half an hour what actually reaches your visitors.
Why accessibility usually fails on the copy
The annual review of the one million most visited home pages produces an uncomfortable figure: 95.9 percent of the pages examined show automatically detectable failures against the Web Content Accessibility Guidelines, at an average of 56.1 errors per home page (WebAIM Million). The distribution is what makes it interesting. Most of those findings do not come from exotic technology but from decisions made in the editorial seat: missing alternative text on 53.1 percent of pages, missing form input labels on 51 percent, empty links on 46.3 percent and a missing document language on 13.5 percent (WebAIM Million). Every one of these arises the moment somebody types a text, uploads an image or names a field – and that is also the cheapest place to fix it. If you are looking for the legal framing, the article on implementing the German Accessibility Act covers it.
Writing clearly is not a second kind of text
The second reason lies in how audits actually run. An independent review had 65 online services tested by people with a range of disabilities along typical user journeys; only about a third were usable without barriers, and merely 20 of 65 could be operated with the keyboard alone (Aktion Mensch). What stood out was how often the obstacles were linguistic: unclear form field labels, alternative texts with little meaning, controls without a comprehensible name (Aktion Mensch). That matches what website projects show in practice: technical defects can usually be repaired in one place in the design system, while textual defects reappear on every single subpage (project experience). If you want to work on general readability in parallel, the article on website copy that gets read rather than skimmed covers the groundwork.
Headings are structure, not styling
Headings do two jobs at once. Visibly they divide the page; invisibly they form the table of contents that assistive technology navigates by. Someone working with a screen reader rarely walks a page paragraph by paragraph; they call up the headings as a list and choose from it. If that list is missing or built illogically, all that remains is listening from top to bottom. The figures show how widespread the problem is: 41.8 percent of the home pages examined skip heading levels, 18.1 percent use more than one H1, and 7.5 percent manage without any heading at all (WebAIM Million). An average home page carries 29.9 headings, of which only 5.1 percent are an H1 (WebAIM Million). The relevant success criteria are worded plainly: structure must be programmatically determinable (WCAG 1.3.1, Level A), and headings must describe topic or purpose (WCAG 2.4.6, Level AA).
- One H1 per page, naming the page content – not the company name and not the slogan.
- Descend levels without gaps: H2 is followed by H3, not H4. Steps back up the hierarchy are fine, steps that skip downwards are not.
- Separate font size from level: if an H3 looks too large, that is a job for the design, not for the choice of level.
- Word headings so they stand on their own; “Our approach” says less in a heading list than “How a job runs from quote to handover”.
- Do not mark up body paragraphs as headings just because they should stand out – emphasis markup exists for that.
- Add subheadings even to short sections: they are the anchor points that make skipping possible.
In practice this means the heading structure of a page should read like an outline. A good test is to copy every heading into an empty file, one under the other. Does the list, without the surrounding text, add up to a comprehensible summary of the page? If it does not, the cause is almost invariably one of two patterns: purely promotional wording with no substance, or headings that refer back to the previous paragraph instead of forward to the next one. How a workable page outline is created from the start is described in the article on which pages a business website really needs; the route from outline to finished page is shown in the overview of how XICflow works.
| In the draft | What a screen reader makes of it | Better solution |
|---|---|---|
| Paragraph set in 24 pixel bold as a section title | no heading, no jump target, no entry in the outline | mark it up as an H2 and control the size in the design |
| Second H1 for the promotional note in the sidebar | two page titles of equal rank, unclear allocation | one H1 for the page content, the sidebar starts at H2 |
| Jumping from H2 straight to H4 for visual reasons | a level is missing, the outline looks broken | use H3 and set the desired size with a class |
| Heading “More information” | interchangeable and meaningless in a heading list | “How a roof refurbishment runs” or “Costs at a glance” |
| Company name as the H1 on every subpage | every page sounds identical, the entry carries no information | page topic as the H1, company name stays in the header |
| Image caption formatted as an H3 | the structure breaks in the middle of a section | mark it up as a caption and leave the levels untouched |
Link text that stands alone
The second navigation route beside the heading list is the link list. It is also produced without surrounding text, which is why link text should be comprehensible in isolation. The relevant criterion does allow the purpose to be derived from the link text together with its programmatically determined context (WCAG 2.4.4, Level A); the stricter version requires comprehension from the link text alone (WCAG 2.4.9, Level AAA). In practice the stricter variant pays off, because it helps search engines at the same time. The spread of the problem is moderate but stubborn: 15.2 percent of the home pages examined contain ambiguous link text such as “click here”, “more” or “continue”, at an average of 5.3 instances per affected page (WebAIM Million). Empty links weigh heavier still, occurring on 46.3 percent of pages – linked icons without a label, for example, which are announced as “link” and nothing else (WebAIM Million).
| Weak link text | Why it fails | Workable wording |
|---|---|---|
| click here | describes the action, not the destination | Open the price list as a page |
| learn more | appears identically several times in a link list | Read more about roof refurbishment |
| continue | meaningless without surrounding text | Continue to the contact form |
| www.example.com/services/roof | read out character by character | Services around the roof |
| Icon without a label | announced as an empty link | give the icon an accessible name |
| Download | format and length stay unknown | Maintenance plan as a PDF, 2 pages |
One destination, one link text
Short sentences, active verbs, plain words
The WCAG contain no Level AA criterion that prescribes a particular sentence length. Comprehensibility is still one of the four principles, and the criterion on reading level sits at Level AAA (WCAG 3.1.5). For companies that means clear writing is rarely a duty with a measurable threshold, yet it is the lever with the widest effect. People with learning difficulties, people reading in a second language, people in a hurry on a phone and people with a temporary lapse in concentration all benefit from the same measures. That is also why the work pays for itself commercially: it reaches far more people than the group most of us picture when accessibility is mentioned. Around 7.9 million people in Germany have a recognised severe disability (Federal Statistical Office), and the European Commission estimates roughly 87 million people with a disability across the European Union (European Commission) – the number of those who benefit from plain language is a multiple of that.
One idea per sentence
Sentences of 15 to 20 words can be followed at reading-aloud speed. Nested constructions with three subordinate clauses lose their shape when heard.
Active rather than passive
“We inspect your system” rather than “your system is inspected”. The verb names the action and the sentence names who performs it.
Lists rather than comma chains
Five services in a list are audibly structured. The same five services inside one sentence blur into an enumeration without footholds.
Concrete words
“We clean the gutters” can be checked. “We take care of your building envelope” leaves open what actually happens.
Most important first
The core of the paragraph belongs in the first sentence. Anyone who moves on after two sentences has already heard the point.
Numerals for numbers
Numerals are announced cleanly by reading software and are quicker to grasp than numbers spelled out inside running text.
The paragraph is the smallest unit of review
Jargon, abbreviations and foreign-language terms
Specialist vocabulary is not a fault as long as it is explained. It becomes a problem when it is assumed without asking. Three cases occur particularly often. First, abbreviations that are neither spelled out nor explained on first use; the matching criterion sits at Level AAA (WCAG 3.1.4), yet comprehension suffers immediately either way. Second, trade terms that are self-evident within the industry but do not land with the customer. Third, foreign-language terms inside running text: reading software pronounces them in the surrounding language and they frequently become unintelligible unless they are marked up. That is exactly what the criterion on language of parts is for (WCAG 3.1.2, Level AA) – and for the document as a whole there is the page language (WCAG 3.1.1, Level A), which is missing on 13.5 percent of the home pages examined (WebAIM Million).
- Spell out abbreviations on first use: “German Accessibility Act (BFSG)” rather than “BFSG” alone.
- Explain industry terms in half a sentence instead of pushing them into a footnote.
- Mark up foreign-language terms so pronunciation stays correct – product names in another language, for instance.
- Terms that have been fully absorbed into the surrounding language need no markup; the rule targets recognisably foreign passages.
- Same thing, same word: do not alternate between “quote”, “estimate” and “offer” for one and the same document.
- A short glossary on the page itself helps more than a PDF glossary in a download area.
A text is accessible enough when a person understands it on first hearing, without having to jump back.
When text disappears into an image or a PDF
The most expensive mistake in this series is also the most convenient one: information that arrives on the page as an image or a PDF. Opening hours as a graphic, the price list as a photo of a table, the job advert as a scanned sheet – to assistive technology all of that is simply a surface. The guidelines are explicit here: text should be conveyed as text rather than as an image of text, unless the presentation is customisable or essential (WCAG 1.4.5, Level AA). Then there is the sheer volume: an average home page contains 66.6 images, of which 16.2 percent carry no alternative text at all; adding missing, questionable and repetitive alternative texts together, more than 25 percent of all images are affected (WebAIM Million). How alternative texts are worded in practice is covered in the article on image formats and alt text.
- Set up opening hours, prices and contact details as real page content, not as a graphic.
- Mark up tables as tables, with a header row and a meaningful caption, instead of embedding them as an image.
- Add a page version alongside PDF documents; the PDF can stay as the printable variant.
- Give informative images a description that replaces the message rather than listing the motif.
- Mark purely decorative graphics as empty so reading software skips them.
- Summarise charts in two additional sentences: what does the curve show, and what follows from it?
- Do not carry information through colour or position alone, such as “the red field on the left”.
Legal texts belong on the page
Video: captions, transcript, audio description
Moving images are where missing editorial work shows most clearly. For prerecorded video with sound the guidelines require captions (WCAG 1.2.2, Level A) plus an alternative for time-based media or an audio description of the visual content (WCAG 1.2.3, Level A); at Level AA audio description for prerecorded video becomes binding on its own. For most company videos that means captions are mandatory, and a transcript underneath the video satisfies several requirements at once at very little cost. Automatically generated captions are a starting point rather than a result – proper names, product designations and place names are regularly misrecognised and have to be corrected editorially (project experience).
Captions
Spoken content plus relevant sounds, synchronised in time. They also help people watching without sound in a noisy environment.
Transcript
The full text below the video, with speakers identified. It is searchable, quotable and legible to search engines.
Audio description
A description of essential visual information that the soundtrack does not carry – figures shown on screen, for example, or steps demonstrated.
Two side effects argue for careful captions and transcripts quite apart from the legal position. First, videos are frequently started without sound, particularly on the move; a transcript rescues the message in that situation. Second, a video is largely opaque to search engines, whereas the matching transcript is text. How content holds up on small screens is set out in the article on mobile usability for a business website.
The editorial checklist
The list below is meant as a final pass before publication rather than a set of rules for writing. It covers the points that arise in the editorial seat and can be fixed there – without access to templates, scripts or the design system. For a medium-sized subpage the pass takes ten to fifteen minutes in practice (project experience). Forms deserve a separate look at field labels and error messages; the requirements there are described in the article on contact forms that turn visits into enquiries.
- Exactly one H1, naming the topic of the page in your own words.
- Heading levels without gaps: no jump from H2 to H4, no level chosen by font size.
- All headings read one after another add up to a sensible outline of the page.
- Every link text names its destination; no “click here”, no standalone “more”, no bare address.
- Linked icons carry an accessible name so no empty link is produced.
- Paragraphs open with their core point and stay under roughly five sentences.
- Abbreviations are spelled out on first use, trade terms explained in half a sentence.
- Foreign-language passages are marked up and the page language is declared.
- Informative images have alternative text that replaces the message.
- Opening hours, prices and contact details sit as text on the page, not inside a graphic.
- Tables are marked up as tables, with a header row and a caption.
- Videos have reviewed captions and a transcript below the player.
- Form fields carry visible labels; error messages name the field and the correction.
- No statement rests on colour, shape or position alone.
The read-aloud test in four steps
Automated checking tools find missing attributes reliably, but they judge neither the quality of an alternative text nor how informative a heading is. That is precisely why the read-aloud test works so well: it makes audible what the screen papers over visually. You need no extra software. Current operating systems include a read-aloud function, and many browsers offer a reading or read-aloud view. Anyone using a screen reader tests closer to reality; for a first pass the built-in function is enough. Only one thing matters: the screen stays out of it.
- Start reading: switch on the read-aloud function of your operating system or your screen reader and open a typical subpage, a service page for instance.
- Listen only: turn the screen away or close your eyes and hear the page from top to bottom. Note every point at which you lose the thread.
- Call up the headings: have the heading list read out and check whether it forms an outline. If a point is missing, a heading is missing.
- Call up the links: have the link list read out. Every entry whose destination you cannot name without surrounding text is a finding.
- Submit the form: fill in the contact form by ear, provoke an error and listen for whether the field and the correction are named.
- Sort the findings: separate editorial findings from technical ones. The editorial ones you can correct straight away, the technical ones belong on the implementation list.
One pass per user journey
Accessibility happens while writing
The effort behind accessible copy depends heavily on when it is spent. If the structure is considered while writing, it costs almost no time. If it is produced afterwards, every correction touches all subpages and frequently the templates as well. This is exactly where XICflow comes in: pages are assembled from a catalogue of blocks that lay down the semantic structure. A section block produces a heading at the matching level, a bullet list produces a list, a table produces a table with a header row. The level sequence therefore survives reordering instead of falling apart when a paragraph is moved. The AI assistant drafts copy in plain language, keeps the heading levels intact and can be told to shorten sentences or explain trade terms. What else the system covers is set out in the XICflow feature overview.
That shifts the work to where it belongs: the business still decides on the content. Whether an alternative text captures the point of a photo, whether a trade term needs explaining for your particular customers, whether a heading names the topic – no system can judge that on its own. What technology can do is stop a sound editorial decision from being undone by the structure. Multilingual sites benefit further, because the language markup follows from the configuration rather than from manual work; the details are in the article on multilingual websites and hreflang. How finished pages look on this foundation can be explored through the example websites; what the build costs is shown on the pricing overview, and further articles on structure, law and technology are collected in the XICflow blog.
Retrofitting is the most expensive route