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Web Accessibility (WCAG) and KVKK: A Double Obligation for Turkish Businesses

Web accessibility and personal data compliance are often handled under the same roof. This article explains the WCAG standard, the legal and inclusion dimensions of accessibility, and why it is managed together with cookie compliance.

JUS. Hukuk Ekibi
Uyum ve Veri Koruma
August 13, 2026
Web Accessibility (WCAG) and KVKK: A Double Obligation for Turkish Businesses

A website is successful not simply because it is fast and stylish, but to the extent that it can be used by everyone. Enabling users with visual, hearing, motor or cognitive differences to use a site without barriers is both an ethical responsibility and an increasingly common compliance obligation. For Turkish businesses, this picture turns into a "double obligation" when combined with personal data compliance: web accessibility standards on one hand and cookie and data protection rules on the other must be met at the same time.

In this article we look at what the WCAG standard is, why accessibility is both a legal and an inclusion requirement, and why it is managed together with cookie compliance.

What Is WCAG?

WCAG (Web Content Accessibility Guidelines) is an internationally recognized standard that defines the accessibility of web content. Published by the W3C, this guideline, with its current version WCAG 2.2, describes in detail how websites should be designed for users with disabilities.

WCAG is built on four core principles: content should be perceivable, operable, understandable and robust. The standard defines three conformance levels:

  • Level A: Basic accessibility requirements.
  • Level AA: The practical conformance level targeted by most regulations and corporate policies.
  • Level AAA: The highest and most comprehensive level of accessibility.

In practice, the reference target for the vast majority of businesses is AA.

EN 301 549 and the Chain of Standards

Although WCAG is a technical guideline on its own, it is referenced by many regulatory frameworks. In Europe, the EN 301 549 standard defines accessibility requirements for digital products and services and is based on WCAG. This chain of standards turns accessibility from a "well-intentioned choice" into a measurable, auditable requirement. For Turkish businesses serving international markets, being familiar with these frameworks matters both for exports and for reputation.

Two Dimensions: Legal Obligation and Inclusion

It is helpful to think of accessibility in two dimensions:

  • Legal dimension: Accessibility is becoming an explicit requirement in a growing number of regulations. For organizations providing public-facing digital services, accessibility is part of compliance.
  • Inclusion dimension: A significant portion of the population lives with some form of disability. An accessible site reaches these users rather than excluding them; it also improves the experience for older users, those with temporary impairments and mobile users.

Accessibility often moves in the same direction as SEO, performance and usability; well-structured headings, descriptive link text and adequate color contrast make a site better for both machines and people.

Why a "Double Obligation"?

Accessibility and cookie compliance live in the same layer, the front end where the user first makes contact with the site. The cookie banner is the first interaction a user encounters; if this banner cannot be used with a keyboard or read by a screen reader, problems arise for both accessibility and valid consent. For this reason, the two areas are often handled together.

The table below compares the two compliance areas:

DimensionWeb Accessibility (WCAG)Cookie / Data Compliance (KVKK)
ReferenceWCAG 2.2, EN 301 549KVKK and related legislation
Visible pointInterface, content, navigationCookie banner, privacy notice
Shared pointAccessible, usable banner and interface

Steps to Implementation

Steps that can be followed to manage the double obligation with a single program:

  1. Scan the current state: Run an automated accessibility scan and a cookie scan on your site.
  2. Set priorities: Rank the findings by impact and criticality.
  3. Make the banner accessible: Ensure the cookie banner is fully compatible with keyboard and screen reader use.
  4. Fix the content: Improve alternative text, form labels, heading hierarchy and color contrast.
  5. Monitor continuously: Plan regular re-scans as the site is updated.

Example Scenario

A tourism platform serving both Turkey and Europe runs an accessibility scan after launching its new website. The scan reveals that the cookie banner cannot be closed without a mouse, that many images lack alternative text and that color contrast is insufficient on some buttons. The team first makes the banner keyboard-accessible, strengthening both WCAG conformance and valid cookie consent at the same time. It then adds alternative text and corrects the contrast values. As a result, the platform can serve customers who use screen readers without friction and advances both compliance areas with a single effort.

Frequently Asked Questions

Which level should be targeted for WCAG conformance?

For most businesses and regulatory frameworks, the practical target is Level AA. AAA is the most comprehensive level but may not always be applicable to every type of content.

Does accessibility concern only users with disabilities?

No. Accessible design improves the experience for everyone, including older users, those with temporary impairments and people browsing on low bandwidth or mobile devices. It also contributes to SEO and general usability.

What does the cookie banner have to do with accessibility?

The cookie banner is the first interaction a user faces. A banner that cannot be used with a keyboard or perceived by a screen reader creates an accessibility violation and also calls into question whether consent is truly free and informed.

Should accessibility and cookie compliance be managed by separate teams?

Because the two areas intersect on the same front end, managing them together is more efficient. A single scanning and remediation cycle makes it possible to advance both compliance goals at the same time.

This content is for general information purposes only and does not constitute legal advice.

With JUS. you can start your website's cookie and accessibility compliance with a free scan and manage it from a single dashboard, request a demo today.

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