Most Accessible for People with Disabilities

Most Accessible for People with Disabilities: expert analysis covering WCAG compliance, screen reader support, motor impairment accommodations, and assistive technology compatibility across leading EUDI Wallet implementations.

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Why Accessibility Matters for EUDI Wallets

Approximately 87 million people in the European Union live with some form of disability. As EUDI Wallets become essential for accessing government services, healthcare, banking, and travel, ensuring these tools work for everyone is not just a matter of compliance but of fundamental rights. The European Accessibility Act, effective since June 2025, establishes binding requirements for digital products including identity wallets.

Digital identity verification is particularly critical for people with disabilities because they often interact with government services and healthcare systems more frequently than the general population. An inaccessible wallet creates a compounding barrier: people who already face obstacles in daily life are further excluded from the digital services designed to make those interactions easier.

The Netherlands has taken a leadership position in this area through its open-source approach. By publishing the NL-wallet code on GitHub, Logius enables accessibility researchers, disability advocacy organizations, and assistive technology vendors to audit and contribute improvements. This transparent development process has led to faster identification and resolution of accessibility issues compared to closed-source alternatives.

How We Evaluated Accessibility

Our assessment used a multi-layered approach aligned with the Web Content Accessibility Guidelines (WCAG) 2.1 at the AA level. We tested each wallet with popular screen readers including VoiceOver (iOS), TalkBack (Android), and external braille displays. We evaluated navigation using only keyboard or switch access, tested with various color vision deficiency simulations, and assessed the usability of each wallet under different text size settings up to 200%.

Beyond technical compliance, we evaluated the cognitive accessibility of each wallet. This includes the clarity of language used, the number of steps required for common tasks, the quality of error messages, and whether the app provides adequate time for users who process information more slowly. Germany's AusweisApp scored particularly well in this area thanks to BSI's complete accessibility guidelines that cover cognitive as well as sensory and motor impairments.

We also consulted accessibility audit reports where available. The Netherlands publishes accessibility statements for its government digital services, and Germany requires BSI certification that includes accessibility verification. France mandates RGAA compliance for all government apps, which aligns with WCAG 2.1. These official assessments provided a baseline for our own evaluation.

Key Accessibility Features to Look For

Screen reader compatibility is the most fundamental accessibility feature. A well-implemented wallet announces all interactive elements, provides context for icons and images through alt text, and maintains a logical reading order. The NL-wallet excels here because its open-source development includes automated accessibility testing in the CI/CD pipeline, catching regressions before they reach users.

For users with motor impairments, look for large touch targets (minimum 44x44 pixels as recommended by WCAG), support for external switch devices, and the ability to complete all actions through voice control. Germany's AusweisApp supports Android's Switch Access and Voice Access services, making it usable for people who cannot interact with a touchscreen. The eID chip-based authentication also provides an alternative to complex on-screen gestures.

Authentication method flexibility is important. Not everyone can use fingerprint recognition or face recognition. The best wallets offer multiple authentication paths including PIN, biometrics, and NFC-based card verification. Belgium's MyGov.be wallet, built on the itsme platform with 7 million users, offers fingerprint, face recognition, and PIN fallback, ensuring users can always find an authentication method that works for them.

Future Developments in Accessible Digital Identity

The European Commission is developing specific accessibility implementing acts for EUDI Wallets that will go beyond current WCAG standards. These are expected to include mandatory voice-guided onboarding, simplified consent screens designed for cognitive accessibility, and standardized emergency recovery procedures that do not require complex multi-step verification processes.

Emerging technologies will further improve accessibility. AI-powered interface adaptation could automatically adjust the wallet's layout, contrast, and interaction patterns based on the user's assistive technology configuration. Haptic feedback patterns for credential verification status are being prototyped by the Netherlands and Germany, providing non-visual confirmation that a transaction has succeeded or requires attention.

The open-source movement in EUDI Wallet development is particularly beneficial for accessibility. As both the Netherlands and Germany publish their wallet code publicly, the collective expertise of the accessibility community can be used to identify and fix issues. Italy's IT-Wallet team has also committed to accessibility-first development, building on the SPID system that already serves 37 million users and must comply with Italian accessibility legislation.