EAA compliance for Hugo: WCAG 2.1 AA checklist & fixes

What the EAA actually requires from a Hugo site

The European Accessibility Act (Directive 2019/882) applies to consumer-facing online services from 28 June 2025. For a Hugo site selling to EU consumers, that means the storefront, checkout, account area, and any embedded payment flow have to meet WCAG 2.1 Level AA via the harmonised standard EN 301 549. Microenterprises with under 10 employees and below €2 million in turnover are exempt for services, but not for products.

Fines vary by member state. Germany caps individual penalties at €100,000; France can fine up to 4% of group turnover; Spain reaches €600,000 for serious or repeated breaches. None of those numbers are theoretical — market surveillance authorities have already started auditing storefronts in Germany and France in the run-up to enforcement.

In practice, the work breaks down into three buckets: theme-level fixes (focus styles, contrast, semantics), interaction-level fixes (carousels, modals, drawers, gallery widgets), and content-level fixes (alt text, headings, descriptive link text). The list below covers the Hugo-specific failure points we see most often during scans.

Top WCAG failures we see on Hugo sites

Across hundreds of Hugo scans, the same handful of issues show up over and over. None of them require ripping the theme apart — most are fixable in a few hours by someone comfortable in the platform's editor or template files.

• Themes that wrap headings in non-semantic divs

  Some Hugo themes use <div class="title"> for visual size.

  1.3.1, 2.4.6

• Code blocks without language labels

  Hugo Chroma syntax highlighting renders <pre><code> without the language hint, hurting screen-reader context.

  4.1.2

Concrete code fixes for Hugo

Below are copy-paste fixes for the most common Hugo issues. They assume you have access to your theme code or the platform's custom-code injection panel. If you cannot edit code directly, share these snippets with whoever maintains the site — every one of them is a ten-minute change.

<!-- layouts/_default/_markup/render-codeblock.html -->
{{ $lang := .Attributes.lang | default "code" }}
<div class="code" role="group" aria-label="{{ $lang }} code example">
  <span class="sr-only">{{ $lang }} code:</span>
  {{ highlight .Inner $lang "" }}
</div>

Tools and plugins worth installing first

• Hugo Pace.js or similar for SPA-like nav (audit if used)

How to scan a Hugo site without missing anything

Automated scanners catch about 30–40% of WCAG issues; the rest need manual review. The good news is that the 30–40% includes the most expensive issues to remediate after the fact, so an automated scan is the cheapest way to get unstuck. Run one before you change a line of theme code.

• Run scans against the built /public output served by any web server.