Earlier quoted context omitted.
They have defined what exactly needs to be done to be compliant, it's basically "meet WCAG 2.1 Level AA" with some additions. WCAG has already been the de facto standard for decades.
I assume you have not read Directive 2016/2102 and/or EN 301 549, because your approach is nice and so very, very, very suable. The issue is not accessibility itself. I'm all for making things simpler. The issue is that the EU framework combines broad principles, partial technical references, vague proportionality requirements, and evolving judicial interpretation. In practice, that means the exact compliance boundar…
> And for the attacker, they only need to find one case of violation - while you need to be correct 100% of the time.
I don't know how European regulators work but even in the litigious U.S., this is not true, at least not in the courts. However, for small businesses, which are more likely to be targeted by the trolls, the cost of proceeding far enough to get a suit dismissed is burdensome. And in the EU, I thought individuals couldn't bring cases to a judge, they have to complain to a regulatory body that can decide whether proceeding is warranted or not.
> implement defensive overcompliance far beyond practical usability requirements
This is like complaining about having fewer grams of rat turd in your flour than legally mandated; "Oh no, we made our product too good!"
In practice, building "reasonable software" has never included making it work for people with disabilities, despite WCAG and the web standards themselves existing for decades.