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Dark mode: accessibility and legal requirements, not a trend

Dark mode is often discussed in terms of style and personal preference. For organisations subject to accessibility legislation for digital public services, however, the issue goes beyond that. It is about accessibility, user control and, in practice, legal requirements. Despite this, awareness remains relatively low. Many organisations still view dark mode purely as a design choice. But when users actively choose how their operating system should appear, it ultimately becomes something else: respecting user needs and creating digital services that work for more people.

Ida Reimers

UX-designer and Consultant manager

What is dark mode?

Dark mode means that a digital interface uses dark backgrounds with light text instead of the traditional light design. The feature is often enabled through operating system or browser settings, allowing the experience to be tailored to individual needs and preferences.

A requirement many organisations overlook

When digital accessibility is discussed, the focus is often on WCAG (Web Content Accessibility Guidelines), international guidelines developed by W3C to make web content accessible. However, Swedish accessibility legislation for digital public services is based on the European standard EN 301 549, which includes additional requirements beyond WCAG 2.1.

One of these is criterion 11.7: Respect user preferences. This means that digital services should follow the user’s choices, such as colour and contrast settings – where dark mode is often included. Digg – Myndigheten för digital förvaltning, which is responsible for supervising compliance with the legislation in Sweden, also states that services should respect user settings for, among other things, colours and contrast.

This does not mean that all services must offer a manual dark mode toggle. What matters is that the interface works in harmony with the user’s own system settings.

Why does it matter?

For many users, dark mode is not just an aesthetic preference – it is a feature that makes digital services easier to use in everyday situations.

Common reasons why users choose dark mode include:

light sensitivity or migraines
reduced visual strain
improved comfort in low-light environments
individual accessibility needs
lower energy consumption on OLED screens

When a service ignores system settings, it risks creating unnecessary barriers – even though the user has already made an active choice in their operating system.

Why dark mode matters for your users

A large share of users already use dark mode

Dark mode has become an established part of today’s digital behaviour. Several studies and industry reports show that its use is widespread, particularly on mobile devices. At the same time, UX research shows that preferences vary. Some users prefer dark mode, others light mode, and many switch between the two depending on the situation.

In a study by Nielsen Norman Group, participants were roughly split into three groups: one third preferred light mode, one third dark mode, and one third used both.

Research also shows that dark mode is not optimal for everyone. Some people read better in light mode, others in dark mode. The key takeaway is therefore not which mode is best, but that users should be able to choose what works best for them.

Why organisations should care – beyond compliance

Supporting users’ colour preferences brings several clear benefits. Interfaces feel more natural when they follow the user’s own settings. Accessibility improves when more people can use a service in a way that works for them. It also makes solutions more future-proof, as system-driven settings are becoming increasingly common.

Organisations that prioritise accessibility and thoughtful design also signal quality, professionalism and a genuine commitment to their users.

The key insight

The most important thing is to respect user preferences and give people control over their digital experience. When a large share of users are already making active choices in their operating systems, the real question is not whether to support dark mode – but whether you can afford not to. At its core, accessibility is about the same thing that good design has always been about: adapting to the user, not the other way around.

Want to learn more?

Would you like to discuss how dark mode and user preferences can be handled in practice, or get support with implementation and accessibility work? Get in touch with us at Consid – we’d be happy to help.