Legal accessibility standards often fail to reflect the real experiences of users with disabilities. Focusing on visually impaired users, we conducted a comparative analysis of international accessibility guidelines and performed empirical testing with 10 participants using smartphone-based scenarios. The study identified 51 key pain points not captured by existing standards, including issues related to feedback clarity, interface responsiveness, and customization. These findings were synthesized into actionable design guidelines to bridge the gap between compliance and actual usability. While the study is limited to visual impairments and smartphone usage, it lays the groundwork for broader application across diverse disability types and ICT devices. This research highlights the importance of aligning accessibility standards with the actual usability needs of visually impaired users.