EAA compliance tools: what automated checks catch, and what they never will

4 September 2026 · 4 min read

Search for an "EAA compliance tool" and you get two very different things wearing the same name. One is an automated scanner: it crawls your pages and reports errors it can measure. The other is an overlay widget: a line of JavaScript that promises compliance in a day. They are not the same product, and only one of them is genuinely useful.

This is what each actually does, and what neither of them can do for you.

Isometric illustration of a laptop with a magnifying glass hovering over an abstract interface
A scanner reads structure, not meaning. That distinction is the whole subject of this article.
What an automated accessibility scanner reliably detects and what it cannot detect, shown as two lists side by side.What a scanner sees, and what it missesCAUGHT AUTOMATICALLYMissing alt attributesColour contrast below 4.5:1Form fields with no labelEmpty links and buttonsMissing lang on the pageBroken heading orderInvalid ARIA rolesONLY A HUMAN CAN JUDGEWhether the alt text is accurateWhether focus order makes senseWhether a custom widget works bykeyboardWhether the error message helpsWhether captions match the audioWhether the page still works at 200%zoomWhether the reading order is logical
Presence is testable, meaning is not. An image with alt="image1234.jpg" passes the automated check and fails the requirement.

What the law points at

The European Accessibility Act, Directive (EU) 2019/882, has applied since 28 June 2025. It covers products and services sold to consumers in the EU: e-commerce, consumer banking, e-books, ticketing and check-in machines, transport information, and more.

Here is the part that trips people up. The Act itself does not contain a list of things to test. It sets the obligation and points at the harmonised standard, EN 301 549, which for web content in turn points at WCAG 2.1 level AA. So when someone says "we need to pass the EAA", what they are going to be measured against is WCAG.

How the European Accessibility Act connects to EN 301 549 and to WCAG 2.1 level AA.What the law actually points atEuropean Accessibility ActDirective (EU) 2019/882. Sets the obligation, not the test.EN 301 549The harmonised European standard. Turns the obligation into testable requirements.WCAG 2.1 level AAThe success criteria your pages are measured against.The Act says "make it accessible". EN 301 549 says how you prove it.
The Act sets the obligation. EN 301 549 turns it into requirements you can test. WCAG 2.1 AA is what your pages are measured against.

The Act adds obligations that WCAG says nothing about: you have to provide information about the accessibility of your service, keep it available, and be able to explain how you meet the requirements. A perfect scanner score does not produce that document.

Where automated scanning genuinely helps

Scanners are excellent at exactly one thing: finding mechanical failures in bulk, across thousands of pages, in minutes. That is not a small thing. If you have 4,000 product pages with a missing form label in a shared template, a scanner finds it in one run and a human never will.

What they reliably catch: missing `alt` attributes, colour contrast below threshold, form controls with no programmatic label, empty links and buttons, a missing `lang` attribute, broken heading order, invalid ARIA roles and references.

But they only see what can be measured mechanically. Every serious study of automated testing puts the share of WCAG issues detectable that way at roughly a third. Not because the tools are bad, but because most accessibility failures are about *meaning*, and meaning is not a property a script can read.

An image with `alt="image1234.jpg"` passes the "has alt text" check. It fails the actual requirement completely. The scanner cannot tell the difference; a person can, in two seconds.
Isometric illustration of a keyboard with a focus ring moving across abstract interface blocks
The keyboard pass is where the real failures show up, and no tool can run it for you.

What no tool can decide for you

About overlays

Overlay widgets deserve a direct answer, because they are sold hard and they are the reason a lot of people search for a compliance tool in the first place.

An overlay cannot fix the underlying HTML that a screen reader reads. It sits on top of it. In practice, users of assistive technology report that overlays frequently make things worse, because they interfere with the settings and behaviour the user has already configured. There is a widely signed community statement to that effect, and enforcement bodies have not accepted overlays as a substitute for conformance.

If a vendor offers you legal compliance from a single script tag, treat that as the claim it is. We wrote about this in more depth in the problem with accessibility overlays.

What a working process looks like

Isometric illustration of a document floating above a panel with three status markers
The accessibility statement is a legal requirement in its own right. A perfect scan does not produce it.
A four step order of work: automated scan, keyboard pass, assistive technology spot checks and the accessibility statement.The order that actually works1ScanClears the mechanicalerrors in bulk. Cheapand fast.2KeyboardTab through every flow.No mouse. Most failuresshow up here.3Screen readerSpot check the journeysthat make you money.4StatementPublish what works, whatdoes not, and how toreport it.
Scanning first is what makes the human time affordable. Doing it the other way round wastes your most expensive resource on the cheapest problems.
  1. Run the scanner first. It is cheap, fast and clears the mechanical noise so that human time is not wasted on it. Run it in CI so regressions do not creep back in.
  2. Do a keyboard pass. Unplug the mouse. Tab through your top five user journeys end to end: search, product, cart, checkout, account. If you cannot complete a purchase with the keyboard alone, nothing else on the list matters yet.
  3. Spot check with a screen reader. NVDA on Windows or VoiceOver on macOS, on the same journeys. You are not auditing everything, you are checking whether the important paths are usable.
  4. Write the accessibility statement. What conforms, what does not yet, what the workaround is, and how someone reports a problem. This is a legal requirement, and it is also the document that shows good faith if anyone ever asks.

The short version

An automated tool is a necessary part of the process and never the whole of it. It removes the errors that are cheap to find so that you can spend expensive human attention on the ones that actually stop people using your site.

Anyone selling you the whole of it in a script tag is selling you the part that does not exist. If you want a starting point, our EAA compliance checklist walks through the requirements one by one.

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