The European Accessibility Act is enforceable. If you are reading this and have not yet checked whether your website or digital services comply, now is the time. This guide walks you through a practical audit process that does not require deep technical expertise to get started.
TL;DR
- An EAA accessibility audit starts with identifying all customer-facing digital touchpoints, not just your homepage
- Automated tools catch roughly 30-40% of accessibility issues; manual and assistive technology testing are essential
- Focus on critical user journeys first: navigation, forms, checkout, account management
- Document everything as you go; the EAA requires you to explain how your services meet accessibility requirements
- Build a remediation roadmap prioritised by user impact, not just technical severity
Step 1: Map Your Digital Estate
Before you test anything, you need to know what you are testing. Most businesses underestimate how many digital touchpoints they have. Think beyond the main website:
- Marketing website and all subdomains
- E-commerce platform (product pages, basket, checkout, order tracking)
- Customer portal or account area
- Mobile applications
- Email templates and newsletters
- PDF documents, downloadable forms, and digital brochures
- Chatbots and live chat interfaces
- Kiosks or in-store digital terminals
Create a simple spreadsheet listing each touchpoint, its URL or location, and who owns it internally. This becomes your audit scope.
Step 2: Identify Critical User Journeys
Not every page carries equal weight. Prioritise the journeys that customers must complete to use your service:
- Finding information: Can a user navigate to key content using only a keyboard? Is the site structure logical with proper heading hierarchy?
- Completing a purchase: Are form labels associated correctly? Are error messages clear and specific? Can the entire checkout flow be completed without a mouse?
- Managing an account: Can users log in, reset passwords, and update details using assistive technology?
- Getting support: Are contact methods accessible? Can a screen reader user operate your chat widget?
Step 3: Run Automated Testing
Automated tools are your starting point, not your finish line. They are good at catching structural issues but miss context-dependent problems. Here are reliable options:
- axe DevTools (browser extension, free tier available): Scans individual pages and provides detailed, actionable reports referencing specific WCAG criteria
- WAVE (wave.webaim.org): Visual overlay tool that highlights issues directly on the page, good for non-technical stakeholders
- Lighthouse (built into Chrome DevTools): Includes an accessibility score and recommendations, though less detailed than axe
- Pa11y (open source CLI): Useful for integrating automated checks into your CI/CD pipeline for ongoing monitoring
Run these tools across your critical journeys and export the results. You will likely find hundreds of issues. Do not panic. Categorise them.
Step 4: Manual Testing
This is where the real audit happens. Automated tools cannot tell you whether your content makes sense, whether your tab order is logical, or whether your custom components behave as expected.
Keyboard-only navigation
Put your mouse away and try to complete every critical journey using only your keyboard. Tab through the page. Can you see where the focus is at all times? Can you operate menus, forms, modals, and interactive elements? Can you escape from overlays and popups?
Screen reader testing
If you have never used a screen reader, start with VoiceOver (built into macOS and iOS) or NVDA (free, Windows). Navigate your key pages and listen. Are images described meaningfully? Are form fields labelled? Are dynamic updates announced? Do headings convey the page structure?
Zoom and text resizing
Zoom your browser to 200% and then 400%. Does the layout still work? Is content truncated or overlapping? Can you still complete key tasks?
Colour and contrast
Check that text meets minimum contrast ratios (4.5:1 for normal text, 3:1 for large text). Verify that colour is not the only means of conveying information (think error states, status indicators, required fields).
Step 5: Document and Prioritise
Compile your findings into a single report. For each issue, record:
- Which WCAG criterion it violates (e.g. 1.1.1 Non-text Content, 2.1.1 Keyboard)
- Where it occurs (URL, component, user journey)
- The impact on users (who is blocked and from doing what)
- A proposed fix
- Priority (critical, high, medium, low)
Prioritise by user impact first. A missing form label on your checkout page is more urgent than a contrast issue on a rarely visited policy page.
Step 6: Write Your Accessibility Statement
The EAA requires service providers to make information available about how their services meet accessibility requirements. An accessibility statement should include:
- Which standard you conform to (EN 301 549, WCAG 2.1 AA)
- Known limitations and the steps you are taking to address them
- Contact details for accessibility-related enquiries
- The date of your last assessment
This is not a legal shield. It is a transparency document. Be honest about where you stand and what you are doing about gaps.
Step 7: Build Ongoing Monitoring
An audit is a point-in-time snapshot. Accessibility degrades with every new feature, content update, and design change unless you build it into your workflow:
- Add automated accessibility checks to your CI/CD pipeline (Pa11y, axe-core)
- Include accessibility criteria in your design review and QA process
- Schedule quarterly manual audits of critical journeys
- Train content editors on accessible content creation (alt text, heading structure, link text)
Need Help With Your Audit?
Running an accessibility audit properly takes expertise. If you need a thorough assessment of your digital estate, a remediation plan, or help integrating accessibility into your development workflow, our team at REPTILEHAUS can help. We work with businesses across Dublin and Ireland on exactly this.
Get in touch to discuss your EAA compliance needs.
📷 Photo by Markus Winkler (@markuswinkler) on Unsplash
