Accessibility Audits Under the EAA: What Inspectors Will Look For

With the European Accessibility Act (EAA) set for full enforcement in June 2025, organizations doing business in the EU must ensure their digital products and services meet accessibility requirements. But what does compliance actually involve? And how do accessibility audits work under the EAA?

This guide breaks down what inspectors will look for, how to prepare, and why monitoring and documentation matter more than ever.

What Triggers an Accessibility Audit?

Regulators in each EU member state are responsible for enforcement. Accessibility audits may be triggered by:

  • Routine regulatory inspections

  • Consumer complaints or advocacy group actions

  • Spot checks in high-risk sectors like e-commerce, banking, or transport

  • Evidence of inaccessible digital content

While enforcement mechanisms differ by country, audits will generally align with WCAG 2.1 and harmonized EU standards.

What Will Inspectors Evaluate?

Inspectors will focus on several key areas of your digital ecosystem:

1. Websites and Mobile Apps Expect testing for:

  • Keyboard navigation and screen reader compatibility

  • Color contrast and text size options

  • Semantic HTML structure

  • Alt text on images

  • Accessible form fields and buttons

2. Digital Documents and E-Content PDFs, eBooks, and digital brochures must include:

  • Logical tagging and reading order

  • Descriptive alt text

  • Accessible tables and headings

  • Screen reader compatibility

3. Customer Service Channels Auditors will assess whether users with disabilities can:

  • Access live chat and self-service portals

  • Navigate contact forms

  • Reach support via accessible communication methods

4. Third-Party Technology Even if you use external platforms or tools, your organization can still be held responsible. Auditors may request:

  • Accessibility conformance statements (e.g., VPATs)

  • Vendor compliance documentation

  • Evidence of due diligence in procurement

5. Accessibility Statement and Feedback Process Your site or service must include:

  • A clear, up-to-date accessibility statement

  • A way for users to report accessibility issues

  • A documented process for responding and remediating

Monitoring and Logging: Your Compliance Lifeline

It’s not enough to identify and fix issues. Regulators want proof that accessibility is a sustained priority.

1. Track Remediation Work Maintain a detailed log that includes:

  • Description of each issue

  • WCAG criteria violated

  • Date identified and resolved

  • Assigned team or vendor

  • Links to fixed content or screenshots

2. Monitor for New or Repeating Issues Use automated tools to:

  • Continuously scan for accessibility problems

  • Prevent regressions after code updates

  • Document incremental improvements

3. Centralize Logs and Reports Whether using Jira, an internal tracker, or an accessibility platform, consolidate your compliance data. Include:

  • Ticket numbers and statuses

  • Remediation timelines

  • Test results and QA sign-offs

4. Show a Repeatable Process Auditors will ask how you:

  • Identify and track issues

  • Prioritize and assign fixes

  • Validate resolutions

  • Ensure accountability

Your logs and monitoring reports are your strongest defense.

Final Thoughts

An EAA audit is more than a checklist—it's a test of your organization's digital maturity and risk management. By preparing your web assets, monitoring continuously, and documenting thoroughly, you can meet compliance requirements and deliver a more inclusive user experience.

Start now. The June 2025 deadline is closer than it seems.

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