A scan tool can support EAA compliance work, but it cannot confirm conformance on its own. Automated scans detect approximately 25% of accessibility issues, which means the remaining 75% requires human evaluation. For organizations subject to the European Accessibility Act, scanning fits as one layer in a broader program that includes manual audits, screen reader testing, and keyboard testing.
| Key Point | What It Means |
|---|---|
| Scan coverage | Automated scans detect approximately 25% of WCAG issues by evaluating HTML, CSS, and ARIA attributes. |
| EAA standard | The EAA references EN 301 549, which incorporates WCAG 2.1 AA as the technical baseline for digital products and services. |
| Monitoring role | Scheduled scans surface regressions between audits, providing recurring visibility into code-level issues. |
| Required complement | A manual audit by accessibility professionals identifies the issues scans cannot detect. |
What a Scan Tool Actually Evaluates
A scan tool loads a web page and runs automated checks against WCAG success criteria. It evaluates the HTML structure, CSS properties, and ARIA attributes that are present in the rendered code. When a rule violation is detected, the scan reports the issue with its location and the criterion it relates to.
This is useful, but the evaluation is mechanical. Scans confirm that an image has an alt attribute. They cannot confirm whether the alt text accurately describes the image. Scans confirm that form fields have associated labels. They cannot confirm whether the label makes sense to a screen reader user in context.
Why Scans Alone Do Not Demonstrate EAA Conformance
The European Accessibility Act applies to products and services placed on the EU market, with most obligations going into effect in June 2025. The technical reference standard is EN 301 549, which incorporates WCAG 2.1 AA. Conformance means the digital product or service meets every applicable success criterion, not only the ones a scanner can verify.
Approximately 75% of WCAG criteria require human evaluation. This includes things like meaningful sequence, link purpose in context, descriptive headings, error identification clarity, and consistent navigation patterns. None of these are reliably detected by code-based checks.
How Scanning Fits Into an EAA Monitoring Program
Scans work well as a recurring monitoring layer between deeper evaluations. Most platforms allow scheduled scans on a daily, weekly, or monthly cadence. Authenticated page scanning, which requires a browser extension running within an active session, extends coverage to gated areas of a product.
A practical structure for EAA monitoring typically includes:
- Baseline manual audit conducted by accessibility professionals against WCAG 2.1 AA, producing a list of issues with prioritization by user impact and risk factor.
- Remediation of identified issues, with validation that fixes resolve the underlying problem.
- Scheduled scans running across key templates and high-traffic pages to surface code-level regressions.
- Periodic re-evaluation after significant product changes or on a recurring cycle.
What Scans Catch That Matters for EAA
Within their 25% coverage, scans reliably catch a meaningful slice of recurring issues: missing alt attributes, missing form labels, missing language attributes, empty buttons and links, invalid ARIA usage, and certain heading structure problems. These are common regressions introduced during ongoing development, which is why scan-based monitoring earns its place in a program.
The value of scanning is high confidence at limited coverage. The reported issues are accurate and actionable, which makes them efficient to assign and fix.
What Scans Miss
Scans cannot evaluate whether content is understandable, whether interactive components behave correctly with assistive technologies, or whether the reading order matches the visual order. They cannot confirm that custom widgets announce state changes to NVDA, JAWS, or VoiceOver. They cannot evaluate keyboard operability across complex flows.
For EAA conformance documentation, a scan report is not sufficient evidence. Regulators and procurement teams reviewing accessibility claims expect evaluation methods that reflect the full standard, which means screen reader testing, keyboard testing, and code inspection conducted by qualified evaluators.
Using Scans as Part of the Answer, Not the Whole Answer
A scan tool is a strong fit for ongoing EAA monitoring when paired with a manual audit. The scan provides recurring visibility. The audit provides the depth required to evaluate the criteria scans cannot reach. Together they form a workable program. Either one alone leaves significant exposure.