EAA compliance checker: what an automated scan can and can't tell you about EN 301 549

What does an EAA compliance checker actually test?

An EAA compliance checker tests the rendered HTML of web pages against clause 9 of EN 301 549, the clause for the web. The Directive itself doesn't name WCAG; EN 301 549 does, and its clause 9 repeats the WCAG 2.1 A and AA success criteria with a "9." in front: WCAG 1.1.1 is clause 9.1.1.1. The rest of the standard covers things a page scanner never sees.

One version note: EN 301 549 v4.1.1, published in September 2026, adds the WCAG 2.2 criteria. Until the European Commission references it in the Official Journal of the EU, v3.2.1 and WCAG 2.1 AA remain the reference.

Source: EUR-Lex, ETSI, AccessibleEU (European Commission)

Which WCAG 2.1 AA criteria can a checker test?

We counted the rules in axe-core's published rule list in October 2026, leaving out deprecated and experimental rules. Twenty criteria have at least one rule:

Having a rule doesn't mean a criterion is fully tested. image-alt finds an image with no alt attribute; it can't tell you that alt="IMG_2041" is useless. color-contrast can't be sure about text over photos and gradients.

The other 30 criteria have no axe-core rule at all:

• Keyboard and focus (4): 2.1.2 No keyboard trap, 2.1.4 Character key shortcuts, 2.4.3 Focus order, 2.4.7 Focus visible.
• Forms and messages (4): 3.3.1 Error identification, 3.3.3 Error suggestion, 3.3.4 Error prevention (legal, financial, data), 4.1.3 Status messages.
• Layout and visuals (7): 1.3.2 Meaningful sequence, 1.3.3 Sensory characteristics, 1.3.4 Orientation, 1.4.5 Images of text, 1.4.10 Reflow, 1.4.11 Non-text contrast, 1.4.13 Content on hover or focus.
• Media (4): 1.2.1, 1.2.3, 1.2.4 and 1.2.5, the audio, video, live caption and audio description criteria.
• Pointer, motion and flashing (4): 2.3.1 Three flashes, 2.5.1 Pointer gestures, 2.5.2 Pointer cancellation, 2.5.4 Motion actuation.
• Navigation and consistency (6): 2.4.5 Multiple ways, 2.4.6 Headings and labels, 3.2.1 On focus, 3.2.2 On input, 3.2.3 Consistent navigation, 3.2.4 Consistent identification.
• Parsing (1): 4.1.1, removed as obsolete in WCAG 2.2.

Several of these decide whether an EU customer can pay at all: a card form that traps focus, an error shown only in red, a "Payment failed" message a screen reader never announces.

Source: Deque Systems, GitHub, W3C

If 30 criteria have no rule, why does a checker find 57% of issues?

Because issues aren't spread evenly across criteria. Deque's 2021 study of more than 2,000 audits found that automated testing caught about 57% of all issues by count. The criteria a checker can test are the ones that fail most often: in WebAIM's February 2026 scan of one million home pages, 83.9% had low contrast text and 53.1% had images without alt text.

So both statements are true: a checker covers less than half of the criteria, and more than half of the issues you'll actually find. Use it for volume and repetition, and spend human time on the 30. Our 6-step test method covers the most important ones; by our estimate it takes one to two hours for a small site.

One fix a checker does catch, and that matters on EU checkouts: an invalid autocomplete value (axe rule autocomplete-valid, WCAG 1.3.5, Level AA). Browsers and password managers can only fill a field for the customer if the token is valid.

Source: Deque Systems, WebAIM, Deque Systems, GitHub

What does the EAA ask for beyond the website code?

The EAA asks service providers to publish information on how their service meets the accessibility requirements (Article 13 and Annex V), in an accessible format. In practice this is an accessibility statement: what conforms, what doesn't yet, and how a customer can reach you. Our free statement generator produces one in five languages. Support services (clause 12 of EN 301 549) must also give information on accessibility features and meet the communication needs of people with disabilities.

Enforcement is national. In the Netherlands, the ACM reported in March 2026 that 61% of about 100 large online shops it tested were not accessible. In France, a court in Caen gave Carrefour six months to make its site accessible, then a penalty of €500 a day (June 2026). Germany's BFSG allows fines of up to €100,000 for certain breaches. For sellers based outside the EU, see the EAA for sellers outside the EU and our EAA guide.

Source: EUR-Lex, ACM (Netherlands Authority for Consumers and Markets), Faire Face, bfsg-gesetz.de

How should you read a checker that says "EAA compliant"?

Treat it as a marketing claim, not a result. On 22 April 2025 the US FTC finalised an order requiring accessiBe to pay $1 million and barring it from claiming without evidence that its product makes websites WCAG-compliant. The FTC acts in the US, but the logic carries: no tool can verify the 30 criteria above. Before you rely on a checker, ask:

1. Which engine and version does it run, and which rules are switched on?
2. Does it scan every template and the full checkout, or only the home page?
3. How does it report "needs review" items: as passes, or as open questions?
4. Does it test PDFs and the mobile app, or say clearly that it doesn't?
5. Does it state, in the report itself, what it can't test?

Our own scan answers the last question in every report: it lists the automated findings by severity and adds a manual checklist for the criteria above. It never says "compliant".

Source: US Federal Trade Commission (FTC)