An expert's perspective on the evolving challenges and opportunities in accessibility testing as we move through 2025
The European Accessibility Act: The Game Changer
June 28, 2025, marked a pivotal moment in digital accessibility. The European Accessibility Act (EAA) officially took effect, fundamentally changing how organizations approach accessibility testing. Unlike previous accessibility regulations that primarily targeted public sector entities, the EAA casts a wide net across private businesses operating in the EU, covering everything from e-commerce platforms to mobile banking apps.
What makes this different? The EAA isn't just about WCAG 2.1 AA compliance—it requires organizations to embed accessibility into their maintenance processes and provide documentation of their accessibility support. Companies must now publish detailed accessibility statements and demonstrate ongoing compliance monitoring, not just one-time fixes.
The penalties are substantial and vary by country, with fines ranging from €60,000 in Ireland to €900,000 in the Netherlands. More critically, non-compliant products can be removed from the EU market entirely—a business-ending consequence for many organizations.
AI-Powered Testing: Promise vs. Reality
The accessibility testing landscape in 2025 is dominated by AI-powered solutions, but the reality is more nuanced than the marketing promises suggest. AI tools can now detect approximately 70% of common accessibility issues automatically, but this leaves a critical 30% that still requires human intervention.
The AI Advantage:
- Real-time issue detection during development
- Automated alt text generation for images (though with limitations)
- Self-healing test capabilities that adapt to UI changes
- Pattern recognition for complex accessibility violations
The AI Limitations:
- False positives remain a significant challenge
- Complex user workflows and dynamic content still require manual validation
- Context-aware accessibility decisions need human judgment
The most effective approach we're seeing is hybrid testing—combining AI automation with expert manual testing. Organizations like AudioEye demonstrate this approach by starting with automated scans and supplementing with accessibility expert reviews.
The Manual vs. Automated Testing Evolution
The debate between manual and automated accessibility testing has evolved beyond a simple either/or choice. In 2025, the question isn't which approach to use, but how to effectively combine them.
Automated testing excels at:
- Rapid scanning of large applications
- Consistent detection of technical violations
- Integration into CI/CD pipelines
- Cost-effective baseline compliance checking
Manual testing remains essential for:
- Real user experience validation
- Complex interaction patterns
- Context-dependent accessibility issues
- Dynamic content and single-page applications
The emerging best practice is to use automated tools for continuous monitoring while scheduling regular manual audits for comprehensive coverage.
Mobile Accessibility: The Overlooked Challenge
Mobile accessibility testing has become increasingly critical as mobile usage continues to dominate digital interactions. Yet many organizations still treat mobile accessibility as an afterthought, focusing primarily on web accessibility.
Key mobile accessibility challenges in 2025:
- Touch target sizing across diverse device types
- Screen reader compatibility with gesture-based navigation
- Testing across multiple operating systems and assistive technologies
- Responsive design accessibility at various screen sizes
The EAA specifically includes mobile applications in its scope, making mobile accessibility testing no longer optional for EU-serving businesses.
Common Mistakes That Persist
Despite increased awareness and better tools, testing teams continue to make predictable accessibility mistakes:
- Over-reliance on automated tools without manual validation
- Missing alt text or generic placeholder text instead of meaningful descriptions
- Insufficient color contrast testing across different viewing conditions
- Keyboard navigation failures in complex single-page applications
- Accessibility overlay dependencies instead of fixing underlying code issues
The WCAG Evolution: Looking Beyond 2.2
While WCAG 2.2 became the standard in October 2023, the accessibility community is already preparing for WCAG 3.0. The upcoming standard represents a fundamental shift from the current success criteria model to an outcomes-based approach with bronze, silver, and gold conformance levels.
WCAG 3.0 key changes:
- Flexible conformance scoring system
- Enhanced support for emerging technologies like AR/VR
- More nuanced approach to cognitive accessibility
- Better personalization and adaptation capabilities
However, WCAG 3.0 remains in early development with no defined release date, meaning organizations should continue focusing on WCAG 2.1/2.2 compliance for the foreseeable future.
Testing in the Age of Regulation
The regulatory landscape has fundamentally changed how we approach accessibility testing. Beyond the EAA, various countries are implementing their own accessibility requirements, creating a complex compliance environment.
Key regulatory trends:
- State-level accessibility laws expanding beyond Colorado HB-21
- Stricter enforcement and higher financial penalties
- Requirements for accessibility statements and ongoing monitoring
- Integration of accessibility into procurement processes
Practical Recommendations for Testing Teams
Based on current industry practices and regulatory requirements, here are my recommendations for accessibility testing in 2025:
1. Implement Hybrid Testing Strategies
Combine automated scanning with expert manual testing. Use automation for continuous monitoring and manual testing for comprehensive audits.
2. Test Early and Often
Integrate accessibility testing into your CI/CD pipeline rather than treating it as a pre-launch activity.
3. Focus on Real User Scenarios
Include users with disabilities in your testing process. Their feedback reveals issues that both automated tools and expert testers might miss.
4. Document Everything
With regulations like the EAA requiring accessibility statements, maintain detailed documentation of your testing processes, findings, and remediation efforts.
5. Stay Current with Tools
The accessibility testing tool landscape is rapidly evolving. Regularly evaluate new tools and approaches, particularly AI-powered solutions.
Looking Ahead
Accessibility testing in 2025 represents a maturation of the discipline. We're moving beyond basic compliance checking toward creating genuinely inclusive digital experiences. The combination of regulatory pressure, improved tooling, and growing awareness is driving organizations to take accessibility seriously.
However, challenges remain. The complexity of modern web applications, the rapid pace of technological change, and the persistent skills gap in accessibility expertise continue to create barriers. Success requires a combination of the right tools, proper training, and organizational commitment to accessibility as a core value rather than a compliance checkbox.
The organizations that will thrive in this new accessibility landscape are those that embrace comprehensive testing strategies, invest in both technology and human expertise, and view accessibility as an opportunity for innovation rather than a regulatory burden.
The future of digital inclusion depends not just on our tools, but on our commitment to creating experiences that work for everyone. As testing professionals, we have both the opportunity and responsibility to lead this transformation.
