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Accessibility · EAA · EN 301 549 · WCAG 2.2

Accessibility conformance, declared honestly.

No tool can prove a website is accessible — the EU Accessibility Act knows it: conformance is a manufacturer self-declaration, not a scanner's stamp. Watchdog proves what fails, pre-fills those criteria, and blocks you from marking them passed without a recorded reason. The conformance claim is yours, signed by a named person. We measure; you declare. We never certify.

A clean automated result is necessary, not sufficient — a green Watchdog score is never a conformance claim.

ACR / VPAT · EN 301 549 ANNEX V

Accessibility Conformance Declaration

Declared bya named person · signed · valid 1 year
1.1.1 Non-text ContentSupports — tool-verified
1.4.3 Contrast (Minimum)Does Not Support — tool-verified
2.4.4 Link PurposeSupports — human attestation

Tooling can only disprove conformance — never prove it. The claims rest on the declarant, not on Watchdog.

The law

What the EU Accessibility Act actually asks of you.

In force 28 June 2025

The EAA (Directive 2019/882) requires covered digital products and services to conform; for the web that means EN 301 549, which currently points at WCAG 2.1 AA and is moving to 2.2 AA. Conformance is established by a manufacturer's self-declaration — you are the declarant. There is no certificate to buy, and no scanner's green tick discharges the obligation.

The honest truth most accessibility tools won't tell you

"One script = compliant" overlay widgets are rejected by the disability community and EU regulators. Automated checks cover roughly a third of WCAG. No tool is accepted as proof of conformance under the EAA — none. A tool can prove a failure; conformance requires manual evaluation (WCAG-EM 1.0) and a human declaration.

Evaluation

Four tiers — what a tool can do, and where a human must.

Tier A

Tool-automated

The machine proves failures — alt text, labels, page language, name/role/value. A failure is real: pre-set to Fail, gates sign-off.

Tier B

Evidence-assisted

Needs rendered runtime + assistive tech — contrast, focus order, reflow, keyboard traps. With the framework on, Watchdog renders your UI in a sandboxed headless browser and runs axe-core, pre-filling criteria with double-render-verified evidence. For apps that can't render statically, the Runtime Evidence module boots the whole app from its own declared setup in an isolated sandbox — you change nothing. All advisory — it never moves your CAI.

Tier C

Human judgement

Meaning no tool decides — is the alt text equivalent? Is the error message clear? You judge it, optionally with an AI-drafted note you review.

Tier D

Non-web (EN 301 549)

Hardware, two-way voice, video, documents, support. Beyond Watchdog's reach — disclosed as pure human attestation, never dressed up.

Integrity

The integrity keystone: we won't let you pass what we caught failing.

The failure-gate

A caught failure pre-sets the criterion to Fail and locks it; marking it Pass requires a written justification, reproduced in full in the Integrity section of the artifact.

Provenance on every line

Every verdict states how it was reached: tool-verified / evidence-assisted / AI-drafted-and-reviewed / human attestation.

The lifecycle

The workflow.

Scan

The accessibility lens assesses the machine-checkable surface of WCAG 2.2 AA + 2.1 AA and reports an honest coverage map — naming the exact criteria it could and couldn't evaluate. A partial signal, stated as one.

Self-assess & evidence

A signed-in member sets the WCAG-EM scope and works every criterion; the gate enforces honesty; supporting documents (a manual test report, a pentest) attach with a hash.

Sign

A named declarant signs. The declaration freezes into immutable, tamper-evident bytes — a SHA-256 you can re-verify. You may honestly conclude "does not fully conform."

Export, require & keep current

Download the ACR/VPAT with the evidence travelling inside it; optionally bind a contract profile; "Extend" re-issues for the next scan, re-running the gate.

Signing and the binding contract clause are business artifacts — activated on Assay.

Make it binding

Put it in the contract.

Contract profile · opt-in clause

Watchdog Accessible Web Delivery — Conformance

  • The delivered web product shall be assessed for accessibility (declared lens, binding)
  • A current, signed accessibility conformance self-declaration shall exist for the accepted run
  • Tooling gates the floor; a named person signs the conformance claim Watchdog cannot make on their behalf

Opt-in. The readiness-only profile stays readiness-only — it never claims conformance.

What Watchdog will never claimWe do not certify and are not a notified body. A Watchdog score is not a conformance claim. "Tool clean" is necessary, not sufficient. We never auto-pass a criterion — nothing is signed without a human. The candour is the product: a claim is only worth what its honesty can survive — a disabled user, a regulator, and a court.

Declare it honestly.

We measure; you declare. We never certify. · What we measure · Security & data