Manual vs. automated accessibility: striking the balance
Accessible design isn't a one-off task. Rather, it's a long-term commitment. It demands you take a look at your publicly facing digital presence and identify areas where you fall short. With every update and expansion, you repeat the process.
It isn't easy, but it matters. As Piers Harrison, Head of Quality Assurance at SQLI UK & ME explains: "Building inclusive digital products is a moral responsibility—the internet should be accessible to everyone. There’s also a commercial incentive: you want the widest possible audience to browse your site. And increasingly, it’s a legal requirement for B2C businesses."
On 28 June 2025, new rules under the EU's European Accessibility Act take effect. B2C eCommerce businesses in the European Economic Area (EEA) must ensure their products meet specific accessibility standards. With the deadline approaching, many businesses are looking for assurance that they’re compliant.
A common question is whether automated tools are enough—or if a human expert is needed to ensure accuracy.
Understanding the criteria
The European Accessibility Act allows member states to create their own monitoring and enforcement processes but proposes standards for conformity: the EN 301 549 version 3.2.1. These European standards directly reference the globally recognised WCAG 2.1 for web accessibility, and offer a ‘presumption of conformity.’ This simply means that if a site meets the specified EN 301 549 requirements, it is presumed to comply with the Act’s obligations. The Act applies to any site that ships to the EU, impacting many UK-based sites that ship to Ireland and other EU destinations.
Here's where it gets complicated: a product can either fail or pass one of the WCAG tests, but that's up to the judgement of a person. A lot of the requirements — like whether a page renders correctly, or is compatible with a screen reader, or whether functional and decorative elements are easily distinguished — are subjective. A human has to interpret the guidelines and determine whether a product meets expectations. This is why having a skilled QA expert is essential for ensuring a product truly meets accessibility standards.
Vayia Malamidou, an Accessibility and Usability Consultant at AbilityNet, explains: "When interpreting the WCAG guidelines, things aren't always clear-cut. Many of the success criteria are hard to interpret, and there's often debate around their intent and objectives."
Vavia made another important point. In many of the WCAG guidelines, success isn't just about whether you've done something, but rather how well you've done something. It's not just enough to ensure that each image is accompanied with alt text. That text has to be correct, descriptive, and complete.
Humans or algorithms?
When performing an accessibility audit, the choice isn't between manual and automated tests, but rather deciding how much automation to use, where to use it, and when.
"It's very important that accessibility audits are done by humans in the first instance, because the requirements are somewhat nuanced, and it's hard to catch every potential issue when you're only relying on automated tools," said Piers.
One audit of automated tools by the UK Government Digital Services team found that the best-performing product only caught 40 per cent of all issues. The worst-performing only identified 13 per cent. Although that study dates from 2018, subsequent examinations show that their performance had not substantially improved in the years since.
Although Vavia pointed out that many automated tools are fast, and they can identify certain HTML issues faster than a human reasonably could, they're nowhere near reliable enough to replace manual testing.
"The general feeling is that an automated tool would pick up 30 to about 60 per cent of accessibility issues. And even within this percentage of success, we sometimes get false positives," she said.
Despite that, Vavia believes there's a place in accessibility testing and remediation for automated tools. She points to generative AI, which can suggest image descriptions that a human can then refine and add to the alt text.
Another example would be using automated tools for long-term monitoring after the completion of the manual test.
"When people are constantly updating content in the CMS, uploading images and so on, you'll probably end up with some regression in accessibility," said Piers. "A monitoring tool can pick that up and alert those responsible, giving them a chance to fix it."
A human-first approach
Ultimately, you build websites and apps for people. It only makes sense that humans — with the ability to comprehend subtle nuances and interpret the subjective criteria of the WCAG standard — should take the lead in accessibility testing.
Automation has its place, but it should be seen as a supporting tool to achieve long-term compliance with the European Accessibility Act.
For those needing extra support, consider getting in touch with SQLI. We take pride in our thorough approach and speed. Within two to three weeks, we can perform a full accessibility assessment of your website, giving your engineers the information they need to fix any problems. We can also highlight and resolve any design flaws and guide your processes to prevent future accessibility issues, setting you up for sustainable success.