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Accessibility · EAA · EN 301 549 · WCAG 2.2

Accessibility conformance, declared honestly.

No tool can prove a website is accessible — and the EU Accessibility Act knows it: conformance is a manufacturer self-declaration, not a scanner's stamp. Watchdog does the part a tool honestly can: it proves what fails, pre-fills those criteria, and then 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, by itself, a conformance claim.

sample artifact
ACR / VPAT · EN 301 549 Annex V · sample

Accessibility Conformance Declaration

Declared by: a named person · signed · valid 1 year

CriterionConformanceBasis
1.1.1 Non-text ContentSupportsTool-verified
1.4.3 Contrast (Minimum)Does Not SupportTool-verified
2.4.4 Link PurposeSupportsHuman attestation

Each line carries how the verdict was reached. Tooling can only disprove conformance — never prove it. The claims rest on the declarant, not on Watchdog.

Trust and transparency

The honest truth most accessibility tools won't tell you.

The snake oil
  • "One script = compliant" overlay widgets — rejected by the disability community and EU regulators alike
  • An "all-green" badge from a crawler that only ever saw the markup
  • Automated checks cover roughly a third of WCAG; the rest needs human judgement
  • No tool is accepted as proof of conformance under the EAA — none
What's actually true
  • A tool can prove a failure (a missing label is a missing label) but never prove the absence of all failures
  • Conformance to EN 301 549 / WCAG 2.2 AA requires manual evaluation (WCAG-EM 1.0)
  • The EAA makes the manufacturer declare conformance — there is no notified body for web
  • So the only honest tool does the provable part and is candid about the rest
The law

What the EU Accessibility Act actually asks of you.

In force 28 June 2025, the EAA (Directive 2019/882) requires that covered digital products and services conform to accessibility requirements — 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 whose green tick discharges the obligation. That is exactly the gap Watchdog fills — honestly.

Evaluation

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

Tier A · tool-automated

The machine proves failures

Criteria with an automatable surface (alt text, labels, page language, name/role/value). A failure here is real, pre-set to Fail, and gates sign-off.

Tier B · evidence-assisted

We render, you confirm

Needs a rendered runtime + assistive tech (contrast, focus order, reflow, keyboard traps). With the framework enabled, Watchdog renders your UI in a sandboxed headless browser and runs axe-core, pre-filling these criteria with reproducible (double-render-verified) evidence — advisory, so you confirm rather than start blank. For apps that can't render statically (Blazor, server-rendered, full-stack), the Runtime Evidence module goes further: Watchdog boots your whole app from its own declared setup (docker-compose / Aspire) in an isolated sandbox and crawls the live screens — you change nothing: no CI step, no SDK, no lock-in. A runtime failure is authoritative; a runtime pass never clears a failure the static analyzer already caught. All of it is advisory evidence — it never moves your Codebase Assurance Index.

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)

Pure human attestation

Hardware, two-way voice, video, documents, software, support. Beyond Watchdog's reach; disclosed as human attestation in the artifact.

Integrity

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

The failure-gate

When static analysis catches a real failure on a criterion, the self-assessment pre-sets it to Fail and locks it. To mark it Pass anyway, you must record a written justification — reproduced, in full, in an Integrity section of the conformance artifact. A thermometer you can hide readings from is rigged; this one can't be.

Provenance on every line

Each criterion's verdict says how it was reached — tool-verified, evidence-assisted, AI-drafted-and-reviewed, or human attestation — so a buyer, an auditor, or your next supplier can see exactly which claims a machine stands behind and which a person does.

The lifecycle

The workflow.

Scan.

Watchdog's accessibility lens assesses the machine-checkable surface of WCAG 2.2 AA — and WCAG 2.1 AA, which EN 301 549 currently cites — and reports an honest coverage map that names the exact criteria it could and could not evaluate. A partial signal, since most success criteria require human judgement.

Self-assess & evidence.

A signed-in member sets the WCAG-EM scope, works through every criterion — the gate enforcing honesty — and attaches supporting documents (a manual test report, screenshots) each criterion can cite. Every upload is hashed.

Sign.

A named declarant signs. The declaration freezes into immutable, tamper-evident bytes (a SHA-256 you can re-verify); it may honestly conclude "does not fully conform" — signing attests the evaluation is complete and accurate.

Export, require & keep current.

Download the ACR/VPAT with your evidence travelling inside it; optionally bind a contract profile to require a current signed declaration; and "Extend" re-issues it for the next scan in one click (re-running the gate).

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.

Honesty guardrails

What Watchdog will never claim.

  • We do not certify accessibility and are not a notified body
  • A Watchdog score is not a conformance claim
  • "Tool clean" means no automated failure — necessary, not sufficient
  • We never auto-pass a criterion on your behalf — nothing is signed without a human
Why the candour is the product

An accessibility claim is only worth what its honesty can survive. By doing the provable part rigorously and refusing to fake the rest, Watchdog gives you a declaration that holds up to a disabled user, a regulator, and a court — not just a marketing page.