Accessibility Audit of digital content – Clearly explained, with examples

For years, accessible web content was only a business and moral responsibility. Few understood the business opportunity, and even fewer felt a moral responsibility towards discriminated users. However, after June 30, 2025, web content – mobile applications, web stores and many other interfaces/systems – must be accessible under both Hungarian and EU law.

In this article, I will write about three topics:

1. What is an accessibility audit and an accessibility plan?
2. What is its relationship with Acts LXXV of 2018 and XVII of 2022?
3. According to the World Wide Web Consortium (W3C), what competencies are required to conduct a web accessibility audit?

In 2015, for the first time in my life, I prepared an accessibility audit for the Zselici Csillagpark, with my friend János Hosszú. I put a check mark next to the WCAG 2.0 success criterion if it met, and a red x when it did not. It became clear at that time that the accessibility audit alone would not help anything. An action plan was needed, which, at my friend's suggestion, we called an accessibility plan.

Over the course of ten years, I created dozens of designs, and the product became more and more refined. Accessibility plans and accessibility audits became concepts. At first, I only wrote suggestions. Since I am a developer myself, I understood their language. Then I got to know UX/UI, so I was increasingly able to give actionable advice in this area.

In addition to developers and designers, the third area for whom accessibility audits are intended is content creators. Many people do not think that the good work of designers and developers is in vain if the user gets stuck due to the uploaded web content. One of the most common mistakes is not adding appropriate alt text to images, even though this can be done with a few steps on almost all systems.

It was an important milestone when I understood the importance of a holistic approach. Accessibility audits were always requested for WCAG AA level. However, few people know that meeting all the success criteria of the standard does not guarantee full accessibility. The standard is very general, and it takes time for new technologies and new research results to be included. The profession is always ahead of the standard.

That is why I decided to supplement the accessibility plan with recommendations that are not mandatory, but are worth implementing. That is why the “best practice” suggestions and the reference to the AAA level success criteria were included – as recommendations.

The latest innovation in the evolution of the accessibility plan – and according to customers, the most useful – is the screencast. A screencast is a screen recording that shows everything the user does. In short, it’s called live testing. We use an application that records the screen, a screen reader, and a microphone. We show you what’s happening in a short video, and we also explain what you want to do.

We also include live testing with our free quick accessibility audit. This is a table with a few accessibility requirements in the first column that you can quickly check. The second column shows whether the requirement meets the WCAG 2.2 Level AA criteria. A red “interferes” result could also mean that some users are getting stuck on the website and abandoning it.

We explain these details in live testing. We present and explain each “blocking” item. We use a screen reader and automated testing. We also explain – if it’s not clear – how it should work so that users don’t get blocked by the error.

Many people think that the WCAG accessibility audit only affects websites, but it also includes mobile applications and much more. WCAG stands for Web Content Accessibility Guidelines. Web content, as its name implies, is not only what browsers display, but also what other digital interfaces display – regardless of the platform on which it was developed.

The introduction to WCAG states: “ These guidelines address accessibility of web content on any kind of device (including desktops, laptops, kiosks, and mobile devices).”

In fact, the WCAG criteria can also be applied to PDF files, which are also used to display digital content. The European Union standard EN 301 549 and PDF/UA also set out specific requirements in this regard.

The European Union – about a quarter of a century after the United States – considered it important to make accessibility mandatory for digital content. In Hungary, this means two accessibility laws:

1. Act LXXV of 2018 on the accessibility of websites and mobile applications of public sector organizations;
2. Act XVII of 2022 on the general rules for compliance with accessibility requirements for products and services.

Both laws aim to make the digital tools we use in our daily lives accessible. Many people still think this means that the visually impaired get a version for the visually impaired, the deaf get a version for the hearing impaired, and those with ADHD get an ADHD version. If we consider not just ADHD but also the different cases of neurodivergence (ND), dozens of versions are needed.

However, the law clearly refers to accessibility according to WCAG, which means something completely different: it is more like a kind of “universal design.” Universal because everyone can use it without any kind of assistance, without a customized version: visually impaired, hearing impaired, neurodiverse.

The purpose of operating system accessibility tools is to allow everyone to set the options they need or find convenient. The accessible interface applies this setting. For example, if we set the dark theme, the website or mobile application should also display the dark theme accordingly.

Accessibility experts know how people with different disabilities deal with the challenges of the digital world. They know why they get stuck, what digital barriers are easier or harder for them to overcome. They can list at least a hundred features that make an assistive device either necessary or a great help for them.

The legislation only requires that web content, i.e. web stores, mobile applications and other interfaces, comply with WCAG. The standard is too general to provide a specific solution in a given case. This task is therefore left to the experts.

WCAG defines three different levels, denoted by one, two, or three A's: A, AA, and AAA. AA includes the thirty criteria of Level A, plus twenty more. AAA adds thirty-six more to the original fifty. WCAG also refers to these primarily as "levels."

Although it is not stated anywhere, currently the WCAG 2.2 AA level is usually specified for legal compliance. However, there is an additional, but more important, sentence in the WCAG: “Although conformance can only be measured at the specified levels, authors are encouraged to make progress on success criteria that go beyond the level of conformance achieved.”

That is why we distinguish between the recommended AAA-level success criterion and the mandatory AA-criterion in our accessibility audit. However, there is more to it than that, because in practice, sometimes the AAA-level success criterion is necessary to ensure that the user does not get stuck on the website. Therefore, we should implement what we can from the AAA level if we really want to serve our users, and we should also include those recommended by experts. These may be necessary because:

• a specific web content falls outside the scope of the standard, such as real-time communication or shocking media elements that may cause post-traumatic stress disorder (PTSD);
• a new technology not yet included in the standard, which was not yet known when the standard was created. For example, it is important that the website adapts to the user's settings. If someone turns on dark mode on their computer or turns off animations, the website should also adapt to this;
• There is more new research emerging about how people with different abilities use digital tools (SeeChart, Data Navigator, etc.). These were also not known when the standard was created.

The European digital accessibility standard, EN 301 549, only includes AA-level criteria. There are three simple and practical reasons for this:

1. There are clearly auditable success criteria at AA level. Here too, there may be personal preferences among experts, but they are minimal.
2. Compliance can be checked better automatically, although free automated software is still very rudimentary: it only detects a third of errors and makes an astonishingly high number of mistakes. However, the nature of the success criteria is much more objective and general at AA level.
3. Not all AAA criteria can be implemented on all surfaces. There are areas where it would be impossible to account for all of them. For example, a reading level that even a high school student should be able to understand all text, or a complete ban on timed content that is meaningless on tests

For consumer e-commerce applications. The relevant legislation was adopted by the European Parliament in 2019. After entering into force on June 28, 2025, all new contracts will include this requirement by default.

When a contractor is commissioned to create such an application, it must be made accessible, without any special mention, otherwise they fall into the category of defective performance under the Civil Code.

But how can the client be sure that the work created by the contractor is accessible? An accessibility audit is suitable for this. Just as a technical inspector at a construction site examines the work of professionals and corrects it if necessary, in the digital world it is the accessibility expert who performs this task.

For a long time, Hungary accepted any IT specialist's certification that the website was accessible, but due to the aforementioned legislation, more and more people are now requesting an accessibility audit to verify that the commissioned designer, developer, or content editor has actually done their job properly.

This is a legitimate demand of the client, as the users are their customers. If not everyone can use the website, it is a loss for them.

Therefore, it is a big question who will assess the accessibility of web content. One of the opinions – and one that is given with great authority – is given by the World Wide Web Organization, the W3C. In its Accessibility Audit Methodology (WCAG-EM), it specifies exactly what knowledge the auditor should have:

• Have in-depth, routine-level knowledge of WCAG and background materials.
• Have theoretical and as much practical knowledge as possible about assistive technologies.
• Know what accessible UX/UI means in detail.
• Have a thorough understanding of how people with different disabilities use the web.

However, the W3C has not yet developed a way to verify and certify expert competencies. So, anyone looking for an auditor is forced to search for the expert who best meets these expectations, based on publications and references.

What the W3C did not do, various private initiatives such as Pluralsight, Webaim, and Cursera did. The most widespread and accepted are the exams of the International Association of Accessibility Professionals (IAAP).

The syllabus for these exams is aligned with the W3C competencies. An average of 50-100 hours of preparation are required for one exam. Based on the university system, this corresponds to 2-4 semesters of subjects.

To get my CPWA certification, I had to pass three requirements:

1. the competency exam (CPACC);
2. the accessible web developer exam (WAS);
3. Five years experience.

The CPWA certification ensures that the candidate has the competencies required by the W3C for accessibility auditing. In addition, each professional has their own profile, as everyone has different strengths and weaknesses.

The audits I conduct have the following characteristics:

1. The most important is the test methodology. During more than fifty audits, I have developed the test cases based on which we get an objective picture of the state of accessibility. I have looked into each test case. I can tell you which WCAG criterion – or perhaps best practice – the given obstacle belongs to. Tests documented in an engineering manner are also suitable for junior testers to use them reliably.
2. A high level of knowledge and use of different operating systems, browsers and screen readers is required.
3. Almost exclusively manual testing. 99 percent of free tools are unsuitable for accessibility testing: they show too many incorrect results. And 50 percent of errors cannot even be detected by automatic tools. With AI, this will be possible in the future. Reliable paid tools are not designed for professionals, but rather for laypeople.

Some people think that accessibility audits are carried out by those affected, people with disabilities, so-called experts by experience. Experts by experience can be invaluable in auditing. Their feedback enriches the experts' knowledge and provides a kind of assurance that their peers, people with similar disabilities, will also be able to use the given Internet tool smoothly.

I like to observe how people struggle with web content. Whenever I can, I visit different people and ask them to let me watch them solve a problem on their digital devices. With my wife, who is visually impaired, this is a daily occurrence. But as technology advances, she also faces new challenges, so I know that if she can use a website with a screen reader, most people who use a screen reader will be able to use it too. But her disability is just one of nearly a hundred that we design for. The experts are looking for a solution that is acceptable to everyone.

For these reasons, experienced experts are not capable of objectively assessing compliance with the WCAG success criteria.

You have to know that experts by experience are also unique personalities. They have preferences, specific coping strategies, ones that no one else has. We would throw all the science into the trash if we thought that everyone who can't use their hands uses their nose to use their tablet - as I saw with a friend of mine.

In my article, I tried to provide assistance in determining when and who should conduct an accessibility audit. Precognox sets high standards in all its services – and our accessibility services are no exception.