Usability Testing for Digital Accessibility – How to Prepare for the European Accessibility Act 2025
Accessibility is not a side project; it is a competitive advantage. One in four adults in the EU has a disability¹. It is not a niche target group; it is a significant proportion of the population. As the population ages and digital services become an increasingly important part of everyday life, the need for inclusive UX also increases. Companies that invest in digital accessibility today are in a stronger legal, technical and commercial position. It is not just about avoiding fines or bad PR. It is about building products that more people can use, appreciate and return to.
European Accessibility Act 2025
The European Accessibility Act 2025 (EAA) will be put into motion on 28 June 2025, it will be a legal requirement that digital services must be accessible to everyone, regardless of their functional ability. This means stricter accessibility requirements for everything from websites to apps and digital payment services. To meet these requirements, you need more than code reviews, you need a deep understanding of how users actually experience your interfaces.
This is where usability testing comes in. By using real user testing with people with different disabilities, you can identify barriers that automated tools never catch⁵. This not only creates a better UX, but it also ensures that you meet both legal requirements and the real needs of users.
Technical guidelines such as WCAG³⁻⁴ (Web Content Accessibility Guidelines) are important, but they don’t tell the whole story. A solution can be formally correct but still be practically inaccessible. It is only when you combine WCAG compliance with usability testing that you get a comprehensive picture of the accessibility of your digital product.
What is WCAG and why is it not enough?
WCAG, or Web Content Accessibility Guidelines, is the technical framework that underpins many digital accessibility laws, including the EAA³⁻⁴. In practice, it is a standard that defines how web content should be made accessible. Version 2.0 is based on four principles: content should be perceptible, manageable, understandable, and robust.
Most laws, including the EAA, require you to achieve WCAG 2.0 level AA³. That’s a reasonable level, but even if you check off every requirement, it doesn’t mean the user experience is good. A technically correct solution can still create frustration, misunderstandings, or unintended obstacles. That’s why user testing is essential⁵. User testing fills in the gaps that neither guidelines nor tools can detect.
Usability Testing: A powerful tool for accessibility
Automated testing tools have gotten better, but they are still limited. They find bugs in code, not in experiences. Usability testing reveals what users are actually struggling with. Navigation issues, lack of contrast, unclear structure. All the things that determine whether someone succeeds in completing a task or gives up.
When users with different type of disabilities such as vision impairment, motor difficulties or neurocognitive variations are involved you open up insights that are impossible to simulate technically⁵. You get to know how your solution works in everyday life, not just in theory. Especially in the run-up to the European Accessibility Act 2025, it is crucial to start early. Testing late in the process can mean expensive rework. By integrating usability testing already at the design stage, you reduce risk and increase value for both users and the business.
AI and usability testing.
At Glimma AI, we combine advanced AI with the depth of usability testing. Our platform analyzes design files, prototypes, and finished products to detect accessibility issues before they are built into the code. This allows you to act quickly without compromising quality or compliance. AI provides breadth. People provide insight. Together, they create accessibility work that is not only sustainable, but also future proof. It is a strategy for meeting accessibility requirements both today and when legislation changes in the future.
Sources Eurostat, Disability statistics – prevalence and demographic breakdowns [Online]. Available: https://ec.europa.eu/eurostat [Accessed: 25 May 2025].
European Commission, The European Accessibility Act [Online]. Available: https://ec.europa.eu/social/main.jsp?catId=1202 [Accessed: 25 May 2025].
W3C, Web Content Accessibility Guidelines (WCAG) [Online]. Available: https://www.w3.org/WAI/standards-guidelines/wcag/ [Accessed: 25 May 2025].
Continual Engine, WCAG 2.0 Compliance Explained [Online]. Available: https://www.continualengine.com/blog/wcag-2-0-compliance/ [Accessed: 25 May 2025].
W3C, Involving Users in Web Projects for Better, Easier Accessibility [Online]. Available: https://www.w3.org/WAI/test-evaluate/involving-users/ [Accessed: 25 May 2025]
