Accessibility Regression Testing: A must-have for European Accessibility Act compliance

There’s no silver bullet for accessibility compliance. With the European Accessibility Act (EAA) coming into enforcement June 28, 2025, companies are scrambling to figure out how to address giant backlogs of accessibility violations.

If you’re a developer, it can feel overwhelming because you need to balance fixing existing issues with developing new features. It's not an option to stop and fix every accessibility violation.

What if you could continue development as normal and fix accessibility issues at your own pace? All while staying demonstrably compliant with EAA. This article breaks down how Accessibility Regression Testing helps you stop violations without stopping development.

What is Accessibility Regression Testing?

Most accessibility testing tools identify WCAG violations at a single point in time, resulting in a flood of issues with no clear path for triage.

In contrast, accessibility regression testing continuously tracks WCAG violations over time, comparing each new code push to a previously accepted baseline. This approach highlights only new or changed violations, so you’re not overwhelmed by preexisting issues when merging a pull request.

EAA compliance for developers

Under the European Accessibility Act, only new or updated features must meet the latest accessibility standards. In practice, this means that if you push new commits that alter a previously accepted baseline, that code is now “new” and must comply. Unchanged components remain legacy and are exempt until June 28, 2030.

• Minor update - If you add a contact form to the “About” page, only the form and its immediate context need to comply.
• Major update - If you redesign the “sign up” flow, the entire flow needs to comply.

Automated regression testing tracks every UI component individually, so you can pinpoint exactly what changed in your accessibility posture without manual effort.

While you’ll still have to judge for yourself if your work is “major” triggering broader accessibility review, you won’t have anxiety about small code changes unwittingly exposing your team to compliance requirements.

Want to learn about what EAA means for developers? Read our in-depth guide.

Baselines: Demonstrable compliance and workflow efficiency

For regression testing to work effectively, it must differentiate between new or modified violations and preexisting ones. This is achieved through baselines—snapshots of your UI’s WCAG compliance status at a specific commit. Baselines help you track which components haven’t changed and therefore don’t need immediate fixes for the EAA.

Put simply, if a component’s baseline was last updated before June 28, 2025, you don’t need to fix issues immediately. Whereas if the baseline was updated after, you probably do. Put together you get these benefits:

• Demonstrate compliance: Provide an audit trail that shows exactly when a component last changed. This shows your team and any external auditors what code may & may not be subject to updated standards.
• Keep the workflow humming: Avoid overwhelming CI pipelines with legacy violations by focusing alerts solely on new ones. This ensures that development continues unimpeded while you gradually address accessibility debt.

What if you update a component that’s reused across pages - are all those pages forced to comply?
Not quite. This scenario isn’t outlined in the letter of the law. But based on our interpretation, updating one component does not oblige you to make every page with that component fully EAA-compliant. You do have to ensure that the component itself meets the new standards though.

Whether every page that uses the component must comply depends on the extent of the update (minor or major) and how it changes the user flow. For example, if CheckoutPage is “significantly altered” because of an update to CreditCardForm component, you probably need to re-evaluate CheckoutPage for compliance because the form is essential to functionality.

Conclusion

Accessibility regression testing gives you the space to fix accessibility issues at your own pace while staying demonstrably compliant with the European Accessibility Act.

By leveraging baselines to clearly define which components are “new” versus unchanged legacy, you can discern which code must meet updated standards. And perhaps more pragmatically, what code can remain on your accessibility backlog.

Ready to get a head start on EAA compliance? Get a free trial of Chromatic Accessibility Regression Testing (no credit card required).