We Consider Ourselves Low Risk
A major global SaaS platform recently made the decision to reject a full accessibility audit. Their internal digital team had raised serious concerns about their platform. The product is used by thousands of customers across multiple countries, including Europe. It failed basic screen reader checks. It lacked an accessibility statement. It had no testing history with disabled users. They knew they had a problem. I was invited to submit a proposal and became the recommended supplier. Two months later, I received a single-line response from their legal team. They considered themselves to be low risk, and therefore would not approve the audit. The digital team were instructed to rely on web accessibility testing tools and make whatever improvements they could. No roadmap. No statement. No guarantee of compliance. This is exactly what we are up against. This is the culture that needs to change.
The Limits Of Web Accessibility Testing
Web accessibility testing tools can play a helpful role, but they are not a solution in themselves. These tools operate by scanning code against a limited subset of the Web Content Accessibility Guidelines (WCAG). They identify missing attributes, contrast issues, or unlabeled elements. What they cannot do is simulate the experience of a real disabled user. They do not tell you if your navigation works using a keyboard. They do not tell you if your content is logical, if your page order is correct, or if someone using a screen reader can complete a form. They do not measure cognitive load, clarity of structure, or consistency across views. Most significantly, they do not confirm whether you meet the expectations of aa web accessibility.
For organisations that are serious about inclusion, these tools should be viewed as an initial scan — not a final assessment. They provide a starting point for conversation, not a compliance certificate. Using only web accessibility testing is like checking a bridge with binoculars and assuming it is safe to cross. There may be visible issues you can address. There will also be structural ones that are invisible unless you step inside. That is what real testing is for.
We Were The Recommended Supplier
In this particular case, the digital team had done their due diligence. They knew what was missing. They recognised the gaps between internal knowledge and actual compliance. They approached us after reviewing our process: real-user testing, full WCAG analysis, video documentation, written reports, and a compliant accessibility statement. We were the preferred partner. They wanted to move forward. For two months, they were held in limbo while the proposal sat in legal. No questions were asked. No clarifications were requested. Just silence. Then a decision was handed down without dialogue. They were considered low risk. That phrase shut the door.
In practice, that meant they would not allocate budget to a manual audit. They would not authorise user testing. The legal team made a business decision that saving money today was worth the risk of a breach tomorrow. The digital team were told to make do. That included running basic web accessibility testing scans, documenting the results, and attempting internal fixes. It was a cost-cutting choice that left the platform — and its users — exposed.
What Does Low Risk Actually Mean?
Low risk is a phrase we hear more and more in boardrooms and legal departments. It rarely comes from developers or designers. It almost never comes from disabled users. It is a legal risk assessment, not a technical or ethical one. It means no lawsuits have been filed yet. It means no major clients have complained. It means the product still sells. It does not mean the platform is accessible. It certainly does not mean the company is protected. It simply means they think they can afford to wait.
For businesses operating internationally, particularly those with clients or users in the EU, this logic is deeply flawed. The European Accessibility Act is now enforceable. Countries are starting to act. Procurement processes are being updated. If a product fails to meet aa web accessibility standards, and that failure leads to exclusion or discrimination, the consequences will come. They may arrive slowly, but they will arrive. Low risk today becomes high cost tomorrow.
Web Accessibility Testing Is Not Enough
At Access by Design, we use a layered approach to accessibility. Web accessibility testing is included — but only as one part. Our audits begin with automated scans to identify basic issues. We then conduct manual testing using a range of assistive technologies. This includes screen readers, voice input software, switch devices, magnifiers, and colour filters. Every test is performed by a disabled user, recorded, and annotated. Our reports combine these findings with WCAG 2.2 compliance checks and usability assessments. The final result is a detailed overview of where your site stands, what needs to change, and how to get there.
Web accessibility testing alone cannot do any of this. It does not test interaction, only code. It does not account for layout changes under zoom. It does not detect confusing language or unclear labelling. It cannot advise on whether your accessibility statement meets legal standards. And it cannot replace the human insight that comes from someone trying to use your site in real time.
Internal Pressure, External Risk
One of the hardest parts of this work is watching good people get blocked by internal politics. Digital teams come to us with urgency and clarity. They have done their research. They are ready to act. Then legal steps in and stalls progress. Or budget holders decide that this year is not the right time. Meanwhile, products are launched that lock out disabled users. Accessibility is framed as a cost centre, not a compliance obligation. The pressure falls on those with the least power to fix the problem. And when external risk becomes reality — when a user complains or a contract is lost — they are the ones who take the blame.
We need a culture shift. One that recognises aa web accessibility as a core responsibility, not a legal escape clause. One that values disabled users as customers, not liabilities. One that understands web accessibility testing is not a shield — it is a mirror. It shows you some of what is broken. It does not show you how people feel when using your site. Only real testing can do that.
Web Accessibility Testing And Legal Exposure
Let us be very clear. If your product is available in the EU, and it fails to meet minimum compliance standards, you are at risk. It does not matter where your business is based. If a user in France, Germany, Spain, or any other member state tries to use your platform and cannot complete their task because of accessibility barriers, that is enough. The requirement is not perfection. It is progress, transparency, and evidence. You must be able to demonstrate that you are aware of the issues, have tested with real users, and have created a plan. That is the value of a proper audit.
The European Accessibility Act is not a distant regulation. It is active. It is specific. It applies to services like banking, ticketing, e-commerce, transport, and online support. It covers both websites and mobile apps. And it aligns directly with aa web accessibility standards. Companies that continue to rely on automated web accessibility testing without further action are not just non-compliant — they are unprepared.
What Proper Testing Reveals
We recently audited a university website that had passed its internal accessibility checks. Their automated scans showed no major errors. Their internal checklist was complete. Yet during testing, our team discovered 14 barriers on the homepage alone. One tester could not access the main menu using their keyboard. Another was unable to submit an application form due to a hidden focus trap. A third found the video captions were auto-generated and incorrect. None of these were flagged by automated tools. All of them would have caused real harm to real users.
This is why real testing matters. This is why web accessibility testing is not enough. The experience of a disabled user is not theoretical. It is lived. It is emotional. It is practical. If your platform causes frustration, confusion, or failure, it does not matter how many green ticks your tool gives you. Your users will know. And they will leave.
Shifting The Corporate Culture
The problem is not that legal teams want to reduce risk. That is their job. The problem is the definition of risk itself. When companies believe risk is limited to lawsuits, they miss the bigger picture. Risk includes lost sales, damaged reputation, negative press, internal demotivation, and failure to serve your full audience. Accessibility is a matter of dignity and reach. It is about making sure everyone can participate. Framing it as a checkbox or a liability reduces it to a tick box. That serves no one.
The good news is that change is possible. We have worked with organisations who began their journey reluctantly and now lead the way. We have seen CEOs become accessibility champions after watching our testing videos. We have helped brands recover from public complaints by publishing a transparent, living accessibility statement. None of this is about perfection. It is about commitment, courage, and care.
Act Before You Are Forced
You do not need to wait for a complaint. You do not need to wait for legislation to catch up. You can book a proper audit today and know where you stand. We will test with real users, provide you with a clear accessibility statement, and support you through every step of your compliance journey. Web accessibility testing has a place in that journey — but only as a starting point.
If you are ready to take action, you can book a free consultation today. We will listen. We will be honest. We will give you a roadmap. Let us help you shift from low risk to long-term leadership.
We Are Not Going Quietly
This blog is not an isolated case. It is one of many. The language may change, but the decision is always the same: delay, deflect, minimise. We are here to say that this cannot continue. We will keep speaking out. We will keep publishing what we see. We will keep supporting those who want to lead. If your organisation is ready to take accessibility seriously, we are ready to walk with you.
