WCAG-EM 2.0: what the updated evaluation methodology means for EAA compliance

On 23 July 2026, the W3C's Accessibility Guidelines Working Group published WCAG-EM 2.0, the WCAG Evaluation Methodology. It replaces the 1.0 version that had stood since 2014 and that most accessibility guidance still quotes. For anyone commissioning or relying on an accessibility audit, the update is worth understanding, because it defines what a credible evaluation actually looks like.

WCAG-EM is not a new rule. It does not add to or change a single requirement in WCAG 2.2, and it is published as a W3C Group Note rather than a standard. What it provides is the agreed process for evaluating how well a digital product meets WCAG, so that different evaluators reach comparable, defensible results. It is the roadmap underneath a serious audit.

The shift that matters: from "website" to "digital product"

The clearest change is in scope. Version 1.0 evaluated websites. Version 2.0 evaluates digital products: websites, web applications, mobile apps, kiosks and self-service terminals, and documents such as PDF and EPUB. That mirrors how the European Accessibility Act already defines its scope, around the product or service a consumer uses, not the technology it is built in. A booking flow, an account area, a mobile app and a PDF statement can all be in scope under the EAA, and the evaluation methodology now reflects that directly.

The five steps of a credible evaluation

The methodology sets out a five-step process. Understanding it is the quickest way to tell a real evaluation from a superficial one.

1. Define the scope. State unambiguously what is being evaluated, the target conformance level (WCAG 2.2 Level AA is the accepted standard), and the browsers and assistive technologies the product is expected to support.
2. Explore the product. Identify common views, essential functionality, the variety of page types, and the technologies relied upon.
3. Select a representative sample. A structured sample covering the range of the product, plus a random sample equal to roughly 10% of it as a check, plus every page in any complete process.
4. Evaluate the sample against the five WCAG 2.2 conformance requirements, including full interaction with forms, errors and confirmations along each journey.
5. Report the findings, documenting scope, sample, technologies and outcomes so the result is transparent and repeatable.

Why journeys, not pages

The methodology is specific about processes. If an evaluation touches any part of a journey, it must include every page in that journey, the default path and the branches a real customer commonly takes. That is a deliberate contrast with page-level scanning, and it is exactly where account creation, checkout and booking flows tend to break. It is also why we scope our own work by journey rather than by page.

The line worth reading twice: a sample is not a conformance claim

The most important point in the document is one that a good deal of compliance marketing skips. Evaluating a representative sample of a product does not permit a WCAG conformance claim for the whole product. The methodology states this plainly, more than once, because unfound errors always remain possible on the pages that were not evaluated.

The practical consequence: a tool or vendor promising "full compliance" from a quick automated pass is not describing something the methodology supports. What a preliminary evaluation is genuinely good for, in the methodology's own words, is identifying obvious barriers and developing an understanding of where a product stands before a full evaluation. That is an honest and useful place to begin, and it is precisely what our Rapid Exposure Check is: a preliminary read of one journey, not a full audit, and never a compliance certificate.

What it means for an accessibility statement

WCAG-EM 2.0 also sets out what a credible evaluation statement contains: the date, the WCAG version and conformance level, a clear definition of the product, the technologies relied upon, the accessibility-support baseline, and, where conformance is only partial, which areas do not conform and why. That is a useful checklist against which to judge any accessibility statement, including your own. The EAA requires a statement; this is the shape of one that would withstand scrutiny.