Soundcheck Accessibility Statement

The European Accessibility Act asks services to publish an accessibility statement: how accessible the site is, what isn't yet, how it was assessed and how people report problems. Every --eaa run drafts one from what its tests found. It also keeps an evidence pack of the files behind it that anyone can verify. This page covers the statement command, its statement: config block, what the draft says, the EARL export for the W3C WCAG-EM Report Tool, the JSON and the evidence pack with evidence verify, sign and keygen.

rhythm soundcheck statement -o accessibility-statement.md   # also .html, .json and .jsonld (EARL)
rhythm soundcheck evidence verify                           # the files and the chain behind it are unchanged

Important

The draft is a draft. Soundcheck never chooses the status ("fully", "partially" or "not compliant"): that [TO DO] is always yours, after your own review. Of the 50 WCAG 2.1 A and AA criteria, 23 can only be judged by a person; the draft says so for each of them. Evidence, not a compliance guarantee.

The statement command

rhythm soundcheck statement [run folder|snapshot] [flags]

It drafts from the newest --eaa run or snapshot, or from the run folder or snapshot you name. Every --eaa run already writes eaa/statement-draft.md into its folder; that file is written again on every run, so edits belong in a copy made with -o.

Flag	Default	Description
--md	on a terminal and for .md	Markdown.
--html		Standalone HTML, printable, with no scripts and a strict Content Security Policy.
--json		JSON, schema rhythm-soundcheck/statement/v1.
--earl		EARL JSON-LD for the W3C WCAG-EM Report Tool (.jsonld).
-o, --output <file>	stdout	Write to a file, format from the extension (.md, .html, .json, .jsonld); repeatable. -o - is stdout.
--layout <name>	model	model: the EU model statement (Implementing Decision (EU) 2018/1523). service: EAA Annex V service information (BFSG Anlage 3 in Germany).
--wcag <version>	the run's	2.1 or 2.2. A 2.2 run can be drawn as 2.1, not the other way round.
--config <file>	.soundcheck/config.yaml	Read statement: from this file.
--lang <code>	en	Only en in 1.3.
--force	off	Replace a draft file you have edited.

rhythm soundcheck statement -o accessibility-statement.md

Statement draft written to accessibility-statement.md
10 [TO DO] markers left

Several formats at once:

rhythm soundcheck statement -o statement.jsonld -o statement.json -o statement.html

Statement draft written to statement.jsonld
Statement draft written to statement.json
Statement draft written to statement.html
10 [TO DO] markers left

Files are written readable by you only (0600) and their SHA-256 is recorded in the run's eaa/written.json. A file you have edited since is never replaced by accident:

rhythm soundcheck: accessibility-statement.md was edited since Soundcheck wrote it; write to another file with -o, or add --force to replace your edits

Exit codes and errors

Code	Meaning
0	Written.
2	Usage error: a bad flag, a missing or wrong statement: block, an edited file without --force.
3	No --eaa data, an interrupted run, or a file couldn't be read or written.

rhythm soundcheck: no --eaa results in .soundcheck yet; run rhythm soundcheck snapshot <url> --eaa first
rhythm soundcheck: the run used the WCAG 2.1 rules; --wcag 2.2 needs a run made with --wcag 2.2
rhythm soundcheck: --layout: "services" isn't one of model, service (did you mean "service"?)

Without the three required keys: statement needs statement.owner, statement.website and statement.contact.email in .soundcheck/config.yaml (rhythm soundcheck init --eaa writes them); a statement without a way to report problems isn't one (exit 2). An interrupted run is refused (<run> was interrupted after 17 of 42 pages; a statement from part of the site would leave problems out. Run it again, exit 3). A symbolic link at an -o path is refused, even with --force.

The statement: block

Your own text lives in .soundcheck/config.yaml, not in the draft, so writing the draft again never loses it. rhythm soundcheck init --eaa writes the block commented out; fill it in:

statement:
  owner: "Ledger Coffee GmbH"
  website: "https://ledger.example"
  contact:
    email: "accessibility@ledger.example"
  response_days: 10
  country: "DE"

Key	Required	What it holds
owner	yes	Who runs the website.
website	yes	The public address. The address the run checked (a staging host, 127.0.0.1 and its port) never appears in the draft.
contact.email	yes	Where people report problems. Use a role address such as accessibility@, not a person's own.
contact.phone, contact.address	no	Other ways to reach you.
response_days	no	Days to reply, 1 to 365.
country	no	ISO 3166 alpha-2 code, such as DE; the enforcement [TO DO] names it.
enforcement	no	The authority that enforces accessibility law and how to reach it.
scope	no	Page globs the statement covers, such as [/, /shop/*, /checkout/*]. Without it the draft covers the pages checked and asks you to confirm them.
service	no	A general description of the service, for --layout service.
known_issues	no	Problems you know about: criterion, text and an optional until date.
manual	no	What a person checked: criterion, result (failures found, no failures found or not checked), by and date, all required. A manual result always wins over the tests for its criterion; the draft records who checked and when and keeps the tests' result next to it.
list_private_paths	no	true lists the paths of a logged-in run; by default only their number.

Everything in the block is published in the statement. Unknown keys and bad values stop the command with exit 2 and name the file and line, such as unknown setting "statement.ownr" (did you mean "statement.owner"?) or statement.country: "de" isn't an ISO 3166 country code such as DE, FR or IE (did you mean "DE"?).

  known_issues:
    - criterion: 1.2.2
      text: "Product videos have no captions yet."
      until: 2027-03-31
  manual:
    - criterion: 1.4.11
      result: no failures found
      by: Jane Doe
      date: 2026-10-20

What the draft says

Every format starts with the same banner:

> **Draft for you to review. Not ready to publish.**
>
> Rhythm Soundcheck 1.3.0 wrote this on 2026-10-29 from a check of 21 pages of https\://ledger.example.
>
> Automated and keyboard tests find some accessibility problems, not all. This is evidence for your own review, not a statement that the site meets WCAG, EN 301 549 or the European Accessibility Act.
>
> Fill in every \[TO DO\], test the criteria marked "needs a person", then delete this box.

The default layout follows the EU model accessibility statement. From the walk-through's comparison, with a keyboard trap and a control that ignores Enter and Space:

# Accessibility statement for Ledger Coffee GmbH

Ledger Coffee GmbH wants https\://ledger.example to be usable by as many people as possible.

This statement covers the 21 pages Soundcheck checked, listed under "Pages checked". [TO DO: set statement.scope to the pages this statement covers, or check that these are all of them.]

## How accessible this website is

[TO DO: choose one after your review: "fully compliant", "partially compliant" or "not compliant" with WCAG 2.1 level AA / EN 301 549 V3.2.1. Soundcheck does not choose this for you. Its tests found failures of 2 of 50 criteria and could not test 23 of them.]

## What isn't accessible yet

### Problems found

Found by Soundcheck's tests on 2026-10-29, or by your own review:

- **2.1.1 Keyboard** (EN 301 549 9.2.1.1): 1 element on 1 page: /a11y/wishlist.php.
- **2.1.2 No Keyboard Trap** (EN 301 549 9.2.1.2): 1 element on 1 page: /a11y/consent.php.

[TO DO: for each problem, say in plain words what doesn't work, for whom and what you offer instead.]

### Disproportionate burden

[TO DO: say if fixing any of this would be a disproportionate burden and why, or delete this section.]

### Content outside the scope of the law

[TO DO: list content the law doesn't cover, such as third-party content you don't control, or delete this section.]

## How this statement was prepared

This statement was prepared on [TO DO: date] by [TO DO: who].

Rhythm Soundcheck 1.3.0 checked 21 pages of https\://ledger.example on 2026-10-29 with automated tests (axe-core 4.14.0 with 65 rules plus 2 Soundcheck checks for WCAG 2.1 A and AA) and a keyboard walkthrough of 21 pages (1 widget tested, 1 key flow run).

It was also checked by [TO DO: your manual review, such as a screen reader test of checkout].

It was last reviewed on [TO DO: date].
...
## Feedback and contact

If something on this website doesn't work for you, tell us: email accessibility\@ledger.example.

We reply within 10 days.

## Enforcement

[TO DO: name the authority that enforces accessibility law in DE and how to reach it; or set statement.enforcement.]

It goes on with the nine limits sentences under What these tests can and can't tell (the same as Honest limits), then three more sections:

• Appendix: every WCAG 2.1 A and AA criterion, a table with the EN 301 549 clause, how Soundcheck tests it and the result:

  | Criterion | Level | EN 301 549 | How Soundcheck tests it | Result |
  |---|---|---|---|---|
  | 1.1.1 Non-text Content | A | 9.1.1.1 | partly: axe aria-meter-name, aria-progressbar-name, image-alt, input-image-alt, object-alt, role-img-alt, svg-img-alt | no failures found by these tests |
  | 1.2.3 Audio Description or Media Alternative (Prerecorded) | A | 9.1.2.3 | not tested: needs a person | not tested: needs a person |
  ...
  | 2.1.1 Keyboard | A | 9.2.1.1 | partly: axe frame-focusable-content, scrollable-region-focusable, server-side-image-map; keyboard/not-reachable, keyboard/not-operable, keyboard/menu, keyboard/flow | failures found (1 element, 1 page) |
  | 2.1.2 No Keyboard Trap | A | 9.2.1.2 | partly: keyboard/trap | failures found (1 element, 1 page) |
  ...
  | 4.1.1 Parsing | A | 9.4.1.1 | not tested: W3C now treats it as always met for HTML; the owner decides how to state it | not tested: W3C now treats it as always met for HTML; the owner decides how to state it |

• Not tested: pages whose audits didn't finish, frames from other sites, key flows that didn't run, 23 criteria need a person: 1.2.3, 1.2.4, ..., Only Chrome was used. The keyboard walk ran at desktop width., No screen reader, voice control or test with disabled users. and the EN 301 549 clauses outside a website check (5, 6, 7, 10, 11 and 12).

• Pages checked: the paths, or for a logged-in run only their number unless list_private_paths: true.

Problems your ignore rules or accepts left out of Soundcheck's results are listed under Accepted or ignored in Soundcheck with their reason. They still count against their criteria: ignoring a problem doesn't fix it. From --layout service, after the wishlist control was ignored:

### Accepted or ignored in Soundcheck

These problems were found and left out of Soundcheck's results by your ignore rules or accepts. They still count against their criteria above.

- **2.1.1** (keyboard/not-operable) on /a11y/wishlist.php: wishlist button is rebuilt in the next sprint

Results in the criteria table

Result	When
failures found (<n> elements, <m> pages)	A test found a failure.
no failures found by these tests	The tests ran and found none. Never "passed".
not tested: needs a person	No test covers the criterion.
not tested: its tests didn't run	The module that tests it didn't run, or no page's audit finished.
not tested: W3C now treats it as always met for HTML; the owner decides how to state it	4.1.1 Parsing (WCAG 2.1 only).
manual: <result> (<by>, <date>); the tests: <tests' result>	You recorded a manual result.

One problem counts once: a missing label reported by a11y/label, a11y/placeholder-label and interact/unlabeled on the same element is one finding. A finding on 214 pages is 1 element on 214 pages.

The service layout

--layout service drafts the service information of EAA Annex V: # Accessibility information for <owner>, ## About the service (from statement.service, else a [TO DO]), ## How the service meets the accessibility requirements with the status [TO DO] and the problems, ## Accessibility features as a [TO DO], then how it was prepared, contact, enforcement, the appendix, not tested and pages checked as in the model layout.

rhythm soundcheck statement --layout service -o accessibility-information.md

Statement draft written to accessibility-information.md
11 [TO DO] markers left

Privacy in the draft

• The address the run checked and the test account's user name never appear; the draft uses statement.website.
• Paths lose their query string and fragment. Tokens after reset, verify, confirm, magic, login and activate are masked (/reset/•••••/), as are secrets.
• A logged-in run lists no paths unless list_private_paths: true.
• Control and bidi characters are removed from every format; Markdown special characters in your text are escaped (hence https\://).

EARL for WCAG-EM

--earl, or -o <file>.jsonld, writes the JSON-LD evaluation that the W3C WCAG-EM Report Tool saves and opens. An evaluator imports it and carries on by hand with the criteria that need a person.

• Scope: the website from statement.website, the owner as title, conformance target AA, the run's WCAG version.
• Sample: every checked page (none for a logged-in run).
• One assertion per criterion: earl:failed for failures found, earl:cantTell for no failures found by these tests (Soundcheck never writes earl:passed) and earl:untested for the rest. A manual entry maps the same way.
• Test mode: earl:semiAuto when a keyboard check tests the criterion, earl:automatic otherwise, earl:manual for your manual entries. Asserted by Rhythm Soundcheck <version>.

JSON

statement --json (schema rhythm-soundcheck/statement/v1) has the top-level keys schema, tool, version, date, layout, wcag, en301549, standard, status (always null), evidence_note, todo, website, owner, pages, private_pages, checked, axe, axe_rules, own_checks, totals, criteria, known_issues, ignored, not_audited, frames, keyboard, notes and limits. From the walk-through, after the trap was fixed:

"totals": {"criteria": 50, "failed": 1, "not_tested": 23}

{
 "id": "2.1.2",
 "title": "No Keyboard Trap",
 "level": "A",
 "principle": "Operable",
 "en301549": "9.2.1.2",
 "coverage": "partly",
 "tested_by": [
  "keyboard/trap"
 ],
 "how_tested": "partly: keyboard/trap",
 "result": "no_failures_found",
 "tests": "no_failures_found",
 "text": "no failures found by these tests",
 "issues": 0,
 "pages": 0,
 "paths": [],
 "manual": null
}

result is failures_found, no_failures_found, not_tested or manual. Lists are [], never null.

The evidence pack

Every --eaa run and snapshot writes eaa/evidence.json (schema rhythm-soundcheck/evidence/v1) in its folder:

.soundcheck/runs/2026-10-28T19-28-47.087Z/
  run.json  pages.jsonl  comparison.json  report.html
  keyboard/<page id>.json              the keyboard traces
  keyflows/<flow>.txt                  the key flows' key presses
  eaa/
    evidence.json                      the pack
    evidence.sig  evidence.pub         after evidence sign
    statement-draft.md                 written again on every --eaa run
    written.json                       SHA-256 of drafts written with -o
    focus/<page id>-<n>.png            focus ring crops

The pack records the Soundcheck, Chrome and axe-core versions (with axe's SHA-256), the run's options, start and end, whether it was interrupted or made with -k, each page's audit status per module (paths masked as in the draft), the eaa summary and the SHA-256 of run.json, the pages file, every keyboard trace and every crop. Each pack names the previous --eaa run or snapshot of the same site and its pack's SHA-256, so the packs form a chain. Runs with a pack are never pruned with the old runs, since that would break the chain.

evidence verify

rhythm soundcheck evidence verify [run folder|snapshot] [--pub <key>]
rhythm soundcheck evidence sign [run folder|snapshot] --key <file>
rhythm soundcheck evidence keygen -o <file>

verify checks every file of the run and every earlier pack in the chain. Without an argument it checks the pack that records the latest start:

$ rhythm soundcheck evidence verify
Verified .soundcheck/runs/2026-10-28T19-28-47.087Z/eaa/evidence.json: every file matches and the chain is whole
not signed

A keyboard trace changed after the run, by one space added at its end:

$ rhythm soundcheck evidence verify
rhythm soundcheck: evidence: keyboard/01cd74fa62.json changed after it was recorded (sha256 differs)

Other failures name the file or the gap: evidence: <file> was deleted after it was recorded, evidence: <file> was added after the pack was recorded, evidence: the run before <id> is missing from the chain (a run folder deleted by hand), evidence: eaa/evidence.sig doesn't match eaa/evidence.json (signature invalid).

Code	Meaning
0	Verified or signed.
1	Verification failed; the message names the file or the gap.
2	Usage error.
3	Can't read: no --eaa results, no pack, or a recorded file that can't be read.

Signing

Make a key once. The private key is written readable by you only and never replaces an existing file:

$ rhythm soundcheck evidence keygen -o soundcheck.key
public key: 3NzvAzkbmfHGS8qUv2ibF9YIvW2vBiHJC7UZ+tcLeWE=
Private key written to soundcheck.key; keep it out of git

Sign a run's pack with it. sign writes eaa/evidence.sig (an Ed25519 signature of evidence.json) and eaa/evidence.pub:

$ rhythm soundcheck evidence sign --key soundcheck.key
Signed .soundcheck/runs/2026-10-28T19-28-47.087Z/eaa/evidence.json

verify then prints the key the pack was signed with:

$ rhythm soundcheck evidence verify
Verified .soundcheck/runs/2026-10-28T19-28-47.087Z/eaa/evidence.json: every file matches and the chain is whole
signed with key 3NzvAzkbmfHGS8qUv2ibF9YIvW2vBiHJC7UZ+tcLeWE=; check it against the key the owner published

Anyone who changes a pack can sign it again with their own key. So publish your public key. Whoever checks a pack compares the key verify prints with it, or passes it with --pub:

$ rhythm soundcheck evidence verify --pub 3NzvAzkbmfHGS8qUv2ibF9YIvW2vBiHJC7UZ+tcLeWE=
Verified .soundcheck/runs/2026-10-28T19-28-47.087Z/eaa/evidence.json: every file matches and the chain is whole
signed with key 3NzvAzkbmfHGS8qUv2ibF9YIvW2vBiHJC7UZ+tcLeWE=, the --pub key

$ rhythm soundcheck evidence verify --pub 8m9Gqva2DKXcrW/7XlBKBaHiNVKQo90VT7KBwfyasm4=
rhythm soundcheck: .soundcheck/runs/2026-10-28T19-28-47.087Z/eaa/evidence.json was signed with key 3NzvAzkbmfHGS8qUv2ibF9YIvW2vBiHJC7UZ+tcLeWE=, not the --pub key

The second exits 1, as does an unsigned pack with --pub (... isn't signed, so it can't match --pub). Other refusals:

rhythm soundcheck: evidence sign needs --key <file>; make one with rhythm soundcheck evidence keygen -o <file>
rhythm soundcheck: can't sign a run made with -k: TLS wasn't verified
rhythm soundcheck: soundcheck.key already exists; keygen never replaces a key, so name a new file
rhythm soundcheck: --pub wants the base64 public key evidence keygen printed

To sign with your identity through Sigstore instead of a key file, run cosign sign-blob eaa/evidence.json in the run folder.

A signed evidence pack proves who produced it and that it wasn't changed afterwards. It doesn't prove the site was in that state for every visitor.

Kept packs

Later runs are chained to a snapshot's pack as it was, so a snapshot's pack is kept before anything changes it. accept into an --eaa snapshot copies the pack, its signature and every file it lists to .soundcheck/evidence/<sha256>/, then records the pack again for the accepted state and drops the old signature (sign again):

$ rhythm soundcheck accept da3cdeac
Accepted da3cdeac Keyboard focus is trapped (/a11y/consent.php)
Snapshot "before" now holds 1 accepted change. Run rhythm soundcheck compare to check again.
note: accept changed run.json, the pages file and snapshot.json of snapshot "before", so its evidence pack was recorded again. The pack from before is kept in .soundcheck/evidence/3579a49bdaf3b118bb9af32aa90182e12a094f50ec490c1416b352d39bc7c478 with its files: evidence verify of later --eaa runs, which are chained to it, checks that copy and notes it

verify checks the kept copy and says so:

$ rhythm soundcheck evidence verify
note: snapshots/before changed by accept after runs/2026-10-28T19-28-47.087Z was chained to it; checked the copy kept in evidence/3579a49bdaf3b118bb9af32aa90182e12a094f50ec490c1416b352d39bc7c478
Verified .soundcheck/runs/2026-10-28T19-29-55.841Z/eaa/evidence.json: every file matches and the chain is whole
not signed

$ rhythm soundcheck evidence verify before
note: snapshots/before was recorded again after accept on 2026-10-28; the pack it replaced is kept in evidence/3579a49bdaf3b118bb9af32aa90182e12a094f50ec490c1416b352d39bc7c478
Verified .soundcheck/snapshots/before/eaa/evidence.json: every file matches and the chain is whole
not signed

Taking a snapshot again under the same name, or deleting it, keeps its pack the same way:

$ rhythm soundcheck snapshots delete before
Deleted snapshot before
note: snapshot "before" had an evidence pack; it is kept in .soundcheck/evidence/3579a49bdaf3b118bb9af32aa90182e12a094f50ec490c1416b352d39bc7c478, so evidence verify of later --eaa runs still checks their chain

Keep .soundcheck/evidence/ with the runs you hand over. A run folder deleted by hand still leaves a gap in the chain.

---

_{← Keyboard walkthrough · Home · CI →}