An in vitro model simulating enzymatic activity in the gastrointestinal tract was developed for the assessment of the potential bioaccessibility of Cd and Pb in cocoa powder and liquor. The model was based on the sequential extraction with simulated gastric and intestinal juices; the residue after the latter extraction was further investigated by using, in parallel, solutions of phytase and cellulase. The solubility of Cd and Pb in the corresponding enzymatic extracts was measured by ICP MS. The bioaccessibility of Cd in cocoa varied from 10 to 50% in gastrointestinal conditions. An additional 20 or 30% of Cd could be recovered by phytase and cellulase, respectively. The bioaccessibility of Pb in gastrointestinal conditions did not exceed 5-10%. Only a few percent more of this metal could be recovered by extraction with phytase and cellulase.