Besides the genereal considerations i reported on #67954, from an a11y perspective I would like to see a few points to be considered:

This component is an ARIA menu. As such, I would like to see the component enforce via code, or at the very least have some linting, to only allow the children expected in an ARIA menu. See similar issue for DropdownMenu Enforce DropdownMenu to follow the ARIA menu pattern or add linting to make sure it does #67795
It should not use an ellipsis icon. This icon has inherent problems as it's little visible for low vision users. See Make the ellipsis button more visible #61909. More importantly, the concept of the ellipsis icon is 'more' but the editor is extending this icon usage to many other concepts and I'm not sure that's ideal. This component is about toggling the visibility of settings. It should be identified with an icon related to settings.
The labeling of the menuitems when the 'reset' action is available should be improved. The visible text mismatches the actual aria label, as the order of the words is different. E.g.

The strings for the speak message __( '%s reset to default' ), __( '%s hidden and reset to default' ), __( '%s is now visible' ) don't follow the WordPress best practices for l10n. In gendered languages, the name of a setting may be masculine or feminine and the adjectives like 'hidden' and 'reset' can't be translated correctly when the gender is unknown.

Screenshot of mismatching visible text and accessible name:

Audit and improve ToolsPanel's a11y #38059

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