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Manual WCAG Website Testing & ADA Compliance

There are a number of reasons why manual WCAG website auditing is necessary to ensure ADA website compliance. While it would be nice to rely on automated tools for testing website accessibility, doing so is a mistake. Automated WCAG testing tools are limited and unable to detect the vast majority of WCAG violations. Therefore, manual WCAG testing is essential to ensure ADA and 508 compliance.

Why are Automated WCAG Website Testing Tools Incomplete?

The important thing to understand is that the Web Content Accessibility Guidelines is nuanced and interpretive, and software is not effective in these testing scenarios. At best, automated can only detect 30% of WCAG issues. To catch the remaining 70% of accessibility issues manual website auditing methods need to be used.

Digital Accessibility: ADA, Sect 508 and WCAG Background 

As the digital world has grown, so has the need to ensure that these website and now mobile apps meet both Title II of the American Disabilities Act and Section 508 of the Rehabilitation Act - plus a growing number of state laws (CA - Unruh Act in particular) designed to ensure that all people have universal access to “places of public accommodation” which now include websites and mobile apps. While the DOJ has dragged its feet in officially making the WCAG the official standard, Section 508 has done so explicitly. Regardless, the WCAG continues to serve the de facto standard as recognized by the courts. The WCAG was created by and is managed by the international governing body, the W3C. What’s important to recognize is that these Web Content Accessibility Guidelines… are just that: guidelines. It’s not a black and white check-list. 

Examples of WCAG Violations that Automated Testing Cannot Detect

Automated web accessibility testing tools are good at catching low-hanging fruit, and for clients with limited budgets, starting with automated website auditing is an acceptable phase-one approach. To better understand why manual accessibility testing is necessary, here are a few examples where automated-only falls short.

Alt Text Accuracy - Image alt tags describe images to screen reader users, and while automated testing can detect whether or not alt tags are present, they cannot verify the relevancy or accuracy of the descriptions. There are providers that promote their AI and claim they can interpret image subjects and automatically write alt tags, however in practice, these are often inaccurate. 

Use of Color - Did you know that one in 10 men are color blind? So it’s important to avoid using color as the only visual means of conveying information, indicating an action, prompting a response, or distinguishing a visual element. 

Label & Title Accuracy - Labels on table columns, input fields, and other page elements require accurate and useful labels to property guide a person using screen readers. Page title may exist, but do they convey the subject of the page?

Keyboard Accessibility - Users who cannot use a mouse will use various keyboard controls to navigate pages. Automated tools are not able to fully test whether focus states that show where the curser is, menu accessibility, and whether the user can navigate logically through a page and without getting stuck in traps.

Video Captions - Does video content include accurate captions that describe the visual experience?

Proper Coding - Some elements of accessibility are not evident on the consumer side. Ensuring that HTML5 and WAI-ARIA elements are properly employed for maximal accessibility will often require a manual check by someone familiar with coding best practices.


Best Practice WCAG Manual Testing Methods for 508 and ADA Compliance

To properly test for 508 and ADA web compliance, you must follow a three step process that begins with automated site-wide auditing, plus manual and assistive technology testing of unique pages/templates to ensure complete website accessibility. 


Automated Testing

There are many automated testing solutions available. Here is a list to consider. A few suggestions here would be to avoid the bolt-on variety that adds website accessibility to a typical website monitoring package. Make sure to only use tools strictly focused on web design. Also do not rely on single page testers; use an auditing tool that will index the entire website. Finally, cheaper solutions will deliver more false positives and negatives that will waste the expensive and limited time of your developers. 

Manual WCAG Website Testing

A qualified accessibility expert who also gets the code is essential (and not especially common). He or she should identify the unique pages/templates of the site and review the code line by line and identify issues that will cause screen readers and other assistive technologies to fail. A good one will then provide remediation guidance to fix each.

Assistive Technology Website Testing

Using screen readers, points, keyboard-only and many other assistive technologies, an accessibility expert should test unique pages and real world use cases that an actual person with a disability will be likely to encounter. 

Web Accessibility Audit Reporting

The key deliverable is reporting that should not only identify each WCAG 2.1 A, AA violation, but also provide remediation guidance to fix each. Be sure to ask for samples from any partner that you’re considering.


How to Choose the Right Manual WCAG Testing Provider?

Choosing a specialist at the level needed to really ensure your website will be properly audited isn’t like choosing a plumber. It’s especially difficult if the person charged with this selection is not a developer. So be sure to pull in a dev during this process because in addition to experience and knowledge of the ADA, WCAG and digital accessibility, it’s essential that you choose a WCAG tester that knows code and speaks geek to effectively guide your developers through remediation. Here is a criteria list to consider when choosing a website accessibility auditing company or contractor:

  • Number of years in digital accessibility
  • Knowledge of the letter and intent of the WCAG
  • Empathy for real-world user scenarios and challenges that people with disabilities face
  • Assistive technology knowledge and experience 
  • Website (and/or mobile) coding experience
  • Knowledge of the legal landscape and what issues trigger lawsuits

Who Should Provide WCAG Website Remediation?

Once you have had a qualified vendor deliver your website accessibility audit, the question is who should perform the remediation. If you have an in-house team or a stable partner who originally built the website and who also has the bandwidth for this project, then that is who should perform the remediation. If the reporting is good and includes solid remediation guidance, then its best to have the original builders do the remediation. This way, they will learn from the process and avoid future issues. 

If your existing website team is no longer a partner or can’t otherwise execute the work, then you can look search for “website accessibility remediation expert” plus the platform you’re on. Or look no further and give us a call.

What to Look Out For

Naturally, there is great demand for a quick and inexpensive solution. And even if one doesn't exist, that won't stop some from claiming such. Avoid what are known as "overlay solutions". These sites have injected code that adds a little blue disabilty icon in the corner that triggers a toolbar with accessibility adjustment options. These claim to make your website 100% ADA compliant overnight using artifical intelligence and javascript to inject corrective code over the existing code. Yet such websites are still getting sued because overlays cannot correct the underlying code, which is left exposed by default to any trolling lawyer. AI or not, automated tools cannot even detect 70% of WCAG issues, so these fail the sniff test right off the bat. The even claim to provide guarantees - however they will not indemnify. Beware.

Also avoid alternate "accessible" or "assistive" websites.  These are seperate websites that are not tied in with the core websites content management system and tend to provide different content and reduced functionality. The ADA states that people with disabilties are entitled to "full and equal enjoyment of the goods, services, facilities, privileges, advantages, or accommodations" that a publich accommodation (website) provides to its customers. This path risks crossing the line of discrimination and should be avoided.


Good luck and please let us know if we can help. Initial assessment and call - no charge.