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Accessibility Testing7 min read

WCAG Compliance Audit in 2027: How to Scope, Buy and Judge One

A WCAG audit is only as good as what it samples and how it tests. This guide covers the 55 WCAG 2.2 AA criteria, which laws apply to you, the W3C's WCAG-EM method, a worked scoping example and what a usable finding looks like.

Published October 26, 2026Last updated October 26, 2026
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Most WCAG compliance audits are bought on price and judged on a score. Both are the wrong measures. The price depends on what was sampled, which most quotes never state. The score depends on what was tested, and a large part of WCAG cannot be tested by a machine at all.

That last point is measurable. The UK Government Digital Service built a single web page containing 143 deliberate accessibility barriers, then ran ten automated tools over it.

Figure 1 · What automated tools catch
Even ten tools together miss three barriers in ten
GOV.UK built a page with 143 deliberate accessibility barriers and ran ten automated tools over it.
Best single tool, errors and warnings only (Tenon)
37%
Best single tool, including manual-check prompts (Asqatasun)
41%
Google Developer Tools
17%
All ten tools combined
71%
42 of 143
barriers missed by every one of the ten tools
29%
of the barriers only a person would have found
Source: GOV.UK Government Digital Service accessibility blog, 24 February 2017. Missed barriers included links identified by colour alone and tables with empty cells. Tools have improved since; the gap they cannot close is judgement.

So an audit that is mostly a scan will miss problems a disabled user meets on day one. This guide covers what a real audit tests, which rules apply to you, the method to insist on, how scoping drives cost, what a usable report looks like, and what to do after it.

What a WCAG audit has to cover in 2027

The current standard is WCAG 2.2, first published as a W3C Recommendation on 5 October 2023 and last updated in December

  1. Most laws and contracts ask for Level AA, so that is the scope to buy.
Figure 2 · What Level AA actually covers
WCAG 2.2 AA is 55 success criteria
The 86 active criteria in WCAG 2.2, by level, counted from the specification.
31 A
24 AA
31 AAA
55 criteria for Level AA conformance
AAA: not required by any law cited here
New in 2.2 at Level A or AA: six criteria an older audit never tested
3.2.6
Consistent Help
A
3.3.7
Redundant Entry
A
2.4.11
Focus Not Obscured (Minimum)
AA
2.5.7
Dragging Movements
AA
2.5.8
Target Size (Minimum)
AA
3.3.8
Accessible Authentication (Minimum)
AA
Removed: 4.1.1 Parsing is obsolete in 2.2. Keep testing it only if a policy cites WCAG 2.0 or 2.1.
Source: WCAG 2.2, W3C Recommendation (current version 12 December 2024). Content that conforms to 2.2 also conforms to 2.0 and 2.1, so a 2.2 AA audit covers older requirements too.

Why 2.2 rather than 2.1

The specification is explicit: "Content that conforms to WCAG 2.2 also conforms to WCAG 2.0 and WCAG 2.1." Auditing to 2.2 AA therefore satisfies a 2.1 or 2.0 requirement as well, with one caveat. Criterion 4.1.1 Parsing was removed in 2.2, so if a contract or regulation names 2.0 or 2.1, ask the auditor to test and report 4.1.1 separately.

The six criteria older audits never checked

An audit run to WCAG 2.1 tests none of the six new Level A and AA criteria. Two of them matter more than the rest for most products. Target Size (Minimum), 2.5.8, catches controls too small to hit reliably. Accessible Authentication (Minimum), 3.3.8, catches login steps that depend on remembering or transcribing something, such as some puzzle checks.

If your last audit predates 2.2, it is not a baseline for 2027. It is a baseline for a standard that has moved.

Which rules apply to you

"Who needs to be WCAG compliant?" has no single answer, because WCAG is a technical standard, not a law. Laws adopt it, each in its own version and with its own dates.

Figure 4 · Which rule applies to you
Four regimes, one audit standard
Who each rule covers, the WCAG version it names, and when it bites.
ADA Title II
WCAG 2.1 AA
US state and local government
26 April 2027 (population 50,000+), 26 April 2028 (smaller and special districts)
ADA Title III
No regulation sets a standard
US businesses open to the public
DOJ applies its general ADA duties; WCAG is the common benchmark
Section 508
WCAG 2.0 A and AA
US federal agencies and their ICT
In force since 18 January 2018
European Accessibility Act
Harmonised standards
Products and services sold in the EU
Applies from 28 June 2025; microenterprises providing services exempt
One audit, several laws: test to WCAG 2.2 AA and the result also covers 2.1 AA and 2.0 AA. Add 4.1.1 only where a policy cites 2.0 or 2.1.
Sources: ADA.gov fact sheet on the Title II web rule (compliance dates as extended by the Interim Final Rule of 20 April 2026); ADA.gov web guidance; US Access Board ICT standards; AccessibleEU; Directive (EU) 2019/882. Not legal advice.

US state and local government

The Department of Justice's Title II web rule names WCAG 2.1 Level AA for web content and mobile apps. The original deadlines were moved by an Interim Final Rule published on 20 April 2026. Governments serving 50,000 or more people now have until 26 April 2027, and smaller ones and special district governments until 26 April 2028. Many pages still quote the 2026 date; it no longer applies.

US businesses

For businesses open to the public, the DOJ's web guidance says the department "does not have a regulation setting out detailed standards". Businesses "have flexibility in how they comply", but the ADA's general duties still apply. In practice WCAG AA is the benchmark used to judge whether a site is accessible, which is why it is the scope worth auditing to.

US federal agencies and their suppliers

Section 508's revised standards require electronic content to conform to WCAG 2.0 Levels A and AA, and have applied since 18 January 2018. Suppliers are usually asked for an Accessibility Conformance Report, covered below.

The European Union

The European Accessibility Act applies from 28 June 2025 to a defined set of products and services, including e-commerce. The directive exempts microenterprises providing services. If you sell into the EU, confirm with counsel which of your services fall in scope before scoping the audit.

None of this is legal advice. It is the reason one well-scoped audit to WCAG 2.2 AA usually serves several regimes at once.

Where most sites actually fail

Before paying for an audit, it helps to know what it will almost certainly find. WebAIM scans the home pages of the top one million websites every year.

Figure 3 · Where sites fail
Six errors account for 96% of what scanners find
WebAIM's 2026 scan of the top one million home pages.
95.9%
of the top one million home pages had detected WCAG failures
56.1
detected errors per home page, up from 51 a year earlier
Share of home pages with each error
Low contrast text
83.9%
Missing image alt text
53.1%
Missing form input labels
51%
Empty links
46.3%
Empty buttons
30.6%
Missing document language
13.5%
Source: WebAIM Million, February 2026 data. Automatic detection only, so the real failure rate is higher: WebAIM puts full conformance "certainly lower than 4.1%". These six are the cheapest findings in any audit.

What that means for your budget

These six error types are cheap for an auditor to find and cheap for you to fix. If you pay for a manual audit before fixing them, you pay expert rates to be told your contrast is low. Run a free automated checker first, fix what it reports, then buy human time for what machines cannot judge.

Our comparison of accessibility testing tools covers which scanners are worth running for that first pass.

The method to insist on: WCAG-EM

The W3C publishes its own method for evaluating a site against WCAG, the WCAG Evaluation Methodology. Version 2.0 was published as a W3C Group Note in July 2026. It is not mandatory, but it is the closest thing the field has to a shared procedure.

Figure 5 · The W3C audit method
WCAG-EM: five steps, in order
Ask any provider whether they follow it. If they have not heard of it, keep looking.
1
Define the evaluation scope
Which product, which WCAG version and level, which browsers and assistive technologies.
You receive: A written scope you sign off
2
Explore the target product
Find the templates, functions, processes and content types that exist.
You receive: An inventory of what will be sampled from
3
Select a representative sample
A structured sample of every template and process, plus a random sample to check it is representative.
You receive: The exact list of pages tested
4
Evaluate the sample
Every success criterion checked on every sampled page, by tools and by people.
You receive: A verdict per criterion per page
5
Report the findings
Results, evidence and the method used, so the audit can be repeated.
You receive: The report you act on
Source: WCAG Evaluation Methodology (WCAG-EM) 2.0, W3C Group Note, 23 July 2026. The method does not require any particular tools, and it does not replace quality assurance during development.

Why the method matters more than the tool list

Two audits of the same site can disagree because they sampled different pages, not because either auditor was wrong. WCAG-EM fixes that by making the sample explicit and adding a random sample to test whether the chosen pages are representative. An audit you cannot repeat is an audit you cannot use to prove progress.

WCAG-EM also states what it is not: it "does not replace the need for quality assurance throughout all phases of product development". An audit is a measurement. It does not make the next release accessible on its own.

Scoping the audit, and why it decides the price

"How much does a WCAG audit cost?" is the most common question, and the honest answer is that it depends on the sample, not the size of the site. Here is the arithmetic on an illustrative online store.

Figure 6 · Scoping, worked
A 1,200-page site is audited on 32 pages
An illustrative online store, sampled the WCAG-EM way: every template, every step of every process, every distinct component, plus a random set.
1,200
URLs on the site
32
pages actually audited
9
Templates
home, listing, product, article, search, account, help, contact, error
14
Processes, every step
sign-up (4 steps), checkout (6), password reset (4)
4
Distinct components
date picker, video player, map, chat widget
5
Random sample
picked at random to test that the rest is representative
32 pages × 55 criteria = 1,760 verdicts. Each one is pass, fail or not applicable, and each fail needs evidence.
Illustrative site, not a client. The arithmetic is the point: audit effort scales with templates and processes, not with URL count, so ask a provider for their sample list before you compare prices.

What drives the effort

  • Templates, not URLs. A thousand product pages built from one template are one template to audit, plus spot checks.
  • Processes. Every step of every flow that a user must complete, because of the complete-process rule below.
  • Distinct components. A custom date picker or video player needs its own careful testing, wherever it appears.
  • Platforms. Web only, or web plus iOS and Android apps. Each platform is a separate evaluation.
  • Assistive technology coverage. Which screen readers, with which browsers. More combinations mean more hours.

How to compare quotes honestly

Ask every provider for three things before comparing prices: the list of pages and flows they will test, the WCAG version and level, and the assistive technology and browser combinations. Two quotes with different sample lists are not comparable, however similar the totals look.

We do not publish price ranges here, because any figure without your sample list would be invented. The useful number is verdicts: pages in the sample multiplied by 55 criteria. That tells you how much work you are actually buying.

Test processes end to end, not page by page

This is the rule most often missed when audits are scoped by URL list. WCAG 2.2 sets five conformance requirements, and two of them change how a site has to be sampled.

Figure 7 · Complete processes
One failing step fails the whole checkout
A payment form a keyboard user cannot complete makes the four accessible pages around it useless to that person.
Checkout, tested page by page
Step 1
Basket
passes
Step 2
Delivery
passes
Step 3
Payment
FAILS
Step 4
Review
passes
Step 5
Confirm
passes
Page-by-page reading
Four of five pages pass. Looks like 80% done.
What WCAG says
The whole checkout fails, every page in it.
Source: WCAG 2.2, conformance requirement 5.2.3 Complete processes, which uses an online store's select-to-checkout sequence as its own example. 5.2.2 adds that a page cannot conform if part of it is excluded.

Full pages

Conformance requirement 5.2.2 says conformance "cannot be achieved if part of a web page is excluded". You cannot exclude a third-party chat widget or cookie banner and call the page conformant. WCAG offers a Statement of Partial Conformance for third-party content you cannot control, but that is a disclosure, not a pass.

Complete processes

Requirement 5.2.3 states that if any page in a process fails, the process fails at that level. The specification's own example is an online store, from product selection to checkout. So sample processes in full: sign-up, login, checkout, password reset, and any form that ends in a submission that matters.

Responsive layouts, apps, documents and third parties

Most quotes are written for "the website" as it looks on the auditor's laptop. Four kinds of content routinely fall outside that, and each one is somewhere users get stuck.

Every screen size is part of the page

WCAG 2.2 adds a note to the full-pages requirement: a full page "includes each variation of the page that is automatically presented by the page for various screen sizes". A responsive site that conforms at desktop width but hides its menu behind an unlabelled icon on a phone does not conform. Ask the auditor which viewport widths they test, and expect at least a phone width and a desktop width for every sampled page.

Mobile apps are a separate evaluation

WCAG was written for web content, but regulators apply it to apps too: the DOJ's Title II rule names WCAG 2.1 AA for state and local government mobile apps as well as websites. An app audit is a different job from a web audit. It uses the platform screen readers, VoiceOver on iOS and TalkBack on Android, along with platform text-size settings and switch access. Price and schedule it separately, and check that the provider names the devices and operating system versions.

Documents behind the links

PDFs, slide decks and spreadsheets linked from a page are content your users need. They are tested against different techniques from HTML pages, and they are often where public-sector sites fail. Decide at scoping time which documents are in the sample: the forms people must complete, and anything published since the last audit, are the usual priorities.

Third-party components

Chat widgets, payment frames, cookie banners, embedded maps and booking tools sit on your pages, so they affect your conformance. Ask each vendor for its Accessibility Conformance Report. Where a component fails and you cannot change it, WCAG's Statement of Partial Conformance lets you disclose that honestly. The better long-term answer is to make accessibility a requirement in the next renewal.

How to test a website for WCAG compliance

A credible audit combines four kinds of testing. Each catches what the others miss.

MethodWhat it catchesWhat it misses
Automated scanningContrast, missing alt text, missing labels, empty links and buttonsWhether alt text is meaningful, whether a flow makes sense
Keyboard-only testingFocus order, focus visibility, keyboard traps, obscured focusProblems only a screen reader exposes
Screen reader testingNames, roles, states, reading order, live updatesPurely visual issues such as target size
Visual and zoom checksReflow at 400% zoom, text spacing, target size, colour relianceAnything in the code a person cannot see

Testing with disabled users

Expert testing finds conformance failures. Testing with people who use assistive technology every day finds usability failures that still pass the criteria. If the product serves a large disabled audience, budget for both. They answer different questions.

What the report should contain

The report is the only thing you keep from an audit. A score on its own tells your developers nothing they can act on. Every finding should look like this.

Figure 8 · What one finding should look like
A finding your developers can fix without a meeting
Eight fields. If a report cannot fill all eight, it is a list of opinions.
Audit finding · example
Finding 14: payment field hidden behind a sticky bar
Criterion
2.4.11 Focus Not Obscured (Minimum), Level AA
Where
Checkout, step 3 (payment). Card number field, viewport 390px wide
Reproduce
Tab from the delivery summary. The sticky 'Pay now' bar covers the focused card number field completely
Who it affects
Keyboard and switch users, screen magnifier users
Severity
Blocker: the payment step cannot be completed without a mouse
Fix
Add scroll padding equal to the bar's height, or stop the bar overlapping focused fields
Evidence
Screenshot, browser and version, assistive technology used
Retest
Status, date and tester after the fix
Illustrative finding, not from a client report. Criterion 2.4.11 is one of the six new at A or AA in WCAG 2.2, so an audit run to 2.1 would not have raised it.

Severity is a judgement, so the scale must be written down

WCAG levels do not tell you what to fix first. A Level AA failure in the payment step matters more than a Level A failure on an archived news page. A useful report ranks findings on a scale it defines in writing:

SeverityMeaningTypical example
BlockerA user cannot complete a taskPayment field unreachable by keyboard
SeriousA task is possible but much harderError messages not announced by screen readers
ModerateFriction, with a workaroundInconsistent headings on content pages
MinorLittle effect on completing tasksRedundant alt text on decorative images

Ask how severity was assigned. If the answer is "the tool decides", the ranking reflects what was easy to detect, not what hurts users.

The summary should answer three questions

  1. Does the sample conform to WCAG 2.2 AA? Yes or no, with the count of failing criteria.
  2. Which complete processes are blocked? These are the failures that stop a user finishing a task, so they come first.
  3. What was tested, and how? The sample list, the method, the tools, and the assistive technology combinations, so the audit can be repeated.

Accessibility Conformance Reports

If you sell to the US government or to large enterprises, buyers will ask for an Accessibility Conformance Report. ITI's VPAT template, now at version 2.5Rev, comes in WCAG, 508, EU and international editions. ITI describes the completed template, with documented testing results, as an ACR. An audit report and an ACR are different documents: the audit tells your team what to fix, the ACR tells your buyers where you stand. A good audit gives you the evidence to write an honest ACR.

Questions that separate a real audit from a scan

AskA credible answerA warning sign
Which method do you follow?WCAG-EM, or a documented equivalent"Our proprietary scanner"
Which WCAG version and level?2.2 AA, plus 4.1.1 if a policy needs 2.0 or 2.12.1, without explanation
Can I see the sample list before we sign?Yes, pages and processes named"We audit the whole site"
Which assistive technologies?Named screen readers and browsers"All major ones"
Who tests manually, and how long?Named testers, hours by platformNo manual hours stated
Is retesting included?Yes, every fixed finding verified"You can self-certify fixes"

Is there a certification for WCAG compliance?

Not from the standard's authors. WCAG 2.2 defines conformance requirements and treats conformance claims as optional, made by the site owner. Some providers issue their own certificates or badges. Read those as a statement by that provider, and ask what sample and date it covers. A badge cannot show that the next release still conforms.

Common mistakes buyers make

  • Buying a scan and calling it an audit. The GOV.UK test above shows how much is left out.
  • Auditing to WCAG 2.1 in 2027. Six A and AA criteria go untested.
  • Scoping by URL count. It inflates cost on large template sites and under-tests small sites with complex flows.
  • Leaving out the logged-in area. Accounts, dashboards and checkout are where users complete tasks, and where processes fail.
  • Skipping the retest. A fix that has not been verified is a hope.
  • Treating the audit as the end. Conformance decays with each release.

After the audit

The report gives you a baseline. Keeping conformance is a process, and it starts the week the report lands.

Figure 9 · After the report
An audit is a baseline, not a finish line
Conformance decays with every release. The loop keeps it.
Audit
Baseline against WCAG 2.2 AA on the agreed sample
↓
Fix
Blockers in complete processes first, then by reach
↓
Retest
Every fixed finding verified by the auditor, not self-certified
↓
Guard
Automated checks in CI for the detectable errors, so they do not return
↓
Re-audit
After a redesign or a new process, or on a fixed cycle
↑ back to Audit on the next cycle
QAble's sequence. The CI guard catches the six error types that make up 96% of automatically detected failures in the WebAIM Million; people still check the rest.

Fix in the right order

Start with blockers inside complete processes, because they stop users finishing tasks. Then fix by reach: issues in shared templates and components fix many pages at once. Leave single-page cosmetic findings for last.

Stop the regressions

Put an automated accessibility check into your CI pipeline so the six common error types cannot come back unnoticed. It will not catch everything, as the tools study shows, but it stops the cheapest failures returning. Our WCAG 2.2 test case library gives your team checks to run by hand between audits.

From our work
None of QAble's published case studies is an accessibility engagement, so there is no client metric to quote here, and we will not invent one.
What we can share is a pattern from testing work generally: the defects that block a real user cluster in forms and multi-step flows, where state changes between steps. That is why this guide puts complete processes first. Treat it as an observation, not a statistic.

For a wider view of the testing that sits around an audit, our website accessibility testing guide covers the day-to-day practice.

A buying sequence that works

  1. Run a free automated checker and fix the obvious errors first
  2. List your templates, processes and distinct components
  3. Decide the standard: WCAG 2.2 AA, plus 4.1.1 if a policy needs it
  4. Ask three providers for their sample list, method and assistive technology set
  5. Compare quotes only on matching sample lists
  6. Insist on findings with all eight fields and a retest
  7. Put automated checks into CI and plan the next audit before this one ends

Steps 2 and 4 decide whether the audit you buy is comparable, repeatable and worth its price.

Getting an audit scoped properly

If you want a sample list before you commit to anything, QAble's accessibility audit service starts with exactly that: the templates, processes and assistive technologies to be tested, against WCAG 2.2 AA.

Frequently Asked Questions

What does WCAG stand for?

Web Content Accessibility Guidelines. They are published by the W3C, and the current version, WCAG 2.2, has 86 active success criteria at three levels: A, AA and AAA. Most laws and contracts ask for Level AA, which means meeting all 55 Level A and AA criteria.

What is a WCAG compliance audit?

It is an evaluation of a sample of your site or app against each WCAG success criterion, carried out by people with the help of tools. A credible audit follows a stated method, such as the W3C's WCAG-EM, names the pages and processes it sampled, and reports every failure with a location, steps to reproduce it and a fix.

Is WCAG the same as ADA compliance?

No. The ADA is a US civil rights law and WCAG is a technical standard. For state and local governments, the DOJ's Title II rule adopts WCAG 2.1 Level AA directly. For businesses open to the public there is no regulation naming a standard, but WCAG AA is the benchmark generally used to judge whether a site is accessible.

What is digital accessibility?

It means people with disabilities can perceive, operate and understand a website, app or document, and that it works with the assistive technologies they use, such as screen readers, magnifiers, switch devices and voice control. WCAG is the most widely adopted standard for measuring it.

What are the four principles of WCAG?

Perceivable, operable, understandable and robust. Every success criterion sits under one of them. They are sometimes searched for as "the four types of accessibility", but they are principles that organise the criteria rather than categories of disability.

How long does a WCAG audit take?

It depends on the sample rather than the size of the site: the number of templates, process steps, distinct components and platforms, and the assistive technology combinations tested. Ask for the sample list first; a provider who can give a timeline without one is guessing.

Can I be sued if my website is not ADA compliant?

In the US, businesses open to the public have faced ADA claims over inaccessible websites, and state and local governments now have a specific rule with compliance dates in 2027 and 2028. Whether a particular site is at risk is a legal question for counsel. An audit gives you evidence of where you stand and a record of what you fixed.

Do automated accessibility checkers make a site compliant?

No. In a GOV.UK test of ten automated tools against 143 deliberate barriers, 42 barriers were missed by every tool. Automated checks are worth running first and keeping in CI, but they cannot judge whether alt text is meaningful or whether a process can be completed with a keyboard.

Should we audit to WCAG 2.1 or 2.2?

Audit to 2.2 Level AA. Content that conforms to WCAG 2.2 also conforms to 2.0 and 2.1, so one audit covers older requirements. The exception is criterion 4.1.1 Parsing, removed in 2.2: test it separately if a law or contract you must meet cites 2.0 or 2.1.

How often should a site be re-audited?

After any redesign, after a new process such as a checkout or sign-up flow ships, and otherwise on a regular cycle agreed with your team. Between audits, automated checks in CI and manual spot checks on changed templates stop conformance decaying with each release.

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