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WCAG 2.1 AA · Section 508 · DHS Trusted Tester

Websites and apps, tested by a person.

An automated scan finds some problems. A person with a keyboard and a screen reader finds the rest. The practice tests the pages, forms and documents people use most against WCAG 2.1 AA, using the Department of Homeland Security Trusted Tester process, then retests each fix and keeps the record.

What applies to your site

The standard depends on who you are. The duty to communicate effectively applies to every covered organization now.

Public entities: Title II

Web content and mobile apps, including what's provided through contracts, have to meet WCAG 2.1 Level AA from April 26, 2027 for entities of 50,000 or more, and from April 26, 2028 for smaller ones and special districts.

28 CFR 35.200

Organizations with HHS money: Section 504

WCAG 2.1 Level AA from May 11, 2027 for organizations with fifteen or more employees whose programs get HHS money, even through a city or state, and from May 10, 2028 for smaller ones.

45 CFR 84.84

Federal agencies: Section 508

The Section 508 Standards use WCAG 2.0 Level AA for electronic content, and they reach the technology agencies buy.

36 CFR Part 1194, Appendix A, E205.4

Businesses and nonprofits: Title III

No Title III technical standard and no compliance date. The duty to communicate effectively applies now, and courts and settlements measure websites against WCAG 2.1 Level AA.

28 CFR 36.303(c)

Where your site stands

Websites, apps and documents are one channel of the obligation, and they draw a growing share of lawsuits. An automated scan finds some problems. A person with a keyboard and a screen reader finds the rest. Public entities, and organizations whose programs get HHS money even through a city or state, have fixed dates in 2027 and 2028. Every covered organization owes effective communication now.

Find the row that describes you today. The row under it is the work.

  1. Stage 1: Untested

    What it looks like
    No one has tested the site. An overlay may be installed. Problems surface as complaints or a demand letter.
    Who does the work
    Nobody, or the web vendor when asked.

    28 CFR 35.160 and 36.303(c)

  2. Stage 2: Scanned

    What it looks like
    An automated scan runs and the error count drops, but nobody has tried the site with a keyboard or a screen reader, and the forms and PDFs people need haven't been checked.
    Who does the work
    Marketing or IT, with a scanning tool.

    WCAG 2.1 Level AA

  3. Stage 3: Tested by hand

    What it looks like
    The pages and tasks people use most are tested against WCAG 2.1 AA by a person, using the Department of Homeland Security Trusted Tester process with assistive technology, and every finding is dated.
    Who does the work
    The practice performs the test remotely. Your developers or vendor fix.

    WCAG 2.1 Level AA

  4. Stage 4: Fixed and retested

    What it looks like
    Findings are fixed in order of impact, each fix is retested by hand, documents are remediated, and an accessibility statement tells people how to report a barrier.
    Who does the work
    Developers and content staff fix. The practice retests and keeps the record.

    28 CFR 35.200(b); 45 CFR 84.84(b)

  5. Stage 5: Built in

    What it looks like
    Accessibility is checked before release, editors and designers work from a short checklist, vendor contracts carry accessibility terms, and the program is measured against the W3C Accessibility Maturity Model.
    Who does the work
    Design, development, content and procurement share it. The practice audits on a schedule.

    W3C Accessibility Maturity Model, as the benchmark

A row describes how the work runs. It isn't a finding that a site conforms.

What testing by hand covers

The test follows a person through the task, not a scanner through the page.

The whole path

Find the page, fill in the form, pay, get the confirmation, return the documents. Each finding says where in that path it sits and who can fix it.

WCAG 2.1 AA

What a scan can't judge

Keyboard access, focus order, whether a screen reader announces errors, and whether alt text says what the image shows. These take a person.

DHS Trusted Tester process

Forms and documents

PDFs and forms people have to complete, often the largest barrier on the site and the one vendors cover least. The practice remediates documents and PDFs.

WCAG 2.1 AA and PDF/UA

Pieces from vendors

Booking, payment and registration tools embedded in your site. The obligation follows the service, whoever owns the code.

28 CFR 35.200(a) and 36.202(a)

An overlay or a widget doesn't make a site conform, and it doesn't replace the program behind the site. More on that on running an ADA program without a dedicated team.

Short answers

Is an automated scan enough?

No. A scan is useful for volume and for catching regressions. It can't tell whether a keyboard user can finish a task or whether a screen reader user hears what changed.

Which WCAG version?

WCAG 2.1 Level AA is the standard in the Title II and HHS rules. It includes every WCAG 2.0 criterion, so the same test covers what Section 508 asks of web content.

28 CFR 35.200(b); 45 CFR 84.84(b)

Do you fix the site?

Your developers or vendor fix the site and the app. The practice specifies each fix, retests it by hand and keeps the record, and it remediates documents and PDFs itself.

ADA Access for All is not a law firm. The work is built to be usable by counsel.

Start with one task

A 30-minute call picks the task people most need to finish on your site and covers what a test by hand would look at first.

Book a 30-minute call