How Manual Audits for Website Accessibility (ADA Compliance) Work

Man in long sleeve shirt, Kris Rivenburgh, closely studies the screen on a Microsoft surface in a conference room.
As an independent consultant, it’s important to be thorough. (source: Kris Rivenburgh)

(Updated for 2024)

A website accessibility audit (sometimes referred to as ADA Website Compliance audit) is performed by one or more technical accessibility experts who meticulously evaluate your digital asset against a version and conformance level of WCAG (usually 2.0 AA or 2.1 AA) and create a report that identifies the accessibility issues that need to be addressed.

Automated accessibility scans (sometimes called “checkers”) are a very useful tool to get a feel for your website’s overall accessibility level, and they help in conducting a manual audit, but they are limited. Scans only flag 25% of accessibility issues in WCAG 2.1 AA.

It is important for buyers to know that scan results are sometimes passed off and sold as an audit or “automated testing”.

With an audit, it’s highly desirable to hire an independent expert or company that specializes in web accessibility and most likely not someone in-house.

However, if you would like to learn how to conduct a basic website accessibility audit, my course, Audits 101, will help you find accessibility issues.

This course is beginner-friendly and takes you step-by-step through understanding how WCAG relates to audits and how to approach auditing a website.

While there’s tremendous benefit in training your digital team, optimally your first digital accessibility audit comes from a reputable third-party. A large part of becoming a good auditor comes from experience in finding accessibility issues.

Audit Process

Here’s how I approach audits:

  1. Ask you for the URL / screen of every page you want audited (or propose the primary page layouts to include in scope).

Websites can easily have hundreds of pages (especially e-commerce sites) and it doesn’t make financial sense to go over each one. The best solution is to examine each of the primary layout templates of your site and then apply the audit results universally across your website, to all identical templates.

For example, let’s say you operate a sporting goods website through the Shopify platform. Rather than evaluating each individual product page, an auditor can look at one product page and identify the issues that would apply to other product pages.

Note that not every screen has its own URL. For example, a checkout process might involve multiple screens / refreshed content contained on the same URL. This is one why it’s important to distinguish between URLs and screens.

2. Check each page / screen (as well as the overall site structure) against WCAG 2.0 AA or 2.1 AA (or 2.2 AA).

(Note: I recommend a WCAG 2.1 AA audit as a baseline. WCAG 2.0 AA is more of a classic standard because it was published in 2008.)

This is the most important, time-consuming part of a manual accessibility audit that doesn’t show up in the final reports.

What’s happening is an expert is diligently evaluating your website against all 50 success criteria in 2.1 AA.

And then there’s the testing the website to make sure everything works as it should (e.g. your website is fully navigable by keyboard, without a mouse).

The areas where you’re in good standing (and don’t need to change anything) won’t show up in the final report but it’s important that each one is accounted for.

3. List the issues for each page template/layout in chronological order

Every page you request to be examined will have a specific list of accessibility issues from that page. The issues should be written out in chronological order so that they’re in sync with the page and easy to spot.

Not every auditor takes this linear approach. However, it is easier for client / client’s developer to make use of the audit.

4. Provide clear remediation instructions and/or examples

For every unique issue listed, instructions or examples of code will be provided. This is so you or your developer, designer, or content editor know precisely how to make your website accessible from the audit.

5. Provide level of severity

Although this is more of an option, it’s always nice when audits include a severity level (e.g., high, low, medium) so your development and design team can prioritize what issues to address first.

6. Leverage automated scans

Automated scans have their place — they help an auditor immediately locate a substantial chunk of potential accessibility issues, saving time and also reducing the human error component of a manual audit.

7. Provide a clean, concise, easy to understand PDF report

Audits should be actionable for clients. If they’re too fluffy, jumbled, technical, or long, it’s defeating.

The best auditors will make sure their reports get right to the point and don’t use technical jargon that needs a translation.

How much does a manual audit cost?

$3,500 to $7,500 is a good price range that’s going to capture the cost to audit most websites.

If you start in the middle at $5,500, you can toggle up or down based on the following factors:

  • Current, general state of accessibility (are you in really bad shape, okay shape, or decent shape?)
  • Sheer volume: Number of pages and length of pages audited
  • Complexity of pages (forms, selectors, media, maps, and dynamic elements all make a page more complex)

Typically an audit will take 2–4 weeks for delivery for agencies with a quicker turnaround time.

Less agile agencies will take 4–6 weeks.

Note 1: You may want a follow-up, post-remediation audit or re-audit once the original issues have been addressed. These audits are easier to do since the website will have far fewer accessibility issues and there is a familiarity with the site. For a post-remediation audit, the price should be significantly lower (40–50% of the original quote) — if conducted by the same company.

Note 2: Beware of the super cheap audit. I had a client recently contact me after they had paid $1,500 for someone to audit their website. The audit amounted to an aggregated report of three different free automatic scans.

When I get asked about audits, people use different terms. Here is the proper context for each.

User Testing

User testing is testing performed by professionals with one or more disabilities. These professionals test a website to make sure it is accessible and practically free of issues.

With user testing, professionals are going through the website without regard for WCAG but instead for what obstacles or issues they practically encounter.

Remember, user testing is related but separate to an audit.


A more affordable approach to audits is to have an expert review your website informally.

Here, you can have consultant screenshare with you on Zoom or Skype, etc. and get a quick overview of the issues on your website.

This isn’t nearly as good as an audit (no documentation, can only cover so much ground, no examples or instructions for remediation) but it’s a very helpful start and will cost less.


We talked about scans earlier. These are automated tools that flag about 1/4 of the issues on your website. Most are free (WAVE and AXE are two good ones).

I recommend WAVE. Plaintiffs’ lawyers use it (so its a great place to start) and it’s easy to use and understand.

Scans are an excellent aid when conducting an audit but, again, they only flag a fraction of the accessibility issues on your website. There are many important issues (that do find their way to ADA compliance litigation) that cannot be caught be a scan.


Digital A11y Tublets Chrome Extension menu with headings element activated and headings highlighted on

There’s this guy named Raghavendra Satish Peri and he’s basically building the ultimate free digital accessibility resource kit at and it’s going unnoticed.

That may sound like hyperbole but what if I told you I just found a new tool (that you don’t know about) that does the following:

  • has a 1 minute learning curve
  • helps with things scans don’t touch
  • helps non-technical people quickly find accessibility elements and issues
  • presents elements and issues visually on the website
  • saves hours of time on audits
  • provides an effective way to review issues (and make sure you don’t miss anything)

Well believe it or not, I have found this utilitarian delight. It’s called DigitalA11y Tublets.

The Backstory

I know Raghava and only found out about the DigitalA11y Tublets Chrome extension because he mentioned it to me.

I didn’t use it right away.

In fact, I didn’t think about it for a while.

But as I was making my new course on how to audit a website, I remembered it.

And I was like, that would be helpful — I should create a lesson on Tublets.

And then I added it to the ADA Compliance Course.

And then I thought, more people really need to know about this and I made the mini demo embedded above.

Incredibly, there are only 774 users for the Tublets extension so far.

But it’s free. It’s simple. It’s easy. And it works.

We live in a world where AccessiBe and UserWay have 20 zillion installs while a completely useful accessibility tool has less than 800.

(Let the layers of societal meaning in that sink in for a second.)

Anyway, I thought you should know about Tublets.

Learn about the ADA compliance for websites legal landscape and services marketplace.

Would you like to certify your website’s accessibility? Read my guide to ADA website certification.

Working on WCAG 2.2 conformance? Study the latest version of the Web Content Accessibility Guidelines with my WCAG 2.2 AA checklist.

Before you get into 2.2, learn the difference between WCAG 2.0 AA and WCAG 2.1 AA.

Are you new to ADA compliance and website accessibility? Read my website accessibility for beginners introduction.

Researching VPATs? Read why you should know what an ACR or accessibility conformance report is. My VPAT certification guide is essential for procurement teams.

The Americans with Disabilities Act is just one of the laws that concerns website accessibility. Read my 504 compliance website and 508 compliance website guides. Companies with employees in Ontario may also be interested in my AODA website compliance requirements explainer.