A government accessibility checklist should connect legal scope to practical evidence: name an accountable owner, set WCAG 2.2 Level AA (or the applicable national standard), test representative journeys with both automated and manual methods, record and fix defects, and publish a current accessibility statement. It must also control suppliers, because outsourcing a website or app does not transfer the public body’s responsibility.
What the checklist needs to prove
A useful checklist is more than a scan report. It should show that the public body has identified every service in scope, selected a defensible standard, tested the ways people actually use the service, acted on failures, and told the public how to get help. Keep evidence for each stage so an internal reviewer, auditor, procurement team or user can see what was tested and what remains unresolved.
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- Accountability: a named service owner and accessibility lead can make decisions and fund remediation.
- Coverage: the inventory includes websites, mobile apps, authenticated areas, documents, intranets, extranets, embedded widgets and outsourced components that users encounter.
- Conformance target: the service states the WCAG version and level, jurisdictional rules, exceptions and acceptance thresholds.
- Evidence: automated results are supplemented by keyboard, focus, zoom, reflow, small-screen, form, media and assistive-technology checks.
- Transparency: a plain-English accessibility statement reports status, known failures, alternatives and a route for complaints or problem reports.
1. Establish governance and scope
Name accountable people
Assign a service owner with authority over budget, delivery and risk. Name an accessibility lead who maintains the backlog, coordinates testing and updates the statement. Record deputies so work does not stop when a person changes role. Include legal, procurement, content, design, development, security and support contacts for services where their decisions affect accessibility.
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List each public domain, subsite, mobile application, campaign microsite, document repository and user journey. Mark whether a journey is public, authenticated or transactional. Include search, account creation, sign-in, payments, applications, appointment booking, appeals, downloads, contact forms and any process needed to exercise a right or obtain a public service.
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Record third-party content and components such as maps, payment screens, video players, chat, analytics consent tools and document viewers. Note the supplier, version, integration owner and renewal date. An outsourced component remains part of the public service: the public body is still responsible for meeting its legal duties.
Capture jurisdiction and review dates
For every item, record the country or jurisdiction, governing legislation, standard version, known exemptions, the date of the last assessment and the next planned review. Keep separate entries for a website and its native mobile app when their technology, release cycle or legal treatment differs.
2. Set the standard and acceptance criteria
Use WCAG 2.2 Level AA for UK public-sector websites and apps
GOV.UK guidance identifies WCAG 2.2 Level AA as the target for UK public-sector websites and mobile applications. The Public Sector Bodies (Websites and Mobile Applications) Accessibility Regulations 2018 came into force on 23 September 2018. Your statement and project records should identify the exact WCAG version and level being applied rather than saying only “accessible.”
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Turn the target into pass/fail evidence
| Area | Acceptance evidence to request |
|---|---|
| Keyboard and focus | Every control and complete journey works without a mouse; focus is visible, ordered and not trapped. |
| Responsive presentation | At the required zoom and narrow viewport, content reflows without loss of information or controls. |
| Structure and content | Headings, landmarks, labels, language, links, tables and status messages expose a logical structure to assistive technology. |
| Forms and errors | Instructions, required fields, error identification, recovery guidance and confirmation messages are available in an accessible form. |
| Media and documents | Captions, transcripts, audio description where needed, accessible PDFs and an alternative format process are defined. |
| Browsers and devices | Supported browser, operating-system, screen-size and assistive-technology combinations are listed and tested. |
| Dynamic features | Menus, dialogs, validation, loading states and live updates announce changes without disorienting users. |
Define what counts as a pass, what evidence must be attached, who can accept a residual risk and when a release is blocked. A supplier’s general conformance claim is not acceptance evidence for your exact version, configuration and content.
3. Select a representative sample
Cover templates and user goals
You do not need to test every page in a first review. Select a sample that represents the service’s templates, content types and risk. Include the home page, global navigation, a content article, search and results, a page with tables or downloads, a form with validation, authentication, a transaction or payment, confirmation and error states, and pages that contain embedded or third-party content.
Weight high-impact journeys
Add every route through which a person applies, pays, submits evidence, checks status, requests an adjustment or accesses information needed to exercise rights. Include common and complex paths, not just the easiest successful path. If a mobile app and website share a back end but use different interfaces, sample both.
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Record the test environment
For each test, note the URL or build, date, browser, operating system, viewport or device, zoom level, keyboard used and assistive technology. Where possible, involve people with a range of disabilities or use documented accessibility personas. Their task-based observations often reveal barriers that a standards inspection misses.
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4. Combine automated and manual testing
Use automation as a first pass
Run an automated scanner such as axe against the sampled pages and key states. Automation can quickly identify issues such as missing labels, duplicate identifiers, contrast failures and invalid structure. Export the rule, element, location, impact and tool version. Treat the result as a queue of clues, not a complete audit: automated tools do not find every accessibility problem and can produce both false positives and false negatives.
Run a keyboard-only check
- Reload the page and operate it without a pointer.
- Tab through links, controls, menus, dialogs and forms; verify a visible focus indicator and a sensible order.
- Open and close menus, date pickers, accordions and dialogs; confirm focus moves into a dialog and returns to the triggering control.
- Check that no component traps focus and that every action has a keyboard alternative.
Check zoom, reflow and small screens
- Increase browser zoom and text size to the levels required by your standard and observe whether content remains usable.
- Resize to a narrow mobile viewport and inspect horizontal scrolling, clipped text, overlapping controls and two-dimensional layouts.
- Repeat a critical transaction at the small size, including error correction and confirmation.
Inspect structure, forms and updates
- Navigate by headings and landmarks; confirm the hierarchy reflects the visual content.
- Check that every input has an associated label, instructions are discoverable and errors identify the field and explain how to fix it.
- Submit incomplete and invalid forms, then verify that focus, summaries and inline messages expose the problem.
- Trigger loading indicators, success messages, validation and live updates; ensure assistive technology receives the change without losing context.
- Review images, charts, icons, captions, transcripts, colour-only cues, link text, page titles and document tags.
Test with assistive technologies
Use the combinations your service supports, such as a screen reader with a desktop browser, a mobile screen reader, magnification or high-contrast settings, speech input and switch or keyboard access. Record the exact versions and settings. For complex or high-risk services, commission a detailed independent audit and schedule a retest after remediation.
5. Log, prioritise and close defects
Use a defect record that another tester can reproduce
Each issue should contain:
- the URL, screen, component or build;
- the relevant WCAG success criterion or EN 301 549 requirement;
- a description of the user impact and who is affected;
- severity and whether it blocks a core transaction;
- precise reproduction steps, test environment and supporting evidence;
- an assigned owner, target date and temporary workaround;
- the fix, retest result, date and tester.
Prioritise barriers to essential services
Fix blockers in authentication, payments, forms, identity checks, submissions and information required to exercise rights before cosmetic issues. Consider frequency, severity, the number of users affected, the availability of an equivalent route and the cost and feasibility of remediation. Set service-level targets for urgent, high and routine defects so priorities do not depend on individual judgment each time.
Document exceptions and disproportionate burden
If a requirement cannot be met, record the evidence behind an exemption or disproportionate-burden decision, who approved it, its duration and the alternative access route. A decision should identify what users cannot do, why the chosen alternative is usable, and when the decision will be reviewed. Do not use “third-party limitation” as a permanent explanation without an owner and remediation plan.
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6. Publish an accessibility statement that helps people
Make it easy to find
Publish the statement as an HTML page linked prominently, normally from every page footer. Use plain English, a descriptive page title and a stable URL. A document-only statement is harder to update and less usable for people who need the information.
Include the required information
- The service’s compliance status: fully, partially or not compliant.
- The standard and evaluation method used, including the assessment date and the scope sampled.
- Known non-compliant areas, their user impact, why they remain, planned fixes and target dates.
- Any content or functionality excluded by law, exemption or disproportionate-burden reasoning.
- How a person can obtain inaccessible content in an alternative format or use an assisted route.
- A contact method for reporting an accessibility problem and the escalation or complaints route if the response is inadequate.
Review the statement after major changes and at least once a year. Update the compliance status when defects are fixed, new content types are added or a new evaluation changes the evidence. Keep an internal change record so the published date reflects a real review.
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Write requirements into the RFQ and statement of work
Specify WCAG 2.2 AA for the website or app, or EN 301 549 and applicable national rules for broader ICT. Define the exact product version, configuration, content responsibilities and supported environments. Ask bidders to explain how they will meet each requirement, not merely to tick a compliance box.
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Require accessibility conformance information for the exact version and configuration being offered, a list of known limitations, test methods, assistive technologies used and remediation commitments. Request sample reports and references to the supplier’s quality process, while reserving the right to run your own tests.
Score accessibility during selection
Include accessibility in the evaluation model with weighted criteria and a pass/fail floor for critical barriers. Use a scripted demonstration of keyboard navigation, focus, zoom, forms, errors and dynamic updates. Ask vendors to show how content authors will create accessible pages and how defects will be tracked.
Make the contract enforceable
- Define accessibility acceptance tests before payment or launch.
- Set remediation times, service levels and escalation for critical defects.
- Require cooperation with independent testing and access to test environments.
- Include accessibility in change control, release approval, renewal and termination decisions.
- Require regular reviews, updated conformance evidence and notice when a dependency changes.
Supplier claims are useful evidence to examine, but they do not replace testing the delivered service. The public body retains accountability even when design, hosting, development or support is contracted out.
8. Run the checklist through the service lifecycle
Before design and build
Identify users and legal scope, set the standard, include accessibility in personas and user stories, and design keyboard, focus, error and content behaviour before visual components are coded. Add accessibility criteria to the definition of done.
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Before launch
Complete the representative sample, automated scan, manual checks and user testing. Resolve blockers, approve any documented residual risk, prepare the statement and verify the reporting mailbox or form. Do not publish a statement that says “fully compliant” when critical journeys have not been tested.
After launch and during change
Run automated checks in continuous integration or content workflows where practical, but retain manual checks for interaction changes. Re-test after major releases, template changes, authentication or payment changes, new documents, vendor upgrades and browser or operating-system support changes. Conduct a periodic independent review for high-risk services.
When a problem is reported
- Acknowledge the report and capture the user’s task, device and assistive technology if they are willing to share them.
- Reproduce the issue, assess whether it blocks a core service and provide an accessible alternative immediately.
- Log the defect with an owner and due date, then communicate the expected next update.
- Test the fix with the original scenario and update the statement or workaround if the status changes.
Common checklist failures and how to correct them
| Failure | Why it fails | Correction |
|---|---|---|
| “The scanner found no errors.” | Automation cannot assess every interaction, user impact or assistive-technology experience. | Add keyboard, focus, zoom, reflow, forms, dynamic-state and user testing. |
| Testing only the home page | Templates, authentication, transactions and error states may use different code. | Sample by template, content type and user goal, with extra weight on high-risk journeys. |
| Leaving the statement until launch | Known failures, alternatives and contacts are not ready when users need them. | Draft it during assessment and publish it with verified status and dates. |
| Accepting a vendor certificate as proof | Evidence may describe another version, configuration or untested content. | Request version-specific evidence and perform acceptance testing on the delivered service. |
| “The supplier owns accessibility.” | Outsourcing does not remove the public body’s legal responsibility. | Keep an internal owner and put testing, remediation and reporting duties in the contract. |
| Recording issues without owners | Unassigned findings become permanent backlog items. | Assign severity, owner, due date, workaround and retest result for every defect. |
| Using an exception as a dead end | Users are left without an equivalent route. | Document the reasoning, provide an accessible alternative and set a review date. |
A practical first-review sequence
- Week 1: scope. Appoint the owner and lead, inventory services and suppliers, identify jurisdiction and applicable standards, and choose representative journeys.
- Week 2: baseline. Run automated scans, prepare keyboard and responsive test scripts, gather supported browser and device details, and schedule users or an independent auditor for complex services.
- Week 3: evidence. Execute manual and assistive-technology tests, capture reproducible defects, and classify blockers in transactions, authentication, forms and rights-related information.
- Week 4: action. Assign owners and dates, fix critical barriers, approve and document any residual risk, verify alternatives, and draft the accessibility statement from the actual findings.
- Before release and thereafter. Re-test fixes, obtain acceptance sign-off, publish the statement, monitor reports, and place the next annual review and change-triggered tests on the service calendar.
This sequence gives a public-service team an auditable trail from scope and standard to user evidence, remediation, procurement controls and public transparency.
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