How Manual Audits for Website Accessibility (ADA Compliance) Work

As an independent consultant, it’s important to be thorough. (source: Kris Rivenburgh)

A website accessibility audit (sometimes referred to as ADA Website Compliance audit) is performed by an accessibility professional(s) 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 containing an assessment of your asset along with issues that need to be addressed.

(Note: Prices are below)

Automated accessibility scans (sometimes called “checkers”) are a very useful tool to get a feel for your website’s overall accessibility level, and they are a great help when conducting a manual audit but they can only flag about 1/4 of accessibility issues in WCAG 2.1 AA.

With a manual audit, it’s highly desirable to hire an independent expert or company that specializes in web accessibility and most likely not someone in-house (auditing your own website is problematic both technically and legally).

Of course, there’s still benefit in a self-audit but optimally your digital accessibility audit comes from a third party.

(Also, don’t use a marketing agency for an accessibility audit.)

Audit Process

Here’s how I approach audits:

  1. Ask you for the URL / screen of every page you want audited

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, say you own an e-commerce sporting goods website. Rather than examining each individual product page, an auditor can look at one product page and identify the issues that would potentially need to be addressed on every other one.

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.

Another consideration is digital assets besides websites. For example, mobile apps will have different screens but not different URLs.

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: As of 2021, 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. WCAG 2.2 AA is expected to be released in the Summer of 2021 so soon conformance with 2.2 AA will be best practice.)

This is the most important, time-consuming part of a manual accessibility audit that nobody sees because it doesn’t show up in the final reports.

What’s happening here is an expert is diligently checking your website against the 38 success criteria that comprise WCAG 2.0 AA (or 50 success criteria, if they’re checking against 2.1 AA).

Some of this involves examining code (e.g. are forms properly labeled).

Another part is simply looking through the different pages of a website (e.g. is the layout consistent and predictable).

And then there’s actually testing the website to make sure everything works as it should (e.g. are the content and functions of a website fully accessible 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. I personally do because I believe it makes it easier for the client / client’s developer to go down the list and implement the changes.

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 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.

I like to use a combination of three automated scans to make sure my audits are as rock solid as possible and I have caught everything that an automated scan might catch.

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 write technical jargon that needs a translation or a long weekend to trudge through.

How much does a manual audit cost?

$2,500 to $12,000 is a good price range that’s going to capture the cost to audit most websites.

If you start in the middle at $6,600, 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.

WCAG 2.1 AA Audits

I highly recommend auditing your website under the WCAG 2.1 AA standard. There’s more work and testing involved (there are 12 additional success criteria) so you can expect a 2.1 AA audit to cost slightly more but most digital accessibility companies offer 2.1 AA by as part of their base pricing anyway.

There’s very little conceivable downside to a 2.1 audit so I highly recommend going for it.

2.0 is the current WCAG version courts in the United States reference but more and more demand letters are referencing 2.1 and 2.1 is where all momentum is so it’s best to conform to WCAG 2.1 AA.

You’ll still be in great shape with 2.0 but 2.1 conformance addresses a handful of key mobile accessibility issues you really want to take care of.

Read more on the difference between WCAG 2.0 and 2.1.

The W3C Web Accessibility Initiative (WAI) was expected to officially release the WCAG 2.2 in November 2020 but, again, this has been delayed until mid 2021.

Note 1: More simple websites might cost $1,500 or less if there isn’t a lot of work to be done. Think of your classic “web presence” website that is static and mostly just information.

Note 2: Many established web accessibility company audits start at $5,000 at a minimum.

Note 3: You may want a follow-up, post-remediation audit (once the original issues have been addressed). These audits are easier to do since the website, app, etc. will naturally have far fewer inaccessible elements 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 performed by the same company.

Note 4: Beware of the super cheap audit. I had a client recently contact me after they had paid $1,500 for someone to audit their e-commerce website. The audit basically amounted to an aggregated report of three different free automatic scans. The report looked nice but the client could have run those scans themselves.

Testing vs. Reviews vs. Scans

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


Testing is best thought of as when users with disabilities test a website to make sure it is robust (i.e, user testing).

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

A good audit will include already include testing for usability but testing typically refers to feedback from someone with a disability.


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 catch about 1/4 of the issues on your website. Most are free (WAVE and AXE are two good ones). Some are paid (Tenon is a good premium scan).

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 catch a fraction of the accessibility issues on your website. There are many important issues (that do find their way to ADA compliance lawsuits) that cannot be caught be a scan.

The efficient part of having access to a paid scan is you can scan an entire website vs. free scans only allow you to scan one page at a time.


Reputable digital accessibility companies (e.g., eSSENTIAL Accessibility, Deque, Level Access, The Paciello Group, etc.) may offer an audit as part of a larger service.

(Disclosure: I am the CAO & CLO at eSSENTIAL.)

For example, you purchase an accessibility plan that includes tech support, legal support, documentation, full scan access, and user testing.

Read more on what user testing entails.

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

In a nutshell

Here are the key takeaways from this article:

  • you need a manual audit regardless of whether you run an accessibility scan
  • It’s best to get a WCAG 2.1 AA audit as 2.1 is the latest version of WCAG
  • you can expect to pay between $2,500 and $12,000
  • cost depends on how complex your website is, how many unique page layouts there are, and your website’s current state of accessibility
  • Make sure to get an audit from a reputable provider




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Kris Rivenburgh

Kris Rivenburgh

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