Accessibility testing in the US: the DOJ rule, the WebAIM Million, and where testers start

Accessibility used to be a topic for a few specialists. In the US it is turning into a testing job with a legal backdrop: a federal rule for state and local government websites, long-standing ADA guidance for businesses, and a yearly study that keeps finding the same defects on almost every home page. Here is what those sources say and what an accessibility tester actually checks.

TL;DR

• The DOJ Title II rule: state and local governments must meet WCAG 2.1 Level AA for web content and mobile apps. Current deadlines: April 26, 2027 (populations of 50,000 or more) and April 26, 2028 (smaller).
• WebAIM Million 2026: 95.9% of one million home pages had detected WCAG 2 failures, 56.1 errors per page on average. Low contrast text came first (83.9%).
• Businesses: DOJ guidance says the ADA applies to the goods and services of public accommodations, web included, and names WCAG as helpful technical guidance.

What the DOJ rule says

On April 24, 2024, the Federal Register published the Department of Justice's final rule under Title II of the ADA, which covers state and local governments. It names WCAG 2.1 Level AA as the technical standard for web content and mobile apps.

The ADA.gov fact sheet currently lists two compliance dates: April 26, 2027 for governments with a population of 50,000 or more, and April 26, 2028 for smaller governments and special district governments. The larger group's date was extended by an interim final rule published on April 20, 2026. Dates can move, so check ADA.gov before you plan around one.

What matters for testers is the standard itself. A rule that points to WCAG 2.1 AA turns "is this site accessible?" into a list of success criteria that can be checked, page by page, and re-checked at every release.

What about private businesses?

The DOJ's web guidance, dated March 18, 2022, says that the ADA's requirements apply to all the goods, services, privileges or activities offered by public accommodations, including on the web. It names WCAG as an existing technical standard and describes it as helpful guidance for making web features accessible. The same page notes that it does not reflect the Title II rule of April 2024.

So for businesses there is guidance, not a Title II-style deadline. This is not legal advice, and whether a given website must meet a given standard is a question for a lawyer. WCAG is simply the common yardstick in both cases.

What the WebAIM Million finds

WebAIM runs automated checks on the home pages of one million websites every year. In the 2026 edition:

• 95.9% of home pages had detected WCAG 2 failures, with an average of 56.1 errors per page;
• low contrast text appeared on 83.9% of pages;
• missing alternative text for images on 53.1%, and missing form input labels on 51%;
• empty links on 46.3% and empty buttons on 30.6%.

Two cautions. These are failures an automated tool can detect on home pages, so they understate the real picture: many problems only show up when a person tries the page with a keyboard or a screen reader. And the study measures the web at large, not US sites specifically. I also looked for a reliable, recent count of accessibility testing jobs in the US and did not find one I could cite, so I am not quoting a number.

What an accessibility tester checks

• Keyboard use. Can every control be reached without a mouse, in a logical order, with a visible focus?
• Screen readers. Are headings, form labels, alternative text and error messages announced correctly?
• Contrast. Under WCAG 2.1 AA, regular text needs a contrast ratio of at least 4.5 to 1 against its background (3 to 1 for large text).
• Tools plus manual checks. An automated scan finds part of the defects; the rest needs hands-on testing.
• Reporting. A useful report names the criterion, the page, the severity and a fix the team can apply.

Notice how closely this list follows the WebAIM findings: contrast, missing labels, empty links and buttons, missing alternative text. The most common defects are also the most testable ones.

Ten minutes to find your first defect

Put the mouse aside and press Tab. If the focus disappears, jumps around, or lands on something you cannot activate with the keyboard, you have already found a defect. Then turn on a screen reader and listen to the same page. Ten minutes of this teaches more than a long checklist, and it is the habit a tester builds first. A written report turns it into something a developer can act on: where, which criterion, how to reproduce, how to fix.

If you want help turning checks like these into a plan for a whole product, ADC also offers software quality and testing consulting, which includes accessibility testing alongside test strategy, automation, performance and security.

The A11y Test specialisation

The "Accessibility Tester" specialisation is one of the QA specialisations on the 3-month tracks page. That page announces WCAG 2.1, screen readers and contrast; 399 hours over 3 months, 100% online; the next session in November; one-on-one mentoring, 6 months of platform access and 24 months of replays. It does not detail the programme beyond those topics. Exact dates, prerequisites and the language of the sessions are confirmed with an advisor, and ADC is a French-language training organisation, so ask before enrolling. No certification is promised for this specialisation.

Prices: €1,500 incl. VAT for individuals, a launch price payable in 1 to 4 interest-free instalments; €7,500 incl. VAT for companies. ADC is not currently eligible for French public funding such as CPF or France Travail, and it does not hold the Qualiopi certification that OPCO funding requires. No job or salary is guaranteed.

Over to you

When did you last run a full keyboard-only pass on your own product, and what was the first defect you found? Do you treat accessibility as a release gate in your team, or as a ticket someone picks up when time allows?

Sources: ADA.gov: Fact Sheet, New Rule on the Accessibility of Web Content and Mobile Apps (Title II rule published April 24, 2024; interim final rule April 20, 2026; accessed October 19, 2026) · ADA.gov: Guidance on Web Accessibility and the ADA (March 18, 2022) · WebAIM: The WebAIM Million, 2026 edition (accessed October 19, 2026) · W3C: Web Content Accessibility Guidelines (WCAG) 2.1

Originally published on AutomationDataCamp. Written with AI assistance. Every figure comes from the sources listed above, as cited in the original article (checked on 19 October 2026). This is not legal advice.

AutomationDataCamp is an online software testing academy (Playwright, API testing, CI, AI-assisted testing, ISTQB prep). More on our site.