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Preparation for the update to ADA’s Title II series: Conduct an accessibility self-audit

Learn how to check your websites and mobile apps for accessibility issues

6/25/2025 12:01:34 PM

Illustration showing a website on a laptop screen being examined with a magnifying glass, representing an accessibility self-audit of digital content for accessibility issues.

Content contributors: MNIT Office of Accessibility

The US Department of Justice (DOJ) added digital accessibility requirements to the Americans with Disabilities Act (ADA) for Minnesota’s state and local government entities. This new rule puts into writing practices that the DOJ has been following for decades. In the article, Update to ADA’s Title II,” we outlined what the new rule means for government staff and how to begin the accessibility journey. Now we kick off a series of articles to dig deeper into preparation and implementation resources for state and local governments as they work toward compliance. 

If your organization is new to digital accessibility, this article is a great starting point. If you've recently begun your accessibility efforts, it can help you prioritize your next steps.

Today’s article focuses on how your team can conduct a self-audit of your websites and mobile applications (apps)  to identify accessibility gaps—and take meaningful action toward compliance.

Begin the process

First, let’s understand the scope of this self-audit. Review this checklist to set up your self-audit expectations: 

Know the accessibility standards and which apply to your agency

  • Title II of the ADA: The updated regulations (official rule) have specific requirements to ensure web content and mobile apps from state and local government entities are accessible to people with disabilities by April 24, 2026*. The ADA provides a helpful fact sheet that everyone should read. The requirement includes:
    • There are exceptions. The fact sheet outlines these.
    • *Note: This deadline is for those entities with a population of 50,000 or more. For those entities with less, or are considered a special district government, the deadline is April 26, 2027. 
  • Revised Section 508 of the Rehabilitation Act: Governs how federal agencies and their suppliers and contractors must support digital accessibility. It includes WCAG 2.0 in addition to standards for software and hardware, among other required criteria. 
    • The State of Minnesota’s executive branch includes revised Section 508 requirements in our state’s digital accessibility standard.
  • European Accessibility Act: Applies to those doing business in the European Union (EU). It is a directive that aims to improve the functioning of the internal market for accessible products and services.

Who’s the team? Identify people who can devote the time to learn about digital accessibility standards and testing, and who can advocate for your agency addressing the gaps and issues identified. They’ll also likely be the people who implement the fixes or educate the people who will.

  • Be sure to include people with disabilities, especially from the user experience standpoint. They can provide insight into why the gaps and issues cause problems and put the agency at risk.

Identify your agency’s digital content: Specifically, to the Title II update, which includes websites, intranets, extranets, and mobile apps.

  • Determine origin of the content: Was it provided by a third-party vendor or was it developed in house?
    • If a third-party vendor created the digital content, and it exists on your website or mobile application, the ADA Title II update pertains to this content. A first step in the self-audit is to acquire the vendor’s Accessibility Conformance Report (ACR). This is a completed version of the Information Technology Industry Council’s Voluntary Product Accessibility Template (VPAT). We cover this in the next section.
    • For content developed by your agency, you will need to perform the VPAT work. We cover this in the next section.
  • Understand how many pages exist. This includes public pages and internal pages. Employees have an equal right to accessible digital content as your public users.
  • Identify scope of templates. If all websites use the same template, your task is far simpler than if every site uses different templates or development platforms.
  • Prepare to document for each type of page and template. This will be critical in tracking results from the self-audit. We cover this in the next section.

Understand your user’s journey: How do they interact with your digital content?

  • Identify specific paths users take to complete tasks.
  • Learn the most visited pages and views/downloads (e.g., PDFs, videos, forms).
  • Consider learning how users get to your site.

Set realistic goals: If this is your first time conducting an accessibility audit, expect it to be a significant effort. We recommend starting with a high-level testing approach. The steps outlined above will help your team better understand the scope of your digital content.

Set clear goals to help you focus on the highest-priority items and understand where your agency stands on accessible content. These goals will also help guide your remediation efforts.

One helpful method is using SMART goals—Specific, Measurable, Achievable, Relevant, and Time-bound. At the State of Minnesota, we use this approach to help employees create clear and actionable objectives. Learn more from this Ultimate Guide to S.M.A.R.T. Goals article.

Start the audit

With a team in place, clear and measurable goals set, and an understanding of what technical standards your agency’s website and mobile app content needs to meet, let’s get to auditing. 

Third party-created content

As mentioned, if the content on your website or mobile app was created by a third party, it needs to meet accessibility standards. Vendors should provide you with an ACR. And your team will need to learn how to review these reports to understand if compliance requirements are met, and the validity of its content.

What to do if the vendor doesn’t have an ACR?

Ask the vendor if they included any accessibility practices in creating the product. The depth and quality of their answer can give you an idea of your next steps.

Then either:

  • Assume it is not accessible and expect to add it to your agency’s remediation plan.
  • Perform your own high-level test to understand what issues exist and help set priorities in your overall remediation plan.

In-house-created content

Should you hire a vendor?

Because the scope of the audit will vary for every team, your agency may decide to handle the audit entirely on its own. However, if the scope is large and feels overwhelming, your agency may bring in a third-party vendor to assist. Your team can still assist in the audit process, but the vendor can help bring in tools and expertise.

When selecting an accessibility audit vendor, keep in mind :

  • What type of assistance do you need? For example, do you want a quick, high-level analysis that can help you benchmark your sites and set priorities? Or are you looking for a more in-depth analysis that provides you with a specific remediation plan for each site?
    • Automated scans will identify 30%-40% of the issues with many potential false negatives and positives that need to be validated. These are valuable as a benchmarking tool, but a more extensive evaluation requires manual testing.
    • Consider using internal resources to conduct high-level analysis to set priorities then have vendors focus on the most high-risk and/or more problematic sites.
  • Avoid quick fixes. Some vendors may claim that their tools can scan and fix your sites’ accessibility issues. Such fixes can cause more issues than they solve
  • Seek experience. Accessibility testing used to be a niche service performed by specialized vendors. As the need has expanded, general consulting firms have added that service to their bench. Ask about teams with IAAP-certified members and documented experience with accessibility audits.

Internal operations

Whether or not you hire a vendor, your team needs to learn more about accessibility. Here are a few helpful resources to use when testing websites and mobile apps or evaluating your vendor’s reports:

Get training

Use tools: Several tools exist to automatically scan and check websites and documents for accessibility issues. It’s also essential to use manual tools, like a keyboard, color contrast checkers, and browser zoom.

Start with a high-level analysis: This will help you determine whether a deeper dive is needed. See our tech tip for more information on a high-level accessibility testing template. 

What about Artificial Intelligence? It helped with outlining this series. And we know agencies are beginning to implement its use in identifying accessibility issues and fixing or adding in accessibility. Make sure it is ethical, and the work is reviewed by a human. The state’s Minnesota IT Services outlines their Public Artificial Intelligence Services Security Standard to help aid employees in the use of AI.

Document findings

Make sure you track everything you do during the audit (including testing tools used, WCAG criteria tested for, etc.) and where you complete testing (specific web page names or locations of mobile app steps or documents). 

A final report of this review data needs to be formatted for the intended audience (who you are reporting to) to understand your agency’s current digital accessibility status in terms of compliance and what that means in terms of risk and remediation (i.e., does any content cause barriers for assistive technology users or users with disabilities, which means they cannot access that content or complete a critical task). Review our tech tip for a template to create this document.

Next Steps

You will need to report your findings and determine how your agency will address the barriers identified. We will cover how to handle these critical steps in future articles.

Future articles in this series

  • Strategize: Plan and Prioritize: In the next article in this series, we’ll cover how to understand your audit results, what actions to take next, and how to communicate your findings to leadership and other key partners.
  • Implementation: Begin to tackle high-priority issues. Determine who will handle the work. Set timelines and include retesting throughout the process.
  • Make it ongoing: Build accessibility into your agency’s workflow from the beginning
  • Recap & final resource guide: Gather all resources into one place, including links to each article in the series.

Resources

A list of resources related to this first part.

Regulations & Conformance

Training

Office of Accessibility

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