Level Access

Author: Level Access

Conforming to the Web Content Accessibility Guidelines (WCAG) Level A and AA is required by laws including Title II of the Americans with Disabilities Act (ADA) and Section 508 of the Rehabilitation Act of 1973—and it’s a best practice for compliance with many others. However, achieving 100% WCAG conformance consistently across complex and constantly updated digital content can be a challenge.

Websites are dynamic, and every change can introduce new violations. Additionally, updates to assistive technologies and browsers can make it difficult for teams to catch all accessibility bugs at a given time. So, how can you maximize accessibility and minimize legal risks if full conformance to WCAG isn’t achievable today?

The answer is to strive for substantial conformance. In this article, we’ll explore what substantial conformance means, and how to work toward this goal to maintain a high level of accessibility and usability by people with disabilities.

Is it possible to be 100% WCAG conformant?

WCAG conformance is measured by page, meaning that each individual page within a website must meet relevant success criteria for a site to be considered conformant at a specific level (A, AA, or AAA). While 100% conformance is achievable in theory, many organizations struggle to maintain full conformance across every webpage. Most websites are in a state of flux, and content updates, design changes, and third-party integrations can all introduce new accessibility barriers. External factors—such as browser updates and changes in assistive technologies—can also influence website accessibility.

These continual shifts can make it difficult for organizations to consistently guarantee 100% conformance to WCAG. This does not mean that accessibility should be disregarded; instead, organizations should focus on achieving substantial conformance.

What is substantial conformance to WCAG?

Substantial conformance means that a website has no critical accessibility barriers preventing users with disabilities from accessing content equitably, privately, and independently. While minor issues may still exist, they should not create significant obstacles for users.

Importantly, substantial conformance is not an arbitrary term. Our definition of substantial conformance is based on the limited exceptions in ADA Title II requirements and our more than 25 years of experience helping organizations achieve accessibility compliance.

Here are some factors to consider when trying to determine whether your website has reached substantial conformance:

  • Regular automated and manual testing: Consistent testing, using both automated and manual methods, is critical to detect new bugs introduced by content changes or external factors. Organizations should monitor site accessibility through automated scans at least monthly, and obtain manual reviews—based on a representative sample of pages—at least annually, or after significant updates.
  • Consistently high accessibility scores: An automatic monitoring health score of at least 80% should be maintained across all digital properties where applicable. Accessibility scores are calculated by monitoring tools, like those in the Level Access Platform, and are based on the number and severity of accessibility issues in a digital experience.
  • No verified critical issues: Any accessibility issues classified as critical—those confirmed by a human tester as major barriers for users with disabilities—must be addressed.
  • A clear resolution plan for limited high-severity issues: While minor and some high-severity issues may exist, there must be documented efforts or a roadmap in place to resolve them.
  • Barrier-free core user flows: Essential website interactions—like completing a purchase—must be fully accessible, particularly for users of assistive technologies.
  • Documented processes for sustaining accessibility: Organizations should have policies and procedures in place to prevent the introduction of new accessibility barriers.
  • Compliance with legal requirements: Organizations covered by certain accessibility regulations may need to meet specific compliance requirements. For example, the Accessibility for Ontarians with Disabilities Act (AODA) mandates that organizations have an active accessibility policy and a multi-year accessibility plan.

How do I ensure that my website achieves substantial conformance?

Achieving substantial conformance isn’t a one-time project—it’s a process that requires a sustained commitment to accessibility. However, with the right approach, it’s entirely within reach. Use the following best practices to make meaningful progress toward your accessibility and compliance goals, even if 100% WCAG conformance is challenging.

1. Establish a regular cadence for accessibility testing.

Testing accessibility on a consistent basis is a pillar of compliance. Implement ongoing monitoring tools to perform automated scans for common issues at regulatory scheduled intervals, and engage experts, including people with disabilities, to perform manual testing for more comprehensive insight.

2. Address critical and high-severity issues promptly.

Any issues that create barriers for users should be prioritized and resolved as quickly as possible. Track your progress in addressing these issues and ensure that solutions are sustainable.

3. Maintain a roadmap for improvements.

Ensure that unresolved issues are scheduled for remediation. Document your plans in internal policies and external accessibility statements. Transparent communication about accessibility within your organization builds accountability for teams. Externally, it fosters trust among users and demonstrates a commitment to continuous improvement.

4. Integrate accessibility into design and development processes.

Embed accessibility into the digital experience creation life cycle to prevent new barriers from emerging. Implement role-specific accessibility training for designers, developers, and content authors, and use tools like Figma plugins and accessibility software development kits (SDKs) to proactively check the accessibility of new content before it’s live.

5. Engage with users with disabilities.

Provide a mechanism for users with disabilities to share feedback on the accessibility of your site and promptly respond to complaints. Involving people with disabilities, including those who rely on assistive technologies, in the design, development, and testing of new content is a best practice to ensure that your site is usable for everyone.

6. Keep up with accessibility standards and legal requirements.

WCAG standards and legal requirements evolve over time. Staying informed about these updates is essential for continued compliance.

Substantial conformance: A practical approach to accessibility

While achieving 100% WCAG conformance may not be feasible all the time, substantial conformance is a practical starting point for any organization. By implementing regular automated and manual testing, proactively embedding accessibility in experience creation, and committing to continuous improvement, you can meaningfully reduce legal risks and improve user experience.

A trusted, third-party accessibility expert will equip your organization with the technology and guidance needed to efficiently reach substantial conformance and sustain accessibility over time. With more than 25 years of experience, Level Access has supported thousands of businesses, institutions, and non-profits to conform with WCAG and comply with legal requirements. To discover how our solutions can streamline and accelerate your accessibility journey, request a demo today.

Frequently asked questions

Is it possible to achieve 100% WCAG conformance?

Achieving 100% WCAG conformance all the time can be challenging due to frequent website updates, third-party content, and evolving assistive technologies. When achieving 100% conformance is not possible or practical, organizations should focus on substantial conformance—ensuring that no critical barriers prevent users with disabilities from accessing content equitably. Regular testing, monitoring, and a commitment to accessibility improvements will help maintain a high level of conformance.

Not all accessibility issues are equally impactful. While critical barriers that prevent users from accessing content must be resolved promptly, minor issues that do not create significant usability problems may allow for more flexibility in remediation timelines. Organizations should prioritize fixing high-severity issues while maintaining a clear roadmap for continuous accessibility improvements.

Maintaining accessibility requires ongoing efforts, including regular automated monitoring and manual testing. Embedding accessibility into the development process, engaging with users with disabilities, and staying informed about evolving WCAG standards and legal requirements will help ensure long-term accessibility and compliance.

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