Why an audit at the end is not enough  

On Friday, I was invited into a meeting with a design agency that was considering bidding for a substantial website project.

The tender required the completed website to undergo an independent audit before launch.

The intention behind that requirement was entirely understandable.

The organisation wanted proof that a good job had been done. It wanted independent assurance that the finished website met WCAG 2.2 AA and could be used by disabled people.

That sounds responsible.

Unfortunately, the process described in the tender made it much less likely that a good job would actually be done.

The proposed approach was broadly:

1. Design and develop the website.
2. Commission an independent audit.
3. Correct the accessibility problems identified.
4. Retest the website.
5. Launch it.

The audit was intended to prove the website had been developed properly.

The problem is that, without an accessibility expert involved during the project, there was no strong reason to believe it would have been developed properly in the first place.

The audit would not simply confirm a successful outcome. It would probably uncover problems that had already been designed, developed and repeated throughout the website.

Someone would then have to pay to correct them.

An audit assesses what has already been built

A good accessibility audit is extremely valuable.

It identifies the barriers disabled people encounter when using a website. It should include manual technical testing and testing by disabled people using the assistive technologies they rely upon.

An audit can establish:

• which accessibility barriers are present
• which WCAG success criteria have not been met
• which users are affected
• how serious the problems are
• what remedial work is required
• whether previous accessibility claims are supported by evidence

That is essential for an existing website where the organisation needs to understand its current position.

It is also useful as an additional layer of independent assurance for a new website, provided the project has sufficient budget.

However, an audit cannot influence decisions that have already been made.

It cannot stop an inaccessible navigation system from being selected several months earlier.

It cannot prevent an unsuitable third-party component from being incorporated into the design.

It cannot change the information architecture before hundreds of pages have been migrated into it.

It cannot advise the design team before colour combinations, form patterns, menus, maps, filters and interactive components have been approved.

It can only assess the finished result.

If that result is inaccessible, the audit has still done its job perfectly.

The website has not.

Independent verification is not the same as accessible delivery

The distinction matters.

The organisation commissioning the website may believe that requiring an independent audit guarantees that the website will be accessible.

It does not.

It guarantees that somebody independent will assess the website.

Those are not the same thing.

The auditor might confirm that the website has been built to an excellent standard.

They might also produce a long report containing serious failures that must be corrected before launch.

The existence of the audit does not determine which outcome occurs.

The quality of the decisions made throughout discovery, design, development, content creation and testing determines that.

An independent audit may verify good work.

It does not create good work.

Accessibility expertise must begin before design

The most reliable way to produce an accessible website is to involve an accessibility expert from the beginning.

That involvement can start during discovery, before the first wireframe has been produced.

At that stage, we can consider:

• who will use the website
• what those people need to accomplish
• the barriers present on the existing website
• the needs of keyboard users
• the needs of screen-reader users
• the needs of voice-recognition users
• the readability and structure of the content
• the accessibility of third-party services
• multilingual and right-to-left content
• how internal editors will manage the website after launch

Potential problems can then be addressed before they become embedded in the project.

Wireframes can be reviewed before designs are approved.

Designs can be reviewed before developers begin building them.

Individual components can be tested while they are being developed.

Forms, menus, modal windows, search tools, maps and filters can be assessed separately before they are repeated across the website.

The purpose is not to demand perfection at every stage.

Website development does not work like that.

The purpose is to identify issues while they are still relatively small, contained and affordable to correct.

The cost can be broadly comparable

One of the most important points is that involving me throughout a project does not necessarily cost substantially more than commissioning me to audit the finished website.

In my experience, the cost is often broadly comparable.

The difference is how that time and expertise are used.

During a retrospective audit, I spend my time identifying and documenting problems that have already been created.

When I am involved throughout the project, I spend that time helping the team avoid those problems, reviewing work as it develops and testing components before they become established across the platform.

The organisation is still paying for accessibility expertise.

However, instead of paying to discover that the work has gone wrong, it is paying to help ensure the work is done properly.

That can save an enormous amount of money.

A component corrected during development may take an hour or 2 to adjust.

The same component discovered during a final audit might already appear across dozens of templates and hundreds of pages. Correcting it can then require redevelopment, content changes, regression testing and further accessibility testing.

The accessibility specialist may cost roughly the same.

The remedial work certainly does not.

British Wireless for the Blind

This is the approach I used when working on the website for British Wireless for the Blind.

The agency recognised that it needed specialist accessibility expertise as part of the development process.

I did not simply arrive at the end, inspect the completed website and hand over a list of everything that was wrong.

I was involved while the website was being developed.

That allowed me to review the work, explain potential barriers and help the team make better decisions while changes were still relatively easy to make.

There were still issues to resolve.

There will almost always be issues during a website project.

The important difference was that they were addressed as part of the development process. They did not remain hidden until immediately before launch.

The finished website reached a much higher standard because accessibility was treated as part of the work, rather than as an examination waiting at the end.

What does the final audit actually prove?

A final independent audit proves that an independent specialist has assessed the finished website and recorded their findings.

It does not automatically prove that the website is compliant.

The findings might demonstrate excellent conformance.

They might demonstrate partial conformance.

They might demonstrate serious and widespread accessibility failures.

The audit report is evidence.

What that evidence says depends upon the quality of the website being tested.

This is why an organisation should not begin with the assumption that the independent audit will provide a reassuring certificate at the end.

Website audits are not certificates.

They are investigations.

They report what is actually there.

When accessibility has been embedded throughout the project, an independent audit should largely confirm that the approach has worked, while perhaps identifying a smaller number of remaining issues.

When accessibility has not been embedded, the audit can become the beginning of an expensive remedial project.

The statement attests to the position reached

The public document that records the website’s accessibility position is its accessibility statement.

A properly prepared accessibility statement should explain:

• whether the website is compliant, partially compliant or non-compliant
• which accessibility standard has been applied
• how the website was tested
• any known accessibility limitations
• any inaccessible third-party content
• how users can report problems
• what the organisation will do when an issue is reported

The statement must be accurate and supported by evidence.

It should not claim compliance merely because an automated testing tool has produced a high score.

It should not claim compliance because the website has an accessibility toolbar or overlay.

It should not claim compliance because an audit has taken place.

It should state the position established through proper testing and professional assessment.

When I have been involved throughout the project, I can test the finished website, evaluate any remaining limitations and prepare an accessibility statement that attests to the genuine conformance position.

The statement does not make the website accessible.

It publicly records what has been achieved through the work completed during the project.

There may not be enough budget for both

Where a project has sufficient funding, the ideal arrangement can include:

• accessibility expertise throughout discovery, design and development
• testing during the build
• testing by disabled people
• staff training
• a properly prepared accessibility statement
• a separate independent pre-launch audit

That gives the organisation accessible delivery and an additional layer of independent assurance.

There is nothing wrong with that model.

The difficulty arises when the budget is too small to fund all of it.

The tender discussed on Friday had a total budget of £30,000 including VAT. It covered the consolidation of several websites, research, design, development, migration, multilingual functionality, an interactive map and directory, testing, training, penetration testing, an independent website audit and remediation.

The agency correctly concluded that the numbers did not work.

It could not fund the development, the specialist work, the independent testing and any significant remediation without somebody absorbing a considerable amount of unpaid work.

In that situation, the organisation must make an informed choice.

It can spend the accessibility budget commissioning an expert after the website has been completed, then use whatever remains to correct the problems discovered.

Alternatively, it can involve the expert from the outset, allowing accessibility to be built into the website and reducing the need for extensive remedial work.

If it requires both embedded expertise and separate independent verification, it must allocate enough money for both.

What it cannot reasonably do is specify both within an inadequate budget and assume that the supplier will somehow absorb the difference.

Proof should be the result of good delivery

Wanting evidence that a website has been built properly is entirely reasonable.

Public bodies, charities and commercial organisations should expect suppliers to demonstrate the accessibility of the work they deliver.

However, the evidence needs to follow a process designed to produce a good result.

It should not be used as a substitute for that process.

An audit commissioned at the end may show that a good job has been done.

It may also prove that the website was not built accessibly and now requires substantial remedial work.

The best way to make the first outcome more likely is to involve accessibility expertise before the website is designed and to retain that involvement throughout development and testing.

That is how we approach accessible web design.

Accessibility is considered during planning, design, development, component testing, content creation and launch.

The completed website is then tested properly, with disabled people involved in the process.

The accessibility statement records the genuine conformance position.

An independent website audit can provide additional verification when the budget supports it.

However, it should verify that accessibility has been delivered properly.

It should not be the first point at which anybody discovers whether it has.

Related posts  

Why Mobile Accessibility Matters More Than Desktop In 2025

Day 44 – Agencies: You Need To Protect Your Clients And Yourselves

Just Start Iona!

What will a website web audit give me?