Accessibility Testing With Disabled Users

This guide is not legal advice

This guide summarizes what the cited sources say. It does not tell you what the law requires of your organization. For that, consult a qualified attorney.

Why conformance checks are not enough

The W3C's Web Accessibility Initiative publishes guidance on involving users in evaluating accessibility. It states that testing with disabled and older people "identifies usability issues that are not discovered by conformance evaluation alone" ¹. Its recommendation is direct: "Combine user involvement with evaluating conformance to WCAG."

Consider a long form where every field has a label, so it passes the relevant success criteria. A screen reader user may still find it exhausting if errors are announced only after submission, if the error summary does not link to the fields, or if the form times out while they are working. Those are the kinds of problems that sessions reveal.

What WCAG 2.2 changed

WCAG 2.2 became a W3C Recommendation on October 5, 2023. It adds nine success criteria to WCAG 2.1 and removes one, 4.1.1 Parsing ².

Several of these affect common website patterns. Sticky headers and cookie banners can hide focused elements, which Focus Not Obscured addresses. Sliders and drag-to-reorder lists need a non-dragging alternative under Dragging Movements. Small icons and tightly packed links run into Target Size (Minimum), which sets a minimum target of 24 by 24 CSS pixels, with exceptions for spacing, equivalent controls, inline targets, user agent controls and essential cases ³. Login steps that rely on remembering or transcribing a code are covered by Accessible Authentication.

What the Department of Justice says

In March 2022, the Department of Justice issued guidance on web accessibility under the Americans with Disabilities Act ⁴. The press release announcing it is now archived content on the department's site. In the guidance's words, Title III bars discrimination "against people with disabilities by businesses open to the public" ⁵. It explains that businesses have flexibility in how they make their online content accessible, and that "Existing technical standards provide helpful guidance", naming the Web Content Accessibility Guidelines and the Section 508 Standards as examples.

The guidance does not certify any testing method as sufficient, and it does not say that passing an automated scan satisfies the ADA. Read the guidance itself and discuss your obligations with counsel.

State and local government sites under Title II

Title II of the ADA covers state and local governments rather than private businesses, and it now has a specific web rule. The Department of Justice adopted web content and mobile app accessibility requirements for those public entities on April 24, 2024. An interim final rule effective April 20, 2026 extended the compliance dates by about a year: to April 26, 2027 for entities serving a population of 50,000 or more, and to April 26, 2028 for smaller entities and special district governments ⁶. If you build or research sites for public agencies, check the current rule text in the Federal Register; this summary is not legal advice.

Planning sessions with assistive technology users

Decide what to cover

Choose two to four core tasks, such as finding a product, completing a form and contacting support. Accessibility sessions take longer than standard sessions, so fewer tasks fit.

Recruit for a range of needs

Include people who use different assistive technologies: screen readers on desktop and phone, screen magnification, voice control, switch access and keyboard-only navigation. Include people with cognitive disabilities and low vision who may use built-in device settings rather than specialist tools. Recruit through specialist panels and disability organizations, and allow extra time.

Let participants use their own setup

Assistive technology is highly personal. People configure speech rate, magnification level, shortcuts and verbosity to suit themselves. Remote sessions on the participant's own device show how your site works with their real setup.

Make the study itself accessible

Send consent forms and instructions in accessible formats ahead of time. Choose a video call tool the participant already uses. Offer breaks. Ask in advance whether the participant needs anything to take part comfortably.

Pay fairly

Participants are sharing expertise as well as time. Plan incentives accordingly, and follow the tracking steps in our guide to consent and incentives.

Moderating accessibility sessions

Screen reader users often listen at high speech rates, so ask the participant to slow it down if you cannot follow, or ask them to describe what they hear. Allow longer silences before prompting. Follow the same neutral questioning rules as any usability test, as described in our task writing guide. If a participant cannot proceed, note exactly where and why, then move on without making them feel responsible.

Turning findings into fixes

For each barrier, record what happened, which assistive technology was involved, the relevant WCAG success criterion if one applies and a specific fix. Some barriers will not map to any success criterion; record them anyway, since they still stop people. Prioritize barriers that block core tasks. Fix them in the site's own code and content, then retest with participants who met the barrier when possible.

A note on overlays

Third-party overlay widgets that promise automatic accessibility fixes do not replace accessible code and content. Barriers should be fixed at the source, and fixes checked with real users.