What testing with disabled people finds that an audit doesn't
Why a page can pass WCAG and still be hard to use, and how to test real tasks with disabled people at each stage of a project, recruited across groups and paid fairly.
In short: An audit checks pages against WCAG's success criteria; a usability test watches disabled people try to finish real tasks, and finds what passes and still gets in their way. W3C advises doing both: testing with users can't show that a site conforms, and conformance alone doesn't show that people can use it.
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When you need this
A ticketing site's checkout was tested last month, and the views tested met WCAG 2.2 at level AA. Since then, the support inbox has had emails from customers who gave up. One, who uses a screen reader, wrote that it took a quarter of an hour to choose two seats. Another couldn't work out from the terms whether a ticket could be refunded.
The team is about to redesign seat selection. Before it does, it wants to know what these customers met, which an audit didn't report, and how to find out before the new design ships rather than from the inbox afterwards.
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What each kind of test answers
The two tests ask different questions, and neither answers the other's:
| Conformance testing | Usability testing | |
|---|---|---|
| The question | Does each page meet each success criterion at the target level? | Can these people finish these tasks, and where do they struggle? |
| Who does it | A tester following a method, as in testing a whole site against WCAG, and standing behind the result | People with disabilities, and older people where they are part of the audience, with a facilitator watching |
| What it records | Pass or fail, for each criterion on each page | Tasks finished, errors, where people slow down or give up, how they feel |
| What it can't show | Whether real people can use the site | Whether the site conforms, or how people outside the study would fare |
W3C's page on involving users in evaluation says that evaluating with disabled and older users "identifies usability issues that are not discovered by conformance evaluation alone", and also that user involvement "alone cannot determine if a website is accessible". It advises combining the two. WCAG-EM, W3C's method for conformance testing, doesn't require testing with users, but strongly recommends involving people with a wide range of abilities.
A usability test aimed at accessibility runs differently from a general one. W3C notes that it usually uses thinking aloud with more facilitator involvement, collects data on errors caused by accessibility barriers rather than on time taken or satisfaction, and puts its tasks where barriers are suspected. It also tends to turn up problems that affect every user, disabled or not.
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Pages that pass and are still hard to use
WCAG 2.2 says in its introduction that its guidelines "are not able to address the needs of people with all types, degrees, and combinations of disability", and that even content conforming at AAA won't be accessible to all of them, "particularly in the cognitive, language, and learning areas". These are things people meet on pages that can pass at AA:
| What people meet | Why the page can still pass | Where it is covered |
|---|---|---|
| 120 seats on a seat map, each a button, so dozens of Tab presses to get past it | No criterion limits the number of Tab stops. 2.4.1 Bypass Blocks asks only for a way past blocks repeated on many pages | Arrow keys inside a widget: roving tabindex or aria-activedescendant, one Tab stop for the whole widget |
| A 300-word description of a venue photo, read in full before the seat list | 1.1.1 asks for a text alternative that serves the equivalent purpose, and sets no length. Technique G94 advises one that is "brief but as informative as possible" | |
| A Help link in the same place on every page, leading to a help centre front page that doesn't answer the question | 3.2.6 Consistent Help asks for help to come in the same order on every page, not for it to answer anything | Help links that move from page to page |
| A refund rule inside a paragraph of legal phrasing | 3.1.5 Reading Level is level AAA, above an AA target | Terms and policies with no plain-language summary |
| An insurance word, such as excess, with no definition | 3.1.3 Unusual Words is level AAA too | Jargon and unusual words with no definition |
W3C's answer to the gap is supplemental guidance: "additional ways to improve accessibility, not required to meet WCAG". Its cognitive accessibility guidance comes from the Working Group Note Making Content Usable for People with Cognitive and Learning Disabilities (29 April 2021), and is grouped under eight objectives:
- Help users understand what things are and how to use them
- Help users find what they need
- Use clear and understandable content
- Help users avoid mistakes and know how to correct them
- Help users focus
- Ensure processes do not rely on memory
- Provide help and support
- Support adaptation and personalization
The Note says plainly that following it "is not required for conformance to WCAG", and that usability testing is the best way to know whether content and design work for people with cognitive and learning disabilities. It also warns against relying on automated testing alone, since automated tools often can't tell whether these users can use the content.
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Involving people at each stage
W3C advises bringing users in from the start of a project, not only at the end: "Conducting informal evaluations throughout development is more effective than only formal usability testing at the end of a project." Its two pages on involving users describe a part for them at each stage:
- Research: learn how people with disabilities use the web, find people with a range of characteristics, and ask them to show you products like yours that work well for them, and ones that don't. Include disabled and older people in use cases, personas, scenarios and workflows.
- Design: when weighing a design choice, such as navigation that expands and collapses, find products that already do it and explore with users what works. Include them in design walkthroughs.
- Prototypes: give people specific tasks on prototypes. The Note on cognitive accessibility adds that testing wireframes, rough drawings of the interface or template pages can find problems early.
- Before launch: a formal usability test, following an established protocol, with representative users doing specific tasks.
Before any session, W3C advises an initial review by someone who knows accessibility, to fix the known barriers first and to focus the sessions on the likely areas of concern. A session spent on a missing label that an audit would have found learns little the audit couldn't. The Note on cognitive accessibility also asks for people with cognitive and learning disabilities in the design and development team itself.
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Who takes part, and paying them fairly
W3C stresses that disabled people are as diverse as any people: different disabilities, sometimes more than one, and wide variation inside each. Visual disability alone runs from total blindness since birth to blurred vision from a recent injury. The cognitive accessibility Note gives an example of why one group isn't enough: content with fewer words and more numbers can suit some autistic and dyslexic users, and shut out people with dyscalculia. It suggests including people with memory, attention, learning, numeric, language and communication, and intellectual disabilities.
Skill with assistive technology matters as much as the disability. Whether to recruit novice, average or advanced users depends on who will use the site: W3C's example is advanced users for an internal application for accountants, and novice users for a public site to apply for disability benefits. A user with too little experience may not be able to use their assistive technology effectively, and a very advanced one may know work-arounds the average user couldn't manage. In the early stages, while the team is still learning how people use the web, W3C suggests people with fairly high experience.
On finding people and treating them well, the sources say:
- Recruiting: disability organisations and self-help groups, social media groups, people the team already knows, and staff who help colleagues get assistive technology or other adjustments. Some projects work with peer researchers who have the disabilities in question. There are also organisations that specialise in recruiting disabled participants.
- Paying: "respect their time and provide appropriate compensation", as for any other participants.
- Informed consent: participants know what the project is for, what they will do, any risks, what personal details are collected and how they are used, and that they can stop at any time. Use a consent form people can understand, check that they have understood it, and get consent from a guardian as well where a participant has one.
- Adjustments: ask beforehand what support people need, such as a quiet room or breaks, and which methods suit them. A participant may bring a carer or friend, who must not do the tasks for them.
Then the caution both W3C pages repeat: "Avoid assuming that input from one person with a disability applies to all people with disabilities." One person doesn't necessarily know how others with the same disability use the web, and may know little about other disabilities.
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Testing tasks, not features
A task is what someone comes to the site to do, given in their terms and not the interface's: "Buy two seats next to each other for the 14 March concert", not "Try the seat map". The Note on cognitive accessibility asks testers not just to ask questions but to have people "complete an action that demonstrates usability". A feature named in the task tells people where to go, and the test no longer shows whether they would have found it.
While people work through the tasks, the Note suggests recording tasks completed and errors made, the time each task takes (relative times say more than absolute ones), and mood and comments. By the end, the team should be able to say what stopped people finishing a task, what confused them, what led to errors, when they got frustrated, and how those problems could be avoided. Make sure participants know they can't do anything wrong: it is the site being tested, not them.
When something goes wrong, W3C lists the places the cause can lie:
- the page's markup or code;
- the browser or media player handling it badly;
- the person's assistive technology handling it badly;
- the person not knowing a feature of their browser, player or assistive technology;
- a design that is hard for everyone, disabled or not.
Only the first and last are faults in the site itself, and a test that can't tell them apart can send a team after the wrong problem. The report then states the scope of the study, the methods and who took part. W3C's example: a study with only blind participants should say that it didn't evaluate conformance and doesn't apply to all people with disabilities. Small studies are useful, but they are not statistically significant.
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Worked example
The ticketing team ran sessions with 6 people before redesigning seat selection:
- 2 screen reader users: one who had used NVDA for less than a year, and one who uses JAWS every day at work;
- 1 person who uses a screen magnifier at high zoom;
- 1 person who uses voice control;
- 1 person with dyslexia;
- 1 person with memory loss after a brain injury.
They were recruited through a disability organisation and a peer researcher, and each was paid the same fee for a 90-minute session, held in person or remotely as each preferred. The consent form was in plain language; the facilitator went through it with each person and reminded them they could stop at any time. Since the site is for the public, the team looked for people new to their assistive technology as well as experts.
There were two tasks: "Buy two seats next to each other for the 14 March concert, and pay with a new card", and "You may not be able to go. Find out whether you can get your money back." What the sessions showed:
| What happened | Who it was | What the audit had recorded |
|---|---|---|
| Pressed Tab 60 times in the seat map, then gave up | The newer NVDA user | 2.1.1 and 2.4.3 pass |
| Got past the seat map with the screen reader's own search | The JAWS user | Nothing: an expert's work-around |
| Listened to the 300-word photo description twice before finding the seat list | Both screen reader users | 1.1.1 passes |
| Couldn't find the refund rule in the terms | The participant with dyslexia | Nothing: 3.1.5 is AAA |
| Followed Help to the help centre front page, and lost the basket on the way back | The participant with memory loss | 3.2.6 passes |
The JAWS user finishing the task didn't mean the seat map worked: it meant one advanced user knew a way round it. The team changed four things, and tested the prototype again with 2 of the same participants and 2 new ones:
- The seat map got a "best available" choice, and became one Tab stop with the arrow keys moving between seats, as arrow keys inside a widget: roving tabindex or aria-activedescendant describes.
- The photo's text alternative became one sentence, with the venue description in the page text below.
- A plain summary of the refund rule went above the terms, as in terms and policies with no plain-language summary.
- Help at checkout links straight to the answer about refunds, and the basket is kept, beyond what help links that move from page to page requires.
The new flow moves focus to each step's heading, as in single-page app route changes that are never announced. That guide notes that screen readers react differently to focus on a heading and on the page's body, so the retest checked it with each participant's own screen reader. The report gives the 6 participants' assistive technology and experience, the tasks, and the changes made, and says the findings come from 6 people and don't stand for every screen reader user or every person with dyslexia.
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Common mistakes
- A usability test reported as an audit, or an audit as proof people can use the site. W3C says neither replaces the other. Conformance is tested as in testing a whole site against WCAG, and standing behind the result.
- One participant's preference made the rule for a group. "Avoid assuming that input from one person with a disability applies to all people with disabilities."
- Only expert users of assistive technology for a public site. Experts know work-arounds; the people the site is for may not. Choose the level of experience from the audience.
- Testing features instead of tasks. "Try the seat map" shows where the seat map is. A task shows whether people would find and finish it.
- Testing only before launch. W3C finds informal testing throughout development more effective than formal testing only at the end, and notes that involving users early limits having to go back and fix problems.
- Sessions spent on barriers an expert review would have found. Fix the known failures first, then test what an audit can't settle.
- Asking people to give their time for nothing. W3C asks teams to respect participants' time and pay them appropriately.
- A carer doing the task. The Note on cognitive accessibility allows a carer to come, and asks the facilitator to watch closely what help they give, since the need for help may point to a design fault.
- A report that doesn't say who took part. Without participants' disabilities, assistive technology and experience, nobody can tell whose experience the findings describe.
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What the standard says
- WCAG 2.2, Introduction (informative): the guidelines "are not able to address the needs of people with all types, degrees, and combinations of disability", and "even content that conforms at the highest level (AAA) will not be accessible to individuals with all types, degrees, or combinations of disability, particularly in the cognitive, language, and learning areas". It encourages authors to refer to the supplemental guidance.
- WCAG 2.2 1.1.1 Non-text Content (required, level A): "All non-text content that is presented to the user has a text alternative that serves the equivalent purpose", with listed exceptions. It sets no length.
- WCAG 2.2 2.4.1 Bypass Blocks (required, level A): "A mechanism is available to bypass blocks of content that are repeated on multiple web pages." It sets no limit on Tab stops.
- Supplemental guidance and the cognitive accessibility Note (advice): "not required to meet WCAG"; following the Note "is not required for conformance to WCAG".
- WCAG-EM 2.0 (advice): involving people with disabilities is "not required for using this methodology", and "strongly recommended".
- Section 508 and JIS X 8341-3:2016: Section 508's web requirement is conformance to WCAG 2.0 A and AA, and JIS X 8341-3:2016 is technically equal to WCAG 2.0. Neither makes a usability test part of conforming. Both are based on WCAG 2.0, so neither includes 3.2.6 Consistent Help, which WCAG added in 2.2.
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Limits
This page says what testing with disabled people finds and how to plan it, not how to run every kind of usability study: W3C points to dedicated resources for test design, protocols and how many participants to include. What informed consent must cover by law depends on the country and the kind of content, which the Note on cognitive accessibility asks teams to check. Which findings to fix first is in which findings to fix first, and when to rebuild instead, and how people with different disabilities move through a page is in how people use the web with assistive technology. Whether a change is good enough for the people it is for is decided by testing it with them again.
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Terms
- conformance testing
- Checking pages against each success criterion at a target level, to say whether each one passes.
- usability testing
- Watching people try to do set tasks on a site, to find where they slow down, make errors or give up.
- task
- A goal a person comes to the site for, such as buying two tickets, given to a participant without naming the controls to use.
- informed consent
- Agreement to take part from someone who knows what the study is for, what is collected and how it is used, and that they can stop at any time.
- supplemental guidance
- W3C advice beyond what WCAG requires, such as the design patterns for cognitive accessibility. Following it is not needed to conform.
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Sources and guides
- Advice Involving Users in Evaluating Web Accessibility (W3C WAI): Basics; Combine User Evaluation with Standards; Drawing Conclusions and Reporting (opens in a new tab)
- Advice Involving Users in Web Projects for Better, Easier Accessibility (W3C WAI): How to Involve Users throughout Your Project; Getting a Range of Users; Working with Users (opens in a new tab)
- Advice Making Content Usable for People with Cognitive and Learning Disabilities (W3C Working Group Note, 29 April 2021): 5 Usability Testing, Focus Groups, and Feedback (opens in a new tab)
- Advice Supplemental Guidance to WCAG 2 (W3C WAI): Cognitive Accessibility Guidance (opens in a new tab)
- Advice WCAG 2.2: Introduction: Background on WCAG 2; WCAG 2 Layers of Guidance (opens in a new tab)
- Required WCAG 2.2: 1.1.1 Non-text Content (opens in a new tab)
- Required WCAG 2.2: 2.4.1 Bypass Blocks (opens in a new tab)
- Advice Technique G94 (Techniques for WCAG 2.2): Description (opens in a new tab)
- Advice WCAG-EM 2.0 (W3C Group Note, 23 July 2026): Involving users (opens in a new tab)
Guides that show it
- Single-page app route changes that are never announced A single-page app's router swaps in the new view and title but leaves focus where it was, so nothing is said and the next Tab starts from the old place.
- Terms and policies with no plain-language summary A subscription's terms sit above its Start button as one paragraph of legal phrasing, so the cancel-by deadline is there only for people who can read it.
- Jargon and unusual words with no definition A car rental booking offers cover for the excess, an insurance word that looks like an everyday one, and nowhere on the page says what it means.
- Help links that move from page to page Every shop page ends its header with a Help link, but the checkout's slimmed-down header drops it and puts Help in the footer, below the payment form.
This page explains a practice, with recreated examples. It is not legal advice, and it is not a finding about a named client.