Guides
ADA and WCAG 2.2 compliance as a sellable service for US studios
US studios can sell ADA and WCAG 2.2 compliance services such as audits, remediation and ACR documents as recurring revenue priced from scoped hours.
What to take away
- The DOJ treats Title III as covering business websites, so a demand letter can arrive without any prior complaint.
- The DOJ does not name a WCAG version. Its guidance points to WCAG as the recognized benchmark, and courts and plaintiffs treat WCAG 2.2 Level AA as the practical standard.
- Automated scanners find about a third of failures. The rest need keyboard and screen reader testing.
- Audits are one-time revenue. Remediation retainers, quarterly regression tests and annual re-audits are the recurring line.
- A VPAT-based ACR is the entry ticket to enterprise, university and government procurement.
- State in the contract that conformance is a point-in-time assessment, not a warranty.
Why accessibility sells now
ADA Title III filings over websites have climbed for years, and the dockets are no longer only retail. Banking, healthcare, hospitality and higher education now appear regularly. Plaintiffs seek injunctive relief and attorney fees, which means a demand letter costs the client money whether or not the claim has merit.
The DOJ has brought its own cases against inaccessible sites and services. Point clients to the government's own record of ADA enforcement cases. It is a public list of the matters the department has brought, and the client can send it straight to their own counsel without anyone having to explain it.
Studios that treat accessibility as a chore donate the hours. Studios that package it attach it to redesigns, CMS migrations and care plans. It also fits the pattern of profitable web design agency services that clients already budget for.
You do not need a specialist on payroll. A trained auditor plus one developer who can fix issues covers most mid-market sites. Subcontract the audit, keep remediation in house, and you keep the margin and the relationship.
What the DOJ guidance actually says
DOJ web accessibility guidance states that Title III applies to businesses open to the public, and that a website is a place of public accommodation when it connects to a physical location or delivers goods and services.
The guidance does not adopt a technical standard. It points to WCAG as the recognized benchmark and leaves the version open.
That gap is a sales problem and a sales tool. Plaintiffs and courts fill the vacuum with WCAG conformance levels, so a site at Level AA has a defensible position and a site with no audit trail has none.
The guidance also covers reasonable modifications and auxiliary aids. It covers unnecessary eligibility criteria too. These translate into plain work:
- alt text
- captions
- keyboard access
- form labels
- consistent navigation
Make the guidance the first page of your packet. It is short, official, free, and it answers the only question the client is asking.
The audit sequence
WCAG 2.2 is a W3C recommendation under four principles: perceivable, operable, understandable, and compatible with current and future assistive technologies. Criteria sit at Levels A, AA and AAA. Most US organizations target AA, and each criterion carries a number, a short name and testable requirements.
Test every Level A and AA criterion, not a sample. The full list lives in the WCAG 2.2 specification. Build a spreadsheet with one row per criterion and columns for status, evidence, severity and owner. That sheet becomes the backbone of the report.
Seven-Step WCAG 2.2 Audit Sequence
- Inventory templates, pick one URL each
- Run two automated scanners, log rules
- Test keyboard-only navigation per template
- Test screen readers and 200/400% zoom
- Check contrast and text spacing overrides
- Manually test forms, errors, timeouts, auth
- Compile findings, map to success criteria
Automated tools catch roughly a third of failures. Manual testing catches the rest. Say that before the kickoff call, or the client will expect a scanner to sign off on the site.
What WCAG 2.2 added and why it bills
WCAG 2.2 added nine success criteria and removed one. The new ones target mobile use, cognitive load and authentication, which are exactly the areas older audits skipped. The W3C explains each change on its What's New in WCAG 2.2 page.
The additions include Focus Not Obscured, Focus Appearance, Dragging Movements, Target Size, Consistent Help, Redundant Entry and Accessible Authentication. Two sit at Level AA, so they change whether a conformance claim is true.
Clients pay for 2.2 work because their procurement and legal teams ask for it. Enterprise buyers and government contractors want a current statement. An audit still citing WCAG 2.1 reads as behind the market.
Sell the delta. A gap assessment against an existing 2.1 audit is a small, fast engagement, and it usually leads to remediation once the client sees the findings.
Scoping the audit before you quote
Scope decisions to settle in writing before testing starts:
Scope Decisions to Settle in Writing
- Domains, subdomains, third-party widgets in scope
- Conformance level to test, usually AA
- Browsers, operating systems, assistive technologies
- Templates and unique page types covered
- PDFs, video and email templates included?
- Client provides staging access, credentials, owners
- Handling of issues found outside scope
- URLs and templates in scope, named one by one.
- Assistive technology and browser versions tested, written down.
- Mobile web and native app surfaces, in or out.
- PDFs, documents and third-party embeds, counted or excluded.
- Content statessigned in, empty cart, error and timeout screens.
- Deliverablesfindings register, severity ratings and retest window.
A worked example: a 40-page ecommerce site with three templates, a cart, a checkout and a PDF return policy. Scope 12 URLs, two screen readers, keyboard testing and a sample of five PDFs. That is 30 to 40 hours of testing and a findings register with severity ratings.
Write the scope into your proposal template so the client sees deliverables, exclusions and assumptions before signing. That habit prevents most scope fights on its own.
Remediation: fixed fee or retainer
Remediation is where the recurring revenue lives. Audits are one-time. Fixes, regression testing and new content are not.
Fixed-Fee Remediation vs Retainer
Fixed-Fee Package
- Coverage
- Defined backlog
- Fixes
- All A and AA issues
- Retesting
- Once after fixes
- Deliverable
- Conformance statement
- Pricing
- After audit findings
Retainer
- Coverage
- Ongoing work
- Fixes
- Set monthly hours
- Retesting
- Quarterly regression
- Deliverable
- Annual re-audit
- Pricing
- Monthly fee
The fixed-fee package covers a defined backlog: fix every Level A and AA issue in the audit, retest, deliver a conformance statement. Price it after the audit, when you know the real volume. Never quote a flat fee before you have findings.
What the fixed fee includes:
- Every Level A and AA item in the findings register, fixed and retested.
- Evidence for each fix, with the test method and the date.
- A conformance statement naming the standard and the review date.
The retainer covers monthly monitoring, a set number of remediation hours, quarterly regression tests and an annual re-audit. It slots into care plans you already sell and makes forecasting easier. It also pairs with the service menu clients already understand.
What the retainer includes:
- Monthly monitoring of new pages, forms and components.
- A fixed block of remediation hours, with unused hours capped.
- Quarterly regression tests on the core templates.
- An annual re-audit with an updated findings register.
Set boundaries. Third-party embeds, legacy PDFs and vendor-controlled widgets may sit outside your control. List them as client responsibilities or separately priced work. On WordPress, Drupal or a headless stack, some fixes belong to the theme, some to plugins, some to whoever edits content.
Writing an ACR with a VPAT
A VPAT is the template. An ACR is the completed report. Enterprise procurement, universities and agencies ask for one during vendor review. Section508.gov publishes a step-by-step guide on how to create an ACR with a VPAT, including the four editions.
Pick the edition that matches the buyer: WCAG, Section 508, EN 301 549 or the international edition. Fill in every criterion with supports, partially supports, does not support, or not applicable. Add remarks with evidence, test methods and dates.
Do not claim full support without testing. A false conformance claim becomes an exhibit in litigation or a breach of contract. If a criterion is partially supported, say so and describe the workaround.
For Section 508 work, the ACR is the entry ticket to federal subcontracting. Pair it with a remediation roadmap so the buyer sees a path to full support.
Pricing the work
Price complexity, not page count. A 20-page marketing site and a 20-page application with authentication are different jobs. Build the number from hours, risk and how much of the work you can reuse.
| Service | Typical scope | Typical price range |
|---|---|---|
| Audit, small site | Up to 10 templates, 12 URLs, one screen reader, manual keyboard pass | $3,500 to $6,000 |
| Audit, mid-market | 10 to 20 templates, 25 URLs, two screen readers, a sample of five PDFs | $7,000 to $15,000 |
| WCAG 2.2 gap assessment | Review of a prior 2.1 audit, delta testing only, short addendum | $2,000 to $4,000 |
| Audit review | Second read of another auditor's findings, severity checked, report rewritten in your name | $1,200 to $2,500 |
| Fixed-fee remediation | Every Level A and AA issue fixed and retested, conformance statement delivered | $8,000 to $30,000 |
| Monthly retainer | Monitoring, a block of remediation hours, quarterly regression tests, annual re-audit | $1,500 to $5,000 per month |
| ACR with VPAT | Every criterion completed with remarks, evidence, test methods and dates | $2,500 to $6,000 |
Illustrative Accessibility Service Pricing
- $3,500-$15,000 | WCAG 2.2 AA audit
- $1,500-$4,000 | 2.2 gap assessment
- $8,000-$60,000 | Remediation project
- $2,000-$10,000/mo | Accessibility retainer
- $2,500-$7,500 | VPAT ACR
Those ranges are typical for US studios, and they move with your loaded hourly rate and how much of the work you can reuse. Substitute your own rate and your own hours to get your floor.
Worked example: the 40-page ecommerce site scoped above takes about 35 hours of testing and reporting at a $120 loaded hourly rate, which is $4,200. Fixed-fee remediation on the same site runs about 60 hours, or $7,200, before any change orders.
Defend scope three ways. Document assumptions in the statement of work. Log out-of-scope requests and price them as change orders. Keep test evidence so you can prove what you tested and when.
Findings belong in regular client reporting too. Evidence-based reports clients trust make renewals easier, because the client can show progress to their own legal or procurement team.
Use contract terms that prevent disputes to cap liability, define acceptance and set a re-test window. New content, new plugins and new third-party scripts can break a passing site the day after you finish.
State-level activity is worth tracking. California, New York, Texas, Florida and Washington all see federal ADA filings, and some have their own accessibility laws. Multi-state clients already live with state-by-state rules post-Wayfair, so the argument lands. Confirm any state requirement with your attorney before you put it in a proposal.
Common questions
How long does an audit take?
A mid-market site with 10 to 15 templates usually runs 30 to 60 hours. Applications with authentication and dynamic content take longer, because every state and error path needs its own pass.
Can we resell an audit we subcontract?
Yes, if the subcontractor permits it and you review the findings yourself. Disclose the arrangement in the statement of work and keep the client relationship in your name.
What if the client refuses to fix anything?
Document the findings and the risk in writing, then offer a phased plan. Unresolved issues remain the client's legal exposure, and your file should show you said so.
