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Simkins and Elgazar

How to Prepare for a Section 508 Accessibility Audit: A Checklist

Maximilian Simkins, Simkins & Elgazar
Accessibility AuditSection 508ChecklistPreparation

An accessibility audit is most efficient when the product under evaluation has already addressed the most common and easily fixable issues. Organizations that prepare before their evaluator arrives spend less on remediation, receive their reports faster, and demonstrate a level of accessibility maturity that strengthens their compliance posture.

This checklist covers the steps you should take before a Section 508 accessibility audit.

Identify What Is in Scope

Before an audit begins, you need to clearly define what will be evaluated. This includes:

  • All web pages or application screens that are part of the federal deliverable
  • Electronic documents (PDFs, Word documents, Excel spreadsheets, PowerPoint presentations) hosted on or linked from the application
  • Multimedia content including video, audio, and interactive media
  • Third-party components embedded in your product (chat widgets, analytics overlays, embedded maps)

Create an inventory of everything in scope. Your evaluator will use this to plan the testing approach and determine representative sampling.

Provide a Stable Testing Environment

Accessibility testing requires a stable environment. Changes deployed during testing invalidate results and create confusion about what was actually evaluated.

Best practices for the testing environment:

  • Freeze deployments during the testing period
  • Provide a staging environment that mirrors production
  • Document any known differences between staging and production
  • Create test accounts with appropriate permissions so the evaluator can access all functionality
  • Provide credentials for any authentication-gated areas

If your application has multiple user roles with different interfaces, provide accounts for each role.

Run an Automated Scan First

Before a manual evaluator arrives, run your own automated accessibility scan. This identifies the obvious issues that would otherwise consume evaluator time on findings that could have been fixed in advance.

Focus on the most common automated findings:

  • Missing alt text on images, add descriptive text for informational images, empty alt="" for decorative ones
  • Color contrast failures, ensure all text meets 4.5:1 contrast ratio for normal text, 3:1 for large text
  • Missing form labels, every form input must have a programmatically associated label
  • Heading hierarchy, headings should follow a logical order (H1, H2, H3) without skipping levels
  • Missing page language, declare lang="en" on the HTML element

Fixing these issues before the audit ensures that evaluator time is spent on the complex manual criteria rather than issues you could have caught yourself. Our free, open-source AccessAudit tool runs comprehensive WCAG 2.x checks on your own machine and produces a prioritized findings report, so you can catch these issues yourself before the audit.

Check Keyboard Navigation

Keyboard accessibility is one of the most frequently failed areas in Section 508 evaluations, and it cannot be assessed by automated tools. Before your audit, manually test the following:

  • Tab through every page to verify that all interactive elements receive focus
  • Verify focus is visible, you should always be able to see which element is focused
  • Check focus order, tab order should follow the logical reading order of the page
  • Test all interactive components with keyboard only, menus, modals, tabs, accordions, form submissions
  • Verify there are no keyboard traps, you should be able to tab away from every element
  • Test skip navigation, a "Skip to main content" link should be the first focusable element

If your application uses custom JavaScript components, keyboard navigation issues are likely. Identify and fix these before the audit.

Review Document Accessibility

If your deliverable includes electronic documents, each document must meet accessibility requirements independently. Common document issues include:

PDFs:

  • Verify the document is tagged (not a scanned image)
  • Check reading order in the tags panel
  • Ensure all images have alt text
  • Verify table structure is properly tagged
  • Check that form fields have labels

Word documents:

  • Use built-in heading styles (not manual formatting)
  • Add alt text to all images
  • Use the built-in table tools (not tabs or spaces to create columns)
  • Run the built-in accessibility checker

Excel spreadsheets:

  • Name all worksheet tabs descriptively
  • Add alt text to charts and images
  • Use header rows in data tables
  • Avoid merged cells where possible

PowerPoint presentations:

  • Set the reading order for each slide
  • Add alt text to all non-decorative images
  • Use slide layouts (not free-form text boxes)
  • Ensure sufficient color contrast

Verify ARIA Usage

If your application uses ARIA (Accessible Rich Internet Applications) attributes, verify they are implemented correctly. Incorrect ARIA is worse than no ARIA, it actively misleads assistive technology users.

Common ARIA issues to check:

  • ARIA roles match the element's actual behavior
  • aria-label and aria-labelledby attributes reference correct elements
  • aria-expanded, aria-selected, and aria-checked states update dynamically
  • Live regions (aria-live) are used appropriately for dynamic content updates
  • ARIA attributes are not duplicating information already provided by native HTML

The first rule of ARIA is: if you can use a native HTML element that provides the behavior you need, use it instead of ARIA.

Prepare Your Team

An accessibility audit is most productive when the evaluator can communicate directly with people who understand the application. Before the audit:

  • Designate a point of contact who can answer questions about the application's functionality and intended behavior
  • Brief your development team so they understand the process and can respond to findings efficiently
  • Set expectations about the timeline, a standard audit takes 2-3 weeks from kickoff to report delivery
  • Plan for remediation, allocate development resources to address findings after the report is delivered

The Audit Readiness Checklist

Use this checklist to track your preparation:

  • Scope inventory complete (pages, documents, multimedia, third-party components)
  • Stable testing environment available with test accounts
  • Automated scan completed and common findings fixed
  • Keyboard navigation tested on all pages
  • Document accessibility reviewed for all PDFs, Word, Excel, and PowerPoint files
  • ARIA usage verified
  • Point of contact designated
  • Development team briefed and remediation resources allocated

Simkins & Elgazar conducts Section 508 accessibility audits using DHS Trusted Tester methodology. We also offer audit readiness guides to help your team prepare. Contact us to schedule your evaluation.