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Play 10: Conduct Section 508 testing

While an expert review of Section 508 conformance claims may provide an indication of accessibility, rigorous testing is required to validate these claims. Section 508 conformance is complex. Vendors and development teams may not fully understand what conformance requires. Therefore, testing is needed to reduce the risk of unknowingly implementing inaccessible technology. Testing needs to be performed regardless of the source, including commercial-off-the-shelf, open source, or custom built technology by your agency, a vendor, or another agency. You can use automated testing tools to augment validation efforts; however, by themselves automated tools can only provide partial coverage of the Section 508 standards. In order to validate full conformance, hands-on testing using a repeatable, systematic testing methodology is needed. In addition, you can use informal reviews by Section 508 experts throughout the development process to identify potential issues before the technology is ready for full Section 508 conformance testing.

Many individuals who are interested in testing to validate the conformance of a given technology solution, and who are new to utilizing the Section 508 technical requirements, mistakenly believe that the use of assistive technology such as screen readers, voice input software, and screen magnification software, provide the best scenarios for determining conformance with the Section 508 technical standards. This is not the case, as these technologies often provide special scripts, routines, and other hacks to compensate for non-conformant technologies, and they are not a true measure of actual conformance of code with the technical requirements of Section 508. They are excellent tools for determining usability, but should not be used as the sole means of determining conformance of any digital service or technology solution under Section 508.

Key Questions:

  • Prior to deployment, how do you incorporate the use of Section 508 testing tools to inspect, validate digital services and technology for Section 508 compliance? After deployment, how do you monitor conformance when components change or are updated?
  • When using agile processes, how do you ensure user stories are validated for Section 508 compliance in each sprint?
  • How do you inform and equip developers and accessibility testers to conduct Section 508 compliance testing?

Basic Checklist

  • Obtain management support to establish Section 508 compliance testing as a requirement prior to deployment.
  • Promote and use a consistent, repeatable, validated testing approach based on a well-defined set of Section 508 test standards, approved testing tools, and documentation processes. (see resources section).
  • Assess your agency’s current approach(s) to:
    • Validate technology prior to deployment (electronic content, software, hardware, closed systems, hardware, telecomm),
    • Conduct accessibility testing (when is it performed, by whom, and for what type(s) of technology), and
    • Conduct accessibility audits using manual inspection and automated tools.
  • Develop accessibility testing policy/procedures that define:
    • When accessibility testing is required (recommend prior to deployment),
    • Who is qualified to perform accessibility testing (recommend obtaining DHS trusted tester certification for web and software developers),
    • The roles of responsibilities of project teams, testers, and the Section 508 Accessibility Program Team,
    • How accessibility test planning will be conducted,
    • How the testing environment will be configured,
    • What accessibility testing tools will be approved for use,
    • What accessibility testing methodologies/methods will be approved for use (example: CIO Council Accessibility Community of Practice endorsed testing methodologies, such as the trusted tester methodology), and
    • How testing results will be tracked and monitored.
  • Determine approach to using tools to support testing, including:
    • Section 508 testing tools to assist with unit testing,
    • Audit tools capable of scanning large volumes of electronic content for Section 508 compliance,
    • Tools to track, report, and monitor testing activities and results.
  • Develop or obtain Section 508 testing expertise:
    • Determine whether the testers will be centralized or decentralized.
    • Identify training needs and, where warranted, certification procedures for individuals who will perform accessibility testing.
    • Develop a cadre of vetted accessibility testers and technical support resources. 

Advanced Checklist

  • Establish risk levels to determine the appropriate level of effort in 508 testing.
  • Report Section 508 compliance results at the program, project, and organization level to your agency’s senior leadership team.
  • Audit test activities to ensure agency employees follow accessibility testing policy and procedures and to identify areas for improvement in the testing process.
  • Incorporate Section 508 compliance testing and monitoring into continuous development environments.


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