Brian Beals, LLC

Accessibility Conformance Reports

Independent WCAG 2.1 Level AA evaluation for public entities. I write the conformance report. I do not do the remediation, and that is the point.

The Department of Justice rule at 28 CFR 35.200 requires WCAG 2.1 Level AA for state and local government web content and digital documents. DOJ extended the compliance dates by one year in an interim final rule published in the Federal Register on April 20, 2026, document 2026-07663.

Compliance dates

Public entities serving 50,000 or more: April 26, 2027
Public entities under 50,000, and all special district governments: April 26, 2028

Confirm which tier applies to your entity before planning against a date. Special districts land on the later date regardless of size.

What you get

An Accessibility Conformance Report in VPAT 2.5 format, the same document your procurement office already asks software vendors to produce. All 50 Level A and Level AA success criteria of WCAG 2.1, each one marked Supports, Partially Supports, Does Not Support or Not Applicable, each one evidenced. Dated and signed.

Alongside it, a prioritized remediation list your web vendor can bid against, and a one-page summary written for a commission meeting or a budget request rather than for an engineer.

If a complaint ever arrives, the question is rarely whether the site was perfect. It is what you knew and what you were doing about it. Fixing everything and keeping no record leaves you with nothing to show.

Federal: Section 508

Section 508 of the Rehabilitation Act, at 36 CFR 1194 Appendix A, works differently. There is no government-wide compliance date. It is in force now, and what it affects is award eligibility.

It reaches two groups. Federal agencies, for the information and communication technology they develop, procure and use. And every company selling that technology to an agency, which is where the deadline is real and immediate: a solicitation asks for a VPAT, and the answer is due with the bid.

If a contracting officer has asked you for an Accessibility Conformance Report and you do not have one, that is a dated problem this quarter, not a 2027 problem. A missing or obviously boilerplate ACR can cost an award before anyone reads the technical approach.

One detail worth knowing, because it trips people up. Section 508 points at WCAG 2.0 Level AA while the Title II rule points at 2.1 Level AA. Building to 2.1 satisfies both, since 2.1 is a superset. The reverse is not true, so a 2.0 conformance claim does not cover a Title II obligation.

Why I do not remediate

A conformance claim written by whoever repaired the site is a self-assessment. The report has to come from outside the work, or it is the vendor grading their own homework and your counsel will say so.

Staying out of the repair work also gives you something useful: a specification your remediation vendor bids against, instead of a per-page quote you have no way to check. I am happy to refer a partner for the repair. I will not be the one holding both ends.

How the evaluation runs

Automated scanning across a representative sample of pages, then manual testing for the criteria a machine cannot settle. Whether an image is decorative or meaningful, whether headings describe their sections, whether reading order carries meaning, whether an error message actually helps. Keyboard traversal and screen reader checks are done by hand.

Every report states plainly what was tested and what was not. A row that mostly worked is Partially Supports. A report that overstates conformance is worse than one that admits a gap, because a reader who finds the gap themselves has reason to doubt every other row.

Documents count too. The Title II rule reaches conventional electronic documents, and an untagged PDF is the most common failure I find. A site can pass while its forms library does not.

The proof

This site carries its own Accessibility Conformance Report. Nineteen pages and all six published documents, evaluated against all 50 Level A and AA criteria on August 30, 2026: 31 Supports, 18 Not Applicable, and 1 Partially Supports, with nothing marked Does Not Support and nothing left unevaluated. The document layer passed too: all six PDFs are tagged, with structure, language, title and figure labelling verified.

The partial is 2.4.5 Multiple Ways, and it is left in on purpose. This report is reachable two ways, from three pages that link it and from the site map, which is what the criterion asks. What it does not carry is site navigation of its own, because it is a standalone document meant to be forwarded. The automated check tests whether every page links to the site map, which over-reports on a document of that kind. Recording it is more useful than arguing it away, and a firm that evaluates its own site and publishes nothing but green has told you less than one that shows its edges.

Four criteria were settled by a person rather than by the scan: meaningful sequence, keyboard traps, headings and labels, and change of context on focus. Those were checked by tabbing the site with a keyboard and listening to it with VoiceOver, including the headings and links lists through the rotor. Reading order cannot be scored mechanically, and no report from this practice will claim it was.

Read the full conformance report. It is the same document a client receives, produced by the same process, published here because a firm that sells conformance reports should have its own on display. It also serves as this site's accessibility statement. The fastest way to judge whether the work is any good is to read one.

Healthcare: Section 504

Healthcare organizations answer to a different rule with an earlier date. The HHS final rule at 45 CFR Part 84 requires WCAG 2.1 Level AA by May 11, 2027 for recipients with 15 or more employees, and it reaches anyone taking Medicare or Medicaid. Its legacy-document exemption stops at any document a patient uses to apply for or access a program, which puts the whole forms library back in scope. See how Section 504 applies to healthcare.

Maryland: CATS+ contractors

Maryland runs its own version of this obligation through a different statute. If you hold or subcontract on CATS+, see how Maryland's nonvisual access clause works.

The firm

Brian Beals, LLC. Service-disabled veteran-owned small business, registered in SAM.gov and based in Punta Gorda, Florida.

UEI: NJLEHNAQATJ6
CAGE: 22XM3

Capability statement

One page each, for your procurement file. Six, because the rule and the certification that matter depend on who is buying. These four cover the practice:

Accessibility practice, ADA Title IIConformance evaluation, ACR and VPAT work, and document inventory, written for state and local government and the April 2027 and 2028 dates.
Accessibility practice, federal Section 508The same evaluation practice framed for 36 CFR 1194: conformance assessment and VPAT for agencies and for vendors answering a solicitation. SDVOSB set-aside eligible.
Federal, SDVOSBSBA-certified service-disabled veteran-owned small business, certified August 2026. Covers the broader AI, analytics and automation practice.
Florida state and local, VBEFlorida-certified Veteran Business Enterprise. Same practice, written for state and local procurement.

Two more are written for a specific rule and live with it: Section 504 for healthcare and Maryland nonvisual access.

All are tagged PDFs: structure tree present, language declared, headings in order, table headers marked, no untagged figures. A firm that hands you an inaccessible document about accessibility has told you something.

Getting started

Twenty minutes is usually enough to tell whether this is worth your time. I will walk you through what a sample of your site shows and what full scope would look like for an entity your size. If the timing is wrong, say so and I will leave it alone.

Get in touch, or write to brian@brianbeals.com.