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Guide

Title II Snapshot vs a full accessibility audit: what each one shows

By ValleyFill · November 10, 2026

Public website teams often hear “we ran a scan,” “we used a checker,” and “we had an audit” as if those phrases describe the same work. They do not. A first look at a handful of pages can show whether basic signals are present. A broader automated review can document more pages and more checks. Neither kind of software result, by itself, is the same as WCAG 2.1 Level AA conformance.

This guide explains the difference in plain language, using the U.S. Department of Justice Title II web rule as the policy backdrop and W3C evaluation guidance as the technical backdrop. It also explains how ValleyFill’s free Title II Snapshot and paid automated audit fit that picture, including what each one leaves out.

What the Title II web rule names as the technical standard

Title II of the Americans with Disabilities Act requires state and local governments to make their services, programs, and activities accessible to people with disabilities, including services offered on websites and in mobile apps. In 2024 the Department of Justice published a final rule with a specific technical standard for that web and mobile content: the Web Content Accessibility Guidelines (WCAG) version 2.1, Level AA. 1

The Department later extended the dates by which public entities must meet that rule. After the interim final rule published on April 20, 2026, the compliance date is April 26, 2027 for state and local governments with a total population of 50,000 or more, and April 26, 2028 for those with a total population under 50,000 and for all special district governments. 1 2

Those dates and the WCAG 2.1 Level AA standard matter because they describe the destination. They do not describe a particular brand of scan or a particular report format. The Department’s small-entity guide is informal guidance and is not a substitute for the rule itself. Confirm how the rule applies to your organization with qualified counsel. 1

If you are still working out which date applies, start with our explanations of the April 2027 and April 2028 deadlines and which deadline applies to school districts, libraries and special districts. Official source links also live on our laws and guidelines page.

First looks and thorough reviews are not the same job

W3C’s Web Accessibility Initiative describes a useful split.

Its Easy Checks resource is a first review. The checks cover only a few accessibility issues and are designed to be quick rather than definitive. A page can appear to pass those checks and still have significant barriers. W3C says more robust assessment is needed to evaluate accessibility comprehensively. 3

For a structured look at how well a site or other digital product conforms to WCAG, W3C publishes the WCAG Evaluation Methodology (WCAG-EM). That methodology walks through defining the scope, exploring the product, selecting a representative sample when every view cannot be tested, evaluating the sample, and reporting the findings. W3C says it is usually best to do preliminary checks before investing in a more thorough review such as WCAG-EM. Applying WCAG-EM successfully requires knowledge of WCAG, accessible design, assistive technologies, and how people with different disabilities use digital products. The methodology also recommends involving real users with disabilities. 4

WCAG 2.1 itself is written so that success criteria can be tested with a combination of automated testing and human evaluation. Conformance at Level AA means the full page satisfies all Level A and Level AA success criteria, or a conforming alternate version is provided. Conformance is for full pages, not for a fragment that leaves part of a page out of scope. If someone makes a conformance claim, WCAG lists required components such as the date, the guidelines version, the level, and a description of the pages covered. 5

Two practical conclusions follow:

What the Title II Snapshot checks

ValleyFill’s Title II Snapshot is a free, no-sign-up check for public bodies. You enter a website address, the type of public body, and a population band. The result includes the Title II web deadline that follows from the type and population band you chose, plus a dated list of basic signals from up to 10 pages and up to 5 PDFs. 6

The Snapshot is an automated, partial check of a few public pages. It is not an audit, not an Accessibility Conformance Report, and not legal advice. A clean result does not mean the site conforms to WCAG 2.1 Level AA or meets the Title II rule. 6

Each line in the results is a basic signal read from page HTML, without running scripts. There is no score and no grade. As described on how the Title II Snapshot works, the current checks look for things such as:

Those checks are useful because they catch problems a person can often fix quickly. They are also limited on purpose. The Snapshot does not judge whether alternative text is accurate, whether a label is clear, whether a language code is correct, or whether PDF tags reflect the real reading order. Content added by scripts is not seen. Encrypted, damaged, or very large PDFs may be unreadable, and that unreadability is not counted as a problem. 7

The deadline in a Snapshot comes from the public-body type and population band you select, using the Title II definitions and the dates as extended in 2026. If you choose “Not sure,” both dates are shown. The tool does not independently verify your population figure or legal classification. 7

What a fuller automated audit adds

A fuller automated review covers more of the site and records the work more completely. ValleyFill’s automated WCAG 2.1 AA audit is that kind of review: software testing against WCAG 2.1 Level AA, scoped to agreed pages and PDFs. The published starting scope is up to 50 pages and 10 PDFs. The report includes findings, fix guidance, and test records. It does not include screen reader testing or other human review, it is not an Accessibility Conformance Report, and a clean automated report does not mean the site conforms to WCAG 2.1 Level AA. There is no compliance guarantee and no legal advice. Published prices are on the pricing page. 8

Compared with the Snapshot, the extra value is mostly scope and documentation:

That is still not a substitute for the human parts of a thorough evaluation. If a procurement requests a signed Accessibility Conformance Report, screen reader evidence, or a WCAG-EM style sample with manual testing, an automated audit alone does not meet that request. Our procurement checklist discusses how to ask vendors what they actually tested.

What automated software cannot decide

W3C is direct about the limits of evaluation tools. Tools can help you identify potential issues quickly and can assist throughout design and development. They cannot check all accessibility aspects automatically. Human judgment is required. Tools can produce false or misleading results. They cannot determine accessibility; they can only assist in doing so. 9

That limit shows up in everyday public-website work. Software can notice that an image has no alt attribute. It cannot tell you whether “photo1” is a useful text alternative, or whether a decorative image should have empty alternative text. It can notice that a form field has a label. It cannot tell you whether the label matches what the field actually collects. It can notice that a heading exists. It cannot tell you whether the heading hierarchy matches the meaning of the page.

The same point applies to PDFs. Tagged structure, a document title, a language, and selectable text are useful signals. They do not prove that the tags follow the visual order, that the title describes the document, or that a scanned page was replaced with real text.

Because WCAG 2.1 Level AA includes criteria that depend on meaning, interaction, and the experience of using assistive technology, an automated pass is not the same as meeting the standard. Treat software findings as evidence about the checks that were run, not as a verdict about the whole site.

How to describe the results without overstating them

When you forward a result to a manager, council, or board, say what was tested and what was not. A short memo can stay accurate with four lines:

  1. What ran. Name the tool or service, the date, and whether it was a Snapshot-style first look or a broader automated audit.
  2. What was in scope. List the number of pages and PDFs, and note any important templates or services that were left out, such as logged-in portals, maps, payment flows, or videos.
  3. What the software can support. Report missing language attributes, missing text alternatives, unlabeled fields, untitled frames, and similar machine-readable problems.
  4. What still needs a person. Say plainly that keyboard access, screen reader behavior, the quality of alternative text, form instructions, captions, and many other WCAG checks were not decided by the software.

Do not write that “the site is compliant,” “we passed Title II,” or “the scan found no issues, so we are done,” unless you have a separately documented basis for that statement. WCAG treats conformance as a claim about full pages and complete processes, and it expects human evaluation alongside automation. 5 9

If the Snapshot deadline differs from the date your counsel expects, treat that as a prompt to re-check the public-body type and population method rather than as a legal finding. Our guide to which Title II deadline applies walks through school districts, libraries, and special districts.

A practical sequence for a small public-web team

You do not have to choose between a first look and later work. W3C’s own framing is to start with preliminary checks, then invest in a more thorough review. 3 4 A realistic sequence looks like this:

This week. Run a first look on the homepage, a search or contact form, and one PDF people actually use. The Title II Snapshot can produce that kind of dated, forwardable list. You can also use W3C’s Easy Checks by hand: look at page titles, text alternatives, headings, contrast, text resize, keyboard focus, and forms. 3 Our WCAG 2.1 AA overview and accessibility standards guide describe those principles and some checks you can run yourself.

Next. Decide which templates and services matter most: agenda packets, utility payments, license renewals, program applications, emergency notices. Put those pages and PDFs in scope for a broader automated review so the findings file matches the work people actually do on the site. 8

Then. Plan the human testing the software cannot finish. That includes keyboard-only use, a screen reader pass on key tasks, and, where you can, review by people with disabilities. WCAG-EM is one documented way to structure that deeper evaluation. 4

Alongside the testing. Keep fixing and publishing. A 90-day plan is often more useful than waiting for a perfect report; see our Title II plan for a small-city IT person.

The Snapshot answers “what basic signals appear on a few public pages today, and which deadline follows from the details I entered?” A fuller automated audit answers “what did software find against WCAG 2.1 Level AA across the pages and PDFs we scoped, and what should we fix first?” Title II still asks whether people with disabilities can use the services, programs, and activities you offer online. That last question needs more than a scan.

Sources and further reading

Official and ValleyFill sources checked November 8, 2026.

  1. ADA.gov: Accessibility of Web Content and Mobile Apps Provided by State and Local Government Entities: A Small Entity Compliance Guide. The guide states that WCAG 2.1, Level AA is the technical standard, lists the extended compliance dates, and notes that it is informal guidance, not a substitute for the rule.
  2. The official version of the April 20, 2026 interim final rule is published in the Federal Register at 91 FR 20902. The 2024 final rule is at 89 FR 31320 (April 24, 2024), as cited in the same ADA.gov guide.
  3. WAI: Easy Checks — A First Review of Web Accessibility. These checks cover only a few issues and are not a comprehensive evaluation.
  4. WAI: WCAG-EM Overview. A structured methodology for conformance evaluation, not additional WCAG requirements.
  5. WCAG 2.1, Conformance, including conformance levels, full pages, complete processes, and optional conformance claims. See also the introduction’s note that WCAG 2.1 is designed to be testable with automated testing and human evaluation.
  6. Title II Snapshot. ValleyFill’s description of the free, automated, partial check.
  7. How the Title II Snapshot works. The current checks, known limits, and fetching rules.
  8. ValleyFill audit services and published pricing. Automated WCAG 2.1 AA testing only; no human review and no compliance guarantee.
  9. WAI: Selecting Web Accessibility Evaluation Tools. Tools assist evaluation; they cannot determine accessibility on their own.

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General educational information, not legal advice. By ValleyFill.

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