Governmentwide Findings: Compliance Key Findings

Overall, reporting entities experienced a decline in Section 508 conformance, with the governmentwide average score dropping from 1.79 in FY23 to 1.74. Amid this broader decline, testing coverage also decreased, with only 70% (down from 78%) of respondents assessing public web pages covering 41% (down from 52%) of total pages. Intranet testing dropped further, with only 41% of entities evaluating 8% of total intranet web pages, a precipitous reduction from 26.1% of total in FY23. While conformance rates for public web pages held steady around 62%, intranet conformance declined from 59% to 52%. Additionally, nearly half of respondents lacked resources for testing high-traffic ICT assets, including top-viewed web pages, documents, and videos. These findings underscore the need for improved testing resource allocation, including testing tools and testing personnel, and prioritization of testing and remediation efforts to drive meaningful improvements in conformance.

To determine the level of Section 508 conformance of ICT, the Assessment asked about conformance of internal and public-facing web pages, top-viewed electronic documents and videos. The Assessment also asked about levels of Section 508 conformance of common digital products, including:

• Conference or workstation reservation systems

• Survey authoring tools and distributed surveys

• Chat or messaging systems

• Learning Management Systems (LMS)

• Publicly-posted Section 508 or digital accessibility policies

• Video players

• Widely used public-facing fillable forms

• FY25 Congressional Justifications (CJ)

• Employee performance portals or equivalent.

The Assessment combined these measures to create a conformance index referred to as “conformance” or “c-index.” On average, governmentwide conformance did not improve and remains low at 1.74 on a 5-point scale compared to 1.79 in FY23. 

The Assessment continued to ask entities to report on the outcomes of accessibility testing of web pages evaluated as part of standard business functions throughout the reporting period for both public internet web pages and internal intranet web pages. Questions covered how many of each the respondent owned and operated, how many were tested for Section 508 conformance, how many web pages fully conformed, average number of defects found, and details on testing methodologies used. While there is much variance in entities who reported both years and the scope of this testing, FY24 data showed:

• Only 70% or 172 respondents reported they performed testing for Section 508 conformance on public internet websites they owned or operated compared to 78% of entities who performed testing last year. Reportedly, 6,964,802 internet web pages were tested, totalling 41% of all internet pages owned or operated by reporting entities, which is down from 52% of all internet pages owned or operated by reporting entities in FY23.³

• On average, 62% of tested internet pages were reported as fully conformant, which is almost the same as FY23 at 61%.⁴

• Even fewer entities reported testing internal intranet pages. Approximately 41% or 100 respondents reported they performed testing for Section 508 conformance on internal intranet websites they owned or operated, down from 60% in FY23. Reportedly, 218,663 intranet web pages were tested, totaling just 8% of all intranet pages owned and operated by reporting entities, a substantial decrease from FY23’s 26.1% of pages tested.⁵ 

• On average, 52% of tested intranet pages were reported as fully Section 508 conformant, a decrease from 59% in FY23.⁶ 

The low numbers reported do not align with M-24-08 guidance nor FY23 Assessment recommendations to increase conformance validation and testing. Future assessment criteria and respondent follow-up will help shed light on changes in testing depth and breadth YOY to better understand swings in reported data.

Entities reported predominantly using hybrid or manual test processes for internal intranet web pages, with little reliance on only automated testing tools. This may be due to security and access limitations of automated tools on intranet content and technologies. Additionally, fewer web pages were tested and fewer pages were found to be fully conformant this year. Both speculative reasons and data provided by reporting entities for why this may be include:

• Intranet pages require more manual testing and limited resources cannot provide comprehensive testing. 

• The technology stack or framework used for intranet has accessibility defects, resulting in 0% conformance of every page.

• Templates used across the intranet are not fully accessible; even one defect may be perpetuated across every page resulting in 0% conformance. 

• Lack of attention or prioritization of intranet content compared to public-facing ICT. 

Entities reported an average of 7.5 defects per internet web page tested during the reporting period.⁸ The average number of defects found on internal intranet pages was slightly less at 6.2 defects per page.

Compliance of Top Viewed ICT 

The Assessment continued to ask entities to test their top 10 viewed internet web pages, intranet web pages, and electronic documents and top five viewed videos. As Figure 3 shows, on average, about half of respondents reported they did not have resources to test any of their top viewed ICT, which remains a high number. With the exception of intranet web pages, slightly more entities submitted results this year for top viewed pieces of ICT and the percentage of conformance of the top viewed ICT slightly improved. However, it is apparent in submitted data that entities do not have, or are not prioritizing, available resources to test ICT they procure, develop, maintain or use.

Figure 3. YOY Comparison of percentages of respondents submitting conformance testing results for the top intranet and internet web pages, electronic documents, and videos (Q71, Q76-78).

Analysis of YOY change shows a continued variation of responses. 4% more entities submitted test results for the top viewed internet pages but 14% fewer entities provided results for top viewed intranet web pages. Additionally, in FY24 both electronic documents and videos saw a small percentage increase in entities who submitted results. Data shows the largest swing in entities who selected Not Applicable in FY24, with:

• 7 entities reporting no public facing internet web pages compared to 3 in FY23.⁹

• 25 entities reporting no intranet pages compared to 22 in FY23.

• 11 entities reporting no public facing electronic documents compared to 5 in FY23.

• 39 entities reporting no videos compared to 24 in FY23. 

As shown in Figure 4, there was a slight YOY increase in the percentage of top viewed ICT that fully conforms with internet page conformance increasing by 1.3%, top documents increasing by 1.7%, and top videos increasing by 4.5%. However, there was a decrease by 4.5% in conformance YOY for top viewed intranet, which is further supported by an indication of a moderate, meaningful increase (WRST: extremely statistically significant) in the conformance failure rate YOY.¹²

The governmentwide Section 508 compliance for the top viewed ICT remains Low, with approximately less than one-third of all top-viewed ICT reporting as fully conformant:

• 23% of top viewed publicly available internet web pages fully conforming to Section 508 standards.

• 20% of the top viewed internal intranet web pages fully conforming to Section 508 standards.

• 25% of the top ten viewed electronic documents posted publicly fully conforming to Section 508 standards.

• 34% of the top five viewed videos fully conforming to Section 508 standards.

Figure 4. YOY comparison of percentage of fully conformant ICT for all top intranet web pages, internet web pages, electronic documents, and videos tested (Q71 to Q76-78)

Data for the top viewed ICT across reporting entities points to a trend of stagnation in accessibility efforts rather than significant progress or regression in the most viewed types of ICT. Despite targeted initiatives and detailed guidance, the majority of reporting entities are maintaining the same level of conformance YOY, with more than 60% showing no movement across all most viewed content types. The breakdown by ICT type is further detailed in Top Viewed Intranet and Internet Web Pages and Top Viewed Electronic Documents and Videos below.

Top Viewed Intranet and Internet Web Pages 

230 reporting entities provided two years of data to analyze. More than half of the entities (61% or 141) reported no change YOY in their compliance of top viewed public internet pages and even more entities (72% or 165) reported no change in compliance of their intranet pages. A full breakdown of the entity counts with YOY top viewed web page changes can be found in Table 2.

22% of entities reported more conformant top viewed internet pages in FY24 but only 12% of entities reported more conformant top viewed intranet web pages in FY24. 

Several factors contribute to the types of changes:

• Some increases in compliance are a result of testing content this year.¹³

• Some decreases in compliance are a result of not testing content this year whereas they reported test results last year.

• Some of the top viewed pages are not the same as last year. 

• Some entities fixed part or all of the content that was not fully conformant last year and that web page remained in the top viewed in FY24.

• Lack of change YOY may be due to either a lack of resources to test content both years or conformance level was the same both years. It may not be an overall indication of ICT conformance.

Of all reporting entities, only 123 (or 50%) of respondents provided results for the top 10 viewed public internet web pages. 115 entities (or 47%) reported not having resources to test and 7 entities reported Not Applicable because they do not have public internet web pages.¹⁵ Overall, entities reported on conformance of 1,161 top viewed public internet web pages in FY24 compared to 1,129 in FY23.

Fewer reporting entities provided results for top 10 viewed internal intranet web pages, with only 78 entities, or 32% of respondents providing data. Many more entities, 142 or 58%, reported no resources to test their most viewed intranet pages, with 25 entities reporting not having an intranet. Overall, in FY24, 712 intranet web pages were tested compared to 824 in FY23.

Several possible reasons for a decrease in the number of entities who tested intranet web pages include:

• Lack of prioritization of intranet testing.

• Intranet testing is more time consuming.

• Lack of staff or capabilities to perform comprehensive testing.

• Challenges related to identifying the top viewed intranet pages.

Top Viewed Electronic Documents and Videos

Less than half of all reporting entities (42%) provided results for the top viewed electronic documents. Over half of all reporting entities (53% or 131 respondents) reported no resources to test the top viewed electronic document, while 11 entities selected that they do not post any electronic documents. In total, 945 top viewed electronic documents were tested in FY24, compared to 905 in FY23.

Ninety-two entities (38%) provided data for their top viewed videos. 114 entities (47%) noted they did not have resources to test and 39 entities reported that they do not produce or host videos. In total, 435 top viewed videos were tested in FY24, compared to 407 in FY23.

For entities with no YOY change for electronic documents:

• 2 entities reported that they did not have electronic documents in either year. 

• 15 entities remained at 100% conformance for electronic documents. 

• 2 entities maintained the same level of compliance (between 20% - 60%).

• 125 entities reported no change due to either a lack of resources to test content both years or 0% conformance of documents tested both years. 

For entities with no YOY change for videos:

• 16 entities noted they did not have videos in either year. 

• 23 entities remained at 100% conformance for videos. 

• 117 entities reported no change due to either a lack of resources to test content both years or 0% conformance of videos tested both years. 

The data for top viewed ICT indicate that reporting entities are essentially treading water in their accessibility efforts. Furthermore, the counts for increased and decreased conformance between FY23 and FY24 are relatively balanced, which suggests that respondents that did make changes largely offset respondents that declined. This balance shows that improvements in some areas are being offset by declines in others, reinforcing an overall pattern of stagnation. 

Compliance of Widely Used ICT

To expand the scope and breadth of ICT products, the Assessment asked about ten specific ICT products used internally by employees and the public. The list of products asked about in FY24 differs from FY23.¹⁶ These new questions asked entities to estimate conformance levels of the following enterprise-wide products:

• Conference or workstation reservation systems

• Survey authoring tool 

• Surveys distributed by the reporting entity

• Chat or real-time messaging system

• Learning management systems

• Publicly posted Section 508 or digital accessibility policy

• Video player 

• Most widely-used public facing fillable form

• Publicly posted FY 25 Congressional Justifications 

• Employee performance portals or equivalent. 

In addition to new ICT, the response options also offered more granularity in how conformant each ICT was. Instead of asking a yes or no question regarding full conformance, the response options asked entities to calculate the percentage of conformance and select between three ranges or select 100% conformant. 

While 100% conformance is the Section 508 standard, few entities reported full conformance of their ICT products. As Figure 5 depicts, the ICT product with the highest percentage of full conformance to applicable standards was the entity’s publicly posted Section 508 policy at 42.4% followed by enterprise-wide chat or real-time messaging system at 32.7%. The ICT product with the lowest percentage of full conformance to applicable standards was the employee performance portal with only 6.9% of entities reporting 100% conformance. This may deeply impact federal employee’s abilities to independently access and use their performance portal to complete required job performance documentation.

Figure 5. Percentages of entities reporting 100% conformance for commonly used ICT products.

The number of reporting entities with 90% or more conformance for ICT products increased , which suggests that while some ICT products may still have some accessibility issues, they may be close to fully conformant. The highest conformance percentage was still the publicly posted Section 508 policy at 61.2% of entities who conform to 90% or more of the standards followed closely again by enterprise-wide chat or real-time messaging system at 60.8% of entities. However, the lowest conforming category was surveys released by entities, with only 27.8% of reporting entities noting conformance with 90% or more of standards. 

Figure 6. Percentage of reporting entities reporting 90% or more conformance by products used internally and by the public (Q80-Q89).

This year, the Assessment asked several questions regarding the accessibility and functionality of enterprise-wide virtual meeting platforms, such as Zoom, Teams, Webex, Adobe Connect, and Google Meet. As most meetings now occur virtually, it is imperative that all federal employees and members of the public have access to accessible virtual meetings. An overwhelming majority of entities reported their virtual meeting platform can be accessed and used by all disability groups, suggesting broad efforts to promote inclusivity in digital communication tools. A majority also indicate their platforms incorporate features or functions to display captions, spotlight or pin American Sign Language interpreters, increase font sizes, restrict use of inaccessible features, and disable motion, demonstrating widespread attention to providing features that support users with disabilities.

Reviewed/Updated: December 2024