The method, applied · published accessibility statements
You published a statement. It is being read against a date
The same tracing work, pointed at your own accessibility statement. What does it claim, what does the regulation require alongside it, and where does the chain between them break. We read it the way a complainant, a reviewing agency, or your own counsel will.
Worked example · one statement, read twice
The same paragraph, from two sides
What you published
“[Entity] is committed to providing a website that is accessible to all users. Our website should be in compliance with Section 508 of the Rehabilitation Act. We use the Web Content Accessibility Guidelines (WCAG) 2.0 Level AA.”
Illustrative composite. Not drawn from any single entity's published statement.
What a reviewer reads
Section 508 binds federal departments and agencies. It does not set the obligation of a Virginia public body.
WCAG 2.0 is not the incorporated standard. 28 C.F.R. § 35.200(b)(3) incorporates WCAG 2.1 Levels A and AA.
No compliance date, and two are in circulation. Scope reads “our website,” which does not reach the portals your users sign in to.
Nothing in what you published is careless. Every element of it is a real provision of federal law. The difficulty is that they are assembled into a claim about an obligation that a different provision creates, and that obligation has a date attached.
The trigger
Two clocks, and they may not agree
The federal compliance dates were amended by an interim final rule published April 20, 2026. Virginia set its own dates in the enactment clause of HB 2541, passed in 2025, and the General Assembly adjourned five weeks before the federal rule issued.
Population 50,000 or more
Federal: April 26, 2027.
Virginia, HB 2541: April 24, 2026.
Population under 50,000
Federal: April 26, 2028.
Virginia, HB 2541: April 26, 2027.
Unsettled
Whether Virginia's dates survive the federal extension is contested. One reading holds that the dates sit in session law a federal agency cannot amend. Another holds that § 2.2-3502 cross-references the federal regulation dynamically, so the state date follows the federal one.
We do not choose between them. We record both, cite both, and set out what each would require of you. That ambiguity is the reason a cited review is worth more than an opinion.
The review
What we look at
A written review of how your published position reads from the outside, and a statement you can defend.
Your statement, against the standard it names
Which authority it cites and whether that authority sets your obligation. Which version of WCAG, at which level, and whether it is the version incorporated by reference. Whether it claims conformance, aspires to it, or leaves the reader unsure which.
Your scope, against your estate
What the statement covers and what your users actually have to sign in to. Subdomains, student and family portals, payment and registration services, board policy systems. Where a service is supplied under contract, § 35.200(a) makes it yours.
Your remedy, against § 35.107
Whether a responsible employee is designated and named, whether grievance procedures are published rather than merely a contact address, and whether the route a user is told to take actually resolves.
Your suppliers, against § 2.2-3503
Which vendors hold your content, what each has certified, and whether you hold an Accessibility Conformance Report and a Vendor Accessibility Roadmap for the systems that need one. Renewal is when you can ask.
Boundaries
What this is not
Stated plainly, because a service implying coverage it lacks is worth less than a narrow one.
Not a conformance test
We run automated checks to orient the review. Automated tools detect a minority of conformance failures under any ruleset, so they cannot establish that a site conforms, and the absence of a finding is not evidence of conformance. This review makes no conformance determination and is not a conformance report.
Not certification
We do not attest conformance, and we will not tell you your position is adequate so that you can publish that.
Not remediation
We do not write, fix, or configure. Where the work is engineering it belongs with your platform team or your supplier.
Not legal advice
Where the question is legal it belongs with counsel, and we will say so.
Why us
The same method, from your side
Our practice traces documents to the authority that governs them and shows where the chain has broken. Applied to a vendor, it produces a picture of how their conformance report reads to you. Applied to your own statement, it produces the same picture from the other end.
We do not maintain the authorities. We maintain the trace: which instrument governs Virginia libraries, school divisions and higher education, whether it is still the operative version, and what moved. Every claim we make carries its source and the date we retrieved it, and where a question is unsettled we say so rather than choosing the convenient answer.
Not a claim to be the deepest accessibility specialists in the market. A claim to have worked out, in writing, what a careful reader will ask you.
Scope and price
Fixed scope, fixed price, a deliverable you keep
Conformance Readiness Review: $7,000
Two weeks. Your published accessibility statement read against the authority that sets your obligation and the standard the regulation incorporates, your stated scope reviewed against the estate your users actually sign in to, and your grievance route checked against § 35.107. Delivered as a written review and a position you can defend.
Additional statements
The review covers one published statement and the estate it names. Where separate schools, campuses or branches publish their own, each is scoped and priced in the statement of work before work begins.
What we need from you
Your published accessibility statement, a list of the systems your users sign in to, any conformance documentation you hold from your suppliers, and thirty minutes with whoever owns the page internally. Findings go to you alone. We do not share, publish, or discuss your position with anyone.
See the method on one page first
Send us one published accessibility statement and we will read it against the regulation that governs you, then send back a page of findings at no charge. Same method, smaller scope, and it is how most conversations here begin.
See the free pre-assessment