In this guide
- 01
Know what conformance means
- 02
See how it lapses
- 03
Keep it from lapsing
Does WCAG conformance last after an audit?
No, not by itself. WCAG conformance holds while the pages stay as tested. When a page changes, the audit result no longer describes it, and a site with few edits lapses slowly.
What WCAG conformance requires, level by level
W3C’s guidance on conformance says “three levels of conformance are defined: A (lowest), AA, and AAA (highest).” One of these WCAG conformance levels must be “met in full.”
For the AA conformance rating set out in WCAG, “the web page satisfies all the Level A and Level AA success criteria” or “a Level AA conforming alternate version is provided.” Four further requirements apply:
This is guidance for WCAG 2.2, not the normative text, and the HHS rule names 2.1. For the standards themselves, read WCAG standards and conformance levels explained.
Why an accessibility audit is a dated snapshot
WCAG-EM, W3C’s evaluation method, requires an evaluation statement to carry the “Date of when the evaluation statement was issued.” For a public statement, “the product owner commits to ensuring the validity and maintaining the accuracy of the evaluation statement made.” The owner carries the statement after the audit, not the auditor.
Audits are often sampled“WCAG 2 conformance claims cannot be made for entire websites based upon the evaluation of a selected sub-set.”
The method also expects repeat evaluation“Evaluation, according to this methodology, may be re-run after a short period.”
WCAG-EM, W3C
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Audit date
-
Content edit
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Plugin or theme update
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New embed or widget
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New page, form or process
The four ways WCAG conformance lapses
Each route changes something the audit tested.
| Route | What changes | Requirement it touches |
|---|---|---|
|
Content edits
|
An image, heading, PDF link, banner or form field | Full pages |
|
Plugin and theme updates
|
A template or plugin that renders on every page | Full pages |
|
New embeds and widgets
|
A video player, chat, map, booking tool or donation iframe | Accessibility-supported uses and non-interference |
|
New pages, forms and processes
|
A volunteer form or donation flow added after the audit | Complete processes |
Content edits
A new image without alt text, a PDF link, a low-contrast banner or an unlabeled form field can each break a criterion that passed at audit. W3C’s guidance says “Be sure to monitor any content that can change without approval from the web page author,” because “a page which once conformed may suddenly fail to conform.”
The WebAIM Million, an automated test of home pages only from February 2026, lists the most common detected failures:
| Detected failure | Home pages |
|---|---|
| Low contrast | 83.9 percent of home pages |
| Missing alt text | 53.1 percent |
| Missing form labels | 51 percent |
| Empty links | 46.3 percent |
| Empty buttons | 30.6 percent |
An editor can introduce each of these in a normal edit. That link is our observation, not WebAIM’s, and the figures are a snapshot, not a measure of decay.
Plugin and theme updates
A change to a theme template, form plugin or menu plugin changes the whole rendered page, and one update can reach every page. Nothing in WordPress compares the result to the audit. No source we found quantifies updates as a cause, so this is mechanism, not a rate.
New embeds and third-party widgets
A video player, chat widget, map, booking tool or donation iframe added later becomes part of the page being judged. Third-party content can also change without anyone at the organization touching it.
New pages, forms and processes
A volunteer form or donation flow added after the audit was never tested. Under W3C’s guidance, “all web pages in the process conform at the specified level or better,” so one failing step fails the process.
What this means for an HHS-funded nonprofit
45 CFR 84.84 sets the dates and the standard. A recipient with 15 or more employees must comply from May 11, 2027, and one with fewer than 15 from May 10, 2028.
The standard is to “comply with Level A and Level AA success criteria and conformance requirements specified in WCAG 2.1.” That is 2.1, not 2.2.
Section 84.84(a) covers content provided directly or through contractual, licensing, or other arrangements. We have not read that clause in full, so check with counsel how it applies to an embed such as a donation form you do not host.
The date sets when the standard applies. Whether pages still conform then depends on what changed after the audit.
How to keep WCAG conformance from lapsing
- 01
Name an owner for each of the four routes: content edits, updates, embeds, and new pages and forms.
- 02
Re-check affected pages after a template or plugin change.
- 03
Test a new form or process end to end before it goes live.
- 04
Keep a list of embedded third-party tools.
- 05
Date your evidence: record when pages were last checked and what changed.
Scanners catch part. WebAIM says “Absence of detected errors does not indicate that a page is accessible or conformant.”
After the next update or new page, compare it against the audited version of the same page. Any change since the audit date is outside what the audit covered.
Updates are one of the four routes, and someone has to run them. NoDrama’s plans include “WordPress, plugins and themes kept current” and visual regression testing, which compares how pages look. It does not test WCAG criteria. NoDrama does no accessibility work, so audits, remediation and WCAG re-checks stay with you and whoever you hire.
Common misreadings of WCAG conformance
What this does not solve
This guide is not an accessibility audit or remediation, and NoDrama’s plans include no accessibility, WCAG, ADA or Section 508 work. It is not legal advice, and applicability depends on funding and headcount. No source we found measures a decay rate.
A conformance claim describes pages as tested, on a date
WCAG conformance is a dated claim about specific full pages and complete processes. Edits, updates, embeds and new pages each change what was tested, so an owner for each route keeps the claim true after the audit.