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Agency accessibility services without the consultancy

How web agencies can package accessibility as a repeatable service: what to scan, what to hand over, and where to bring in a specialist.

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Pavel Charkasau

Agency accessibility services work best as a fixed-scope delivery step, not an open-ended audit practice. The package is deliberately small: a baseline scan of the pages a client's customers actually use, a prioritized fix list your developers work through, a short manual pass on the things a scanner cannot judge, a re-scan that shows what changed, and an honest accessibility statement at handover. Add a monitoring retainer so the site doesn't drift after you leave. That is something you can quote and repeat across a portfolio.

What you leave out matters as much. A formal conformance evaluation under WCAG-EM belongs with a specialist, and so does a VPAT for a procurement team, research with screen-reader users, and anything resembling legal advice. Say so in the proposal. Clients rarely mind hearing where a scope ends. They mind finding out later.

What belongs in an agency accessibility service?

Six deliverables cover most client work. Each has a clear finish line, which is what keeps this from turning into consulting.

A baseline of the real site. Not the homepage. Scan the flows a customer moves through: sign-up, search, checkout, the account area behind the login. Barriers cluster there, and those are the pages people write in about.

A prioritized fix list. The W3C's own guidance on urgent repairs tells you how to sort it. Prioritize repairs that "appear on multiple web pages, such as navigation bars", that are "critical to complete processes, such as purchase forms", and that are "Web Content Accessibility Guidelines (WCAG) Level A issues", alongside low-effort repairs that "require less time, cost, or skills to repair" (W3C WAI). A navigation bar with an unlabeled menu button is one fix that clears the same error on every page of the site. Start there.

A manual pass on a bounded checklist. Keyboard order, focus visibility, whether a screen reader announces something other than "button button". You do not need a certified auditor for this. You need someone on your team who has done it before and a written list, like the WCAG checklist, so the work is the same on every project.

A re-scan after the fixes. The delta is the deliverable. "We closed 41 of the 52 machine-detectable issues, and here are the 11 that need design decisions from you" is a sentence a client can act on.

Then there's the statement. For EU clients it isn't optional, and I'll come back to why below.

Last, monitoring. A site that passed in March drifts by June, usually because someone published a PDF or a marketing team added a hero video without captions. Scheduled re-scans catch that. This is also the part that turns a project fee into recurring revenue.

Where should an agency stop?

Four things sit outside a packaged service, and knowing why protects you.

A formal conformance evaluation is a defined methodology, not a thorough scan. WCAG-EM 2.0 sets out five steps: define the evaluation scope, explore the target product, select a representative sample set, evaluate the selected sample set, report the findings. It expects an evaluator with a "solid understanding of how to evaluate content using WCAG 2, accessible design, assistive technologies, and of how people with different disabilities use digital products" (W3C, W3C Group Note, 23 July 2026). Note what the methodology says about its own output: in most situations, using it alone "does not result in being able to make WCAG 2 conformance claims", because you evaluated a sample. If a specialist working to a published methodology stops short of that claim, an agency should be nowhere near it.

A VPAT or Accessibility Conformance Report is a procurement document. When a client sells to US federal buyers, the report has to survive a contracting officer reading it, and getting it wrong is worse than not having one.

Research with disabled users is its own discipline. A keyboard pass tells you a control is reachable. It doesn't tell you the flow makes sense to someone using a screen reader for the first time.

Legal questions go to the client's counsel. "Are we compliant?" is not a question a scan answers, and answering it anyway is how agencies inherit risk they were never paid for.

Referring this work out costs you less than you think. I'd rather an agency sell a small honest package and hand the audit to a specialist than sell an audit it can't defend in a meeting. The second one ends the client relationship, not just the project.

Who is responsible, the agency or the client?

The client, in almost every case, and your contract should reflect that.

Under the European Accessibility Act, the obligation attaches to the economic operator. Article 3 defines a service provider as "any natural or legal person who provides a service on the Union market or makes offers to provide such a service to consumers in the Union" (Directive (EU) 2019/882). That is your client running the shop, not the studio that built it. Article 13 puts the ongoing duties on that provider: design and deliver the service to the accessibility requirements, publish information explaining how it does so, keep procedures in place as the service and the standards change, and take corrective action if something falls out of line. The requirements have applied since 28 June 2025.

Two practical consequences for an agency. First, your scope is whatever the contract says you built and tested, on the date you tested it. Write that down. Second, the client needs a published accessibility statement covering the service, and they will ask you to write it, because you have the findings. Draft it from actual scan and review results rather than a template, using something like the statement generator, and keep the known gaps in it. A statement documents effort and current state, not a certificate, and one that overclaims is worse than none.

The same split holds elsewhere. EN 301 549 is the standard the client's service is measured against in the EU, and under the ADA or Section 508 in the US the duty sits with the covered entity. You're the supplier.

How do you price it without hourly audit work?

Three moving parts, and only one of them is hourly.

Charge a fixed onboarding fee for the baseline plus the first prioritized fix list. Once you've run it on a few sites you know what it costs you.

Remediation is billed off that list at your normal development rate. It is development, and your team already knows how to quote it.

Sell monitoring as a flat monthly line, and make sure your tooling cost is flat too. Per-scan and traffic-based pricing quietly punishes you for scanning thoroughly, which is the opposite of what you want your delivery team doing. Our own agency plan runs up to 25 sites and 25 team members on one flat per-organization price, with no traffic surcharge, for exactly that reason.

One margin note. White-label output helps here — your name and logo on the exported report is what makes it feel like your service rather than a resold tool. Keep the coverage and manual-review notices visible when you do it. A rebranded report that quietly drops "these are the machine-detectable findings" is how an honest deliverable becomes a false claim with your logo on it.

How do you split the work across your existing team?

You probably don't need a new hire. Most WCAG failures trace back to a decision someone on your team already makes.

The W3C's draft Accessibility Roles and Responsibilities Mapping maps success criteria onto four roles (UX designer, visual designer, content author, front-end developer) and marks each role as primary, secondary, or contributor for a given task. Primary means "accountable for an accessibility task" (W3C WAI ARRM, draft, 24 July 2025). Color contrast belongs to whoever picks the palette. Alt text belongs to the person writing the page. Focus management inside a modal is front-end work and nobody else's. Once each is assigned, accessibility stops being a phase at the end of the build and becomes part of the definition of done for work people already do.

The exception is the manual review pass. Give that to one person and let them get good at it, because a keyboard-and-screen-reader run is a skill that improves fast with repetition.

What should never be in the package?

Overlays, and any word that means "done".

Reselling an accessibility widget puts your agency's name on a claim the US Federal Trade Commission has already ruled deceptive. Its April 2025 final order requires accessiBe to pay $1 million and "bars accessiBe from representing that its automated products can make any website WCAG-compliant or can ensure continued compliance with WCAG over time, unless it has the evidence to support such claims" (FTC). If you put that promise in a client proposal, you own it. Our alternatives pages hold the same line for each widget vendor.

Badges and certificates fail for the same reason. So does any language implying the automated part is the whole job. Automated testing finds a meaningful share of real problems: Deque's analysis of more than 2,000 audits put it near 57% of issues by volume, above the older 20–30% figure based on how many success criteria a tool can evaluate at all (Deque, March 2021). The W3C is blunt about the ceiling: "no tool alone can determine if a site meets accessibility standards" (W3C WAI). Say that in the proposal. It is what makes the manual pass and the retainer make sense to a buyer.

Frequently asked questions

Can a web agency offer accessibility services without hiring an auditor?

Yes, for a bounded scope. An agency can run baseline scans, prioritize and fix machine-detectable issues, do a manual keyboard and screen-reader pass against a written checklist, and produce handover evidence, all with its existing team. A formal conformance evaluation, a VPAT, or a legal opinion needs a specialist.

Who is legally responsible for an accessible website, the agency or the client?

The client, in most cases. Under the European Accessibility Act the duties in Article 13 fall on the service provider, defined as the person providing the service on the Union market (Directive (EU) 2019/882). The agency's exposure comes from its contract and from any claim it makes about the result.

How should an agency price accessibility work?

A fixed onboarding fee for the baseline and prioritized fix list, remediation at the normal development rate, and a flat monthly monitoring retainer. Keep the underlying tooling on flat pricing so thorough scanning doesn't increase your cost per client.

Should an agency resell an accessibility overlay to clients?

No. The FTC's April 2025 order against accessiBe bars claims that an automated product can make a site WCAG-compliant without evidence (FTC). An overlay patches the page at runtime and leaves the client's code unchanged, so the barrier stays and the claim becomes yours.

What should an agency hand over at the end of a project?

The scan history for the client's saved site, the fix list showing what was closed and what remains, the completed manual checklist with who ran it and when, and a drafted accessibility statement that names the known gaps. No certificate, no badge, no score presented as conformance.

Run one on a client site

Pick the client project you're least sure about and scan a page from it — checkout, sign-up, whatever a customer has to get through. You'll see the finding list with the exact element and success criterion, which is the first half of the package described above. Start a free scan, or read how we test on the methodology page.

Sources

Written by Pavel Charkasau, founder of wcagc.com. Last updated 23 August 2026.