Australian organizations face a critical decision about their accessibility compliance approach: should they conduct periodic accessibility audits, or implement continuous monitoring? This comprehensive guide explains both approaches, their strengths and limitations, and why continuous monitoring is increasingly becoming the standard for demonstrating due diligence under the DDA 1992.
Key Takeaways
- One-off audits provide valuable insights but become outdated as soon as your website changes
- Continuous monitoring provides ongoing evidence of due diligence - critical for DDA defense
- The optimal approach combines continuous automated monitoring with periodic expert audits
- Continuous monitoring is more cost-effective than frequent professional audits
What is an Accessibility Audit?
An accessibility audit is a comprehensive, point-in-time assessment of your website's compliance with accessibility standards, typically WCAG 2.1 Level AA.
Types of Accessibility Audits
Automated Audits
Software tools scan your website for common accessibility issues.
Advantages:
- • Fast and cost-effective
- • Can scan entire websites
- • Consistent and repeatable
- • Good for identifying common technical issues
Limitations:
- • Can only detect ~30-40% of WCAG issues
- • Cannot assess subjective criteria (like content clarity)
- • May produce false positives
- • Cannot test complex interactions
Manual Expert Audits
Accessibility specialists manually test your website using assistive technologies.
Advantages:
- • Comprehensive coverage of WCAG criteria
- • Can assess subjective and complex issues
- • Tests real-world user experience
- • Provides expert recommendations
Limitations:
- • Expensive (typically $5,000-$50,000+)
- • Time-consuming (2-8 weeks)
- • Usually limited to sample of pages
- • Becomes outdated as website changes
User Testing with People with Disabilities
Real users with disabilities test your website and provide feedback.
Advantages:
- • Reveals real-world barriers
- • Provides valuable user perspective
- • Demonstrates commitment to inclusion
- • Can uncover unexpected issues
Limitations:
- • Very expensive and time-consuming
- • Requires careful planning and recruitment
- • Small sample size
- • Not a replacement for WCAG conformance testing
What a Professional Audit Typically Includes
- Automated scanning - Initial automated test of entire site
- Manual testing - Expert review of representative sample pages
- Keyboard navigation testing - All functionality tested via keyboard
- Screen reader testing - Testing with NVDA, JAWS, or VoiceOver
- Color contrast analysis - Verification of all text contrast ratios
- Code review - Examination of HTML semantics and ARIA usage
- Detailed report - Documentation of all issues with remediation guidance
- VPAT documentation - Conformance report suitable for procurement
Cost of Professional Audits in Australia
Typical pricing for accessibility audits from Australian providers:
- Small website (5-10 pages): $5,000 - $10,000
- Medium website (20-50 pages): $15,000 - $30,000
- Large website (100+ pages): $40,000 - $80,000+
- Enterprise application: $50,000 - $150,000+
The Audit Validity Problem
An accessibility audit is only valid for the exact version of your website that was tested. Any content updates, design changes, or new features can introduce new accessibility barriers - meaning your expensive audit is outdated immediately after deployment.
What is Continuous Accessibility Monitoring?
Continuous monitoring involves regular, automated scanning of your website to detect accessibility issues as they arise, combined with ongoing documentation of compliance efforts.
How Continuous Monitoring Works
Automated Scheduled Scans
Your website is scanned regularly (daily, weekly, or monthly) against WCAG 2.1 Level AA criteria.
Issue Detection and Tracking
New accessibility issues are identified and tracked over time, showing both improvements and regressions.
Timestamped Documentation
Every scan generates a timestamped report, creating an audit trail of your compliance efforts.
Trend Analysis
Historical data shows compliance trends over time, demonstrating ongoing commitment to accessibility.
Alerts and Notifications
Get notified when new issues are detected or when your accessibility posture changes.
Benefits of Continuous Monitoring
Always Current
Your compliance data is never more than a few days old, even as your website evolves.
Ongoing Due Diligence Evidence
Demonstrates continuous commitment to accessibility - critical for DDA defense.
Early Detection
Catch new accessibility issues immediately after deployment, before users encounter them.
Cost-Effective
Dramatically less expensive than conducting frequent professional audits.
Scalable
Can monitor entire websites, not just sample pages, regardless of size.
Supports Agile Development
Works with modern continuous deployment practices, testing each release automatically.
Limitations of Continuous Monitoring
It's important to understand what continuous monitoring cannot do:
- Cannot replace comprehensive manual testing for complex interactions
- Cannot assess subjective criteria like content clarity
- Cannot test behind authentication without configuration
- Cannot evaluate user experience as comprehensively as user testing
- Detects ~30-40% of WCAG issues (same as any automated tool)
Head-to-Head Comparison
| Factor | One-Off Audit | Continuous Monitoring |
|---|---|---|
| Cost | $5,000 - $80,000+ per audit | $49 - $199/month |
| Frequency | Once per year (typically) | Weekly or monthly |
| Coverage | 100% of WCAG (manual + automated) | ~30-40% of WCAG (automated only) |
| Validity Period | Until next website change | Always current |
| Time to Results | 2-8 weeks | Minutes to hours |
| Due Diligence Evidence | Point-in-time snapshot | Ongoing documented commitment |
| Pages Tested | Sample (5-50 pages typically) | Entire website |
| Expert Analysis | Yes | No (but can be added separately) |
| Trend Analysis | No | Yes |
| VPAT Generation | Yes | Limited (automated criteria only) |
The Optimal Approach: Hybrid Strategy
The most effective accessibility compliance strategy combines the strengths of both approaches:
Recommended Hybrid Approach
Continuous Monitoring (Ongoing)
Implement automated continuous monitoring as your foundation:
- • Weekly or monthly automated scans
- • Documented history of compliance efforts
- • Early detection of new issues
- • Always-current compliance data
Professional Audit (Annual or Bi-Annual)
Conduct comprehensive expert audits periodically:
- • Full manual WCAG 2.1 AA assessment
- • Expert recommendations for complex issues
- • Assistive technology testing
- • VPAT documentation for procurement
User Testing (As Needed)
Conduct user testing for major releases or redesigns:
- • Real users with disabilities testing key workflows
- • Validates that technical compliance translates to usability
- • Provides valuable insights for improvement
Cost Comparison: One Year
Understanding the economics of different approaches:
Audit-Only Approach
- • 1 professional audit/year
- • Valid for ~2 weeks
- • 48 weeks without current data
- • No trend analysis
Hybrid Approach
- ✓ Continuous monitoring ($588/yr)
- ✓ 1 professional audit/year
- ✓ Always current data
- ✓ Due diligence evidence
- ✓ Expert analysis
Monitoring-Only
- • Continuous monitoring only
- • Always current data
- • Limited coverage (~40%)
- • No expert analysis
Due Diligence and Legal Considerations
From a legal perspective, demonstrating ongoing due diligence is more valuable than point-in-time audit reports.
Why Continuous Evidence Matters
If a discrimination complaint is filed under the DDA, you'll need to demonstrate that you've taken reasonable steps to ensure accessibility. Evidence includes:
- Regular testing and monitoring
- Documentation of issues discovered and remediated
- Ongoing commitment to accessibility
- Resources allocated to compliance
- Staff training on accessibility
A single audit from 11 months ago provides weak evidence of ongoing commitment. Continuous monitoring with documented remediation provides strong evidence.
What Courts and Tribunals Want to See
Based on Australian discrimination cases, evidence of due diligence should show:
- Regular testing - Not just one-off assessments
- Remediation efforts - Evidence you fix issues when discovered
- Process improvement - Systems to prevent future barriers
- Resource allocation - Budget and staff dedicated to accessibility
- Timeline of efforts - Historical record of compliance activities
Legal Perspective
"We took reasonable steps to ensure accessibility" is much more credible when backed by 52 weekly monitoring reports showing consistent effort, compared to a single audit report from the previous year.
Government Procurement Perspective
For government suppliers, continuous monitoring provides additional benefits:
- Always have current compliance data ready for tender submissions
- Demonstrate ongoing commitment, not just pre-procurement testing
- Historical trend data shows continuous improvement
- Can quickly generate reports for different timeframes
- Supplements professional audits with between-audit monitoring
Which Approach is Right for Your Organization?
Choose Continuous Monitoring If:
- ✓ You have limited budget for accessibility compliance
- ✓ Your website changes frequently
- ✓ You want to demonstrate ongoing due diligence
- ✓ You need always-current compliance data
- ✓ You want to catch issues before they impact users
- ✓ You're comfortable addressing issues identified by automated tools
Add Professional Audit If:
- ✓ You're preparing for government procurement
- ✓ You need comprehensive VPAT documentation
- ✓ Your website has complex interactions or functionality
- ✓ You want expert recommendations and guidance
- ✓ You're undergoing a major redesign or rebuild
- ✓ You need to address subjective WCAG criteria
Add User Testing If:
- ✓ You're launching a major new service or product
- ✓ You want to validate real-world usability
- ✓ You serve a diverse user base with disabilities
- ✓ You want deeper insights beyond technical compliance
- ✓ You have budget for comprehensive accessibility investment
The Bottom Line
For most Australian organizations, continuous monitoring should be the foundation of your accessibility compliance strategy, supplemented by periodic professional audits for comprehensive validation and expert guidance.
Start with Continuous Monitoring Today
Begin building your ongoing evidence of due diligence with a free WCAG 2.1 Level AA scan
Legal Disclaimer: This guide provides general information about accessibility compliance approaches in Australia. It does not constitute legal advice. Organizations should consult qualified legal and accessibility professionals for advice specific to their circumstances. The effectiveness of any compliance approach depends on proper implementation and your specific situation. ComplyWeb provides monitoring and compliance evidence but does not guarantee full legal compliance or protection from discrimination complaints.