Partial WCAG conformance means a digital asset meets some, but not all, of the Web Content Accessibility Guidelines success criteria at a given level. It is not a recognized conformance claim under WCAG. A page either conforms fully to a level (A, AA, or AAA) or it does not conform. There is no middle ground in the standard itself.
That said, partial conformance is a reality for most organizations at some point in their accessibility journey. Understanding what it means, how it affects your legal standing, and what to do about it is critical for making informed decisions.
| Factor | Detail |
|---|---|
| Definition | Some WCAG success criteria are met, but full conformance to a level is not achieved |
| Recognized by WCAG? | No. WCAG only recognizes full conformance at Level A, AA, or AAA |
| Legal protection | Partial conformance alone does not satisfy ADA compliance or EAA compliance requirements |
| Common scenario | Organizations mid-remediation or working toward WCAG 2.1 AA or WCAG 2.2 AA |
| Path forward | A (manual) accessibility audit identifies remaining issues so remediation can continue |
How WCAG Defines Conformance
WCAG conformance is binary. To conform at Level AA, every applicable Level A and Level AA success criterion must be satisfied for the full page. If even one criterion is not met on a page, that page does not conform.
WCAG does include a concept called a “statement of partial conformance due to third-party content.” This applies when content from an external source (like an embedded feed or third-party component) introduces issues outside your control. It does not apply to your own content or code.
Outside of that narrow exception, WCAG does not recognize degrees of conformance. You are either at the level or you are not.
Why Do Organizations End Up Partially Conformant?
Most organizations land in a state of partial conformance because they are in progress. They have completed an audit, started remediation, and resolved many issues but not all of them. This is normal and expected during a multi-phase accessibility project.
Other common reasons include new content published without accessibility review, third-party components introducing issues that development teams cannot directly control, legacy code or templates that predate the organization’s accessibility initiative, and reliance on automated scans, which only flag approximately 25% of issues, leaving the rest unidentified.
None of these reasons are unusual. But each one means full WCAG 2.1 AA or WCAG 2.2 AA conformance has not been reached.
Does Partial Conformance Reduce Legal Risk?
It depends on what “partial” looks like and the legal context. Under ADA compliance, courts and plaintiffs look at whether people with disabilities can access and use the website. A site with a few minor issues reads very differently than one with dozens of unresolved accessibility gaps.
Organizations that can demonstrate active, documented progress toward conformance are generally in a stronger position than those with no effort at all. An accessibility statement, audit reports, remediation timelines, and tracking documentation all contribute to showing good faith.
But partial conformance alone is not a legal defense. The ADA does not reference WCAG directly in its statute, and EAA compliance in the European Union maps to the EN 301 549 standard, which itself references WCAG 2.1 AA. In both cases, the expectation is conformance, not partial progress.
The distinction matters: documented progress toward conformance reduces risk. Stopping at partial conformance and treating it as sufficient does not.
Is a Statement of Partial Conformance Worth Publishing?
An accessibility statement that honestly describes where you are, what issues remain, and what your timeline looks like is worth publishing. Transparency builds trust with users and demonstrates organizational commitment.
A statement that overstates your conformance level or implies full conformance when it does not exist creates liability. If your statement says “WCAG 2.1 AA conformant” and an audit or lawsuit identifies significant issues, that statement works against you.
Accessible.org recommends publishing an accessibility statement that is accurate and specific. Name the standard you are working toward. Describe what has been completed. Provide a way for users to report accessibility issues they encounter.
How to Move from Partial to Full Conformance
The path from partial to full WCAG conformance follows the same steps regardless of where you are in the process.
First, a (manual) accessibility audit conducted by a qualified auditor identifies the remaining issues against WCAG 2.1 AA or WCAG 2.2 AA. This is the only way to determine your actual conformance status. Automated scans cannot do this (scans only flag approximately 25% of issues).
Second, remediation addresses each identified issue systematically. Many organizations prioritize based on user impact or risk, resolving the most significant accessibility gaps first.
Third, validation confirms fixes were implemented correctly. An auditor re-evaluates the remediated pages to verify conformance.
Fourth, ongoing monitoring and periodic audits keep conformance current as content changes. WCAG conformance is not a one-time achievement. It requires maintenance.
Accessible.org audits are always fully manual, and the Accessibility Tracker Platform can help organizations manage their issues, track remediation progress, and maintain documentation throughout the project.
What About VPATs and ACRs for Partially Conformant Products?
A VPAT is a template used to produce an Accessibility Conformance Report (ACR). The ACR documents the conformance status of a product against a standard like WCAG 2.1 AA, Section 508, or EN 301 549.
An ACR can and often does reflect a product that is not fully conformant. Each success criterion receives a status: Supports, Partially Supports, Does Not Support, or Not Applicable. A product with “Partially Supports” entries is, by definition, not fully conformant.
This is expected in procurement. Buyers reviewing ACRs understand that most products have some issues. What matters is the severity and scope of those issues and whether the vendor is actively working toward resolution.
An ACR that honestly reflects partial conformance is far more valuable than one that inflates the status. Procurement teams and government agencies are increasingly sophisticated about identifying red flags in ACRs.
Can partial WCAG conformance satisfy procurement requirements?
It depends on the buyer. Some procurement processes require full WCAG 2.1 AA conformance. Others evaluate ACRs on a comparative basis and accept products that are not yet fully conformant if the vendor demonstrates a credible remediation plan. The ACR is the document that tells the story either way.
How long does it take to go from partial to full conformance?
Timeline varies based on the number of issues, the complexity of the digital asset, and the development resources available. A small website might reach full conformance within weeks after an audit. A large web application or platform could take several months of phased remediation and validation.
Should you wait for full conformance before publishing an accessibility statement?
No. An accurate statement published during your accessibility project is better than no statement at all. Describe your current status, the standard you are targeting, your remediation timeline, and how users can report accessibility issues. Update the statement as your conformance status changes.
Partial WCAG conformance is a waypoint, not a destination. Organizations that treat it as their current position on a clear path to full conformance protect their users, reduce legal risk, and build a stronger digital presence over time.
Contact Accessible.org to discuss your current conformance status and the steps to reach full WCAG 2.1 AA or WCAG 2.2 AA conformance.
