Login.

gov Accessibility Conformance Report (ACR)

Revised Section 508 Edition
(Based on VPAT® Version 2.4Rev)

Name of Product/Version
Identity Verification (IdV)

Report Date
March 3, 2023

Product Description
Login.gov is a secure sign in service used by the public to sign in to participating government agencies . Some agencies require an applicant
to verify their identity. Identity verification is the process where a user proves their identity by uploading documents and information to
Login.gov. Login.gov only confirms that the applicant is who they claim to be and does not make any determination of eligibility for agency
services.

Contact Information
Email: [email protected]

Notes
This report only covers the identity verification process, and does not include the authentication process. The report for the authentication
process is available as a PDF file (Updated August 3, 2021).

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Evaluation Methods Used
Login.gov used moderated and manual usability testing to determine accessibility compliance. The identity verification process was
evaluated using these methods:

● Cognitive disability study: Moderated, remote usability testing with four participants who identify as having a cognitive disability
● Blind disability study: Moderated, remote usability testing with two participants who identify as blind
● Automated, manual, and screen readers
○ Automated: Used WebAIM Web Accessibility Evaluation Tool (WAVE) extension (Chrome 3.1.6) as an automated testing tool
○ Manual, including automated: Used Microsoft Accessibility Insights for Web (Chrome 2.35.0) as both an automated and
manual testing tool to check for ~55 of the most common issues and an in-depth assessment of 23 areas
○ Screen readers: Used assistive technologies
■ Apple VoiceOver on a MacBook Pro with macOS Monterey 12.6
■ Apple VoiceOver on an iPhone 12 with iOS 16.2
■ NVDA 2022.3.2 on a Windows 11s laptop
■ In addition, the simulation environment included:
● On a desktop, a mouse was disabled to simulate a keyboard-only navigation experience
● On a desktop, a monitor was covered (or “curtain-ed”) to simulate the environment of not having access to visual
information; Also, on an iPhone, the curtain mode was enabled.

Evaluation limitations of each method

● Cognitive disability and blind disability studies: Both study samples are small; however, the trends are consistent among each set of
participants. We will seek opportunities to broaden the sample size and diversity.
● Screen readers:
○ The limitation of simulation: The evaluator responsible for conducting the VPAT assessment is a sighted person. To mitigate
this limitation, the evaluator also conducted sessions with two blind participants.
○ The limitation of accessing a variety of screen readers: Since the evaluator does not have access to a JAWS screen reader and
an Android device with TalkBack this evaluation lacks representation of both technologies. To mitigate the JAWS issue, the
evaluator conducted a session with a JAWS user.

Applicable Standards/Guidelines
This report covers the degree of conformance for the following accessibility standard/guidelines:

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 Standard/Guideline Included In Report

Web Content Accessibility Guidelines 2.0 Level A (Yes)

Level AA (Yes)
Level AAA (No)

Revised Section 508 standards published January 18, 2017 and corrected January 22, 2018 (Yes)

Terms
The terms used in the Conformance Level information are defined as follows:

● Supports: The functionality of the product has at least one method that meets the criterion without known defects or
meets with equivalent facilitation.
● Partially supports: Some functionality of the product does not meet the criterion.
● Does not support: The majority of product functionality does not meet the criterion.
● Not applicable: The criterion is not relevant to the product.
● Not evaluated: The product has not been evaluated against the criterion. This can be used only in WCAG 2.0 Level AAA.

WCAG 2.0 Report

Tables 1 and 2 also document conformance with Revised Section 508:

● Chapter 5 – 501.1 Scope, 504.2 Content Creation or Editing

● Chapter 6 – 602.3 Electronic Support Documentation

Note: When reporting on conformance with the WCAG 2.0 Success Criteria, they are scoped for full pages, complete processes,
and accessibility-supported ways of using technology as documented in the WCAG 2.0 Conformance Requirements.

Table 1: Success Criteria, Level A

Notes: None

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 Criteria Conformance Level Remarks and Explanations
The website presents sufficient text alternatives for
most instances of non-text content.

Exception: One of the illustration images is read as

1.1.1 Non-text Content (Level A) Partially supports “image,” which does not provide sufficient
description

A resolution for the exception is tracked and

planned.

The website does not contain prerecorded

1.2.1 Audio-only and Video-only (Prerecorded) (Level A) Not applicable
audio-only or video-only materials.

The website does not contain prerecorded

1.2.2 Captions (Prerecorded) (Level A) Not applicable
synchronized media.

The website does not contain prerecorded video

1.2.3 Audio Description or Media Alternative
Not applicable content that requires audio description or media
(Prerecorded) (Level A)
alternative.
Most information, structure, and relations conveyed
on the website are programmatically determined or
available in text.

Exceptions include
● The “Add your ID” file input component has
state changes, which could confuse an
1.3.1 Info and Relationships (Level A) Partially supports
assistive technology user.
● The “Zip code” field uses an <input
type=”tel”> element, which would include
“telephone” in a screen reader
announcement when it should not.

Resolutions for exceptions are tracked and planned.

The website content is presented in a meaningful

1.3.2 Meaningful Sequence (Level A) Supports
and programmatically determined sequence.

The website does not rely solely on sensory

1.3.3 Sensory Characteristics (Level A) Supports
characteristics.

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 Criteria Conformance Level Remarks and Explanations
The website does not use color as the only visual
1.4.1 Use of Color (Level A) Supports
means of conveying information.

The website does not contain audio that plays

1.4.2 Audio Control (Level A) Not applicable
automatically.

The functionality of website content is operable

through a keyboard interface.

2.1.1 Keyboard (Level A) Supports Note: This criterion excludes any underlying
function that requires input depending on the user’s
movement, e.g., taking pictures of a document with
a mobile phone.

2.1.2 No Keyboard Trap (Level A) Supports The website does not include keyboard traps.

The website includes a mechanism to extend the

2.2.1 Timing Adjustable (Level A) Supports time when a time limit is applicable and does not
compromise security.

The website does not include elements that move,

2.2.2 Pause, Stop, Hide (Level A) Not applicable
blink, scroll, or auto-update.

2.3.1 Three Flashes or Below Threshold (Level A) Not applicable The website does not contain flashing content.

The website has a “Skip to main content” link,

2.4.1 Bypass Blocks (Level A) Supports providing a mechanism to jump to the first element
of the main content.

The webpages have titles that describe topic or

2.4.2 Page Titled (Level A) Supports
purpose.

The website’s components receive focus in a

2.4.3 Focus Order (Level A) Supports
meaningful order.

The purpose of each link can be determined from

2.4.4 Link Purpose (In Context) (Level A) Supports the link text alone or the link text together with its
programmatically determined link context.

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 Criteria Conformance Level Remarks and Explanations
The language of each webpage can be
3.1.1 Language of Page (Level A) Supports programmatically determined by HTML lang
attribute.

The website’s components do not initiate a change

3.2.1 On Focus (Level A) Supports
of context when receiving focus.

The website components do not automatically cause

3.2.2 On Input (Level A) Supports
a change of context on user input.

When an input error is automatically detected, the

3.3.1 Error Identification (Level A) Supports error is identified and described in the text with
multiple cues.
Most input fields are provided with a label or an
instruction.

Exception: The “How should we send a code?”

content contains two radio buttons that do not
include a legend label. While the radio buttons are
3.3.2 Labels or Instructions (Level A) Partially supports
located within the text section that explains the
purpose of the radio buttons, the lack of a fieldset
could impact a screen reader user.

A resolution for the exception is tracked and

planned.
The website uses semantically correct markup for
interface elements.

4.1.1 Parsing (Level A) Supports Note: Automated accessibility tests are

implemented and enhanced to check for HTML
markup validity, e.g., incomplete tag, invalid nesting,
and duplicate attributes.

The website components have name, role, and value

4.1.2 Name, Role, Value (Level A) Supports
that can be programmatically determined.

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Table 2: Success Criteria, Level AA
Notes: None

Criteria Conformance Level Remarks and Explanations

The website presents sufficient text alternatives for
most instances of non-text content.

Exception: One of the illustration images is read as

1.2.4 Captions (Live) (Level AA) Not applicable “image,” which does not provide sufficient
description

A resolution for the exception is tracked and

planned.

The website does not contain a prerecorded video

1.2.5 Audio Description (Prerecorded) (Level AA) Not applicable
that would require an audio description.

The website visual presentation of text has a

1.4.3 Contrast (Minimum) (Level AA) Partially supports
contrast ratio of at least 4.5:1.

The website text can be resized without assistive

1.4.4 Resize text (Level AA) Supports technology up to 200 percent without loss of
content or functionality.

The website uses text rather than images of text to

1.4.5 Images of Text (Level AA) Supports
convey information.

The website is primarily experienced in a sequential

manner where the webpage is the result of, or a step
2.4.5 Multiple Ways (Level AA) Supports in, a process. When applicable, the website provides
links between webpages for users who need to start
over or to update.

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 Criteria Conformance Level Remarks and Explanations
Most headings and labels are descriptive.

Exception: The “How should we send a code?”

content contains two radio buttons that do not
2.4.6 Headings and Labels (Level AA) Partially supports
include a legend label. While there is a text section
that explains the purpose of the radio buttons, the
lack of a fieldset could impact an assistive
technology user.
Most focusable elements on the website have a
visible keyboard focus indicator.

2.4.7 Focus Visible (Level AA) Partially supports Exception: When JAWS users are not using the Auto
Forms Mode, the virtual cursor outline may not
create a consistent navigation experience when
interacting with radio button content.

The language of each content section is

3.1.2 Language of Parts (Level AA) Supports
programmatically determined.

The website provides consistent and repeatable

3.2.3 Consistent Navigation (Level AA) Supports
navigation orders.

Most components and elements that have the same

functionality within the website are identified
consistently.

3.2.4 Consistent Identification (Level AA) Partially supports Exception: A non-text illustration is not consistent
with other text alternatives.

A resolution for the exception is tracked and

planned.
When an input error is automatically detected, and a
suggestion is known, an error message is provided
3.3.3 Error Suggestion (Level AA) Supports with a suggestion. Also, the message may provide a
description of an error unless it compromises the
security of the user.

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 Criteria Conformance Level Remarks and Explanations
The website does not contain financial transactions
but does include a legal commitment (or an
3.3.4 Error Prevention (Legal, Financial, Data)
Supports agreement) and sensitive data sharing. A required
(Level AA)
check or confirmation is available as a mechanism in
a few instances when applicable.

Table 3: Success Criteria, Level AAA

Notes: While the VPAT 2.4 Rev 508 does not require Login.gov to meet Success Criteria (AAA), Login.gov strives to meet or beyond them
when applicable.

Criteria Conformance Level Remarks and Explanations

The website does not contain prerecorded
1.2.6 Sign Language (Prerecorded) (Level AAA)
Not applicable synchronized media that require sign language
Revised Section 508 – Does not apply
interpretation.
1.2.7 Extended Audio Description (Prerecorded) (Level The website does not contain prerecorded
AAA) Not applicable synchronized media that require extended audio
Revised Section 508 – Does not apply description.

1.2.8 Media Alternative (Prerecorded) (Level AAA) The website does not contain prerecorded
Not applicable
Revised Section 508 – Does not apply synchronized media that require media alternatives.

1.2.9 Audio-only (Live) (Level AAA) The website does not contain live audio-only content
Not applicable
Revised Section 508 – Does not apply that requires alternatives for time-based media.

Most visual presentation of text has a contrast ratio

of at least 7:1 and 4:5:1 for large text.

Exceptions (Does not meet Level AAA)

1.4.6 Contrast (Enhanced) (Level AAA)
Not applicable ● An element that use Login.gov’s primary
Revised Section 508 – Does not apply
color (Blue) for a non-bolded text have a
contrast ratio of 5.14:1 on a white background
● A hint text has a contrast ratio of 4.54:1 on a
white background

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 Criteria Conformance Level Remarks and Explanations
The website does not contain prerecorded
1.4.7 Low or No Background Audio (Level AAA)
Not applicable audio-content that require low or no background
Revised Section 508 – Does not apply
audio.

1.4.8 Visual Presentation (Level AAA) The website has a mechanism available to support
Supports
Revised Section 508 – Does not apply text configuration.

1.4.9 Images of Text (No Exception) (Level AAA) The website does not use images of text as pure
Not applicable
Revised Section 508 – Does not apply decoration.

All content, except one, is operable from the

keyboard.
2.1.3 Keyboard (No Exception) (Level AAA)
Not applicable
Revised Section 508 – Does not apply Exception: The act of taking pictures of a document
with a mobile depends on the path of the user’s
movement, not with a keyboard.
For security reasons, timed interaction is necessary.
Login.gov ends a session when the user hasn’t
2.2.3 No Timing (Level AAA)
Not applicable moved to a new page for a specific amount of time.
Revised Section 508 – Does not apply
In these instances, the website provides users to
adjust the time when appropriate (2.2.1).
The website contains an interruption that requires
2.2.4 Interruptions (Level AAA) immediate action to preserve the security of the
Not applicable
Revised Section 508 – Does not apply user, which is qualified as an “emergency” under the
WCAG 2.0 criterion.

2.2.5 Re-authenticating (Level AAA) For security reasons, the user’s data is not saved
Not applicable
Revised Section 508 – Does not apply after being logged out due to a period of inactivity.

2.3.2 Three Flashes (Level AAA) The website does not contain anything that flashes
Supports
Revised Section 508 – Does not apply more than three times in any one-second period.

2.4.8 Location (Level AAA) A step indicator component is available, providing

Supports
Revised Section 508 – Does not apply information about the user’s location on the website.

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 Criteria Conformance Level Remarks and Explanations
Most links can be determined from the link text
alone.

Exception: A webpage has a “Learn more” link,

2.4.9 Link Purpose (Link Only) (Level AAA)
Not applicable which is not sufficient to be determined from the
Revised Section 508 – Does not apply
link text alone.

A resolution for the exception is tracked and

planned.

2.4.10 Section Headings (Level AAA) The section headings are used to organize the
Supports
Revised Section 508 – Does not apply content throughout the website.

While the website uses plain language, Login.gov

3.1.3 Unusual Words (Level AAA)
Not Evaluated has yet to evaluate and develop a mechanism for
Revised Section 508 – Does not apply
identifying unusual words.
While the website uses plain language, Login.gov
3.1.4 Abbreviations (Level AAA)
Not evaluated has yet to evaluate and develop a mechanism for
Revised Section 508 – Does not apply
identifying abbreviations.
While the website uses plain language, Login.gov
3.1.5 Reading Level (Level AAA)
Not evaluated has yet to evaluate and develop a mechanism for
Revised Section 508 – Does not apply
identifying reading level.
While the website uses plain language, Login.gov
3.1.6 Pronunciation (Level AAA)
Not evaluated has yet to evaluate and develop a mechanism for
Revised Section 508 – Does not apply
identifying pronunciation.

3.2.5 Change on Request (Level AAA) The website content gives full control of changes of
Supports
Revised Section 508 – Does not apply context.

3.3.5 Help (Level AAA) The website provides context-sensitive help related
Supports
Revised Section 508 – Does not apply to the function currently being performed.

The website provides all three error prevention

3.3.6 Error Prevention (All) (Level AAA)
Supports methods as safeguards, depending on the context:
Revised Section 508 – Does not apply
Reversible, Checked, and Confirmed.

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Revised Section 508 Report
Notes: None

Chapter 3: Functional Performance Criteria (FPC)

Notes: For more detailed information regarding the remarks and explanations, contact Login.gov at [email protected].

Criteria Conformance Level Remarks and Explanations

The website requests document capture or upload
that is not usable for users without vision.

302.1 Without Vision Partially supports The website contains alphanumeric characters in a
few instances such as a one-time code, which could
be challenging to memorize or parse with assistive
technology.
The website requests document capture or upload
that is not usable for users with limited vision.

302.2 With Limited Vision Partially supports The website contains alphanumeric characters in a
few instances such as a one-time code, which could
be challenging to memorize or parse with assistive
technology.
In an instance when a meaning of color is
communicated, it is adjoined with a descriptive text
302.3 Without Perception of Color Supports
and/or icon to ensure perceivability and
understandability.
The website sends a one-time code, which Login.gov
provides an option of receiving as a text message
(SMS) instead of a phone call (voice).
302.4 Without Hearing Supports
Note: The code is repeated several times to ensure
understandability if the user chooses a phone call
(voice) option.

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 Criteria Conformance Level Remarks and Explanations
The website provides two options for receiving a
one-time code: Text message (SMS) or Phone call
(Voice).
302.5 With Limited Hearing Supports
Note: The code is repeated several times to ensure
understandability if the user chooses a phone call
(voice) option.

The website does not require any speech to be used

302.6 Without Speech Not applicable
for input, control, or operation.

Login.gov has yet to test with users with limited

302.7 With Limited Manipulation Not evaluated
manipulation for this product.

Login.gov has yet to test with users with limited

302.8 With Limited Reach and Strength Not evaluated
reach and strength for this product.

Login.gov uses plain language throughout the

webpages that helps make the website readable for
all users.

Exception: While users with cognitive disabilities

302.9 With Limited Language, Cognitive, and Learning were able to navigate and complete identity
Partially supports
Abilities verification, there are aspects of the flow that are
repetitive and confusing to these users. The flow is
also longer than these users feel is appropriate.
More work is needed to evaluate an identity
verification flow that is simple and streamlined to
follow.

Chapter 4: Hardware
Notes: Login.gov does not create hardware that transmits information or has a user interface. For this reason, the chapter has been omitted.

Chapter 5: Software
Notes: Login.gov does not contain platform software that has access to platform accessibility services. For this reason, the chapter has been
omitted.

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Chapter 6: Support Documentation and Services
Notes: While Login.gov provides support documents and services, it is considered a separate product entity since it overlaps with other
products. For this reason, the chapter has been omitted.

What’s next
Goal 1: Meet Conformance Level AAA Rating
Meet WCAG Levels A and AA, and applicable sections of the WCAG 2.0 AAA conformance level. Priorities include these:

● Improve contrast ratio in the visual presentation of text

● Determine each mechanism to evaluate for unusual words, abbreviations, reading level, and pronunciation

WCAG 2.0 conformance level AAA includes several criteria pertaining to language and multilingualism. By addressing certain functional and
design elements, Login.gov will remove barriers preventing users from completing the identity verification process. Priorities include these:

● Continue to explore the possibility of adding additional languages beyond English, French (Canada) and Spanish (Mexico)
● Improve translations capabilities and proficiency

Goal 2: Usability Testing

A key aspect of building an inclusive Login.gov is incorporating direct public feedback in our research. Priorities include these:

● Regularly conduct usability testing of new features with persons who have disabilities
● Provide a variety of support options for identity verification including:
○ In person proofing (IPP)
○ Phone support for identity verification in addition to email support
● Discover challenges and gaps in the identity verification process for users who:
○ Are novice English speakers (ESL)
○ Are assistive technology users, such as those who use a braille display

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