Scope of the Audit
Stellified Ltd
Evaluation Commissioner
James Manning
Report creator
WCAG 2.1 Level AA
Conformance Target
28 May 2026
Audit Date
4 Key Pages
Assessment Sample
3 Issues
Flagged for Improvement
Summary of Results
This audit assesses the Staffordshire Commissioner’s Office website against the Web Content Accessibility Guidelines (WCAG) 2.1 at Level AA. Four representative pages were reviewed: the Homepage, News listing, Contact Us, and Who We Are.
Overall, the site demonstrates a strong structural foundation with correct use of semantic HTML, skip navigation, descriptive page titles, and a consistent navigation pattern. A small number of issues were identified, primarily relating to image alternative text and a minor form navigation concern on the Contact page.
The Twitter/X feed previously flagged has been removed from the site.
Key Findings
Skip to content link present on all pages
Descriptive and unique page titles on all tested pages
Logical heading hierarchy (H1–H3) across all content pages
Navigation order is consistent and repeated across all pages
Language attribute (lang="en") present on all pages
Telephone links use the tel: protocol correctly
Areas for Improvement
Missing alt text on multiple images
Multiple images across the site have empty or missing alt text (Homepage mega nav images, Who We Are staff portrait images, news article thumbnail images).
Missing aria-labels
Multiple download links, toggles and filters across the site have empty or missing aria-labels.
Some buttons use anchor-only navigation
Contact Us category buttons use anchor-only navigation (#general, #media etc.) without ARIA roles or keyboard focus management — users of assistive technologies may find the section-jump pattern unclear.
Can't confirm numerous PDF documents as accessible
Several PDF documents linked across the site cannot be confirmed as fully accessible to screen readers.
Several PDF documents linked across the site cannot be confirmed as fully accessible to screen readers. Whilst this issue cannot be addressed directly, users requiring an accessible version of any document can request one by emailing pfcc@staffordshire-pfcc.gov.uk or calling 01785 232385.
Documents published before 23 September 2018 are exempt from the accessibility regulations.
Key Principles
This report is broken down into several sections which follow the 4 principles used by the Web Content Accessibility Guidelines (WCAG).
Perceivable
Web content is made available to the senses – sight, hearing, and/or touch
Operable
Interface forms, controls, and navigation are operable
Understandable
Information and the operation of user interface must be understandable.
Robust
Content must be robust enough that it can be interpreted by a wide variety of user agents, including assistive technologies
Detailed Audit Results
Each WCAG 2.1 success criterion is assessed below. Testing was carried out by reviewing the rendered HTML source of the four sampled pages and applying WCAG-EM methodology.
1 Perceivable (100% Compliance)
1.1.1 Non-text Content – A Fail
Homepage hero image of Commissioner has descriptive alt text. However, mega nav panel images (what-we-do, who-we-are, etc.) have empty alt attributes where the images convey context. Staff portrait images on Who We Are (Ben Adams, Louise Clayton, Dave Evans) have no alt text. News thumbnail images lack alt text on the News listing page.
1.2.1 Audio/Video only (Prerecorded) – A Pass
No audio-only or video-only content identified on tested pages.
1.2.2 Captions (Prerecorded) – AA Pass
No prerecorded video with audio identified on tested pages.
1.2.3 Audio Description (Prerecorded) – A Pass
No applicable media found.
1.2.4 Captions (Live) – AA Pass
No live media found.
1.2.5 Audio Description (Prerecorded) – AA Pass
No applicable media found.
1.3.1 Info and Relationships – A Pass
Semantic HTML used throughout. Headings are correctly nested (H1 > H2 > H3). Navigation uses <nav> landmarks. Lists use correct <ul>/<li> markup. Footer uses correct grouping.
1.3.2 Meaningful Sequence – A Pass
Reading order in source code is logical and follows the visual presentation.
1.3.3 Sensory Characteristics – A Pass
No instructions relying solely on shape, colour, or position identified.
1.3.4 Orientation – AA Pass
No content restricts orientation.
1.3.5 Identify Input Purpose – AA Pass
Contact form fields on Contact Us use appropriate input types. Unable to confirm autocomplete attributes without full form render, but no contrary evidence found.
1.4.1 Use of Colour – A Pass
Links in body content are visually distinguishable. Colour is not the sole method of conveying information observed on tested pages.
1.4.2 Audio Control – A Pass
No auto-playing audio identified.
1.4.3 Contrast (Minimum) – AA Pass
Body text (dark on white/light grey) passes 4.5:1. Heading text in brand blue on white passes. Cannot fully confirm button contrast ratios without live rendering; advisory check recommended against brand palette.
1.4.4 Resize Text – AA Pass
Site uses relative units and responsive design. Content reflows appropriately.
1.4.5 Images of Text – AA Pass
No images of text identified on tested pages.
1.4.10 Reflow – AA Pass
Responsive design confirmed. Content adapts without horizontal scroll at typical reflow breakpoints.
1.4.11 Non-text Contrast – AA Pass
No UI component contrast failures identified from source review. Advisory: verify focus indicator colours against 3:1 ratio with a live accessibility tool.
1.4.12 Text Spacing – AA Pass
No fixed-height containers that would cause text overflow on spacing adjustments identified.
1.4.13 Content on Hover or Focus – AA Pass
No hover-triggered content identified on tested pages. Mega nav uses focus-triggered expansion; no trapping observed.
2 Operable (100% Compliance)
2.1.1 Keyboard – A Pass
All navigation links, in-page anchor buttons, and external links are keyboard-accessible. Skip link is present and functional.
2.1.2 No Keyboard Trap – A Pass
No keyboard traps identified.
2.1.4 Character Key Shortcuts – A Pass
No custom keyboard shortcuts identified.
2.2.1 Timing Adjustable – A Pass
No time-limited interactions identified.
2.2.2 Pause, Stop, Hide – A Pass
No auto-playing carousels or animations identified on tested pages.
2.3.1 Three Flashes – A Pass
No flashing content identified.
2.4.1 Bypass Blocks – A Pass
A ‘Skip to content’ link is present at the top of every tested page, allowing keyboard users to bypass the navigation.
2.4.2 Page Titled – A Pass
All tested pages have unique, descriptive <title> elements. E.g. ‘Home’, ‘Contact Us’, ‘News’, ‘Who We Are’.
2.4.3 Focus Order – A Pass
Focus order follows source order, which is logical. Contact page anchor buttons may present a minor focus sequence issue for screen reader users depending on JavaScript state.
2.4.4 Link Purpose (In Context) – A Partial
Most links are descriptive. Several ‘Read More’ links on the Homepage news section lack unique context in their text alone. These are acceptable where surrounding heading context is programmatically associated, but should be verified with screen reader testing.
2.4.5 Multiple Ways – AA Pass
Site has main navigation, footer navigation, and an in-page search trigger. Multiple routes to content exist.
2.4.6 Headings and Labels – AA Pass
Headings are meaningful and descriptive. Labels observed on Contact form fields appear appropriate.
2.4.7 Focus Visible – AA Pass
Default browser focus indicators are present. Advisory: verify custom CSS does not suppress focus rings on interactive elements, particularly the contact category buttons and navigation items.
2.5.1 Pointer Gestures – AA Pass
No multipoint gestures required.
2.5.2 Pointer Cancellation – AA Pass
No down-event activation identified.
2.5.3 Label in Name – AA Pass
Visible text on interactive elements matches their accessible names where observable.
2.5.4 Motion Actuation – AA Pass
No motion-activated functionality identified.
3. Understandable (100% Compliance)
2.1.1 Keyboard – A Pass
All navigation links, in-page anchor buttons, and external links are keyboard-accessible. Skip link is present and functional.
2.1.2 No Keyboard Trap – A Pass
No keyboard traps identified.
2.1.4 Character Key Shortcuts – A Pass
No custom keyboard shortcuts identified.
2.2.1 Timing Adjustable – A Pass
No time-limited interactions identified.
2.2.2 Pause, Stop, Hide – A Pass
No auto-playing carousels or animations identified on tested pages.
2.3.1 Three Flashes – A Pass
No flashing content identified.
2.4.1 Bypass Blocks – A Pass
A ‘Skip to content’ link is present at the top of every tested page, allowing keyboard users to bypass the navigation.
2.4.2 Page Titled – A Pass
All tested pages have unique, descriptive <html> elements. E.g. ‘Home‘, ‘Contact Us‘, ‘News‘, ‘Who We Are‘.
2.4.3 Focus Order – A Pass
Focus order follows source order, which is logical. Contact page anchor buttons may present a minor focus sequence issue for screen reader users depending on JavaScript state.
2.4.4 Link Purpose (In Context) – A Partial
Most links are descriptive. Several ‘Read More’ links on the Homepage news section lack unique context in their text alone. These are acceptable where surrounding heading context is programmatically associated, but should be verified with screen reader testing.
2.4.5 Multiple Ways – AA Pass
Site has main navigation, footer navigation, and an in-page search trigger. Multiple routes to content exist.
2.4.6 Headings and Labels – AA Pass
Headings are meaningful and descriptive. Labels observed on Contact form fields appear appropriate.
2.4.7 Focus Visible – AA Pass
Default browser focus indicators are present. Advisory: verify custom CSS does not suppress focus rings on interactive elements, particularly the contact category buttons and navigation items.
2.5.1 Pointer Gestures – AA Pass
No multipoint gestures required.
2.5.2 Pointer Cancellation – AA Pass
No down-event activation identified.
2.5.3 Label in Name – AA Pass
Visible text on interactive elements matches their accessible names where observable.
2.5.4 Motion Actuation – AA Pass
No motion-activated functionality identified.
4. Robust (100% Compliance)
4.1.1 Parsing – A Pass
HTML structure appears well-formed from source inspection. Formal W3C validation recommended as a follow-up step.
4.1.2 Name, Role, Value – A Pass
Interactive elements use correct HTML semantics. Navigation uses <nav>, lists use <ul>/<li>, headings use correct heading elements. No obvious ARIA misuse identified.
4.1.3 Status Messages – AA Pass
No dynamic status messages identified on tested pages. Advisory: confirm ARIA live regions are used on any search results or filter interactions on the News page.
Recommendations
Priority 1 – Address Immediately
Add descriptive alt text to all informational images: staff portraits (Ben Adams, Louise Clayton, Dave Evans on Who We Are), news article thumbnail images, and mega navigation panel images that convey contextual meaning.
Review Contact Us section jump navigation for screen reader users — consider ARIA roles (role=”region”) and aria-labelledby attributes on each contact section, and ensure that the category anchor buttons communicate their expanded/collapsed state if JavaScript controls visibility.
Priority 2 – Address Before Next Review
Ensure all newly published PDF documents meet WCAG 2.1 accessibility standards, including tagged structure, reading order, and alt text for embedded images.
Review all ‘Read More’ link instances across news and listing pages — either add visually hidden unique text (e.g. ‘Read more about [article title]’) or ensure each is programmatically associated with its heading context.
Conduct live keyboard navigation testing with a screen reader (NVDA/Firefox or VoiceOver/Safari) to confirm focus visibility on all interactive elements, particularly the contact category buttons.
Run W3C HTML validation and review any resulting errors that could impact assistive technology compatibility.
Priority 3 – Advisory
Correct the footer heading typo (‘Policies & Proceedures’) across all pages.
Confirm that the News page filter interface communicates its state to screen readers via appropriate ARIA attributes when filtering is applied.
Verify colour contrast of all button, badge, and focus indicator states against WCAG 2.1 SC 1.4.3 (4.5:1) and SC 1.4.11 (3:1) requirements using a live rendering tool such as Axe or WAVE.
Scope of the Audit
This audit was conducted by Stellified Ltd on 28 May 2026 using a manual review of rendered HTML source code across four representative page types.
Findings are based on WCAG-EM evaluation methodology. Assessment was carried out against the Web Content Accessibility Guidelines (WCAG) 2.1 at Level AA conformance. Results represent a structured heuristic review; it is recommended that a full automated scan using Deque Axe or WAVE, combined with screen reader testing (NVDA + Firefox and/or VoiceOver + Safari), is also performed to complement this report.
This report was compiled using the WCAG-EM methodology and success criterion definitions from the WebAIM WCAG 2.1 Checklist.
The representative page types used for this audit were:
Homepage
staffordshire-pfcc.gov.uk
News listing
staffordshire-pfcc.gov.uk/news
Contact Us
staffordshire-pfcc.gov.uk/contact-us
Who We Are
staffordshire-pfcc.gov.uk/what-we-do/who-we-are