Accessibility by Default

The standard created to unify the government violates the government's own accessibility standard.

An open audit and governance protocol for government design systems. I audited the Brazilian federal government's official design reference (DSGov) and a university design system (Bold) with the same procedure. I found 277 level AA barriers at the source of public digital services.

  • Undergraduate thesis defended at UFSC, grade 10 out of 10, December 2025
  • Open data
  • Replicable method

Declared conformance is not verified conformance.

Public digital services are essential citizenship infrastructure, not a convenience. Brazilian law guarantees the right of access, and millions of people depend on it every day.

The systems these services are built from declare conformance with WCAG and eMAG. When you audit the code, the declaration does not hold.

18.6 million

people with disabilities in Brazil (8.9% of the population) depend on that access.

IBGE, PNAD Contínua 2022

The barrier is not only in the published screen. It can live in the source that produces the screen.

One source, many services.

Design systems are official component libraries: buttons, forms, menus, tables. Teams across the government copy these components to build their services. It is efficient by design.

And that is exactly why a barrier present in the source tends to repeat in every service that consumes it. Auditing product by product treats the symptom. The cause lives in the source.

Diagram of one source feeding many servicesOne origin node, the design system, connects to five service nodes. Whatever enters the source tends to repeat in every service that consumes it.SourceService 1Service 2Service 3Service 4Service 5
One origin node, the design system, connects to five service nodes. Whatever enters the source tends to repeat in every service that consumes it.

Fixing at the source tends to distribute the fix to every consuming service.

What was audited, and why these two.

Padrão Digital de Governo (DSGov)

The Brazilian federal government's official design standard, published by the Secretariat of Digital Government. It is the reference source for the entire federal government.

Bold Design System

The design system of Laboratório Bridge, at UFSC. An academic counterpoint audited with the same procedure.

Fairness note

The procedure was identical for both: same flow, same battery, same 8 verification categories, same environment. The study also credits what the systems get right: both passed 100% of the visible-focus checks, with no focus trap, across the instrumented components.

Disclosure

The author has an academic affiliation with UFSC. The audit is independent, the procedure is identical, and Bold's internal share of critical failures is higher than DSGov's (40.0% versus 22.3%), which rules out any suggestion of favoritism.

A protocol in four layers.

The method is the Hybrid Audit and Verification Framework. It integrates four complementary layers, converts abstract standards into auditable metrics, and keeps every finding tied to archived evidence.

The four layers

  1. Automated audit

    axe-core, Lighthouse and WAVE over the official component documentation.

  2. Heuristic inspection

    Guided by the WAI-ARIA practices.

  3. eMAG 3.1 checklist

    The Brazilian standard, item by item.

  4. Synthesis matrix

    Consolidation and prioritization of the barriers found.

Counting pipeline

The count goes through an auditable funnel:

  1. Raw

    The full output of the tools.

  2. Deduplication

    By rule plus selector plus context.

  3. AA filter

    Only what violates level AA remains.

Every finding has a 26-field evaluation record, tied to the standard (WCAG, eMAG, WAI-ARIA) and to the evidence.

Reproducible environment

Pinned environment (tool version, browser and viewport recorded), public scripts under the MIT license, data under CC BY 4.0, with SHA-256 hashes. Any team can repeat the steps without asking for permission.

  • MIT (scripts)
  • CC BY 4.0 (data)
  • SHA-256 (integrity)

Per-Component Verification Checklist

Appendix C of the thesis on one page: the priority checks per component, with WCAG and eMAG criteria and the recommended actions for each system.

Download the checklist (PDF, 1 page, in Portuguese)

Source: Xikota, T. K. C. Acessibilidade Digital em Design Systems Públicos, undergraduate thesis, UFSC, 2025, Appendix C.

What the audit found.

277

unique level AA non-conformities in the official documentation of the two systems.

Bold
7527% of the total
DSGov
20273% of the total

Table 4 of the thesis

The illusion of the high score

Meanwhile, the automated accessibility score of the home pages was 98 for Bold and 92 for DSGov. The high score coexists with 75 and 202 verified failures in the documentation.

Bold

Lighthouse score (home page)98

75Verified AA failures (documentation)

DSGov

Lighthouse score (home page)92

202Verified AA failures (documentation)

Text equivalent: Bold scores 98 on Lighthouse for its home page and has 75 verified AA failures in its documentation; DSGov scores 92 and has 202 failures. The score and the failures measure different surfaces: the score looks at the home page, the audit looks at the component documentation. The score does not capture the failures.

A high score is not enough.

Tables 4 and 7 of the thesis

The factory defect

The failures sit in the structure that assisted navigation relies on, and they exist only in the State's system. aria-required-parent (40 occurrences) and listitem (37 occurrences) appear in DSGov and have zero incidence in Bold.

These occurrences live in DSGov's official documentation portal. The government's reference fails its own standard, on its own site.

Table 5 of the thesis

The most frequent barrier

Contrast below 4.5:1 is the most frequent barrier: 128 occurrences across the two systems combined, concentrated in the code example blocks of the reference documentation. In DSGov, contrast accounts for about 53% of the failures.

The measured contrast ratios include 4.02:1 and 3.75:1 in Bold and 3.07:1 and 3.58:1 in DSGov, all below the 4.5:1 minimum.

Section 4.4.5 and Chart 2 of the thesis

Re-audit

I re-ran the protocol against the live version of both systems on July 30, 2026, with a pinned environment, and recorded the diffs against the September to November 2025 collection in the open dataset. None of the study's anchor numbers changed.

From abstract standard to design decision.

WCAG and eMAG are dense standards. The framework translates them into operational decisions of design, code and governance, organizing each barrier by the human capability it affects.

Failures by human capability (POUR synthesis)
Perceivable41 of 137 checks
Operable19 of 45 checks
Understandable15 of 20 checks
Robust0 of 0 checks

The zero under Robust is a classification artifact, not an absence of errors: the ARIA structure errors were coded under another guideline (1.3.1).

Reading by capability prioritizes fixes by their effect on the person, not by the order of the tool. Designing the system that produces the interfaces is higher-order design. The delivered artifact is that system.

Four mechanisms to keep the barrier out of the source.

  1. Accessibility gate in CI/CD

    With a non-regression policy. No new component enters the source with a barrier the battery can detect.

  2. Per-component accessibility contract

    In the Definition of Done. Accessibility becomes a criterion for done, not a later review.

  3. Single source of truth

    One canonical place for the component and its accessible behavior.

  4. Public conformance dashboard

    The real barrier density becomes visible to maintainers and citizens.

Feasibility note

The mechanisms use tools public agencies already operate (CI/CD, axe-core). The audit layer of the protocol has already run in full: the 277 barriers are its output. The four governance mechanisms are a recommendation grounded in that evidence, not yet deployed in any agency.

Adoption of the protocol by an agency can keep new barriers from entering via the CI/CD gate. It is a recommendation, not a deployment.

Proof of concept for the correction

Experimental correction in a fork, not incorporated by the maintainer

The correction specified by the protocol was applied to a fork of the sample code of the DSGov menu component (Push variant, developer tab). Under the same pinned audit, the 22 ARIA structure violation nodes (aria-required-parent 21, aria-required-children 1) stopped being flagged. Before, after, diff and hashes are published in the open dataset.

What holds today, and what can come later.

Proven

  • The evidence exists, is public and is usable now.
  • 277 traced barriers, each with a record and archived evidence.
  • Open dataset, checklist and evaluation records ready for reuse.
  • A protocol replicable for free: a public team can repeat the audit on another design system without asking for permission.

Potential

  • Fixing a barrier at the source tends to distribute the fix to every service that consumes it.
  • Adopting the gate can keep new barriers from entering.
  • Less duplicated rework, longer-lived components and non-repeated audits can reduce digital and operational waste.

How success is measured

By the number of unique level AA non-conformities under constant scope (same pages, same battery, pinned environment), broken down by severity. Today: 202 in DSGov and 75 in Bold. Success is that series going down (critical and serious first) and not regressing, published on the conformance dashboard. The constant scope is what keeps the yardstick from being gamed by changing the sample.

Environmental note

The environmental impact here is indirect, derived from the logic of reducing rework and redundant auditing. The thesis itself treats the convergence between accessibility and sustainability as a future agenda, not a measured result. No number.

What this study did not do, stated in full.

  1. There was no testing with people. The analysis covers documents and code, with automated auditing and heuristic inspection by one auditor. No user testing, no participation of people with disabilities, no screen reader operated by the author, no second evaluator.

  2. Automated coverage reaches about one sixth of the WCAG criteria (Fischer, Lundell and Gamalielsson, 2025). The rest depends on manual inspection, which does not scale with a single auditor.

  3. It is a snapshot from September to November 2025. Systems change; the number is dated.

  4. The propagation of a barrier through consuming services is a structural mechanism of adoption, treated in conditional language. No effect was measured in any derived service.

  5. The author's affiliation with UFSC is declared. Mitigations: independent tooling, identical procedure, and Bold's internal share of critical failures being higher than DSGov's (40.0% versus 22.3%).

Every limitation is also the next step. Nothing here is hidden, because nothing here needs to be.

Where the evidence can grow.

  1. Sessions with people with disabilities and screen readers, to validate in use the barriers the code audit pointed out.

  2. Expanding manual inspection and adding a second evaluator, increasing coverage beyond what automation reaches.

  3. Taking the protocol to a maintainer team, to test the non-regression gate in real operation.

  4. Repeating the audit on new snapshots, turning the snapshot into a time series.

These are planned steps. This page does not claim any of them has already happened.

Source, data and credits.

Academic credit

Author
Thiago Kenji Corrêa Xikota
Advisor
Prof. Raul Sidnei Wazlawick
Committee
Raul Sidnei Wazlawick, Berenice Santos Gonçalves, Fabiane Barreto Vavassori Benitti
Institution
Universidade Federal de Santa Catarina, BSc in Computer Science
Defense
December 10, 2025, grade 10 out of 10

A work derived from the same research was approved on the official list of the BrasilGov Academy Forum 2026 under the title Inclusão por Padrão (academic circuit). Accessibility by Default is the name of the protocol in the design circuit. Same research, two circuits, both declared.

Accessibility of this page.

This page aims for WCAG 2.1 level AA conformance. A page that argues for accessibility has the obligation to be accessible.

axe: zero violations. Lighthouse accessibility: 100. And, consistent with what this project argues, the high score is not enough: the full audit report of this page is right here, so you can verify what the score does not show.

Full audit of this page

Found a barrier here? Write to thiagoxikota@gmail.com. The fix goes into the page.

Next step

If this protocol speaks to a problem you, your agency or your team are facing, write to me. I read and answer personally.

Talk to me about this protocol

The audit used off-the-shelf accessibility testing tools: axe DevTools, Lighthouse and WAVE. They are technical verification instruments, operated in a deterministic and documented way. The rigor is in the protocol that organizes them, not in the tools themselves.

Thiago Xikota, 2026