Thanks @brianteeman for this finding.
Disabled buttons with listcheck=true such as the Actions button in our backend list views are not WCAG 2.1.
In this case we set the button to disabled until an item is selected.
The a11y issue with this is that it makes the button invisible to AT so the user will not even know it exists - it has no focus at all.
The alternative is to use aria-disabled instead.
That keeps the button as focussable and announces that the button is disabled (and optionaly what you have to do to make it enabled).
Also the disabled button is focussable and accessible
Not accessible
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I have most of the PR ready for this. It is fully b/c
Note that in addition to what @chmst said above we have to programmatically remove the functionality from the button as aria-disabled doesnt actually do that.