In Zelda's first scene, when she allows Elisa to punch in in front of her, Yolanda chastises her, and Zelda responds by claiming she was saving Elisa's spot, leading to a short argument.

The rules specifically say "talk", so does sign language count? If so, Zelda and Elisa talk constantly. And is the creature technically a man because he has a penis? If so, then a lot of the movie is talking about him, or their boss. (Obviously sign language is still talking, just trying to debate, but I find it funny how technically borderline both situations are.

Sign language counts! There's nothing in the rules about what language the two named women need to speak.

Hell no, this movie do not pass the test, both females characters establish a communication, one through sign language, the other woman can speak. They do talk about men, if you count the creature as a male and also Zelda (Octavia Spencer) talk about her husband and their marriage.

It doesn’t matter if they DO talk about men. If they have one conversation not about a man, the movie passes

If you think this movie doesn't pass only because Elisa uses sign language, you're probably ableistic asshole and you need to rethink your approach to the whole social justice thing.

This movie is produced and directed by Guillermo del Toro, and received many Oscar nominations and won many of those awards in 2017. The main protagonist is a mute woman named Elisa, who works in a government lab as a janitor. Her main character arc is that she falls in love with the sea creature that is being studied/tortured at the government lab, and wants to free him. With the help of her coworker, Zelda, and her neighbor, Giles, Elisa and the sea creature barely escape back into the water.

There are three minority representations in the film. One being Zelda, the other being Elisa (as she is mute), and Giles (a closeted gay man). Nearly everyone else in the movie is a cis white man. What was funny to me is that while Elisa's love interest is a mythical sea creature, the film makes it obviously clear that he is male, specifically when Zelda asks Elisa if he has a penis.

This film had a few moments of "male gaze", specifically towards the beginning. We see Elisa getting ready, undressing, and masturbating in the bath tub, along with a few other instances of female nudity.

The Shape of Water passes the Bechdel test, but just barely. Zelda and Elisa generally talk about Zelda's husband, the other men at the facility, or the (male) sea creature, but there is one scene where Zelda is talking to another woman about how she is holding Elisa's place in the clock-in line.