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Articles May 17, 2024

Making Accessibility Business as Usual: How to Start Working Toward Accessibility Conformance

Matt Leahy Virginia Booth
Matt Leahy, Virginia Booth

​Every year, the demand for businesses, government agencies, and other organizations to provide accessible digital experiences increases. First and foremost, the public expects it. In a 2022 CapTech survey, we found that 51% of consumers are willing to pay more to companies committed to digital accessibility. Furthermore, both state and federal laws continue to evolve to make it a mandate that digital spaces are held to the same standard as physical spaces, requiring equitable online access to products and services for users across the diverse spectrum of physical, sensory, and cognitive ability.

​In 2022, the Department of Justice (DOJ) issued guidance that digital accessibility is necessary for compliance with the Americans With Disabilities Act. And in 2024, the DOJ published a rule specifically mandating conformance with WCAG (Web Content Accessibility Guidelines) 2.1 AA standards for state and local government websites and mobile apps. On top of this, many states like California, Colorado, and Virginia are issuing their own accessibility legislation.

​The need to comply with accessibility standards is apparent, but the path to get there can be unclear and daunting. 

Organizations may struggle to determine what is required, how to accurately assess the accessibility of their digital spaces, and where to begin with pursuing accessibility remediation. Achieving accessibility maturity is indeed a significant undertaking, and it won’t happen overnight. However, with a strong commitment and a clear plan, it’s possible for any organization to significantly improve their accessibility posture and provide richer experiences for all of their users.

​In April 2024, we presented a webinar through the Colorado Statewide Internet Portal Authority (SIPA), “Making Accessibility ‘Business As Usual,’” with recommended steps that organizations can take to work towards compliance with accessibility standards.

​In this post, we’ll cover how organizations can get started, build momentum, and begin making progress toward achieving their accessibility goals. In future posts, we’ll explain how you can account for accessibility throughout design and development workflows, as well as best practices for monitoring and improve your accessibility maturity over time.

​Set a Goal (and Share It!)

​The first step is to set a goal. Make sure to include key representatives from different areas of your organization to participate in this process and align on your accessibility target.

​Start with researching what laws and regulations apply to your state and industry and what the requirements are to comply with them. Virtually all accessibility laws and litigation rely on the Web Content Accessibility Guidelines (WCAG) to provide a technical standard to measure accessibility. Level AA is usually the required standard, but the targeted WCAG version may differ. The most recent version is 2.2, released in late 2023.

​Then, determine who will be responsible and accountable for driving and maintaining your accessibility targets and what support they will need in order to be successful. This may include executive sponsorship, design and development standards, testing and remediation tools, or training and resources.  

Remember, it’s unlikely that your existing experiences will become WCAG conformant overnight, so identify what is feasible to accomplish in the next quarter, the next six months, the next year, and the next few years. ​Finally, communicate your goals and plans to your organization – we recommend formalizing this with an accessibility commitment or policy.

​Your commitment should include:

Targeted Standard

The accessibility standards and conformance level you’re targeting, such as WCAG 2.2 AA


A roadmap with key milestones you aim to achieve


Measures being taken to monitor and improve accessibility


Contact information for reporting accessibility issues or seeking assistance

​Understand Your Current State

​In order to create a plan to achieve conformance, you need to know your starting point, and to do so, you will need a comprehensive audit of your website. We recommend identifying a trained accessibility partner to complete this assessment.

​Start by defining a representative sample of pages on your site that include examples of all major functional components – such as buttons, sliders, or forms – and content types – such as copy, images, and video. These samples pages should then be evaluated through a combination of automated and manual tests.

​Automated testing is performed using tools that can automatically scan the content and front-end code of your website and flag potential accessibility issues. Common examples are SiteImprove, Axe Dev Tools, and WAVE, and many of these tools include free versions.

    While automated testing is a critical starting point and can quickly identify many straightforward accessibility issues, it will only catch between 25 and 50% of all accessibility barriers that may exist on a website. For this reason, automated testing should always be complemented with manual testing.

    Manual testing includes activities such as: 

    • Navigating and operating the site using only a keyboard 
    • ​Navigating and operating the site using a screen reader or other assistive technology 
    • ​Testing the site’s support for zooming and text resizing 
    • ​Testing color contrast for important non-text elements, like graphics and interactive controls 
    • ​Reviewing media such as videos for appropriate transcripts and captioning 
    • ​Assessing documents hosted on the site

      Accessibility Conformance Report (ACR)

      ​Your accessibility partner should compile the results into a comprehensive report called an Accessibility Conformance Report (ACR). The most common format for an ACR is the Voluntary Product Accessibility Template (VPAT). An ACR will summarize how successfully the website meets the targeted WCAG standard and outline how it conforms with each specific WCAG criterion.

      ​You’ll also want to request similar accessibility documentation from any vendors that supply plugins, tools, or other technology used on your website. By using their services on your website, you are liable for the accessibility of the features they provide. Make sure you understand their accessibility policies and procedures, as well as their plans to address accessibility if they don’t currently meet your targeted standard. Check vendor contracts as well, and make sure accessibility is included as a requirement.

      ​Equipped with these insights, you’ll want to publish an accessibility statement on your site. Even if you are just getting started, publishing an accessibility statement is critical to establishing transparency and accountability with your users. Your statement may be very simple at first, but you can add more detail as you learn more through audits and remediation.​

      ​Your accessibility statement should:

        Outline your website’s current level of accessibility and WCAG conformance

        ​Inform users about the measures being taken to monitor and improve accessibility

        ​Provide contact information for reporting accessibility issues or seeking assistance

        ​Provide Training and Resources

        ​It’s imperative that everyone in your organization have a strong awareness of accessibility and that individuals directly involved in crafting your digital experiences have a strong understanding of how to successfully address accessibility in their work. Equip associates with training tailored to their specific roles and responsibilities. Everyone plays a part in achieving accessible outcomes, but the knowledge and skills they need will differ.

        ​Start with training on accessibility fundamentals for everyone in your organization. Then consider role-specific training for those who are part of building and maintaining your site. For example, developers should receive training on accessible development and accessibility testing methods, while content authors may need training on accessible writing and how to produce accessible documents.

        ​Adopt Best Practices for New Content

        ​It is possible that your website or app will need design and code updates to meet accessibility standards, and that may take time. In the meantime, you don’t have to wait to start adopting best practices for any new content produced for your website. And establishing these standards now will help ensure that you can maintain the accessibility of your website as it grows in the future.

        With a little training and perhaps a checklist to reference, these standards are easy for any content author to follow:

        • ​Always define alternate text on informative images that describes the purpose or content of the image, and avoid images that contain important text whenever possible.
        • ​Include captions, transcripts, and audio descriptions as appropriate for all audio or video content. 
        • ​Write page titles, headings, and link text that are unique and informative.
        • ​Use headings, lists, and tables for their intended purpose only. These elements should not be used solely to achieve a certain layout or appearance.
        • ​Write in simple, plain language. Aim for a 9th grade reading level or below, and avoid using unfamiliar terms, acronyms, or figurative language that may not be understandable to all.
        •  ​Avoid using sensory cues in copy. For example, “required steps are colored red.” If a user is color blind cannot readily identify the color red, they will struggle to follow these instructions.

            ​What’s Next?

            ​When you are able to make more significant updates and start improving the design and coding of your website, accounting for accessibility from the beginning and throughout the process can significantly reduce the rework you have to deal with later on. And establishing these standards now will help you more easily meet accessibility standards on any future projects.