How to Develop Organizational Policies on Web Accessibility

How to Develop Organizational Policies on Web Accessibility

Last Edited September 11, 2023 by Garenne Bigby in Accessibility Testing

For anyone creating and managing their own website, it is important to have a clear, organized planning policy for all content. This will ensure that visitors to the site can accurately access desired content and that your content will display and function as desired. This article will explore some of the most common challenges with web accessibility and offer advice on how to develop some of the best organizational policies on web accessibility.

Start Early

It is much easier and cheaper to have a clear idea of your accessibility policy before you operate a website. Try to define and publish your accessibility policy as soon as possible. This will make it much easier to work into the rest of your content, and will also benefit any relationships you may make with third parties along the way. You don’t want to begin creating all of your content, and then realize you need to (or at least should) meet a particular conformance level, which none of your current content complies with. 

Stay Current

It is your responsibility to make sure that your accessibility policy keeps up with any changes in guidelines. If you specifically reference a particular guideline, make sure that you are referencing the most recent one, or whichever one your website actually adheres to. A crucial aspect of any internal policies should include regular review of conformance.

Define Conformance Level

You should define which conformance level your website adheres to. There are three different levels of conformance—A, AA, and AAA. AA is pretty standard as the accepted level of conformance. However, do not promise to achieve an AA level of conformance if at this time your website can only realistically attain a level A. If you meet the lowest conformance level at the time, be open and honest about it, and perhaps publish a statements declaring that your site has set a goal of reaching a higher level of conformance at a specified date.

Define the Scope of Your Policy

What is the scope of your policy? What does it cover? How does it apply to different parts of your website?  For example, how does it address third party content? What about mobile content? What about tools, content, and sites that are only accessible internally? Define your policy and what all you want it to cover. It’s totally up to you, but it’s important to clearly define what the scope of your policy is so that you know how to manage your content and what benchmark it needs to meet.

Example: The accessibility policy of ABC123 applies to all existing, updated, and new material found on the website

Set Milestones

For any accessibility or policy goals that you have not met, you need to identify them and set a target date for achieving them. For those milestones that have already been reached, be sure to document that on the website or in the policy itself (e.g. “This policy was last reviewed and approved May 2018”). 

You will likely want more of these milestones to be posted internally rather than externally, but it is important to inform website visitors at least of when your overall accessibility policy achieved the current level. If there are any significant accessibility barriers, be sure to prioritize those first. Milestones should be specific and should address the various areas of website management. 

Example 1: This accessibility policy will be reviewed periodically to ensure it is up to date and adheres to any changes in law, regulation, or industry best practice standards. It is the intention of ABC123 to consider updating the policy to a more advanced version of XXX’s Web Content Accessibility Guidelines as soon as those are made available. 

Example 2:By [specified date] all multimedia player vendors used by ABC123 shall provide information to ABC123 information regarding their conformance with UAAG 1.0 conformance requirements. By [specified date] ABC123 will prioritize its relationships

Design Your Policy

Think about if you want a separate web accessibility policy, or if you just want web accessibility to be woven into all or some of your other policies. For example, you could provide a section within your non-discrimination policy that discusses how that tied into web accessibility. If you do opt for a separate policy to address web accessibility, you should still make reference to it where appropriate (e.g. in your equal opportunity policy statement, business guidelines, etc.). 

Another common approach is to have an internal accessibility policy which guides all of the internal aspects of content creation and website management plus a separate, public accessibility statement. The perk of this is that you can have a short and to-the-point accessibility guarantee on your web page. This ensures to your visitors that you will not discriminate or give different experiences to different users, but simultaneously have a more in-depth policy which gives employees and content creators guidelines to follow to ensure your website’s accessibility mission is met.

Be Specific

Once you have an initial design for your accessibility policy, be sure to include a direct reference to industry-approved guidelines. This will help your employees be clear on what guidelines are to be met when creating or publishing content, and it offers visitors to your site a clear benchmark that the website should be achieving. Especially on the internal side of things, an accessibility policy should include subsets that cover web content creation, web content publication, authoring tool accessibility, and user agent accessibility. 

Your internal policy should include what level of compliance your website obtains, how, why, relevant definitions, contact information or third-party content providers, any legal disclaimers or guidelines that may be necessary, and anything else that may be relevant to your specific website. Below is an example of a standard external accessibility policy that might show up on a website. 

Example: ABC123 adheres to the accessibility guidelines as laid out by XXX (Level AA conformance) to ensure that this website is accessible to people with disabilities. If you have any issues, please contact (email address).

An internal monitoring program to ensure appropriate conformance level will be initiated no later than [specified date]. All vendors that supply software used in developing ABC123’s site must prove their conformance to XXX's Authoring Tool Accessibility Guidelines 2.0, Conformance Level A by [date]. Links to this policy can be found on ABC123’s homepage. This policy will regularly be reviewed [optional; insert specific review guidelines] so that any issues can be addressed in a timely manner.”

Know the Risks

To help motivate you, you should be familiar with the risks of non-compliance that your website can face. Some companies have been sued in court due to lack of accessibility or statements of compliance that were false. You can face serious financial and legal trouble if you do not meet the accessibility requirements of your jurisdiction. Different countries or states may have different requirements, and it could also depend on what type of website you have. 

You must educate and inform yourself, even seeking legal expertise if needed, to make sure you know what benchmark your website must hit. This is where clear, concise policies also come in handy: be explicit about the standards that you are meeting, and then be sure that you are meeting them. This is not the place to brag about meeting conformance level AA if you are actually at AAA. Be honest and transparent to avoid any trouble. 

Know Your Standards

There are commonly different standards for different companies. For example, any government website will likely have greater accessibility requirements than most privately-owned websites. Also understand if there are different requirements depending on the type of products or content that your offer on your website. 

If your website is for an educational entity or offers educational resources, there may also be stronger requirements that you need to adhere to. And remember what was discussed before—it’s best to start early, so inform yourself of these requirements before you start. 

Third Party Content

You will definitely need to make sure that your policy addressed syndicated or procured third-party content. This is of utmost importance especially in those areas of your website which are primarily controlled by a third party service (such as video streaming or payment processing). 

In order to be compliant with accessibility requirements, all website owners must make sure that this content is also accessible. If any third party content is inaccessible, then you will need to offer an alternative. You are held responsible for the accessibility of all aspects of your site, not any third party that you may work with. 

This is also an important area where you will want to have a strong internal policy regarding accessibility and third parties. You will want all of your content creators and web developers to know exactly what the standards are for your website and any third party relationships. 

Example: ABC123’s accessibility policy applies to any and all Web content initiated or updated by ABC123. Additionally, ABC123 makes is a priority to ensure that all third-party partners meet the same level of access and takes the following steps:

  • Providing third-party content developers with a copy of ABC123’s accessibility policy annually

  • Partnering as often as possible with third-party content providers who adhere to a similar accessibility policy

  • Monitoring and providing feedback to inaccessible third parties

  • Seeking relationships with alternative third-party content providers in the cases that an original provider fails to meet our desired conformance level

Establish a Review Policy

Like any good and effective policy, your accessibility policy will regularly need to be reviewed and updated. Especially if your website is not where you would like it to be in terms of accessibility (say it’s currently at AAA and you want to meet AA standards), it’s important to check back in regularly on your policy to see if you are successfully working towards meeting that goal.

Internally, reviewing your accessibility policy should be an important part of your internal management. Anyone who regularly creates, edits, or distributes content for your process should be familiar with the policy and held accountable. Regular internal review of the process also helps everyone involved know where the policy currently is at, and what needs to be done to maintain the status or improve it. 

This review process can be published on your website along with your accessibility statement if you would like. This will give visitors added piece of mind, knowing that you are aware of your accessibility policy and spot-check it regularly. It is also helpful to encourage feedback on your policies from visitors to the website. This will help you be informed of any bugs or malfunctions with accessibility that you may not otherwise have known about.

Whether it’s internally, externally, or both, just make sure this review process is published somewhere; this will hold you and your team accountable.

Example: This policy is reviewed on a regular basis, no less than once every three months, by the website manager and other appropriate parties. If you believe any inaccurate claim has been made about this accessibility policy, please contact (email address). 

Establish a Review Process

Your review policy simply outlines how often you check and update (if needed) your accessibility policy. A review process includes all of the steps that are taken to thoroughly review how your accessibility policy is functioning in the real world. Even though you guarantee that the website complies with level AA conformance, how will you know that that is a fact? Who will check this? How often? What is your benchmark? How will the results be documented and where?

An example review process could reflect something like this: The website manager runs an accessibility check once per month, at least. This check would include checking recent content published, as well as older content. It should include anything created/edited/published internally, as well as a spot-check of third-party material. All results should be documented in a central location, where all future and past checks are also documented. 

Visitor feedback should also be part of this review process, and you will need to come up with a policy to specifically address this feedback (how quickly to respond, how to respond, action to be taken, etc.). Also include follow-up and documentation protocol. 

Example: All departments will review once per month all areas of ABC123’s Website which it regularly maintains. This review should comply with the standards and processes described in [handbook or other reference point]. Simultaneously, all departments will also review any new or updated material that it is responsible for publishing on the website using the same standard. 

Maintaining Your Policy

As has been mentioned many times throughout the article, you always need to keep your policy up-to-date to make sure you are providing website visitors and content producers with the most accurate information. Part of your review process should be consistent reviews, which will help ensure that your policy is both correct and appropriate. 

Also be aware of literature and advances in the arena, so that you know when new accessibility guidelines, tools, or requirements are out there. Keep in mind how updates, changing content, or third-party agreements or use could affect your accessibility policy. Be sure that you have a policy that is appropriate for your website and beneficial to your visitors. 

Planning for the Future

It is critical to always keep one eye on the future when creating policies. This is when your review policy will be especially helpful and will ensure that your accessibility policy doesn’t become outdated. You want to make sure that all of your policies have a clear point in time for review. Also, create a policy that will cover your website even if it grows or changes in the near future. 

You may have a small website with little traffic now, but things change quickly in the internet world, and you must be ready. As mentioned above, start early and review often to ensure that your website is accessible and compliant both now and in the future. 

Final Words

Hopefully, by, now you understand how important it is for every Web site to have a clear statement regarding its accessibility policy. You have probably also realized that there is much more to this than simply throwing together a couple of sentences that promise to make your Website accessible to all viewers. 

A good accessibility policy will be successful when it has other strong policies and practices to back it up (review policy, benchmarks, etc.). Utilizing the information discussed above and having an educated and dedicated team will help ensure that your Website meets the necessary requirements and ensures a successful visit to your Website. 


Garenne Bigby
Author: Garenne BigbyWebsite:
Founder of DYNO Mapper and Former Advisory Committee Representative at the W3C.


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