How to Build a Successful Digital Accessibility Program

This strategic outline can help any organization build a successful digital accessibility program.

1. Project Foundation

1.1 Create Your Accessibility Policy

Your accessibility policy serves as the north star for your entire program. Start by securing executive buy-in through a brief presentation on legal risks and market opportunities.

Core Policy Components:

• Commitment Statement – Clear, public declaration of your accessibility goals
• Scope Definition – Specific list of all digital assets covered
• Technical Standards – WCAG 2.1 AA (or 2.2 AA) as your baseline
• Legal Framework – ADA Title II/III, Section 508, state laws
• Governance Structure – Committee formation and reporting lines
• Review Schedule – Annual policy updates and revisions

Write your commitment statement in plain language that anyone can understand. Avoid legal jargon or hedging language. State clearly that your organization is committed to digital accessibility and will work to meet a WCAG standard across all digital assets.

Also, be practical and realistic. You cannot possibly expect to make multiple significant digital assets fully conformant within a short time span. Prioritize assets and plan for a reasonable, but quick pace for reach individual projects.

Rather than a sweeping goal of full WCAG 2.1 AA conformance across all assets. Start with individual blocks with specific targets.

1.2 Establish Your Budget Framework

Accessibility requires both upfront investment and an expense that will decrease and plateau over time. Plan for higher Year 1 costs with steady-state funding in subsequent years. Most organizations underestimate initial costs and overestimate their ability to maintain accessibility without dedicated resources.

Our accessibility cost calculator can help you budget for audit, user testing, and VPAT services.

2. Asset Discovery and Prioritization

2.1 Conduct Digital Asset Inventory

You can’t fix what you don’t know exists. Many organizations discover forgotten microsites, legacy applications, and document libraries during this process. Involve every department to ensure nothing is missed.

Inventory Process Steps:

• Send asset request forms to all department heads
• Review web analytics for all tracked properties
• Check DNS records for subdomains and microsites
• Catalog all document repositories and media libraries
• Document third-party tools and embedded content
• Include mobile apps, kiosks, and digital displays
• Add all social media channels and external pages (e.g., Hubspot landing page form)

Create a master spreadsheet tracking each asset’s details. Include ownership information, usage metrics, technical specifications, and known accessibility issues.

2.2 Prioritize Assets Strategically

Not all digital assets carry equal risk or importance. Use a scoring matrix to objectively prioritize remediation efforts and allocate resources where they’ll have the most impact.

Priority Scoring Factors:

• Legal Risk (1-5) – Public-facing transaction sites score highest
• User Volume (1-5) – Daily active users and page views
• Business Impact (1-5) – Revenue generation and operational criticality
• Technical Complexity (1-5) – Inverse scoring; simple sites score higher
• Content Volatility (1-5) – Frequently updated content needs more attention

Calculate composite scores by multiplying factors. Assets scoring 80+ become Priority 1, requiring immediate attention. Scores of 50-79 are Priority 2, addressed within six months. Lower scores can be scheduled for later phases or bundled with planned redesigns.

You may even sub-categorize priorities by the top 5-15 pages or screens for assets (rather than the entire asset).

3. Roles and Responsibilities

3.1 Define Your Accessibility Team Structure

Success requires clear ownership and accountability at every level. Each role needs specific responsibilities, adequate time allocation, and measurable objectives.

Executive Sponsor: This must be a senior leader with budget authority and political capital. They remove barriers, secure resources, and communicate accessibility’s importance throughout the organization. Choose someone who has successfully led other transformation initiatives.

Accessibility Program Manager: Your program quarterback who coordinates all activities across departments. This role requires 50-100% time allocation depending on organization size. They manage vendor relationships, track compliance metrics, and report progress to leadership.

Technical Accessibility Lead: A senior developer or architect who becomes your in-house WCAG expert. They define technical standards, review code, and lead internal training efforts. Budget for their certification and ongoing education.

Department Champions: Embedded representatives who ensure their teams follow accessibility practices. These aren’t full-time roles but require 5-10 hours monthly for meetings, coordination, and local problem-solving.

3.2 Establish Accountability Measures

Define clear success metrics for each role and incorporate them into performance reviews. Without accountability, accessibility becomes everyone’s responsibility and no one’s priority.

Key Performance Indicators by Role:

• Executive Sponsor – Budget approved, obstacles removed, executive presentations delivered
• Program Manager – Project milestones met, compliance levels achieved, stakeholder satisfaction
• Technical Lead – Standards documented, code reviews completed, training sessions delivered
• Department Champions – Team compliance rates, issue resolution time, knowledge transfer completed

4. Documentation Requirements

4.1 Essential Accessibility Documentation

Proper documentation demonstrates compliance efforts and provides evidence of your accessibility program’s effectiveness. The below documents serve both internal tracking and external compliance purposes.

Documentation Types:

• VPAT/ACR – Standardized documentation for accessibility of products and services
• Accessibility Statement – Public-facing commitment and contact information
• Audit Reports – Detailed findings from professional evaluations
• Conformance Statement – Document stating a digital asset is fully WCAG conformant
• Provider Certification – Certification for third-party accessibility company
• Remediation Logs – Tracking of all issues identified and resolved
• Training Records – Documentation of who completed which training when

4.2 Creating and Maintaining Documentation

You can create your own internal documents, but it’s highly recommended you source crucial VPATs, audits, and certification from external services. However, having internal expertise will improve your ability to create reliable and accurate documentation.

If you fill in VPATs internally, follow this process:

ACR Creation Process:

1. Use the current ITI VPAT template (version 2.4 or latest)
2. Complete all sections thoroughly – never leave sections blank
3. Evaluate against each technical standard criterion systematically
4. Document specific support levels: Supports, Partially Supports, Does Not Support, Not Applicable
5. Include detailed remarks explaining partial support or non-conformance
6. Have technical and legal teams review before publication

5. Vendor Selection and Management

5.1 Identify Required External Services

Focus on two primary external services: professional auditing and user testing with people with disabilities. Build internal capacity for everything else through comprehensive training programs.

Essential External Services:

• Professional Accessibility Audits – Comprehensive evaluations by technical experts
• User Testing Services – Formal sessions where professionals with disabilities test your assets
• Legal Consultation – Interpretation of laws and regulations and risk assessment

Services to Build In-House:

• Code remediation capabilities through developer training
• Content accessibility through writer and designer education
• Quality assurance processes with accessibility checkpoints
• Ongoing maintenance and updates

5.2 Evaluate and Select Vendors

Apply the via negativa approach to vendor selection – first eliminate vendors with problematic practices, then evaluate remaining candidates on positive criteria.

Red Flags – Automatic Disqualification:

• Sells or promotes custom overlays, overlay widgets, or plugins
• Focuses primarily on automated scans
• Promotes or markets automated remediation or automated audits
• Indicates you can combine scans and screen reader testing for an audit

Essential Vendor Qualifications:

• Attention to detail
• Outlines audit specifics (evaluation methodologies, environments, WCAG standard)
• Clear, actionable audit reports
• Ability to produce professional documentation

Request proposals from at least three vendors for audit services. During evaluation, ask about their methodology in detail.

Determine whether they are more concerned with automated “solutions” or professional services.

6. Implementation Process

6.1 Conduct Baseline Professional Audits

Start with comprehensive audits of your Priority 1 assets conducted by qualified external auditors. These establish your baseline and identify specific issues requiring remediation. Expect audits to take 3-4 weeks per major property.

Professional Audit Components:

• Comprehensive inspection
• Keyboard testing
• Screen reader testing with JAWS, NVDA, and/or VoiceOver
• Mobile accessibility evaluation on iOS and Android

Thoroughly review audit scope to ensure all important pages or screens are included (or have a predetermined scope). Ensure auditors have access to all primary pages and screens including authenticated areas.

6.2 Use Audit Platform for Issue Tracking

Use a dedicated audit-based accessibility platform such as Accessibility Tracker to track and manage all identified issues (not just scan results). This centralizes your remediation efforts and provides clear visibility into progress.

Platform Requirements:

• Import findings directly from audit reports
• Assign issues to specific team members
• Monitor remediation progress with dashboards
• Generate reports for stakeholders

An audit-based platform will save you a significant amount of time and streamline your individual project progress.

6.3 Execute Remediation Plan

Transform audit findings into actionable work items within your accessibility platform. Prioritize based on user impact or risk factor.

Remediation Workflow:

1. Prioritize Issues – an Accessibility Tracker platform can help with this
2. Assign Ownership – Map issues to responsible teams in the platform
3. Set Deadlines – Urgent issues within 30 days, Critical within 60 days
4. Document Fixes – Record remediation approach in the platform
5. Validate Fixes – Verify each remediation before marking complete
6. Update Documentation – Record patterns for preventing recurrence

6.4 Implement Comprehensive Training Program

Build internal expertise through role-specific training. This reduces long-term costs and creates accessibility knowledge throughout your organization. Consider the WCAG Course as cost effective online training that can teach your team the requirements in the Web Content Accessibility Guidelines (WCAG).

7. User Testing with People with Disabilities

7.1 Establish User Testing Program

Real feedback from people with disabilities provides insights that technical audits cannot capture. Establish regular user testing sessions to validate your accessibility efforts.

User testing sessions can provide invaluable feedback beyond audits. User testers will relay their experience and offer both accessibility and usability recommendations.

User Testing Components:

• Test with actual assistive technology users
• Focus on critical user tasks and workflows
• Document both barriers and successful interactions
• Gather suggestions for improvement

Schedule user testing sessions quarterly for Priority 1 assets and bi-annually for other properties. Include both structured tasks and open exploration to discover unexpected issues.

7.2 Integrate User Feedback

User feedback often identifies issues that technical audits miss. Create a systematic process for incorporating this feedback into your remediation efforts.

Feedback Integration Process:

1. Document all findings in your accessibility platform
2. Correlate user-reported issues with technical audit findings
3. Prioritize issues that affect task completion
4. Share video clips of testing sessions with development teams

8. Compliance Reporting

8.1 Internal Reporting Structure

Establish clear reporting lines and regular communication cadences to keep stakeholders informed and engaged.

8.2 External Documentation

Maintain current public-facing documentation that demonstrates your commitment and provides transparency about your accessibility efforts.

Accessibility Statement Components:

• Organization’s commitment to accessibility
• Contact methods for feedback and support
• Date of last update
• Link to current VPAT/ACR if applicable

Update your accessibility statement quarterly or whenever significant changes occur. Include specific progress metrics to demonstrate continuous improvement. Provide multiple contact methods including email, phone, and postal address.

9. Ongoing Compliance Strategy

9.1 Bi-Annual Audit Schedule

Maintain compliance through regular professional audits. Schedule comprehensive audits every six months for critical properties and annually for lower-priority assets.

Bi-Annual Audit Process:

• Month 1: Schedule audits with qualified firm
• Month 2: Conduct comprehensive evaluation
• Month 3: Review findings and update platform
• Months 4-5: Remediate identified issues
• Month 6: Validate fixes and update documentation

This regular cadence ensures you catch new issues before they become systemic problems. It also demonstrates ongoing diligence for legal compliance purposes.

9.2 Continuous Improvement

Focus on preventing new issues through process improvements and knowledge building rather than perpetual remediation cycles.

Prevention Strategies:

• Incorporate accessibility requirements into project briefs
• Include accessibility requirements in vendor contracts
• Build component libraries with accessibility built in
• Create design patterns that are accessible by default
• Establish code review processes with accessibility checks
• Require accessibility sign-off before launches

Document your processes and share across your organization. Create an accessibility playbook capturing your standards and patterns. Recognize teams that excel at accessibility to reinforce its importance.

10. Timeline and Milestones

10.1 Implementation Roadmap

This timeline assumes a medium-sized organization with 5-10 major digital properties. Adjust based on your specific scope and resources.

10.2 Success Checkpoints

Establish clear milestones to track progress and maintain momentum. Missing early milestones often indicates resource or commitment issues requiring intervention.

Month 3 Checkpoint:

• Policy approved and published
• Budget allocated and protected
• Core team hired or assigned
• Priority 1 assets identified
• Audit firm contracted
• Accessibility platform configured

Month 6 Checkpoint:

• All P1 assets audited
• Critical issues remediated
• 50% of staff trained
• First user testing completed
• First compliance report published
• Initial VPATs/ACRs completed

Month 12 Checkpoint:

• 80% WCAG 2.1 AA compliance achieved
• All staff trained
• Second audit cycle completed
• User feedback system operational
• Program ROI documented
• Professional conformance certification obtained

11. Risk Management

11.1 Common Problems

Most accessibility programs encounter predictable difficulties. Recognize and address these early to maintain progress.

Primary Risks:

• Insufficient Budget – Secure multi-year funding commitment upfront
• Lack of Executive Support – Get written commitment and regular updates
• Poor Vendor Selection – Avoid overlay vendors and scan-only approaches
• Scope Creep – Stick to prioritization despite pressure
• Training Gaps – Make training mandatory with tracking

11.2 Legal Compliance

Maintain strong legal position through comprehensive documentation and consistent progress.

Legal Protection Strategies:

• Conduct regular professional audits (bi-annual minimum)
• Document all remediation efforts in your platform
• Maintain current accessibility statement
• Respond to feedback within 48 hours
• Keep detailed records of user testing
• Update VPATs with each major release

Summary

Digital accessibility requires sustained commitment and systematic execution. This strategy plan provides a practical roadmap focused on professional audits, user testing, and building internal capabilities. Success comes from consistent progress rather than perfection.

Start with professional audits to establish your baseline. Build internal expertise through comprehensive training. Validate your efforts through user testing with people with disabilities. Track everything in a dedicated accessibility platform. Maintain compliance through bi-annual audits rather than relying on automated scans.

Every barrier you remove improves someone’s ability to use your digital properties. Begin today with your highest-priority assets and expand systematically. Document your progress through VPATs and conformance reports. Most importantly, listen to users with disabilities – they are your best guide to creating truly accessible experiences.

If you’d like help with accessibility, Accessible.org can provide excellent audit, user testing, and VPAT services.

Our Accessibility Tracker platform is highly recommended to track progress on individual projects.