Accessibility governance baseline

Purpose

When to use this baseline

Use it when establishing or reviewing a digital accessibility program, joining a new portfolio, procuring technology, scaling a design system, or correcting a process that discovers barriers only near release.

This baseline supports governance design; it is not legal advice, a conformance claim, or a substitute for evaluating the applicable law, policy, standard, technology, and user context.

Policy to practice

Define a commitment teams can act on

The operating commitment should identify:

• the products, services, content, internal systems, and procurements in scope;
• the standards and organizational policies that apply, including supported platforms and technologies;
• how disabled people participate in research, design, evaluation, and feedback;
• the minimum evidence required before consequential decisions and release;
• ownership, escalation, exception, remediation, and public-communication expectations;
• the capability, funding, and time teams receive to meet the commitment.

Avoid promises that name a standard without explaining how work will be governed. A commitment is operational only when it changes requirements, resources, decisions, and accountability.

Accountability

Assign decision rights across the system

Accountable leader

Sets the commitment, funds the capability, accepts material residual risk, and reviews systemic performance.

Product or service owner

Owns accessible outcomes, requirements, prioritization, remediation, and release readiness.

Accessibility specialist

Advises, evaluates, documents limitations, supports interpretation, and escalates material risk without becoming the sole owner of accessibility.

Design, content, and engineering

Apply accessible patterns, preserve intent through implementation, test their work, and resolve findings within their disciplines.

Research and HCD

Include disabled people responsibly, identify barriers and workarounds, and connect evidence to decisions without treating conformance as equivalent to usability.

Procurement, legal, security, and operations

Apply their authority while preserving accessibility requirements, evidence, contractual remedies, support, and change controls.

Name who can stop or condition a release, who may accept residual risk, and where unresolved disagreement goes. Accessibility specialists provide critical authority and evidence, but the organization must not transfer all accountability to them.

Operating controls

Govern accessibility across the lifecycle

Assurance

Require evidence appropriate to the decision

• Record scope, environment, methods, assistive technology, results, limitations, evaluator, and date.
• Use automated testing for repeatable coverage, not as proof that an experience is accessible.
• Include keyboard, zoom, reflow, contrast, forced colors, reduced motion, semantics, focus, errors, and assistive-technology behavior as applicable.
• Evaluate complete tasks and states, not only isolated components or ideal paths.
• Separate standards conformance, usability, compatibility, and organizational acceptance decisions.
• Retain traceability from findings to requirements, defects, decisions, remediation, and verification.

Residual risk

Do not let exceptions become silent policy

Every exception should state the unmet requirement, affected people, evidence, impact, reason, compensating access, accountable authority, remediation owner, due date, and review trigger. It should be visible to support and operational teams and reconsidered when technology, evidence, or circumstances change.

Track repeated exceptions as systemic evidence. Recurrence may indicate inadequate components, procurement controls, staffing, training, architecture, incentives, or decision authority—not a series of unrelated defects.

Continuous improvement

Measure capability and lived outcomes

• Can disabled people report barriers through an accessible, responsive channel?
• Are material findings assigned, prioritized, verified, and closed with evidence?
• Do teams detect regressions before users must report them?
• Are third-party accessibility claims checked throughout the relationship?
• Do recurring findings change components, standards, training, or governance?
• Can leaders see unresolved risk, remediation age, recurrence, and affected journeys?
• Are conformance statements and accessibility documentation current and supportable?
• Does evidence from disabled people influence portfolio and investment decisions?