Best Practices for Compliance 

Plan for accessibility—don’t wait for complaints!

Solve problems with staff, not lawyers

Policies & Staff

  • Adopt policy and publicize policy
    • Setting standard (WCAG 2.0/2.1 Levels A & AA)
  • Hire/assign responsible staff
    • With sufficient authority and budgetary authority
    • With sufficient expertise
  • Training for developers and content creators
  • Provide experts/resources for developers and content creators

Pre-Posting Procedures

  • Set procedures for pre-posting reviews of accessibility of new content
  • Establish responsibility to approve and document exceptions
    • ADA
      • Undue burden
      • Fundamental alteration
  • Establish accountability mechanisms for developers and content creators who post inaccessible material


  • Procurement accessibility policy
  • Contract language
  • Audit capability
  • Accountability mechanisms
  • Remediation responsibility


  • Audit to identify barriers
  • Prioritize
    • Frequency of customer encounters
    • Importance of function
    • Severity of the barrier
    • Ease of remediation
    • BUT: Don’t assume people with disabilities won’t be interested in certain content (Eason v. New York State Board of Elections (S.D.N.Y) example)
  • Specify
    • Schedule for barrier elimination
      • Page by page
      • Barrier type by barrier type
      • Format by format
  • Assign
    • Person(s) responsible for implementation, oversight, progress tracking, reporting
    • Resources ($, staff, time)
  • Track and report progress
  • Update (every 5 years at least)
  • Establish and publish interim means for providing alternative access during remediation
    • Phone line where trained staff will read web information
    • Email address to request accessible versions of documents
    • Process for escalating accessibility requests/complaints
    • Vendors with deadlines for converting to accessible formats on request


  • Set schedules and responsibility for periodic audits
    • Internal and by qualified vendor
    • Automated and manual/user audits


  • Build Trust and Access Experts
    • Invite and welcome feedback – and respond
    • Publicize your efforts, plans, and progress
    • Hire user testers
    • Include people with disabilities in Beta testers
  • Great policies are only as good as their implementation
    • Training
    • High level involvement