[ROUGH DRAFT] Developing Organizational Policies on Web Accessibility

Note: This document is a rough draft in development, and should not be referenced or quoted under any circumstances.
Current approved information is at www.w3.org/WAI/impl/pol
Last updated: $Date: 2008/11/24 20:38:04 $ [analysis & changelog]

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This page is part of a resource suite that recommends strategies and best practices for organizations planning to adopt Web Content Accessibility Guidelines (WCAG) or updating to WCAG 2.0 from WCAG 1.0.Whether your organization is adopting its first Web accessibility policy, considering updating from WCAG 1.0 to WCAG 2.0, or migrating to WCAG from other standards, this document addresses considerations that can arise when developing or revising your organization's policies on Web accessibility. The following sections address considerations in setting organizational policy in more detail by:

If you already have a Web accessibility policy, revisiting these topics is recommended, as the legal or social factors informing your policy may have changed since your policy was established.

Identifying Legal and Policy Factors that Apply to Your Organization

Because governmental policies exist that apply to some kinds of Web sites in some countries, organizations should ensure that their policies at least require the minimum accessibility mandated by any policies that already apply to their sites. Legal and policy factors apply differently to specific organizations and situations. For example, one organization might be required by explicit government regulations to make its Web sites accessible, while another organization follows the Web accessibility policies recommended by its trade association or required by a partner company.

To understand legal and policy implications for transitioning your Web content to WCAG version 2, you first must know what policies apply to your organization. For guidance, the following questions can help you identify how the legal and policy aspects of Web accessibility apply to the organization:

If the organization:

If so, then clarify whether the policy explicitly targets an existing Web accessbility standard or guideline, its version, and a level of conformance. For example, the Canadian Look and Feel Standards targets WCAG version 1, Priority 1 and 2, with an effective date of January 1, 2007.

If you are uncertain whether your organization is subject to Web accessibility policies or legislation, see Determining Applicable Policies. Once you have confirmed the applicable policies, you should also question:

Determining Applicable Policies

Web accessibility requirements can be in the form of policies, laws, regulations, standards, guidelines, directives, communications, orders, or other types of documents. Policies Relating to Web Accessibility lists governmental legislation and related information for many countries and regions.

Some governments have laws that specifically require that certain types of Web sites are accessible. Others might not directly specify Web accessibility, yet the Web is indirectly covered under broader anti-discrimination legislation, information and communications technology policy, or other laws or policies.

An organization might be required by non-governmental policies to make its Web site accessible, such as a university Web accessibility policy that requires department Web sites be accessible. Sometimes organizations are compelled to meet other policies, such as policies from trade or industry associations, professional associations, or standards organizations.

Considerations for Different Types of Organizations

Considerations Beyond Requirements

Sometimes the required standards or minimum conformance level might not adequately meet the needs of the Web site's users with disabilities. If the needs of people with some disabilities are left out of the required accessibility standards, an organization might choose to meet additional guidelines in order to provide sufficient accessibility. Version 2 of the WCAG guidelines may cover a wider range of disabilities, and so conformance to version 2 may help the organization meet these users' needs.

Considerations for the Future

It is almost always significantly easier, more effective, and less expensive to incorporate accessibility early in Web site development or redesign, rather than retrofit existing sites later. Therefore, many organizations that might be subject to Web accessibility requirements in the future choose to incorporate Web accessibility as soon as feasible.

An organization might be subject to additional Web accessible requirements in the future because:

Some policies reference specific guidelines or standards for Web accessibility and include dates for compliance. For example, a policy might state that Web sites meet Web Content Accessibility Guidelines (WCAG) Level A by a certain date and WCAG Level AA checkpoints by a later date. However, an organization might determine that it is most efficient to address all the requirements at the same time.

Understanding Risks for Non-Compliance

Once the applicable policies are understood, your organization should understand the risks of non-compliance with those policies. For example, some organizations have faced legal action for not making their Web sites accessible. Not complying with accessibility requirements can result in significant legal costs and have negative impact on the organization's reputation. At times, the legal requirements for an organization might be unclear. In such cases, some organizations determine that it is in their best interest (financially and otherwise) to make their sites accessible, rather than risk legal action.

Addressing Multiple Standards

As described above, an organization may be subject to multiple Web accessibility policies; for example, standards from governments in different counties where they operate, from a trade association, and from a partner organization. Addressing different standards is more complex than addressing a single standard; however, because there is almost always significant overlap between standards, the work to meet two different standards is not twice the work to address one standard. In most cases an organization meeting the more comprehensive standard can easily ensure that other standards are also met.

For organizations that are concerned about meeting multiple standards, it can be effective to include in the business case detail on the overlap between standards. For example, an appendix that shows the similarities between the different standards can illustrate where it is not much more effort to meet multiple standards.

Fortunately for Web authors, version 2 of WCAG was developed simultaneously with other standards updates. When the Telecommunications and Electronic and Information Technology Advisory Committee (TEITAC) reviewed the original Section 508 guidelines, they did so with consideration of WCAG and other Web accessibility standards.  The committee’s membership included representatives from industry, disability groups, individuals contributing to the WCAG version 2 update and others working on European based Web standards. The effect of this effort has been to harmonize standards. With WCAG version 2, Level AA, adopters can be assured of meeting or nearly meeting myriad other Web accessibility standards.

Crafting Your Organization's Web Accessibility Policy

Organizational policies can be very simple, or very comprehensive. In either case, your policy should identify the standard and its version to which the organization commits to conform. For example, a simple policy might state:

[This organization] is committed to ensuring accessibility of its Web site for people with disabilities. All the pages on our Web site will conform to W3C/WAI's Web Content Accessibility Guidelines 2.0, Conformance Level Double A."

A more comprehensive policy might indicate:

A sample comprehensive policy might state:

"[This organization] is committed to ensuring accessibility of its Web site for people with disabilities. New and updated Web content produced by our organization will conform to W3C/WAI's Web Content Accessibility Guidelines 2.0, Conformance Level A, by [date]. Existing Web content produced by our organization, and new, updated, and existing Web content provided for our site by third-party developers, will conform to Conformance Level Double A by [date]. We will initiate an internal monitoring program by [date]. Vendors supplying software used to develop our site will be required to provide information by [date] on conformance to W3C/WAI's Authoring Tool Accessibility Guidelines 2.0, Conformance Level A. Our home page and our 'about this site' page will include links to this policy. We will review this policy in the future to consider updating it to an advanced version of W3C's Web Content Accessibility Guidelines once available."

The following sections describe the steps to develop your Web accessibility policy in greater detail.

1. Reference guidelines clearly

The term "WAI Guidelines" is non-specific; it can refer to any one of the three accessibility guidelines produced by W3C/WAI. In addition, it can refer to either the current version (2.0) or the previous version (1.0). Provide a clear reference to the specific guidelines document and its version with which conformance is expected:

Version 2 of these guidelines are currently in varying states of completion. WCAG 2 will reach technical recommendation first; ATAG and UAAG are each currently in working draft stage. Organizations wishing to require conformance to WCAG 2.0 once that becomes a W3C Recommendation may specify conformance to the "Web Content Accessibility Guidelines" without specifying a version number.

2. Specify conformance level

3. Define scope of Web site(s)

4. Set milestones for conformance

5. Define monitoring, conformance claims, and follow-up process

6. Provide for integration and updating of policy