Developing Organizational Policies on Web Accessibility

introduction - reference - conformance - scope - milestones - monitoring - updating

1. Introduction

This document addresses considerations that can arise when developing organizational policies on Web accessibility.

Organizational policies can be very simple, or very comprehensive:

Example of simple policy:

"[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 1.0, Conformance Level Double A."

Example of comprehensive policy:

"[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 1.0, 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 1.0, 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."

Since there are existing governmental policies which 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 which already apply to their sites.

The following sections address considerations in setting organizational policy in more detail.

2. Reference guidelines clearly

The term "WAI Guidelines" is non-specific, as it can refer to any one of the three accessibility guidelines produced by W3C/WAI. Provide a clear reference to the specific guidelines document with which conformance is expected:
- "Web Content Accessibility Guidelines 1.0" (WCAG 1.0) is the W3C/WAI specification which explains how to make Web sites accessible.
- "Authoring Tool Accessibility Guidelines 1.0" (ATAG 1.0) is the W3C/WAI specification which explains how to make software better support the production of accessible Web content.
- "User Agent Accessibility Guidelines 1.0" (UAAG 1.0) is the specification which explains how to make accessible browsers and multimedia players.
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.

3. Specify conformance level

Specify an expected level of conformance for Web site(s). For example:
- "Conformance to WCAG 1.0 Level A" sets the expectation that a Web site would fulfill all priority one checkpoints, which address absolute barriers to accessing content on a Web site.
- "Conformance to WCAG 1.0 Double A" sets the expectation that a Web site would fulfill all priority one and priority two checkpoints, which address absolute and substantial barriers to accessing content on a Web site.
- "Conformance to WCAG 1.0 Triple A" sets the expectation that a Web site would fulfill all priority one, two, and three checkpoints, which address absolute, substantial, and minor barriers to accessing content on a Web site.
Specify an expected level of conformance for authoring tools used by the organization, or by third party developers, to produce content for the organization's Web site.
- "Conformance to ATAG 1.0 Level A" sets the expectation that Web authoring software acquired by an organization can fulfill all priority one checkpoints for accessibility of the software user interface and support for production of accessible content. [See example under "#5 Set milestones" below.]
- [To add to terms of subcontract]: "[Subcontracted Web developer] will consider the use of ATAG 1.0 conformant software where available. If not using ATAG 1.0 conformant authoring tools, [subcontracted Web developer] will ensure that all content and templates generated for [this organization's] production of content is WCAG 1.0 Double A -conformant, and contains no markup that will interfere with generation of WCAG 1.0-conformant content.
- See "Selecting and Using Authoring Tools for Web Accessibility" for additional detail.

4. Define scope of Web site(s)

Specify to what extent this organization's requirements should apply to new, updated, and existing Web pages. For example:
- "This policy applies to all new, updated, and existing Web pages."
Specify to what extent requirements should apply to Web pages provided by a third-party (subcontractor, or other information provider, but as part of main site). The Web site's users may need access to primary and to third-party content equally. It may take additional effort to educate and get compliance from third-party content developers. For example:
- "This policy applies to all Web content produced or updated by [this organization]. In addition, [this organization] is taking the following steps to ensure accessibility of content provided by third-party developers [NOTE that for some sites, accessibility of third-party content may be essential to complying with government policy]:
  - informing third-party developers of [this organization's] policy on Web accessibility;
  - providing links to information and resources on implementing Web accessibility;
  - providing the following incentives to providers of WCAG 1.0 Double A conformant content...;
  - monitoring and providing feedback on inaccessible third-party content;
  - seeking alternative third-party content providers where original providers continue to provide non-conformant content.

5. Set milestones

Set a date by which the organizations Web site(s) will meet a given conformance level. For example:
- "By [date] [this organization's] Web sites will meet WCAG 1.0 Double A Conformance Level."
In some cases it may be practical to phase in accessibility by addressing all of priority one checkpoints rapidly, since these can be absolute barriers if unaddressed; then phasing in priority two checkpoints with the next round of site improvements [no later than a specified date]; with priority three checkpoints left as optional. For example:
- "By [first date] [this organization's] Web sites will meet WCAG 1.0 Level A Conformance Level; and by [second date] [this organization's] Web sites will meet WCAG 1.0 Double A Conformance Level."
Consider how to address questions of priorities that may arise especially for Web sites with a large number of pages. Do not make assumptions about which areas of a Web site or which Web services people with disabilities are interested in or not. For example:
- "This policy applies to all areas of this organization's internal and external Web sites, including legacy content."
- Or, "This policy applies to all areas of this organization's internal and external Web sites, with priority to [specify which areas] areas of the site; however, all areas of the site are expected to conform to [specify conformance level] by [second date].
Consider setting date(s) for accessibility support in software. For example:
- "By [first date], all vendors of authoring tools used by [this company] should provide information regarding their plans for ATAG 1.0 conformance in future versions of their software. By [second date] [this company] will preferentially purchase ATAG 1.0-conformant authoring tools."
Consider setting dates for browser and multimedia conformance, without restricting people's ability to use adaptive browsers.
- "By [date], all vendors of browsers and multimedia players used by [this company] should provide information regarding their plans for UAAG 1.0 conformance in future versions of their software. By [second date] [this company] will preferentially purchase UAAG 1.0-conformant browsers and multimedia players.
Consider setting dates for establishing internal resources for training, technical assistance, monitoring, and/or an internal Web page with links to such resources.

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

Specify a recommended process and schedule for reviewing the organization's Web site for accessibility. For example:
- "Each department will review all areas of the organizations' Web site under its control using the process described at Evaluating Web Sites for Accessibility, and will review all new material that it publishes by using the same process."
- Each section of the Web site will include links for feedback on the site; this information will be compiled and considered during the review process."
Specify whether or not conformant pages, or sections of a Web site, should be labeled as such. For example:
- "The introductory page for sections of the Web site that have been determined to be conformant according to [link] process should display the [WCAG 1.0 Double A logo] or bear the following statement ["this page conforms to..."]
Consider specifying a periodic review of areas of the Web site by an internal department with the authority to follow up on non-conformant areas of the Web site. For example:
- "[This organization] will conduct periodic reviews of the Web site and any department with non-conforming Web pages will be asked to correct the problem within two weeks. Further problems in accessibility of an area will result in [specify as appropriate]"

7. Provide for integration and updating of policy

If the organization has or is developing an overall policy for Web sites, for instance establishing best practices for use of Web standards, support for a privacy policy, internationalization, use of metadata, usability, etc., it can be useful to incorporate accessibility in the overall policy, rather than to establish accessibility as a stand-alone policy.
Organizations referencing WCAG 1.0 may want to incorporate mechanisms to review and update, or to automatically update their policies at whatever point WCAG 2.0 is finalized as a W3C Recommendation. [NOTE, July 2002: While WCAG 1.0 will be stable and referenceable for some time, WCAG 2.0 is expected to better address advanced Web technologies and at the same time be easier to implement.]

Last updated July 11, 2002 by Judy Brewer <jbrewer@w3.org> with assistance from participants of the EOWG.

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