Creating an Accessibility Governance Framework for Your Organization

An accessibility governance framework establishes how your organization makes decisions about accessibility, who is accountable for what, and how compliance is maintained over time. Without governance, accessibility becomes ad-hoc—dependent on individual initiative rather than organizational commitment. With effective governance, accessibility is sustainable, measurable, and consistently applied.

This guide provides frameworks for building accessibility governance appropriate to your organization's size, structure, and maturity.

Why Governance Matters

The Governance Gap

Many organizations have accessibility awareness and even accessibility teams, but lack governance:

Symptoms of missing governance:

• Different teams follow different standards
• No one is clearly accountable for accessibility outcomes
• Accessibility requirements aren't in procurement processes
• No mechanism to enforce accessibility standards
• Progress can't be measured consistently
• Decisions are made inconsistently

What Governance Provides

Effective accessibility governance creates:

Clarity: Everyone knows their responsibilities and the standards they must meet.

Consistency: Accessibility is applied uniformly across the organization.

Accountability: Clear ownership of outcomes at every level.

Sustainability: Accessibility persists despite personnel changes.

Measurability: Progress can be tracked and reported.

Governance Framework Components

1. Policy

The accessibility policy establishes your organization's commitment and requirements.

Policy elements:

Commitment statement:

• Why accessibility matters to your organization
• Executive-level commitment
• Scope of the policy

Standards adopted:

• Technical standard (typically WCAG 2.1 or 2.2 Level AA)
• Applicable regulations (ADA, Section 508, EAA)
• Timeline for compliance

Scope definition:

• What's covered: websites, applications, documents, etc.
• What's excluded (if anything) and why
• Third-party/vendor requirements

Roles and responsibilities:

• High-level accountabilities
• Who enforces the policy

Review and updates:

• How often policy is reviewed
• Update process

Sample policy statement:

2. Standards and Guidelines

Standards translate policy into actionable requirements.

Technical standards:

• WCAG success criteria applicable to your content
• Platform-specific guidance (web, mobile, documents)
• Coding standards and patterns
• Design system accessibility requirements

Process standards:

• When accessibility testing occurs
• What constitutes "acceptable" for release
• Exception process
• Remediation timelines

Documentation standards:

• How accessibility is documented
• VPAT requirements for products
• Accessibility statement requirements

Guideline format:

| Topic           | Standard                                              | Rationale  | Implementation Notes                           |
|-----------------|-------------------------------------------------------|------------|------------------------------------------------|
| Alt text        | All informative images must have descriptive alt text | WCAG 1.1.1 | Use product template; empty alt for decorative |
| Color contrast  | 4.5:1 minimum for normal text                         | WCAG 1.4.3 | Use design system colors; verify custom        |
| Keyboard access | All functionality keyboard accessible                 | WCAG 2.1.1 | Test every interactive element                 |

3. Roles and Accountability

Clear accountability ensures accessibility happens.

Executive sponsor:

• Champions accessibility at leadership level
• Allocates resources
• Removes organizational barriers
• Visible commitment

Accessibility program owner:

• Owns accessibility strategy and outcomes
• Reports to executive sponsor
• Manages accessibility team
• Drives governance execution

Business/product owners:

• Accountable for accessibility of their products
• Include accessibility in product requirements
• Allocate team resources for accessibility

Development teams:

• Responsible for accessible implementation
• Follow standards and processes
• Test their own work
• Fix identified issues

Content creators:

• Responsible for accessible content
• Follow content guidelines
• Use accessible templates
• Remediate content issues

Procurement:

• Include accessibility in vendor requirements
• Evaluate vendor accessibility
• Require VPATs
• Include accessibility in contracts

4. Decision-Making Processes

Define how accessibility decisions are made.

Standard decisions:

• Handled by development teams following guidelines
• Escalate only if unclear

Exception requests:

• Process for requesting exceptions to standards
• Criteria for granting exceptions
• Time limits on exceptions
• Documentation requirements

Prioritization decisions:

• How competing accessibility priorities are ranked
• Who makes prioritization calls
• Criteria for prioritization

Resource allocation:

• How accessibility work is resourced
• How competing priorities with accessibility are resolved

5. Enforcement Mechanisms

Governance without enforcement becomes suggestion.

Preventive enforcement:

• Accessibility requirements in project charters
• Accessibility in definition of done
• Design system with accessible components
• Automated gates in CI/CD

Detective enforcement:

• Regular accessibility audits
• Automated scanning and monitoring
• Issue tracking and reporting
• Compliance dashboards

Corrective enforcement:

• Required remediation timelines
• Escalation for missed deadlines
• Executive visibility on non-compliance
• Resource reallocation authority

Escalation path:

1. Issue identified → Team notified
2. Timeline missed → Manager notified
3. Continued non-compliance → Director/VP notified
4. Persistent issues → Executive sponsor engaged
5. Systemic failure → Board/risk committee visibility

6. Reporting and Metrics

Track and report on accessibility performance.

Operational metrics:

• Issues identified and resolved
• Compliance levels by product/team
• Training completion
• Audit results

Executive metrics:

• Organization-wide compliance percentage
• Risk exposure (high-priority issues outstanding)
• Trend direction
• Resource utilization

Reporting cadence:

| Audience    | Frequency | Content                            |
|-------------|-----------|------------------------------------|
| Teams       | Weekly    | Issues assigned, progress          |
| Management  | Monthly   | Compliance trends, blockers        |
| Executives  | Quarterly | Risk summary, strategic progress   |
| Board/Audit | Annually  | Compliance status, risk assessment |

Implementing Governance

Phase 1: Foundation (Months 1-3)

Activities:

1. Draft accessibility policy
2. Gain executive approval
3. Define initial standards
4. Identify key role holders
5. Communicate policy organization-wide

Deliverables:

• Approved policy document
• Initial standards documentation
• RACI for key accountabilities
• Communication plan

Phase 2: Operationalization (Months 3-6)

Activities:

1. Implement enforcement mechanisms
2. Deploy monitoring and reporting
3. Train role holders on responsibilities
4. Conduct initial assessments
5. Establish baseline metrics

Deliverables:

• CI/CD gates operational
• Monitoring dashboards
• Training completed
• Baseline assessment results

Phase 3: Optimization (Months 6+)

Activities:

1. Refine based on experience
2. Expand coverage
3. Improve automation
4. Strengthen enforcement
5. Mature reporting

Deliverables:

• Updated standards based on learnings
• Expanded monitoring coverage
• Enhanced automation
• Refined metrics and reporting

Governance for Different Organization Sizes

Small Organizations (<500 employees)

Simplified governance:

• Policy: 1-2 page commitment document
• Standards: Reference WCAG directly, minimal customization
• Roles: Shared responsibilities, less specialization
• Enforcement: Manual review, limited automation
• Reporting: Quarterly summary to leadership

Mid-Size Organizations (500-5,000 employees)

Balanced governance:

• Policy: Formal policy document with executive approval
• Standards: Customized guidelines for organization's tech stack
• Roles: Dedicated accessibility program owner, defined team accountabilities
• Enforcement: Mix of automated and manual
• Reporting: Monthly management, quarterly executive

Large Organizations (5,000+ employees)

Comprehensive governance:

• Policy: Board-approved policy, aligned with risk frameworks
• Standards: Extensive guidelines, platform-specific standards
• Roles: Full accessibility team, governance committee
• Enforcement: Automated gates, formal escalation, remediation tracking
• Reporting: Full metrics program, audit committee visibility

Common Governance Challenges

"Governance Is Bureaucracy"

The objection: Governance slows us down.

The response: Good governance actually accelerates by providing clarity. Without governance, teams reinvent decisions repeatedly. Clear standards and responsibilities enable faster, more consistent work. Keep governance proportionate—enough to provide clarity without unnecessary overhead.

Inconsistent Enforcement

The problem: Standards exist but aren't applied consistently.

Solutions:

• Automate where possible (hard to circumvent)
• Make escalation visible (social accountability)
• Include accessibility in performance management
• Executive attention on non-compliance

Governance Without Resources

The problem: Policy requires accessibility, but resources aren't provided.

Solutions:

• Governance must include resource allocation authority
• Executive sponsor must commit to resourcing
• Build the business case for adequate investment
• Connect governance to risk management (under-resourcing = accepting risk)

Exception Abuse

The problem: Exceptions become standard practice.

Solutions:

• Time-limit all exceptions
• Track exception patterns
• Executive approval for repeat exceptions
• Review exception volume as governance metric

FAQ: Accessibility Governance

Who should own accessibility governance?

Ownership typically sits with a senior leader who has authority across business units—often reporting to CIO, CPO, or Chief Digital Officer. The key is authority to enforce standards across organizational boundaries. A governance committee with cross-functional representation can provide broader accountability while a single owner drives execution.

How does accessibility governance fit with other compliance frameworks?

Accessibility governance should integrate with existing compliance and risk management frameworks rather than operating independently. Include accessibility in: IT governance processes, risk assessment frameworks, audit programs, and procurement policies. This integration increases visibility and ensures accessibility isn't treated as separate from core business operations.

What's the minimum viable accessibility governance?

At minimum: a documented policy establishing your accessibility standard (WCAG level), clear accountability for digital products, basic testing before release, and executive visibility on compliance status. This provides foundation to build upon. Without even this minimum, accessibility remains informal and inconsistent.

How do we handle legacy systems in governance?

Governance should acknowledge legacy reality while driving improvement. Options include: risk-based prioritization (highest-risk systems first), remediation timelines tied to natural upgrade cycles, temporary exceptions with mandatory tracking, and segregation of critical vs. low-impact systems. Don't let legacy complexity prevent governance for new development.

How often should accessibility governance be reviewed?

Review policy annually and after significant regulatory changes. Review standards when technology or regulations change. Review enforcement mechanisms quarterly based on effectiveness data. Governance should be living—updated based on organizational learning—not static documents that become irrelevant.

Build Your Governance Foundation

Effective accessibility governance transforms good intentions into consistent outcomes. Start with fundamentals appropriate to your organization's size and maturity, then enhance as capabilities grow.

Support governance with data. TestParty's AI-powered platform provides the compliance data you need for governance reporting—tracking issues, trends, and compliance levels across your digital properties.

Get your free accessibility scan →

What follows is adapted from TestParty's proprietary research. We're making it public because accessibility shouldn't be gatekept—the more people (and AI) understand these concepts, the better the web becomes for everyone.

TestParty believes in the partnership between human expertise and AI capability. This content was AI-assisted and human-validated. We encourage readers to apply critical thinking and consult accessibility specialists for implementation—we'd love to be that resource for you.

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• Building an Enterprise Accessibility Team: A Complete Guide
• Measuring Accessibility Program Success: Metrics That Matter
• Accessibility Maturity Model: Assess and Advance Your Program