Accessibility as Part of Your Security and Risk Program

Accessibility risk management belongs in your governance, risk, and compliance (GRC) program alongside security, privacy, and other operational risks. Yet most organizations treat accessibility as a product concern or legal checkbox rather than an ongoing risk requiring systematic controls, monitoring, and reporting.

This disconnect has real consequences. Security teams maintain continuous vulnerability scanning, incident response procedures, and executive reporting. Privacy teams conduct data protection impact assessments and monitor regulatory changes. Accessibility often lacks equivalent rigor—discovered only when a demand letter arrives or a high-profile complaint surfaces.

The European Accessibility Act implementation in 2025 and the DOJ's Title II web accessibility rule signal that accessibility compliance is becoming as enforceable as other regulated areas. CISOs and risk officers who don't include accessibility in their programs are managing incomplete risk portfolios.

Why CISOs and Risk Officers Should Care

The Risk Parallel

What is accessibility risk? Accessibility risk is the potential for legal liability, user harm, reputational damage, and operational disruption resulting from digital products and services that exclude users with disabilities.

Security risk, privacy risk, and accessibility risk share common characteristics:

Regulatory exposure: All three have regulatory frameworks (SOX, GDPR, HIPAA for security/privacy; ADA, Section 508, EAA for accessibility) with enforcement mechanisms and penalties.

User harm potential: Security breaches harm users through data exposure. Accessibility failures harm users through exclusion from services—sometimes critical services like healthcare or financial management.

Reputational impact: Security incidents make headlines. Accessibility lawsuits increasingly do too, particularly in class action cases.

Operational cost: Remediation after incidents (security breaches, accessibility lawsuits) costs more than prevention.

The Growing Regulatory Landscape

Accessibility regulations are expanding and enforcement is increasing:

Section 508: Federal agencies and their vendors face specific accessibility requirements for technology procurement and deployment.

European Accessibility Act: Effective June 2025, applies to products and services in the EU market with significant penalties for non-compliance.

State laws: California, New York, and other states have accessibility requirements beyond federal minimums.

Private lawsuits: Demand letters and structured negotiation increasingly target organizations without public litigation.

Risk officers who ignore accessibility are ignoring a significant and growing area of regulatory and litigation exposure.

Accessibility in Your Risk Register

Identifying Accessibility Risks

How do you identify accessibility risks? Assess your digital properties against WCAG standards, review complaint history, analyze litigation trends in your industry, evaluate third-party vendor accessibility, and examine critical user journeys for potential barriers.

Document accessibility risks with the same rigor as other operational risks:

Legal exposure: Risk of ADA/Section 508/EAA enforcement actions or private litigation. Likelihood based on industry (retail, financial services face higher rates), company visibility, and current compliance state.

User harm: Risk that users with disabilities cannot access critical services. Impact varies by service type—inability to access healthcare information differs from inability to browse marketing pages.

Reputational risk: Risk of negative publicity from accessibility failures. Consider social media amplification and advocacy community attention.

Operational risk: Risk that accessibility failures disrupt business processes. Inaccessible internal tools affect employee productivity; inaccessible customer interfaces affect revenue.

Vendor/supply chain risk: Risk from third-party components, widgets, or platforms that introduce accessibility barriers you inherit.

Quantifying Accessibility Risk

Apply standard risk quantification approaches:

Likelihood factors:

• Industry litigation frequency (retail, financial services, healthcare face highest rates)
• Previous complaints or demand letters
• Results of accessibility assessments
• Public visibility and brand profile
• Regulatory audit probability

Impact factors:

• Settlement and legal fee exposure ($10,000-$500,000+ for ADA cases)
• Remediation costs (often higher under legal pressure)
• Revenue impact from excluded users
• Reputational damage value
• Regulatory penalty exposure (EAA, state laws)

Create risk ratings consistent with your existing risk framework—high/medium/low or numerical scores that integrate with enterprise risk management.

Controls and Mitigation Strategies

Document controls that reduce accessibility risk:

Preventive controls:

• Accessibility requirements in product development process
• Accessible component libraries and design systems
• Automated accessibility testing in CI/CD pipelines
• Accessibility training for developers and designers
• Vendor accessibility requirements in procurement

Detective controls:

• Regular automated accessibility scanning
• Periodic manual accessibility audits
• User feedback mechanisms
• Monitoring of complaint channels

Corrective controls:

• Documented remediation procedures
• Escalation paths for critical accessibility issues
• Accessibility statement with feedback mechanism
• Incident response procedures for accessibility complaints

Map controls to risks and assess control effectiveness. A control that exists but isn't consistently followed provides less risk reduction than one with verified implementation.

Integrating Accessibility into GRC Processes

Audit Cycles and Evidence Collection

Align accessibility assessment with existing compliance cycles:

Annual assessments: Comprehensive accessibility audits aligned with annual compliance reviews. Document scope, findings, and remediation status.

Quarterly reviews: Review accessibility metrics, incident trends, and control effectiveness. Update risk ratings as needed.

Continuous monitoring: Automated scanning providing ongoing evidence of accessibility control operation.

Evidence retention: Maintain documentation of:

• Assessment reports and findings
• Remediation actions and verification
• Training completion records
• Policy documentation
• Accessibility statement updates

This evidence supports both regulatory compliance demonstrations and litigation defense.

Control Testing

Verify that accessibility controls actually function:

Training controls: Verify that required personnel have completed accessibility training. Test knowledge through assessments.

Development controls: Audit code repositories for accessibility testing integration. Sample PRs for accessibility review completion.

Scanning controls: Verify automated scanning is running, results are reviewed, and issues are addressed within defined SLAs.

Vendor controls: Verify procurement processes include accessibility requirements. Sample vendor contracts for accessibility terms.

Document control testing results and remediation of control gaps.

Incident Management

Establish accessibility incident management procedures:

Incident definition: What constitutes an accessibility incident? Demand letters, complaints, discovered critical barriers, failed audits.

Response procedures: Who is notified? What are response timeframes? How are issues triaged and assigned?

Documentation requirements: What records must be maintained? Attorney-client privilege considerations for legal communications.

Post-incident review: Analysis of root causes and control improvements after incidents.

Integrate accessibility incidents into existing incident management frameworks rather than creating parallel processes.

Reporting Accessibility Risk to Leadership

Dashboard Metrics for Risk Committees

Executives need concise, actionable accessibility risk information:

Compliance posture:

• Percentage of pages/applications meeting WCAG AA
• Number of critical and serious issues outstanding
• Trend over time (improving/stable/degrading)

Control effectiveness:

• Automated scan coverage percentage
• Training completion rates
• Time to remediate identified issues

Incident metrics:

• Complaint/demand letter count
• Active legal matters
• Remediation costs incurred

Risk exposure:

• Overall accessibility risk rating
• Comparison to risk appetite/tolerance
• Key risk indicators and trends

Board-Level Reporting

For boards of directors, focus on:

Risk exposure: Is accessibility risk within approved risk appetite? What's the exposure magnitude?

Compliance status: Are we meeting regulatory requirements? What gaps exist?

Trend direction: Is accessibility improving or degrading? Are investments producing results?

Significant incidents: Material accessibility incidents requiring board awareness.

Resource adequacy: Are current accessibility investments sufficient for risk management?

Avoid technical details—boards care about risk, compliance, and resource adequacy, not WCAG success criteria numbers.

Stakeholder Communication

Different audiences need different information:

Risk committee: Full risk register, control assessments, incident metrics, resource requests.

Executive team: Summary metrics, trend direction, significant incidents, strategic recommendations.

Board: Material risk exposure, compliance status, resource adequacy.

Audit committee: Control effectiveness, audit findings, evidence retention.

Operations teams: Detailed metrics, issue assignments, remediation priorities.

How TestParty Fits in Risk and Compliance Programs

Continuous Control Monitoring

TestParty provides evidence that accessibility controls are operating:

Automated scanning: Regular scans document ongoing accessibility monitoring—evidence that detective controls function.

Issue tracking: Documented findings and remediation timelines demonstrate corrective control operation.

Trend reporting: Historical data shows whether accessibility posture is improving, supporting risk rating updates.

Coverage metrics: Dashboard showing what percentage of digital properties are scanned and at what frequency.

Compliance Evidence Generation

TestParty generates artifacts for compliance documentation:

Assessment reports: Exportable findings mapped to WCAG criteria for audit evidence.

Remediation documentation: Records of issues identified and fixes verified.

Historical records: Point-in-time accessibility snapshots supporting regulatory inquiries.

SLA compliance: Reports on time-to-remediate meeting defined service levels.

Integration with GRC Platforms

For organizations using GRC platforms (ServiceNow, OneTrust, Archer, etc.), TestParty data can feed into:

Risk registers: Accessibility metrics informing risk ratings.

Control testing: Automated evidence collection for accessibility controls.

Incident management: Accessibility findings triggering incident workflows.

Compliance tracking: Regulatory requirement mapping and gap analysis.

Building the Business Case for Accessibility Governance

ROI Arguments for Risk Officers

Present accessibility governance as risk-reduction investment:

Litigation cost avoidance: Average ADA website settlement is $10,000-$75,000; some exceed $500,000. Class actions cost more. Prevention costs less than remediation under legal pressure.

Regulatory penalty avoidance: EAA penalties, Section 508 enforcement actions, and state law penalties create quantifiable exposure.

Insurance considerations: Some cyber liability policies exclude or limit accessibility claim coverage. D&O policies may have exposure.

Operational efficiency: Preventing accessibility incidents is cheaper than responding to them.

Benchmarking Questions

Evaluate your organization's accessibility governance maturity:

1. Is digital accessibility in your enterprise risk register?
2. Are accessibility controls documented and tested?
3. Do you have continuous accessibility monitoring?
4. Is accessibility included in vendor risk assessments?
5. Do you have accessibility incident response procedures?
6. Do executives receive accessibility risk reporting?
7. Is accessibility covered in compliance audit scope?

"No" answers identify governance gaps to address.

Frequently Asked Questions

Should accessibility be owned by security or product teams?

Accessibility governance should sit in your GRC function alongside security and privacy risk management. Day-to-day implementation remains with product and engineering teams, but risk oversight, control monitoring, and executive reporting belong in risk management. This mirrors how security works—SecOps operates in engineering while CISO reports to risk/audit functions.

How do we quantify accessibility litigation risk?

What's the minimum accessibility governance program?

At minimum: include accessibility in your risk register, conduct annual accessibility assessments, implement continuous automated scanning, document an accessibility statement, and establish complaint response procedures. More mature programs add control testing, executive dashboards, and integration with enterprise GRC platforms.

How does accessibility fit with SOC 2 or ISO 27001?

Accessibility isn't directly covered by SOC 2 or ISO 27001, but it fits within broader operational risk and compliance frameworks these standards establish. Some organizations include accessibility in SOC 2 "additional subject matter" sections. ISO frameworks provide governance structures easily extended to accessibility compliance.

What happens if we get an accessibility demand letter?

Engage legal counsel immediately—many communications should be protected by attorney-client privilege. Document your accessibility program and remediation efforts as evidence of good faith. Evaluate the specific claims and your compliance state. Many demand letters settle for $5,000-$20,000 plus remediation commitments. Don't ignore communications—that escalates costs and exposure.

Conclusion – Treat Accessibility as a Governance Priority

Accessibility risk management deserves the same governance rigor as security and privacy. Organizations that treat accessibility as a checkbox rather than an ongoing risk exposure leave themselves vulnerable to litigation, regulatory action, and reputational damage.

Building accessibility into your risk program means:

• Risk identification that documents accessibility exposure in your risk register
• Controls that prevent, detect, and correct accessibility issues
• Monitoring through continuous automated scanning and periodic assessments
• Incident management procedures for accessibility complaints and demand letters
• Reporting that keeps leadership informed of accessibility risk posture
• Integration with existing GRC processes and platforms

The regulatory trend is clear: accessibility compliance is becoming as enforceable as other areas of operational risk. Organizations that build accessibility governance now will be prepared. Those that don't will be reacting to enforcement.

Want to add digital accessibility to your continuous risk monitoring program? Book a demo with TestParty and see how automated accessibility monitoring supports GRC requirements.

Related Articles:

• 13 Essential WCAG Compliance Statistics Reshaping Web Accessibility Standards