Accessibility for project managers
The key to successfully delivering accessibility is often down to whether the Project Manager embeds accessibility into every sprint or defers it to an exercise in remediation. Remediation is usually where an accessibility specialist audits and provides guidance, but this is not a scalable practice across the organisation, and it is not an Agile practice.
To support a more embedded approach, this document provides the Project Manager with links to resources that include Colt's technical Accessibility Guidance.
To embed accessibility into any project there are some simple steps that will enable it to be delivered as a fundamental part of a project and have minimal impact on resource, time or cost.
1. Before the project starts
Step #1
Ensure that the business case has not only flagged accessibility as a legal risk, but is also referencing the correct laws and policies listed in the Legal Risk Guide.
Step #2
To ensure that accessibility acceptance criteria as well as areas of responsibility, delivery and reporting are identified at the start of the project, the Accessibility RACI provides three variants for mapping areas of activity and responsibility into the Waterfall process.
Step #3
Ensure that the team are aware of the importance of Colt's Accessibility Strategy and make sure that they are also aware of the accessibility guidance and resources in place that will enable them to deliver Colt's ambition.
Step #4
Check if the developers have access to a platform they can use for the automated aspects of accessibility testing.
Step #5
If there is any content being planned as part of the project, which includes downloadable documentation, videos, content images, email newsletters or datasheets, ensure that content creators are aware of the guidance for both content creation and accessible document formatting.
Step #6
Most important of all is to ensure every sprint uses the guidance available, and accessibility is not deferred to an audit or sprint at the end as this will invariably swamp the backlog with tickets. Shifting accessibility left is a more cost-effective approach and stops accessibility being descoped to the point that it introduces legal risk (See Step #1)
Step #7
If the project involves the procurement of third party widgets or digital services with a UI, ensure the vendor evidences the accessibility of their product through the provision of an Accessibility Conformance Report (ACR) or VPAT, as well as a product accessibility roadmap.
2. The definition of done
Regardless of the methodology being used, Waterfall or Agile, Done has to be identified for every sprint. The Colt Developer Accessibility guides enable the core practices to be approached in a way that outputs accessible code, and where a specific component is being created, the links to accessible component best practices will enable their design to be more universal and usable.
The definition of done (DoD) is when all conditions, or acceptance criteria, that a software product must satisfy are met and ready to be accepted by a user, customer, team, or consuming system. We must meet the definition of done to ensure quality. It lowers rework, by preventing user stories that don't meet the definition from being promoted to higher level environments. It will prevent features that don't meet the definition from being delivered to the customer or user.
3. Manual vs automated testing
Automated accessibility testing is possible, however as accessibility is mostly about user outcomes, this will only ever cover about 20% of what is needed, so it is imperative that manual testing is planned from the start.
The manual UAT tests from the Colt Accessibility Guidelines are listed in the spreadsheet below. Make sure the individual tests are used as acceptance criteria for the relevant user stories, and the outcomes are captured. This will stop accessibility overwhelming the backlog.
For automated testing, there are some tools that can be used to alleviate the pressure on QA. These mostly cover the Robustness principle within the WCAG guidelines, with the other three principles needing to be tested manually. This will always need to be carried out using a combination of two tools. Firstly, an HTML validator to ensure that the content renders properly within the browser, and a more specialist tool to evaluate specific requirements for assistive technology support.
For general websites the accessibility testing should be done using Deque's Axe. This set of tests should be able to be integrated into any test platform. Here are some common integrations:
An exception is anything built using Salesforce, which should use the Sa11y test library as this is aligned with the Salesforce platform.
It is important to ensure the outcome of both the automated and manual testing is captured on an ongoing basis, including the delivery of any content assets, so if there is a legal challenge Colt can evidence that it has been inclusive in its approach.
4. User accessibility requirements
To ensure everyone can use Colt's products and services Colt has established an Accessibility Roadmap which is a key strategic business objective.
What that means in terms of user experience is that applications and pages should be accessible to users of assistive technologies. This includes simple objectives such as ensuring that everything is accessible using a keyboard only, to ensuring that if a user cannot see the screen, what they hear using their screen reader makes perfect sense.
Accessibility as defined by the W3C has 4 principles; Perceivable, Operable, Understandable and Robust. The first three of these refer to the user experience that you should consider when creating user requirements.
To make this easier Colt has created a set of accessibility guides which start by explaining what the desired user outcome is, as well as the methodologies, techniques and tests that will enable this to be delivered successfully.
Colour Perception
To ensure this can be evaluated there is an accompanying manual test script that can be added to the UAT activity undertaken by the Test Manager.
The introduction to each guide has everything needed to create User Requirements (Waterfall) or User Stories (Agile) and should be reviewed at the beginning of every project.
Screen reader user experience
To get an idea of how enabling the inclusion of user requirements can be, this video about screen reader user experience from Microsoft's Accessibility Team demonstrates the effectiveness of small considerations.
Experiencing your product with the Narrator Screen Reader is advised. How to do this is explained by the Colt guide, Using Windows Narrator to Test Web Accessibility.
5. Legal risks
Accessibility isn't just a legal requirement, but also is a fundamental aspect of Colt's strategic aims, which are outlined in Colt's Accessibility Roadmap, which is a part of Colt's Diversity, Equity and Inclusion strategy.
As well as opportunities, when it comes to digital inclusion there are also legal risks which should be identified in every business case. The purpose of this document is to enable anyone in Colt who is creating a business case that involves the creation of a web or mobile client or internal facing user interface, to flag the correct national or international legal framework as a Risk.
The type of risk is dependent on two things:
Where in the world a project will be implemented, marketed or made publicly available.
Whether the product or service is intended for public use, for employees or to be integrated into other organisations' employee services.
Risk in terms of disability should be considered beyond regulation as many clients have procurement, diversity or employment policies that cover the subject of accessibility, and many organisation make public commitments through organisations like Valuable500 or Disability:In to show how important inclusion is to their business and brand. Aligning with client policies reduces legal as well as business risk.
Nothing on this page constitutes legal advice and should only be for identifying laws and regulatory frameworks that require consideration. This is also not an exhaustive list of laws for each of the countries, and many have additional anti-discrimination laws for example that should also be considered, so further investigation may be necessary.
International law and guidelines
United Nations Convention on the Rights of Persons with Disabilities (UNCRPD)
The United Nations Convention on the Rights of Persons with Disabilities requires member states to work towards "the identification and elimination of obstacles and barriers to accessibility" in many areas, including "information, communications and other services, including electronic services." This mostly, but not exclusively applies to governmental services.
Web Content Accessibility Guidelines (WCAG)
The Web Content Accessibility Guidelines provide recommendations for evaluating whether online content is accessible. The guidelines themselves are not legal frameworks, meaning that digital systems should be Perceivable, Operable, Understandable and Robust. Although the guidelines are not a law or legal requirement, meeting their criteria is considered evidence of legal compliance in many jurisdictions, and those laws often contain references to the UNCRPD (see above) or require outcomes to be comparative and/or equitable. The WCAG guidelines are not the most usable resource, as they are more retrospective then informative, even though their content is very useful, which is why Colt has its own guides for Project Managers, Developers and Content Producers.
United States
Rehabilitation Act, Section 508
Section 508 of the US Rehabilitation Act requires that all electronic and information technology developed, procured, maintained, or used by the US federal government "is accessible to and usable by individuals with disabilities to people with disabilities."
While this regulation is a legal requirement for federal agencies and organisations receiving federal funding, compliance may also be a concern for organisations providing services to federal agencies. If businesses intend to provide products or services to other companies with government contracts, then there is likely to be a requirement to prove that the particular digital aspect is Section 508 compliant. This is often done using the format of a Voluntary Product Accessibility Template (VPAT) which can be completed by cross referencing the requirements with the outcomes of the accessibility requirements and testing using the Colt Accessibility Guidelines. This may need to be carried out by a specialist supplier.
Note that if the guidelines have been followed and evidenced, then an audit may not be necessary, however some expert assistance may be required to deliver this from a VPAT specialist.
As the act asks for systems to be usable as well as accessible to people with disabilities, then this aspect may also require further investigation and evidencing.
Americans with Disabilities Act Titles II and III
Title II of the Americans with Disabilities Act (ADA) covers state and local government entities. It requires them to ensure that their programs, services, and activities are accessible to people with disabilities, which includes both public and employment environments. While Title II focuses on government entities, private businesses, and organisations may still be impacted if they provide services or products to a regulated public entity.
Title III of the US Americans with Disabilities Act (ADA) focuses on prohibiting discrimination against people with disabilities in "places of public accommodation," including most private businesses open to the public. US courts have found that websites are a place of public accommodation and can be subject to ADA Title III requirements.
California's Unruh Civil Rights Act (UCRA)
Some US states have their own laws that regulate accessibility. One of the most commonly known and used is the Unruh Civil Rights Act in California. This law requires businesses to provide equal access to their services and facilities. While originally intended for brick-and-mortar establishments, courts have held that the UCRA also requires businesses with websites to make these accessible too. This law is aimed at businesses with a 'nexus in California', but may impact organisations who provide services to those businesses. For more information about US State Regulation, see The Office of Lainey Feingold's page on US Law for the latest updates.
United Kingdom
Equality Act
The UK Equality Act 2010 prohibits discrimination against people with disabilities and requires providers of goods, services, and facilities to anticipate the needs of potential disabled customers and make reasonable adjustments. This applies to websites and digital content, not just physical premises. This covers both service provision as well as employment and in both cases, there is a broad consensus that aligning a website with WCAG standards and demonstrating that disability access was a planned and actioned requirement demonstrates the "reasonable adjustments" required by this act.
Public Sector Bodies Accessibility Regulations 2018/2022
This regulation applies to any website or mobile app (internal or public facing) bought or built by a public sector body in the UK. It imposes stricter requirements on public sector organisations, primarily government organisations, and charities, regarding accessibility for websites and mobile apps. Covered entities must provide an accessibility statement on their website or app, which could include a link in the footer or About section or the app to Colt's Accessibility Roadmap. This regulation aligns with the European Standard EN 301 549 for accessibility of ICT products and services.
European Accessibility Act (EAA) in the UK
Although this act is currently only enforceable in the EU and it has not been ratified within the UK yet, because the UK has voluntarily adopted other EU regulations it is expected to also adopt this one. The EAA must be followed by non-EU-based companies that may wish to sell within the EU market.
European Union
The following guidance is relevant to all member states: Austria, Belgium, Bulgaria, Croatia, Republic of Cyprus, Czech Republic, Denmark, Estonia, Finland, France, Germany, Greece, Hungary, Ireland, Italy, Latvia, Lithuania, Luxembourg, Malta, Netherlands, Poland, Portugal, Romania, Slovakia, Slovenia, Spain and Sweden.
EU Charter of Fundamental Rights
The EU Charter of Fundamental Rights, Article 26: Integration of persons with disabilities, protects and guarantees equal access for people with disabilities. Although the Charter does not directly apply to private businesses or organisations located outside the European Union, businesses could still be affected if they have contractual relationships with EU entities.
European Standard EN 301 549
This standard applies to websites, mobile apps, and some specific telecommunications services in the EU public sector (owned, controlled, or funded by governments of European Union countries). This standard is expected to form the basis for a presumption of conformity with the European Accessibility Act (EAA), so it is also relevant to the EU private sector.
The EN 301 549 standard generally follows the Web Content Accessibility Guidelines (WCAG) 2.1 AA with some additions that include:
When accessibility features are activated on a user's operating system, the digital product or service should comply with those settings.
Hardware products should accommodate users with restricted mobility, dexterity, or physical strength.
Support services and documentation must provide information about user accessibility.
The European Accessibility Act (EAA)
The European Accessibility Act (EAA) is a European Union directive that extends the existing European human rights laws that protect and guarantee equal access for people with disabilities to specific services and products. Businesses must ensure that products and services covered by the act are accessible by June 28, 2025. For legacy products and services, the deadline is extended to 2030.
This act requires services to deliver against the WCAG Principles. Although this act is currently only enforceable in the EU (it has not been ratified within the UK yet, but is expected to be), it must be followed by non-EU-based companies that may wish to sell within the EU market.
India
The Rights of Persons with Disabilities Act
This law in India requires the government and commercial organisations to make "Reasonable Accommodation", for people with disabilities, and refers directly to websites, mobile applications, telecommunications services and workplace adjustments. The Act focuses on "the removal of barriers" to specific disability groups and uses WCAG as the benchmark for both government or commercial websites, although it does not directly point to which version. More information on disability legislation in India is available on the Department of Empowerment for Persons with Disabilities website.
Japan
Promotion of Information Accessibility and Communication for Persons with Disabilities
In May 2021, the "Act for Eliminating Discrimination against Persons with Disabilities" was revised, making it a legal obligation for private businesses as well as public institutions to provide reasonable accommodations only if people with disabilities request improvements to their products and services including their websites and mobile apps. However in May 2022, the "Law on the Promotion of Information Accessibility and Communication for Persons with Disabilities" was enacted.
In this new legislation it is essential that information and communication be accessible to all persons with disabilities. This law establishes basic principles for this purpose, but more specific measures are still awaiting consideration; however they are expected to align with the Japanese Industrial Standards (JIS) 8341-3 which is identical to WCAG 2.0.
The current version is JIS X 8341-3:2016 (Japanese) which has the same success criteria as WCAG 2.0.
Canada
The Canadian Human Rights Act protects disabled people in Canada from discrimination when they are employed by or receive services from the federal government, First Nations governments or private companies that are regulated by the federal government including telecommunications companies.
Canadian provincial regulation
The Accessibility for Ontarians with Disabilities Act (AODA) covers provincially-regulated public and private activities and standards have been enacted for the provision of accessible Information and Communications. AODA is notable as it carries a $100,000.00 fine for corporations that fail to comply. The regulations include standards for: Customer Service, Information and Communication and Employment.
Accessible British Columbia Act covers a mixture of standards in employment, delivery of services, information and communication, and procurement. It extends the range of principles beyond WCAG including Universal Design, where the core design of any product or service should be accessible to the widest possible range of user abilities in its default state.
Accessible Saskatchewan Act covers a mixture of standards and includes access to computer hardware, software and employment.
Accessibility for Manitobans Act (AMA) focuses on barriers for people with disabilities. The legislation applies to both the public and private sectors, and there are rolling timelines for different sectors. It is made up of five standards, including areas of customer service, employment, information and communication. The Province of Manitoba Disabilities Issues Office (DIO) supports the legislation.
Nova Scotia Accessibility Act (Bill 59) focuses on barriers for people with disabilities. This legislation applies to both the public and private sectors and includes the areas of the delivery and receipt of goods and services, employment, information and communication. Nova Scotia has launched the Nova Scotia Accessibility Directorate with resources and information about the Act.
Norway
Norway is the only country which has a dedicated government agency that monitors the entirety of its digital landscape including both government and commercial organisations. Norway's regulatory framework focuses on a mixture of WCAG guidelines and user outcomes. Norwegian digital accessibility legislation in 2023 article with links to Norwegian accessibility policies.
Norway has also chosen to follow the EN 301 549 standard to facilitate trade with the EU.
Resources and further information
Office of Lainey Feingold overviews of US Regulations and Global Policy and Regulations which are regularly updated.
O2 settles disability case for £160k. Source: BBC News.
The Americans with Disabilities Act in Cyberspace: Website Accessibility Standards [PDF] "A New York federal district court explained, in approving such a settlement, that WCAG is 'an appropriate standard to judge … compliance with any accessibility requirements of the ADA.' In the court's view, WCAG is 'nearly universally accepted.'" Congressional Research Service Legal Sidebar.
The Indian Manual for Rights of Persons with Disabilities Act 2016 is written for people without a law background to easily understand the Act.
Shaping a more disabled-friendly digital ecosystem 2023 Article from The Hindu.
New law bans bias against people with disabilities 2016 article from The Japan Times.
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