The Right Way to Accessibility Accountability

Why This Matters to You

If you sell digital content or applications to a university or to the public sector, this discussion matters a lot. The approach taken by CSU is a best practice and this presentation indicates how more and more large organizations will be requiring the accessibility of your products to be demonstrated in the future.

The Challenge

Acquiring accessible IT products is one of the biggest challenges facing organizations today. Large and small institutions are often required to provide an accessible experience to their users. Even if they are not required to do so they can still face an accessibility legal complaint by failing to provide an accessible experience. Interestingly, the vendors who sell these IT products and online services are usually not required to ensure they are accessible and are usually not motivated to do so.

Last week I was privileged to be invited as a presenter at the first session of the International Association of Accessibility Professionals (IAAP) 5-part Higher Education series of webinars on the topic of Driving Accessibility Campus Improvements. The session touched on an effective way to help vendors take responsibility for the accessibility of their products and services. While this discussion was focused on Higher Education Institutions, the method used could just as easily be incorporated by other sizeable organizations. In so doing, smaller organizations would also benefit.

The presenters for this IAAP webinar were:

Why Me?

For over ten years, I've worked directly with CSU's Chancellor's Office and the 23 campuses of CSU in helping them migrate towards and manage web accessibility. This included extensive weekly calls with the Chancellor's Office and their Community of Practice. More recently, we have worked with CSU's procurement personnel in helping a vendor verify its ACR. I've also worked with other public entities that require third-party accessibility reviews, such as the Commonwealth of Massachusetts.

The Answer

To meet the challenge of ensuring that procured IT is accessible, California State University (CSU) developed a process that integrates accessibility requirements into campus business processes and puts the responsibility on vendors for the accessibility of their product(s).

We are not going to go into the details presented in that webinar, but we do want to cover some of the items the CSU requires of product vendors before making a purchase as well as some of the benefits that come as a result, not just to CSU but also to the vendors that go through this process.

Prior to integrating accessibility requirements into their business processes, CSU faced the same challenge many others face when choosing a product or service which also needs to be accessible. That is having no choice but to take the vendor at their word that their products are accessible. Vendors may believe they have done their due diligence in incorporating accessibility or they may just be saying whatever they need to say in order to close the sale. I would like to think it is the former and it is just a matter of not truly understanding what it really means to be accessible.

Recognizing this disconnect on the part of their vendors, CSU decided to try a different method to hold the vendors accountable. CSU found that the appropriate time to put the responsibility for accessibility on the vendor is during the acquisition process. They did this by insisting on accurate accessibility documentation, commitments from the vendor for accessibility improvements to the product, and informative details for the users of the product. Setting forth these requirements proved crucial to driving product improvements.

For critical services and products, CSU also requires a third-party accessibility review. Having this accurate documentation then allows campuses to create Equally Effective Alternative Access Plans and students that encounter barriers can be quickly served with workarounds or accommodations.

The Benefits

The benefits of holding the vendor accountable during the acquisition process may be obvious for CSU. Instead of relying on the vendor to attest to the accessibility of their product, the vendor must now engage with a third-party accessibility consultant to review and create an independent Accessibility Conformance Report (ACR) in addition to other requirements we will cover a bit later. The end result is that CSU now knows just how accessible the product they are purchasing really is and what issues may exist. Additionally, they have access to the vendor’s intentions in addressing these issues along with their estimated timeline. If the vendor refuses to address the accessibility issues, CSU doesn’t purchase the solution. The vendor misses out on a large sale and CSU can find another vendor who is willing to take accessibility seriously.

What I found more interesting is the benefits for the vendors who go through this process. Both Hyrum and Sam, from GoReact, confirmed that going through the acquisition process with CSU was not easy or cheap but that it empowered their company in better understanding accessibility and in also establishing accessibility as part of the development lifecycle. They also mentioned that they are on track in refining their product’s accessibility in addition to positioning themselves to stand out from their competition when it comes to accessibility. In other words, they are a much more competitive choice because of going through the CSU acquisition process and will be even more so as they address any remaining accessibility issues.

This is just a single example of one vendor who now has a better grasp of accessibility, sees the need of taking it seriously, and has incorporated it into their product creation and development process. The long-term effect is that other customers of GoReact will also benefit. CSU’s efforts of holding vendors accountable is an excellent example of how larger organizations and institutions can have a huge impact in the accessibility world and results in a much more effective form of advocacy than what we currently see through litigation because it encourages accessibility in a proactive (instead of a reactive) way. This approach is also what distinguishes laws like Section 508 from other civil rights laws because it provides a market incentive for companies to continually improve the accessibility of their products for people with disabilities. CSU did not arrive at their process easily or overnight but they are willing to share it so all can benefit. Let’s hope their efforts start a movement in the vendor realm and that the accessibility of a product or service is held at the same level of importance as privacy and security.

The Details (Sort Of)

We are not able to provide the details of everything that was discussed during the IAAP webinar, but we can fill you in on what the vendor is expected to provide. For critical products and services, CSU asks the following from the vendor who is seeking to sell their solution:

Accessibility Conformance Report (ACR)

The ACR outlines how well a product or service supports accessibility and is derived from the Voluntary Product Accessibility Template (VPAT). CSU will request an ACR based on the Section 508 version of the VPAT. The third-party accessibility consultant’s review of the product or service is used to create the ACR and if your consultant does not create this ACR for you, you may be asked to provide the audit report from your accessibility consultant in addition to the ACR.

A third-party audit can be costly, and we recommend that you do not wait until time is of the essence to engage with an outside accessibility consultant. Doing so will likely increase the cost of the review due to time constraints and also lessens the amount of time your team will have to address any of the issues identified.

If you are currently in need of a third-party review and ACR for your product or service, please contact us to discuss how we can help.  Email us at!

Accessibility Roadmap

The Accessibility Roadmap outlines how and when your team plans to address the accessibility issues identified in the ACR. This is something your development team will need to create and provide since they are familiar with the product and how much work fixing the various issues may require. Keep in mind, focusing on the blocking issues is the highest priority. Other issues that do not prevent a user from accomplishing a critical task should be addressed after the blocking issues, in most cases.

Accessibility Statement

An Accessibility Statement should not be a generic statement but rather one that is specific to your product or service. It should also be easily found from within your product or service. This statement should clearly outline your commitment toward accessibility along with a summary of the current overall level of compliance. It should also outline any product accessibility features and current issues, including the workarounds, if they exists. Including a user feedback mechanism is also a must for a well-crafted statement.

Creating a complete and effective Accessibility Statement is something most quality accessibility consultants can help craft. If you find yourself needing help, please contact us to discuss how we can assist. Email us at!

Vendor Product Accessibility Demonstration

The Vendor Product Accessibility Demonstration is where the rubber meets the road in the sense that you must now prove that your product or service can be used with only the keyboard and with assistive technologies. A basic overview will be requested as well as your ability to successfully step through user tasks. This can be difficult if you are unfamiliar with accessibility testing and using assistive technology. This is where a quality third-party accessibility consultant can provide assistance. You want to let your consultant know up front as it will require preparation to make sure your demonstration goes well and with no surprises.

Once again, if you need help, please contact us to discuss how we can help. Email us at!


Placing the responsibility of addressing accessibility on the vendor just makes sense. The days of taking on the legal risk of inaccessible products and services will hopefully be a thing of the past. Because integrating accessibility requirements into the business acquisition processes can take effort and time, not every organization will be able to do so. If the bigger players make it a point to follow CSU’s example it helps create a reason for vendors to take accessibility seriously, which can have a long-lasting effect for all sizes of organizations. It really is a win-win approach and CSU’s effort and example is to be applauded.

If you are a vendor of a product or service, or if you need to ensure that your organization is creating accessible online content, please consider working with a third-party accessibility consultant.

Converge Accessibility can help you get on track. We offer third-party accessibility audits and can help your teams align their efforts toward accessibility with our WebAlign product.

We look forward to talking with you more about how we can help! Email us at, today!

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