Two designers collaboratively planning a mobile app interface using paper wireframes, illustrating early-stage UX design with accessibility in mind.
Editorial

Why Digital Accessibility Must Be Treated as a Risk Management Priority

7 minute read
Lawrence Shaw avatar
By
SAVED
Many brands still fail WCAG standards. Treating digital accessibility as a risk may finally drive real progress.

The Gist

  • Most websites still fail accessibility tests. Surveys show little progress toward meeting WCAG 2.x guidelines despite years of attention.
  • Accessibility remains a leadership blind spot. Confusing technical language and jargon often hide the risks instead of revealing them.
  • Treat it as a risk, not just ethics or tech. Framing accessibility as a business risk—like cybersecurity—helps drive real progress.

How can brands move forward with digital accessibility? Treat it as risk management issue

Over six years, surveys like the WebAIM Million have consistently shown the vast majority of websites fail to meet the WCAG 2.x guidelines on digital accessibility. Collectively we’ve made more or less zero progress. Why? 

In my experience, digital accessibility often struggles to gain traction with leadership. Not because they don’t care, but because the information isn’t usually presented in a clear, actionable way. The field is overly technical, scattered across multiple standards, and filled with jargon. Often, the same teams responsible for delivering accessibility also produce the reports, which can result in outputs that are too technical and confusing, hiding the real issues and risks rather than highlighting them. 

Without straightforward, risk-focused reporting, accessibility remains invisible to senior leaders, and that lack of clarity filters down through the organization. As a result, teams on the ground don’t have the mandate, support or tools they need to tackle the root causes effectively, leaving accessibility stuck in the same place year after year.

Table of Contents

Risk Management Opens Doors

The best way for brands to break this cycle? Treat digital accessibility as a risk management issue, and report that to senior management in a clear way they can actually understand. Only then, will digital accessibility start to get the attention it deserves. 

Risk opens doors. Nothing is better at supporting a business case or forcing a quick decision than a risk management issue. The high levels of risk around cybersecurity, for example, are well known. If digital accessibility issues were considered on par with cybersecurity issues, then progress would be swift and substantial. 

Accessibility Is a Risk Issue Not a Technical Issue

Of course, accessibility already is a risk issue. Organizations need to be able to navigate the sea of digital accessibility regulations that sometimes go under the radar to make sure they are compliant.

However, all too often teams present digital accessibility to senior leaders in all its highly technical glory, turning it into an issue that leaders neither fully understand nor want to engage with. They will not want to be accountable for something they only half understand. 

The detail is confusing and off-putting. Your CFO, CIO or head of risk cannot appreciate a 50-page expert report with endless lists of recommendations and technical checkpoints. Their eyes glaze over, and, before you have said “WCAG 2.2,” their attention is elsewhere. 

Common Accessibility Reporting Mistakes

How well-intentioned reporting can miss the mark—and what to do instead.

Common MistakeWhy It FailsBetter Approach
Lengthy technical reportsToo complex for executives to digest or act onUse simple scorecards and RAG dashboards
Focusing solely on WCAG complianceOverlooks real-world business risks and impactsLink accessibility to legal, financial and reputational risks
Omitting user impact or real examplesMakes the issue feel abstract or theoreticalInclude real user stories or customer complaints
Assuming leaders are technical expertsThey disengage if they don't understand the reportTailor reports for CFO, CIO or risk leadership specifically

In fact, the only people who can fully appreciate the expert report are other experts. The great irony about continually presenting accessibility as a more technical issue means it has sometimes become a less accessible topic in the wider sense.

The numbers around reporting digital accessibility can also add to the confusion if there is too much technical detail in the numbers. A 2021 UK survey of C-suite attitudes towards digital accessibility listed “It’s hard to measure the impact” as the top barrier to delivering digital accessibility. A simple scorecard or dashboard approach, for example with Red-Amber-Green status, is a better way to illustrate that progress made on accessibility compliance equates to risk reduction.

Related Article: Digital Accessibility Drives Customer Loyalty and Inclusion

The Ethical Dimension

As well as the technical angle, teams sometimes present digital accessibility to leaders as a moral issue – improving it will help make a positive contribution to a more inclusive world. In an ideal world, leaders would regard a lack of digital accessibility as an ethical issue and would immediately order corrective action. 

Unfortunately, in my view this rarely happens. All too often there is a clear disconnect between genuine good intentions and actually making tangible advances. For example, an analysis (editor's note: by the author's company) shows even the Valuable 500 collective – a great initiative consisting of 500 large brands publicly committed to disability inclusion – have very few brands who actually have fully accessible websites.

Five Steps to Better Accessibility

Accessibility Risk vs. Traditional Technical Framing

How presenting accessibility differently changes outcomes.

ApproachTypical OutcomeBest Practice
Technical report with WCAG checkpointsIgnored by executives; little progress madeSummarize in dashboards or risk-impact language
Presented as a moral obligationGoodwill but no investment or actionBack ethical case with compliance risk and brand impact
Framed as a risk management issueExecutive attention, funding, and actionCompare to cybersecurity or data privacy risk

So how can brands treat accessibility as a risk issue and have a better chance of making tangible progress? Most approaches to risk management first attempt to understand the actual level of risk and then address the root causes that are driving the risk. Taking this approach to digital accessibility, suggests a five-step methodology for brands to follow.

1. Use Independent Data to Understand Your Risk Exposure

It is critical to get an independent, data-driven view of your risk exposure across your digital footprint. This has gotten both easier and cheaper through a range of digital accessibility tools and solutions that increasingly use intelligent automation and AI to identify the issues across the pages that need to be dealt with. Some solutions are even free to use. You can get an independent, unbiased snapshot of where you are and get a sense of the priority areas to address to where you need to be. This is essential to help get a handle on the extent of the problem and the related risk.

2. Present the Risk to the Right CXO in the Right Way

It is very important to present the right data to the right leaders in the right format, in a simple way that will resonate and is not difficult to understand. Avoid the detail that is of little interest to your CIO, CFO or your head of risk and go with more of a scorecard approach. 

You want risk-focused messaging that drives action. Getting your CFO to appreciate that the current risk is moderate to high because 90% of your website pages are not accessible and break the law, leaving the business exposed to financial penalties of between $10k and $50K, is more of the message you want to be conveying.

3. Leverage AI to Support Staff With Tools and Training

Addressing the root causes around digital accessibility usually requires a multi-pronged effort, starting with supporting your staff with the tools and training to understand and fix accessibility issues. 

Here AI and intelligent automation again makes a vast difference. The significant majority of accessibility issues are content-related; for example leading to problems with color contrast. The truth is that AI will not only be able to spot a large proportion of these, it can also automatically fix them, too, and you can make tangible, real-world progress at speed and at scale in a way that is simply not possible just relying on human effort.

4. Establish Vendor Accountability and Set Procurement Standards

For most brands, managing a site means working with both an agency and a CMS vendor. There may also be brand agencies producing assets and other third parties. You want to make sure these suppliers are on the same accessibility journey as you and are accountable for the accessibility of what they are responsible for. That might result in a change in operations, minor product tweaks and establishing some ongoing KPIs, as well as a change in the terms of a contract, if possible. Evolving legislation in the US is also tending to put more emphasis on vendor accountability.

You should also change your procurement processes around new contracts to establish better support for accessibility going forward:

  • Define the accessibility standards you expect to a project to be delivered against and stipulate that payments will not be made until these are met.

  • Add a contract clause to cover costs relating to the eventuality of litigation. Here, asking for "costs contribution" in the event of claim is usually more practical than asking for indemnity.

5. Establish Clarity Over Accountability and Reporting

If you have addressed the root cause, you want to ensure that it does not reoccur. This requires having clear accountability for digital accessibility – ideally at the C-suite level – and ensuring there is ongoing reporting that focuses on risk, while also equipping the team fixing any issues to keep momentum. 

Learning Opportunities

Focusing on Risk Leads to Real-World Outcomes

Let’s not lose sight of the fact that the most important thing is to make tangible progress on making websites more accessible. The world of risk can sometimes feel like one step removed from the real world – dominated by discussions about points that only really matter to lawyers and risk professionals.

But actually viewing digital accessibility through a risk and compliance lens tends to drive the action which actually makes a difference and leads to more inclusive websites. We need to get the attention of the C-suite, and taking a risk management perspective is the most pragmatic way to achieve that.

Core Questions About Digital Accessibility and Risk

Editor's note: Why hasn’t digital accessibility improved across most websites? What stops leadership from acting? These core questions uncover where the real roadblocks are—and how to fix them.

Why do most websites still fail digital accessibility tests?

Despite increased awareness and regulation, lack of leadership engagement and overly technical reporting have limited progress.

How can accessibility become a business priority?

Framing accessibility as a risk issue—akin to cybersecurity—grabs executive attention and enables better investment decisions.

Why isn’t the ethical case alone working?

Even well-intentioned leaders often fail to act unless there’s a clear, risk-based business justification behind accessibility efforts.

What are practical ways to present accessibility risk?

Use scorecards and dashboards rather than dense technical reports. Keep it simple, visual, and targeted to specific CXO roles.

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About the Author
Lawrence Shaw

Lawrence Shaw is the founder of AAAnow. He has managed the Boeing/RR 777 EMCS, launched an ISP in 1999 and an early e-commerce platform in 2002. Connect with Lawrence Shaw:

Main image: Phimwilai | Adobe Stock
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