Building your approach

1. Engaging with senior management

The first step of building your accessibility approach is to engage with your senior management. Make sure that this item is discussed at the highest level, explaining:

  • What digital accessibility is
  • The benefits to society and the organisation
  • The new legal requirement in the public sector and the consequences of non-compliance
  • Different approaches for managing the requirement and the resource/timescales around them

The outcome of this engagement should be an accountable individual appointed within the organisation at a senior level, as well as an appropriate approach and the relevant requirements laid out. 

2. Creating policy and governance

With senior management buy-in, an approach selected and resources confirmed for this work, the next step is to put accessibility requirements into policy to ensure that the necessary governance is in place for accountability purposes. You will need to determine: 

  • Who is accountable overall?
  • Who is responsible for reporting into the accountable person on progress and how is this done? How can issues be escalated?
  • Who is responsible for accessibility of websites?
  • Who is responsible for the accessibility of content on websites?

3. Building an accessibility roadmap 

Next, you need an accessibility roadmap to map your journey towards improving accessibility. You need to think about:

  • Accessibility maturity – where are you now and where do you want to be as an organisation? 
  • What are the overall objectives of this piece of work? Is it business as usual in future? 
  • What are the timescales and deliverables? 

4. Building an accessibility audit framework

Every organisation needs a plan for how they are going to meet the regulations in terms of testing and resolving issues, and we call this an audit framework. A framework builds upon and widens GDS’ recommendations for a website to create a comprehensive plan for a web estate.

To build a framework, ask yourself a number of questions which we’ve categorised into four sections:

  1. Resources
  2. Scope
  3. Process and governance
  4. Measuring success. 

Audit Framework – Resources

  • Who will be auditing?​
  • What testing equipment is available?​
  • Manual or automated testing?

Audit Framework – Scope

  • What needs to be audited?​
  • Full audits or dip-testing?​​
  • What systems should be prioritised?​

Audit Framework – Process and Governance


  • How is an audit initiated?​
  • How is an audit carried out? ​
  • What happens after an audit?​
  • How do you ensure quality control of audit results?​
  • How is this all tracked and managed? ​

Governance :

  • Who is responsible in your organisation for a system’s accessibility? ​
  • What happens if remedial actions cannot be made?​
  • How should remedial actions be prioritised?

Audit Framework – Measuring Success

  • How is an audit’s success measured?
  • How are audit results evidenced and reported?

5. Engaging with procurement

Once you’ve created a concrete plan for improving the accessibility of existing systems, you should look at how to ensure that the requirements are built into any new systems you procure. You should: 

  • Identify where web based systems are being purchased
  • Help commissioners understand the requirement
  • Work with procurement teams to build into all stages of process (e.g. ITTs, RFQs, T&Cs, standard contract wording)
  • Teach them how to respond to supplier responses.

6. Engaging with staff

Finally, with a comprehensive plan in place for managing accessibility, you should look to ensure that colleagues and staff within your organisation have the information and skills required to create accessible content. This can include:

  • Communications plans to raise awareness
  • Celebrating accessibility events (e.g. Global Accessibility Awareness Day in May) 
  • Training and e-learning programmes
  • External events and training.