How to Build a Website Accessibility Program and Governance Model

Too often, organizations approach accessibility reactively, fixing issues only when lawsuits threaten or audits reveal problems, a costly, risky, and unsustainable approach. 

A strong accessibility program changes that.

Organizations with mature programs establish clear policies, implement consistent testing processes, assign accountability at every level, and continuously improve over time. More simply, they shift from reactive fixes to proactive design. 

The result? Fewer defects, broader market reach, and reduced legal exposure.

Below, we’ll discuss the steps to build a program that works. You’ll learn how to assess your current maturity level, establish governance frameworks, structure your accessibility team, implement a phased rollout plan, and scale to enterprise-level capability.

Most organizations take 18 to 36 months to progress from Level 1 to Level 3. The Americans with Disabilities Act(opens in a new tab) (ADA)’s updated web accessibility rules(opens in a new tab) can guide compliance expectations and help inform program policies. Additionally, the W3C Accessibility Maturity Model can help structure that journey. Start with a baseline assessment to identify gaps, inform investment decisions, and give stakeholders a shared starting point.

From there, you can build a program with clear governance, defined roles, and a scaling strategy designed for enterprise adoption. 

Building Your Governance Framework

Strong accessibility governance rests on three pillars: policy, standards, and accountability.

Each pillar ensures that accessibility is not treated as an afterthought but embedded into your processes, decision-making, and culture. These pillars work together; weaken on and you weaken all of them.

Policy Development

Accessibility policies define your organization’s commitment to accessibility and ensure consistent decision-making across teams. A strong policy typically covers:

• A formal accessibility statement with executive sponsorship

• Vendor and third-party procurement requirements

• Integration into your development lifecycle processes

• Regular reviews to keep pace with evolving standards

A baseline assessment is a good starting point for shaping these policies. If you’re looking for practical guidance, an ADA compliance checklist can help without prescribing your entire program.

Standards Selection

Standards set the technical and functional expectations for accessible digital experiences. Most organizations adopt the Web Content Accessibility Guidelines(opens in a new tab) (WCAG) version 2.1 Level AA, which the ADA and Accessibility for Ontarians with Disabilities Act(opens in a new tab) (AODA) reference.

Key resources to guide your standards include: 

• WCAG 2.1 requirements overview

• Section 508 compliance for U.S. government-facing content

Clear standards give teams a shared language for accessibility. And a consistent bar to build against.

Accountability Structures

Even strong policies and standards can fail without accountability. Clear structures ensure decisions are made, exceptions are managed, and progress is monitored:

• Decision-making authority for accessibility investments and approvals

• Escalation paths for issues that require leadership intervention

• Feedback mechanisms to capture input from users with disabilities

Accountability is what turns aspirational goals into measurable outcomes and keeps accessibility from slipping down the priority list.

Organizational Structure and Roles

So how do you actually build one? A few approaches work consistently across organizations of different sizes and stages.

Building Your Accessibility Center of Excellence

As you mature your accessibility efforts, you may want to consider establishing a formal structure to coordinate strategy, standards, and execution. 

One of the most common approaches is creating an Accessibility Center of Excellence (CoE), a centralized group responsible for guiding and scaling accessibility practices across your organization. The CoE defines accessibility standards, provides guidance and resources, and helps product teams implement accessible digital experiences. 

Rather than performing all accessibility work directly, the CoE enables consistency and accountability by combining centralized leadership with distributed implementation across design, engineering, and product teams. This structure allows you to build internal expertise while ensuring accessibility is integrated into everyday workflows.

There are a few ways to structure a CoE, depending on how your organization operates:

• Centralized Model: The accessibility team reviews and fixes all issues. High quality, but hard to scale.

• Federated Model: The CoE sets standards and provides tools; product teams own implementation. Scales better, but requires strong capability building.

Most organizations ultimately adopt a hybrid model: a small central team that handles governance and expertise, with distributed teams responsible for implementing accessibility in their own products and workflows.

Organizations can also leverage consulting support for scaling programs to accelerate implementation and strengthen governance

Core Accessibility Roles

​​Clear roles are key to scaling your accessibility program. While the CoE provides guidance, these roles ensure strategy, standards, and implementation are embedded across teams:

Person walking on a smartphone map with a location pin, next to an accessibility icon on a green background.

Implementation Roadmap for a Digital Accessibility Maturity Model and Program

Building a sustainable accessibility program takes more than fixing issues as they come up. You need a structured roadmap,  one that introduces accessibility governance, builds internal expertise, and integrates accessibility practices into everyday digital workflows.

The four phases below outline a practical roadmap for building a scalable web accessibility maturity model and establishing an effective digital inclusion program.

Phase 1: Assessment (Months 1 to 2)

The assessment phase establishes your current accessibility baseline. During this first phase, teams must conduct an accessibility audit to evaluate current processes, identify gaps, and determine how existing practices align with an accessibility maturity model. It’s also a chance to get the right stakeholders on board early.

Primary tasks for Phase 1:

• Conduct a maturity assessment

• Inventory existing accessibility issues

• Assess team skill gaps

• Document current processes

• Align stakeholders

Additionally, an expert audit can also help, giving teams a detailed picture of where they stand and clear fix priorities to inform planning.

Phase 2: Planning (Months 2 to 3)

Once the current state is understood, you can define your target maturity level and establish a formal accessibility governance model. 

During this phase, leaders develop the program strategy, identify responsible roles such as the accessibility program manager, and build executive alignment to support long-term investment.

Primary tasks for Phase 2:

• Define target accessibility maturity level

• Build an ROI-driven business case

• Secure executive sponsorship

• Prioritize fix initiatives based on impact and risk

• Create governance documentation and program guidelines

Phase 3: Foundation (Months 3 to 6)

With strategy and governance defined, you can now begin operationalizing accessibility practices. Many companies establish a centralized accessibility center of excellence or core accessibility team during this phase to guide implementation and provide expertise across product teams.

Primary tasks for Phase 3:

• Hire or designate core team members

• Implement testing tools

• Launch role-specific training

• Remediate high-priority issues

• Establish reporting dashboards

Phase 4: Scaling (Months 6 to 12)

After the foundational program is in place, you can now expand accessibility practices across your teams and products. The focus shifts toward automation, broader adoption, and continuous improvement, allowing accessibility to become a consistent part of the organization’s broader digital inclusion program.

Primary tasks for Phase 4:

• Expand the accessibility champions network across teams

• Integrate accessibility into design systems and reusable components

• Automate accessibility checks with CI/CD testing

• Conduct quarterly maturity reassessments

• Refine processes based on program metrics and feedback

Key Success Metrics

Tracking program performance is critical for demonstrating progress within the accessibility maturity model and maintaining executive support. You can typically monitor a mix of operational, quality, and risk-related indicators, such as:

• Accessibility defects per release

• Conformance rates across digital properties

• Average fix time for identified issues

• User satisfaction and feedback trends

• Legal and compliance risk exposure trends

Now, let’s look at strategies and metrics you can implement to best manage your program.

Program Management Essentials

Stakeholder Engagement

Engaging the right stakeholders early is critical for securing executive buy-in and ensuring the program’s long-term success. Here’s what that looks like:

• Executives care about legal risk, market expansion, operational efficiency, and brand reputation.

• Product teams respond to quality improvements and reduced technical debt.

• Legal teams provide regulatory guidance.

• Marketing positions accessibility as a differentiator.

The bottom line: Effective engagement is continuous.

Stakeholders should be informed of progress, involved in key decisions, and empowered to support accessibility goals within their teams. Regular updates, dashboards, and clear governance structures help maintain alignment across functions.

Champions Program

A strong champions program is essential for scaling accessibility practices across distributed teams. Champions are volunteers embedded in product, design, and engineering teams who advocate for accessibility, share knowledge, and help teams adopt best practices.

A successful program typically includes:

• Gathering volunteers from across product teams, ensuring representation in design, development, and content functions.

• Providing structured training and skill-building certification opportunities to develop expertise and confidence.

• Creating a community of practice to encourage collaboration, peer learning, and sharing of lessons learned

• Recognizing contributions through visibility in internal communications or other acknowledgment methods, reinforcing engagement and commitment

Metrics and Continuous Improvement

Measuring progress is crucial for demonstrating program value and driving ongoing improvement. Some ot the top metrics to watch include:

• Leading indicators, such as accessibility test coverage, training completion, and champion participation, provide insight into how well processes are being adopted. 

• Lagging indicators, such as defect rates, conformance rates, and remediation timelines, reveal the program's real-world impact on products and users.

Continuous improvement is supported through regular assessments. Conduct quarterly maturity reassessments, refine processes, and adjust priorities based on metrics and feedback. 

By linking measurement to program goals, you can advance accessibility maturity, strengthen governance, and ensure accessibility becomes a core, sustainable part of digital operations.

A bar chart going up next to an accessibility symbol, laid on top of a faint background of skyscrapers

Scaling to Enterprise Maturity

As you advance along the accessibility maturity model, you move from foundational practices toward proactive, enterprise-wide integration. At this stage, accessibility is embedded in design, development, and governance processes, enabling consistent, scalable results.

Proactive Integration

Optimized programs integrate accessibility early, ensuring issues are identified and resolved before release:

• Shift-left testing in design and development

• Accessible-by-default component libraries for consistent design

• Predictive risk identification to anticipate potential accessibility challenges

These practices indicate your organization is operating at an optimized maturity level, where accessibility is part of every stage of the development lifecycle.

Enterprise Scaling

Scaling accessibility across multiple business units requires structure, collaboration, and clear governance:

• Federated CoE across business units

• Shared services and centralized infrastructure for consistency and efficiency

• Leverage enterprise consulting support to accelerate scaling and refine governance

• Cross-functional guilds to promote knowledge and sharing

Technology Enablement

Technology enhances efficiency and helps maintain consistent accessibility practices:

• API-driven testing integration

• Automated remediation where possible

• AI-assisted compliance monitoring

These approaches reduce manual effort, improve coverage, and support continuous improvement.

Vendor Management

Enterprise accessibility programs extend governance to external partners:

• Accessibility in RFP requirements

• Third-party audits

• Contractual conformance obligations

5 Signs of Optimization Maturity

Overall, organizations at this stage typically demonstrate five signs of maturity:

1. Accessibility is integrated early in design and development

2. Accessible-by-default component libraries and design systems

3. Cross-functional collaboration through a federated CoE

4. Technology-enabled automation for testing and remediation

5. Vendor compliance and risk management

When governance, technology, and organizational alignment work together, accessibility stops being a checklist and becomes a key part of how you build.

Assess Your Accessibility Program Today

Building an accessibility program helps you move from reactive compliance to proactive design. Mature programs expand market reach, reduce technical debt, improve product quality, and strengthen brand reputation.

Ready to achieve the latter? Start with a maturity assessment. From there, you can understand your starting point, define program goals, and plan governance and capability development to advance systematically.

At AudioEye, we support organizations at every stage, from initial assessment to enterprise-level scaling. 

Assess your site against key accessibility standards with AudioEye’s free accessibility scan.