Digital Accessibility as a Reasonable Accommodation: What Employers Need to Know

When most people think about reasonable accommodations under the Americans with Disabilities Act (ADA), things like modified desks, accessible entrances, or flexible work schedules are usually the first things that come to mind. But in a world where nearly everything happens online, one area is often overlooked: digital accessibility.

Onboarding portals, collaboration tools, CMS platforms, internal tools — the modern workplace runs on technology. If that tech isn’t accessible, it can shut employees, particularly those with disabilities, out of the very resources they need to succeed. It’s also key to ensuring your business complies with accessibility laws, including the ADA. 

Even as more organizations move to remote work, adopt cloud-based systems, and increase digital collaboration, online accessibility has never been more important. And yet, it’s still missing from many conversations around workplace inclusion. 

Below, you’ll learn how to ensure employees have the accessible tools and solutions needed to succeed in their roles, as well as what your responsibilities are as an employer to provide them. But first, a quick refresher on the ADA and reasonable accommodations.

What is Considered a Reasonable Accommodation Under the ADA?

Under the ADA, employers are required to provide reasonable accommodations to qualified individuals with disabilities. These adjustments or modifications allow a person with a disability to participate in the hiring process, perform essential job functions, or access the same tools or solutions as their peers. 

Traditionally, these accommodations have focused on physical accessibility and are approved on a case-by-case basis. Common types of accommodations include:

• Installing ramps or automatic doors

• Providing ergonomic workstations

• Offering sign language interpreters for meetings 

• Adjusting work schedules or allowing remote work

• Reassigning non-essential job duties

But as the workplace has become more digital, accommodation requests have also shifted to online settings. That brings us to the often overlooked piece of the puzzle: digital accessibility.

The Case for Digital Accessibility as a Reasonable Accommodation

What do we mean when we say digital accessibility? The concept is about designing websites, software, online documents, and other digital tools so that people with disabilities can use them, regardless of how they can navigate or interact with technology.

Digital accessibility ensures that key accessibility features are added to online content or platforms, including:

• Screen reader compatibility for blind, low vision users, or those with other visual impairments.

• Keyboard-only navigation for users who don’t rely on a mouse.

• Captions or transcripts for video or non-text content.

• Accessible online documents and forms that can be read and completed using assistive technology

Digital tools are essential to nearly every job function — from onboarding and benefits enrollment to team communication and performance reviews. If those tools aren’t accessible, disabled employees may be left without the ability to do their jobs successfully, or even access critical information at all. 

This creates much more than a barrier — it’s an equity breakdown. And under the ADA, failing to make digital tools accessible could mean failing to provide a reasonable accommodation. 

How Digital Accessibility Shows up in Accommodation Requests

So, how do these requests for accessible digital tools show up in reasonable accommodation requests? Requests might not always be framed in technical terms, but the need remains the same: employees need equal access to digital tools. 

Examples of digital accessibility-related accommodation requests include:

• A blind user requesting that internal software be compatible with screen readers like JAWS or NVDA.

• A Deaf employee asks for captions or transcripts on required training videos.

• A neurodivergent employee (or those with cognitive disabilities) requesting simplified layouts or the ability to turn off animations in a company portal. 

• A remote worker requests that the PDF forms used for HR processes be accessible and fillable. 

A stylized web page that shows a number of accessibility errors.

Common Gaps and Risks Employers Overlook

As an employer, you’re likely working hard to ensure your employees are comfortable and set up for success. However, even if you’re well-intentioned, you may be falling short when it comes to digital accessibility — not because of negligence, but because many tools that are part of the employee experience aren’t considered. 

Unfortunately, these oversights can lead to serious accessibility barriers — and potential legal risk. 

Here are some of the most commonly overlooked areas:

• Onboarding portals: New hires rely on online portals to complete paperwork, review and sign policies, and set up accounts. If these platforms aren’t compatible with assistive technology, some employees may be unable to complete onboarding independently.

• HRIS systems: Human Resources Information Systems (HRIS) house critical functions like time tracking, PTO requests, payroll, and performance management. Yet, many of these platforms are not fully accessible — especially for screen reader users or keyboard-only navigation.

• Benefits platforms: Employees must be able to explore, select, and manage their benefits independently. Inaccessible insurance portals, PDF forms, or benefits enrollment tools can leave employees without equal access to much-needed benefits information. 

• Collaboration tools: Chat apps, project management platforms, and virtual whiteboards can exclude some team members if they lack keyboard navigation, sufficient color contrast, or screen reader support. 

• Learning management systems (LMS): Training portals are a major part of employee development and compliance. But many LMS platforms include videos without captions, PDFs without proper tags or labels, or interactive elements that can only be navigated with a mouse — all of which can make the LMS out of reach for some employees. 

• Training materials: From mandatory compliance courses to professional development content, these materials can be completely inaccessible if they don’t include much-needed accessibility features. 

• Internal tools and custom software: In-house platforms often escape accessibility audits altogether, especially when they’re built quickly or rely on outdated code. But they’re subject to the same legal and ethical standards as public-facing software. 

What happens if these tools aren’t accessible? What’s the risk? Excluding employees from essential functions opens the door to ADA-related complaints or lawsuits. The opportunity: Treating accessibility as a proactive part of your workplace culture — not just a reactive fix.

What to Do If You Receive a Digital Accessibility Accommodation Request

The digital world isn’t going anywhere, which is why it’s critical for employers to be prepared to handle digital accommodation requests appropriately and in compliance with the law. Here’s how to respond if an employee raises a concern about inaccessible technology or requests support to access digital tools.

1. Understand Your Obligation

The first thing to understand about reasonable accommodation requests (whether physical or digital) is that you must respond. Under the ADA, employers are legally required to engage in an interactive process, which is a collaborative conversation aimed at identifying the barrier and exploring potential solutions.

Legally, you don’t have to provide the exact accommodation request; however, you do have to consider reasonable alternatives that effectively resolve the barrier. You must provide an accommodation unless doing so would cause undue hardship, such as significant difficulty or expense, based on the size and resources of your organization. 

2. Respond Effectively

Once you’ve evaluated the request and determined your next steps forward, it’s time to respond. Here’s how to do so in a way that shows you support the employee and are committed to meeting ADA compliance requirements:

• Respond quickly: Acknowledge the request and begin the interactive process as soon as possible, as delays can lead to frustration or exclusion. 

• Engage in the interactive process: Ask clarifying questions, explore potential solutions with the employee, and document the conversation. 

• Involve the right stakeholders: As needed, bring in IT, HR, legal, and accessibility experts to assess what changes are possible.

• Document the process: Keep a written record of communications happening around the request, including decisions and timelines. 

• Provide interim solutions: If a long-term fix will take time, offer short-term workarounds or assistance to ensure the employee has access. 

3. Don’t Wait for a Request

Rather than waiting for a request to come across your desk, build accessibility into your work environment from the start. Many accommodation requests can be avoided altogether if your digital tools, platforms, and content are designed with accessibility in mind.

Proactively choosing accessible technologies, following standards like the Web Content Accessibility Guidelines (WCAG), and auditing internal systems can present barriers before they arise — and significantly lower your legal risk. 

A laptop representing restaurants, ecommerce, and education websites.

How to Proactively Support Digital Accessibility in the Workplace

Rather than waiting until a barrier is reported to prioritize accessibility, start now. When a request comes in, someone has already been excluded — building accessibility into your workplace systems and processes helps you avoid that. Plus, it reduces legal risk, minimizes accommodation requests, and creates a more equitable employee experience.

Here are the key steps you can take to strengthen digital accessibility across your organization:

• Audit your digital content: Review your internal systems, tools, and documents for common accessibility issues. Pay close attention to platforms or tools used for hiring, onboarding, benefits, training, and day-to-day collaboration. Automated accessibility tools (like this one from AudioEye) can help you catch common issues, but it’s important to supplement that testing with expert audits to find more complex barriers.

• Vet tools for accessibility: When evaluating or purchasing new software, include accessibility in your procurement checklist. Ask vendors about conformance with WCAG guidelines and test products yourself or with assistive technology to ensure they’re accessible.

• Train teams on accessible design and procurement: Ensure your IT, HR, and content teams understand the basics of accessibility and accessible design. Accessibility training helps prevent future issues and empowers teams to spot and fix barriers early. 

• Set up a centralized accessibility policy and response process: Create clear procedures for handling requests and issues. This ensures consistency, accountability, and a better experience for your employees.

• Encourage employees to speak up: Create a culture where employees feel comfortable and secure reporting accessibility barriers. Encourage them to do so promptly and reassure them that their request will be taken seriously.

• Include accessibility in your internal strategies: Accessibility is part of building a truly inclusive and accessible workplace. Ensure it’s aligned with your broader HR, IT, design, development, and other key processes. 

By making accessibility a shared responsibility across departments, you’re not just checking a compliance box — you’re creating a workplace where everyone has the tools and support needed to succeed.

Build Accessibility In, Don’t Bolt It On

Reasonable accommodations are essential — but they’re just one part of building an accessible workplace. As digital tools become more embedded into the future of your tools, processes, and culture, accessibility must be a priority, not treated as an afterthought when someone encounters a barrier. 

By proactively addressing accessibility, you not only reduce legal costs and avoid costly rework but also create a more accessible, efficient, and future-ready organization. With AudioEye, embedding accessibility into every part of your organization is seamless. 

AudioEye’s three-pronged approach to accessibility takes out the guesswork, providing solutions that build accessibility into digital tools and content from the start. From our Web Accessibility Checker that identifies 30 WCAG violations (more than any other tool on the market) to our Expert Audits from accessibility experts and real users with disabilities, AudioEye helps you detect and fix accessibility issues at scale. Plus, with AudioEye Assurance, you’ll enjoy a level of protection that’s 400% better than consulting or automation-only approaches. 

Whether you’re just starting to evaluate accessibility or looking to scale your existing efforts, AudioEye helps you move beyond reactive fixes and build a digital workplace where access isn’t something people have to ask for.

Ready to get started? Use our free Web Accessibility Checker to see how accessible your existing content is.

Want to see AudioEye in action? Schedule a demo now.