1. Purpose 

The purpose of this procedure is to ensure that all university-affiliated websites meet the UW Minimum Digital Accessibility Technical Standard. This procedure establishes a consistent process for accessibility review, remediation, and monitoring. It is designed to reduce institutional risk, provide equitable access to digital content for all users, and ensure accountability by requiring business units to address accessibility barriers.

2. Scope 

This procedure applies to:

• All Units launching, maintaining, or significantly updating university-affiliated websites.
• Websites hosted on university infrastructure or externally hosted on behalf of any University unit, regardless of funding source.
• Vendors or contractors developing websites on behalf of UW units.

3. References 

• APS 2.3 Information Technology, Telecommunications and Networking Projects, and Acquisitions
• APS 9.0 Digital Accessibility
• Minimum Digital Accessibility Standard (Interim)

• DOJ Final Rule on Web Accessibility under Title II (2024)

• WaTech USER-01 Digital Accessibility Policy
• Accessible Technology Tools

4. Definitions

Academic or Administrative Unit (Unit)   

Academic or Administrative Units are divisions, campuses, or colleges headed by an executive who reports directly to the President or the Provost.

Digital Accessibility

Digital accessibility means a person with a disability is afforded the opportunity to acquire the same information, engage in the same interactions, and enjoy the same services within the same time frame as a person without a disability in an equally effective and equally integrated manner, with substantially equivalent ease of use. A person with a disability must be able to obtain information as fully, equally, and independently as a person without a disability.

Digital Content

Digital content refers to all digital information and materials made available through University of Washington websites, web applications, or mobile applications. This includes, but is not limited to, webpages, documents (such as PDFs, Word, Excel, or PowerPoint files), multimedia (such as videos, audio recordings, and images), online course materials, electronic forms, mobile applications, and interactive tools or dashboards.

5. Roles and Responsibilities 

Role	Responsibility
Business Units (Schools, Colleges, Departments, and Administrative Units)	Initiate accessibility reviews prior to launching or relaunching university-affiliated websites. Conduct testing using DubBot or other automated accessibility checker tools. Conduct manual accessibility testing using methods available on the Accessible Technology website. Develop and implement remediation plans for identified accessibility issues. Monitor ongoing compliance through dashboards, scans, and periodic audits. Ensure website footer incorporates an accessibility link for reporting access barriers.
Compliance & Risk Services (CRS)	Maintain records of accessibility, compliance status and remediation plans. Escalate unresolved or high-priority accessibility issues to compliance or governance bodies when necessary.
UW Information Technology, Accessible Technology Services (UWIT ATS)	Provide consultation and technical support to business units in conducting reviews and developing remediation plans. Support units with guidance, training, and recommended tools for accessibility compliance.
University Marketing & Communications (UMAC)	Develop and maintain centrally supported website themes that comply with technical standards. Ensure themes align with the University’s brand guidelines (logos, colors, typography, and layouts) and ensure updates to brand guidelines comply with the technical standards. Ensure themes include a standard University of Washington footer, which includes an accessibility link for reporting access barriers. Provide an HTML option of the standard University of Washington footer to support consistent implementation across custom platforms and applications.
Vendors and Contractors	Resolve identified accessibility issues in accordance with contract terms and timelines. Cooperate with business units and UWIT ATS in remediation planning and testing.
Compliance and Governance Bodies (e.g., ADA Digital Accessibility Committee, ERM, or equivalent oversight authority)	Receive escalations from CRS when business units fail to comply with accessibility requirements. Impose enforcement measures, which may include restricting visibility or disabling non-compliant sites. Ensure institutional accountability and alignment with federal and state accessibility regulations.

6. Procedure Steps

1.       Pre-Launch Accessibility Review

Prior to launching or significantly updating a university-affiliated website, the business unit must conduct an accessibility review. The review must include:

• Automated testing with DubBot or other accessibility testing tools.
• Manual testing using methods available on the Accessible Technology website.
• Confirmation website footer includes accessibility link for reporting access barriers.
• Retain testing results for 1 year after date of activity in accordance with records retention policy Audit Trails and System Usage Monitoring.

2.       Existing Websites Accessibility Review

All existing websites must undergo an accessibility assessment within 6 months of this procedure’s effective date. The review must include:

• Automated testing with DubBot or other accessibility testing tools.
• Manual testing using methods available on the Accessible Technology website.
• Confirmation that website footer includes accessibility link for reporting access barriers.
• Retain testing results for 1 year after date of activity in accordance with records retention policy Audit Trails and System Usage Monitoring.

Sites identified as high-traffic, high-impact (student-facing, patient-facing, admissions, financial aid, registrar, etc.) must be prioritized for early review.

3.       Remediation of Accessibility Issues

If issues are identified, the business unit must develop a remediation plan that specifies:

• Priority of issues (high, medium, low).
• Responsible party (internal developer, vendor, etc.).
• Timeline for resolution.

All high-priority issues must be resolved prior to launch.

4.       Ongoing Monitoring

Following launch, the business unit must incorporate accessibility checking into their ongoing web development and content authoring workflows. All updates to the website, including changes to features and updates to content, must comply with the accessibility standard prior to publishing.

If significant accessibility regressions are found, the business unit must immediately initiate corrective action.

5.      Escalation and Enforcement

If a business unit fails to complete reviews, or resolve high-priority accessibility issues, CRS will escalate the issue to the appropriate compliance or governance body.

• Escalation may result in restrictions on the website’s visibility, removal of non-compliant content, or other enforcement measures outlined in Technical Standard.

7. Exceptions

Full conformance with the Minimum Digital Accessibility Technical Standard is expected.
Limited exceptions may apply when digital content is inherently visual, historical, or experimental (e.g., testing, prototype, or research phase), or when external factors restrict full accessibility.

8. Compliance and Enforcement

Monitoring and enforcement are designed to protect the university from legal, reputational, and equity risks while ensuring equitable access to digital content for all users. Units are accountable for compliance, but support and consultation will be provided through ATS. Methods for monitoring accessibility of websites include:

• Automated testing with DubBot or other accessibility testing tools.
• Manual testing using methods available on the Accessible Technology website.
• Digital Accessibility Dashboards developed by Information Technology, available to business unit leaders. 

9. Revision History

Version	Date	Author	Description
1.0	09/22/2025	Shoda	Initial draft
1.1	10/13/2025	Shoda	Governance feedback incorporated
1.2	10/29/2025	Shoda	SME feedback incorporated