Exceptions to the Minimum Digital Accessibility Technical Standard for Web Apps and Mobile Apps


1. Purpose

Ensure a clear process for web application and mobile app owners to request exceptions to the UW Minimum Digital Accessibility Technical Standard, that:

2. Scope

This procedure applies to applications acquired, developed, distributed, used, purchased, or implemented by or for the University and used to provide University services, programs, or activities regardless of the source of funding.

3. References

4. Definitions

Mobile applications (“apps”)

Mobile applications mean software application developed for a mobile device platform (e.g., iOS, Android) that is public-facing and distributed via an app store or similar channel, and affiliated with a UW unit.

Provisional Approval

Provisional Approval means a product which does not fully meet the Minimum Digital Accessibility Technical Standards is approved for use within defined requirements. Provisional approval must include an expiration date, by which time the product must either be submitted for a new scope and risk review or stop being used.

Temporary Alternative Access Plan (TAAP)

Temporary Alternative Access Plan outlines known accessibility barriers in a product and provides alternative means of access that the university will implement while the Supplier works toward compliance. This ensures we do not shift the burden of workarounds to users with disabilities.

5. Roles and Responsibilities

List all relevant roles and their responsibilities in executing or overseeing the procedure:

Role Responsibility
Product Owner / Purchaser
  • Submits exception request that includes all the required information using the digital accessibility exception request form.
  • Manages relationships with product content creators, designers, developers, and/or suppliers.
  • Works collaboratively with Civil Rights Compliance Office, Review Panel, CIO, and other exception process partners to ensure a smooth and effective process. E.g., provide timely feedback on questions.
  • Ensures that products meet provisional requirements.
Civil Rights Compliance Office (CRC)
  • Provides scope and risk assessment findings.
  • Determines if low-risk products qualify to be used with provisional approval.
  • Determines provisional requirements and expiration dates for low-risk products with provisional approval.
Information Technology, Accessible Technology Services (UWIT ATS)
  • Provides findings from a review of the supplier’s Accessibility Conformance Report (ACR).
  • Provides findings from a Manual Accessibility Test.
Supplier
  • Works collaboratively with Product Owner / Purchaser to ensure a smooth and effective process. E.g., provide timely feedback on questions.
Digital Accessibility Exception Review Panel (Review Panel)
  • Determines if medium- or high-risk products qualify to be used with provisional approval.
  • Determines provisional requirements and expiration dates for medium- or high-risk products with provisional approval.
  • Elevates products that do not qualify for provisional approval to the CIO.
CIO
  • Decides level of acceptable risk for products elevated from the Review Panel.
  • Approves or rejects exception requests.
  • Determines provisional requirements and expiration dates for products with approved exceptions.

6. Procedure Steps

A. Scope and Risk Assessment

  1. Before a Product Owner / Purchaser requests an exception, the product must be evaluated for scope and risk. See the Procedure for Digital Product Acessibility Reviews.

B. Initiation

  1. Product Owner / Purchaser submits a digital accessibility exception request, which includes a Temporary Alternative Access Plan (TAAP).
  2. CRC provides scope and risk review findings to the Review Panel.
  3. UWIT ATS provides applicable findings from an ACR Review and Manual Accessibility Test to the Review Panel.

C. Provisional Approval

  1. The Review Panel evaluates the exception request and findings.
  2. Review Panel determines if a product qualifies to be used with provisional approval.
    • If a product qualifies for provisional approval, the Review Panel determines provisional requirements such as specific blocking issues that need to be remediated, provision of a roadmap by the Supplier, implementation of workarounds identified in the TAAP, and reassessment dates by which provisional requirements are expected to be met. The Product Owner / Purchaser may continue to procure and use the product if provisional requirements are met.
    • If a product does not qualify for provisional approval, the Review Panel elevates the product to the CIO.

D. Exceptions

  1. CIO determines level of acceptable risk for a product elevated from the Review Panel.
  2. CIO approves or rejects exception requests.
    • If an exception is approved, the Product Owner / Purchaser may continue to procure and use the product if provisional requirements are met.
    • If an exception is not approved, the product may not be used.

E. Implement Provisional Requirements

  1. After provisional approval is granted or an exception is approved, Content / Product Owner must work with CRC, UWIT ATS, product content creators, designers, developers, and/or suppliers to ensure that provisional requirements are completed.

F. Validation

  1. UWIT ATS reviews and validates that provisional requirements are met either prior to launch or on a timeline specified by the provisional requirements.
    • If the product meets provisional requirements, the Product Owner / Purchaser may continue to use the product.
    • If the product does not meet provisional requirements, the product may not be used.

G. Documentation

  1. CRC confirms documentation of decisions, provisional requirements, outcomes, and expiration dates.

7. Compliance and Enforcement

8. Revision History

Version Date Author Description
1.0 01/14/2026 Beth Somerfield Initial release
1.1 07/16/2026

Beth Somerfield

Erik Steen

Terrill Thompson

 Added supplier roadmap to possible provisional requirements

Related Policies

Related Standard

Related Procedures