1. Establish an accessibility policy
and standards. This is a good initial
step as it provides a framework for staff
handling web access problems. Adopting a policy and standard also communicates your bank’s commitment to
providing an accessible website. Policy
statements may include the accessibility standard used, the level of conformance, and the scope of the policy (e.g.,
the electronic information technology
2. Develop an accessibility webpage.
With the increasing risk of litigation,
it is imperative that banks consider including information on accessibility on
the webpage and having a process for
customers to report web access problems and receive help.
3. Appoint personnel to oversee accessibility issues. This requires staff to
identify electronic information technology in use by the bank and assess the
accessibility of the technology.
4. Direct departments to create an
implementation plan. After appointed
personnel have conducted an initial as-
sessment, departments should develop
a clearly outlined plan for providing
access to the inaccessible electronic in-
5. Ensure vendor contracts require
compliance with the standard adopted
in the accessibility policy. Contract
provisions can be extremely important
for banks that use a third-party vendor
to develop and manage their website.
Some businesses have made the mistake
of thinking vendors will always comply
with the accessibility standard adopted
in the company’s policy. However, the
reality is, sometimes they do not.
WCAG 2.0 AA
If your bank has not already adopted
a compliance standard, ABA suggests
WCAG 2.0 AA. WCAG 2.0 is a set of voluntary guidelines published by a private
standards-setting organization known
as the World Wide Web Consortium.
Furthermore, it addresses accessibility
barriers for a wide range of disabilities,
including individuals with vision, hearing, cognitive, and motor disabilities.
The standard has three levels of
conformance, A, AA, and AAA. The
intermediate conformance level, AA, has
been adopted for Section 508 and is typi-
cally used by private sector experts. More
importantly, this is the standard that DOJ
has required companies to comply with in
its settlement agreements and consent de-
crees. Some examples of the guidelines the
AA standard includes are: screen reader
compatibility; captions for audio content;
text resizing; and keyboard only access.
Because WCAG 2.0 is a technical stan-
dard, compliance typically requires the ex-
pertise of web content developers. If your
bank needs assistance in trying to comply
with this standard, consider consulting
ABA’s endorsed solutions provider, Level
Access at www.levelaccess.com.
Website accessibility should be a priority
for banks and other covered entities. In
the absence of regulations, there is a lot
of risk and uncertainty about legal and
technical requirements. However, the
risk can be managed with appropriate
policies and adoption of recognized accessibility standards. ■
ABOUT THE AUTHOR
TONI CANNADY is the Senior
Research Assistant at
Association, where she works
on ADA Title III issues and
ABA’s Enforcement Action Database. Toni
can be reached at firstname.lastname@example.org.
DOJ’s failure to
coupled with the
hundreds of lawsuits filed
each year, has led to a
patchwork of inconsistent
opinions by state and