Accessibility Risk Reduction Playbook: Closing the Gap in Your Accessibility Program
Playbook
Many teams think they’re making accessibility progress—until a sudden demand letter or lawsuit exposes issues that they weren’t aware of. And the problems don’t stop there. Audits that should bring clarity only lead to more confusion. Developers slog through backlogs of fixes, unsure whether their work is actually making an impact.
If this story feels familiar, your accessibility program likely has a risk gap. But what exactly is this gap? Why does it occur? And how can you close it to protect your organization?
We’ll answer these and more questions in this practical playbook. And if you’re ready to get insight on your current risk status, start with a free risk assessment from our team.
What is the risk gap?
Accessibility teams often struggle to understand their real accessibility risk and prioritize the issues that matter most. This lack of clarity and prioritization is known as the “risk gap.” And if you’re involved in managing accessibility work, chances are that you’ve experienced this to some degree.
Even if you’re dedicating time and resources to compliance, you may not have reliable insight into your organization’s true risk status, or a clear sense of which issues to focus on first to reduce exposure.
As a result, you may think your accessibility program is working well—but still be vulnerable to legal, regulatory, and business risks.
Does your accessibility program have a risk gap?
How do you know if the risk gap is limiting your accessibility program’s impact? Warning signs that you may be struggling with this challenge include:
- You feel like you’re making meaningful progress on digital accessibility, but still face demand letters, lawsuits, regulatory action, or user complaints.
- You’ve run automated scans or obtained manual audits to reveal accessibility issues, but you’re not sure how to make sense of the findings or where to start.
- Your development teams are fixing issues, but the same problems keep resurfacing across releases.
If your risk exposure feels uncertain, you’re hardly alone. According to our Seventh Annual State of Digital Accessibility Report, 92% of professionals say they’re at least “somewhat confident” in the accessibility of their digital experiences—but nearly six in ten still feel exposed to legal or regulatory action.
What’s causing the risk gap?
Why do so many well-intentioned teams struggle to understand and prioritize accessibility risk? There are three parts to the problem.
All three of these problems are common culprits for escalating risk—but they don’t all need to be present at the same time for this gap to occur. Any one of them, on its own, can make it virtually impossible for teams to understand and reduce their exposure.
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Automation only shows part of the picture:
Automated testing finds issues fast but rarely explains root causes—allowing the same problems to reappear in new content and features. -
Manual audits don’t scale on their own:
Manual audits deliver critical context on root causes, but they’re time-intensive—making them hard to scale across large, dynamic digital portfolios. -
Teams end up fixing symptoms, not systems:
Developers are stuck reactively remediating individual issues, instead of stopping problems at the source. This creates rework, inflates costs, and limits accessibility programs’ long-term impact.
What are the consequences of the risk gap?
Left unaddressed, the risk gap has serious consequences. At best, it can leave organizations confused and unsure how to progress. At worst, it can jeopardize organizations’ reputations and bottom-line revenue by leading to lawsuits, lost business, and stalled innovation.
Most importantly, unaddressed accessibility issues block people with disabilities from equitably engaging with your digital experiences.
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Lawsuits and regulatory penalties:
Digital accessibility lawsuits remain widespread under the Americans with Disabilities Act (ADA) and related laws, and settlements can be costly—not to mention damage public image. Meanwhile, violating global regulations like the European Accessibility Act (EAA) can result in steep penalties. -
Lost business:
Digital product buyers increasingly require documented proof of accessibility as part of the procurement process. If you’re a vendor and you can’t provide that proof, typically in the form of a completed Voluntary Product Accessibility Template (VPAT®), you’re putting both new deals and existing contracts on the line. And if you work for a consumer brand, customers with disabilities who are unable to access your products or services won't hesitate to take their business elsewhere. -
Stalled innovation:
If you receive a lawsuit, you’ll probably need to address issues in a tight time frame as part of your settlement terms. The same thing happens if you’re a vendor, and your buyers request a VPAT you’re not prepared to deliver. Rushed fixes drain development resources, delaying new product launches and feature releases.
How to close the risk gap:
A step-by-step roadmap
Grappling with risk exposure can be frustrating when you’re pouring time, energy, and resources into your accessibility program. Thankfully, there’s a proven path forward. With the right tools and support in place, you can take the following steps to gain clarity on your current risk status, prioritize what matters, and provide an experience that is available to everyone.
1. Combine automated monitoring with expert-led audits.
Strategic organizations use two approaches to get comprehensive insight on accessibility risk:
- Automated scanning, which rapidly detects many common issues
- Manual evaluations performed by experts, including people with disabilities
Combining both is critical because automation provides scale and efficiency, particularly within content, while human judgment adds the context and validation to uncover issues affecting real users with disabilities that automation alone can’t.
2. Unify testing data with an accessibility platform.
To get a complete picture of accessibility risk, it’s helpful to consolidate findings from audits and scans across all of your organization’s websites, apps, and other assets in a single platform. This allows your team to understand risk across your organization, without wrangling spreadsheets.
Additionally, with all your data in one place, automation and human expertise can be applied to surface patterns, root causes, and systemic issues you can address to improve accessibility at scale.
Make sure to document all your progress with testing and your plans for remediation. If you’re facing legal action, being able to quickly prove your efforts to advance accessibility, and point to a clear roadmap for fixing issues, is a critical piece of a strong defense.
3. Prioritize fixes based on impact.
Teams can prioritize issues in one of two ways:
- Sort findings manually by severity and complexity, then tackle critical, low-complexity items first.
- Use an accessibility platform that automatically groups recurring findings, surfaces role-relevant issues, and highlights the highest-impact fixes. A platform is especially valuable for identifying similar issues that repeat across pages, components, and templates.
To inform prioritization, make sure you have a sound process in place for collecting—and responding to—feedback from users with disabilities. Any issues reported by your users should be considered high-priority and addressed swiftly.
4. Get proactive by surfacing risk before production.
It’s much faster, and more cost-effective, to fix accessibility issues during the build process than in live experiences. One way to accomplish this is by embedding automated accessibility testing into your CI/CD pipeline.
For example, with tools like Level CI, developers can catch issues early, so quality stays high and bugs are less likely to resurface in new releases. Some tools even enable developers to fix problems programmatically in their integrated development environment (IDE) with AI support, eliminating context-switching. Think about it this way: You wouldn’t write a report, print it, then run the spellchecker. Integrated tools serve as a spellchecker on steroids in your development environment.
Risk reduction in practice:
How a leading retail brand closed the gap for good
When a cult-favorite retail brand received a legal complaint alleging its website was inaccessible to people with disabilities, they swiftly obtained an audit. However, the team struggled to prioritize the backlog of issues identified in this evaluation—and as progress stalled, the brand remained a target for lawsuits.
The solution? The Level Access Platform gave the team a unified system for understanding and addressing risk, so they could isolate high-impact issues and swiftly fix them. As a result, the brand:
- Cleared its accessibility backlog, resolving 99% of identified issues.
- Improved customer experience.
- Shifted focus from reactive remediation to proactive prevention.
- Reduced legal risk.
Turn uncertainty into control
When accessibility risk is unclear, progress stalls. But with the right solution, you can replace guesswork with actionable insight—closing the risk gap for long-term confidence. Our free risk assessment can help you start gaining clarity on your accessibility risk.
Additional resources to help you close the risk gap:
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