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Pyramid with 5 levels of DAMM Maturity - Initial, Managed, Defined, Quantitatively Managed, Optimizing

In my last post in the Digital Accessibility Maturity Model (DAMM) Series I detailed the Communications Dimension of DAMM. In this post I’ll discuss the Policies and Standards Dimension, the associated aspects and artifacts, and what each of the five maturity levels looks like for this dimension. (DAMM Definitions and Acronyms)

The Policies and Standards Dimension measures the extent to which an organization has accessibility policies and technical standards. This dimension includes an overarching accessibility policy, specific policies in use throughout the development and support lifecycle, and detailed accessibility technical standards. The policy should include a determination of whether or not the organization will implement accessibility on a go-forward basis, or create remediation or obsolescence plans for inaccessible legacy systems.


  • Accessibility Policy – The maturity of the accessibility policy within the organization. This includes the creation of the policy, its deployment into the organization, operational conformance to the policy and maintenance of the policy on an ongoing basis.
  • Accessibility Standards – The maturity of the technical accessibility standards for the organization. The technical accessibility standards maturity includes the scope of the coverage of the standards both in terms of technology platforms and in terms of roles impacted.
  • Issue Resolution – The maturity of the organization with respect to resolving accessibility complaints from employees, customers, or members of the public.


  • Accessibility Policy – An accessibility policy covering the entire organization and addressing key policy areas.
  • Accessibility Technical Standards – A set of accessibility technical standards, such as those generally published in AMP using the testing control configuration and role specific configurations for the organization, or whatever technical standards apply to the organization.
  • Issue Resolution Policy – A fixed set of steps that will be followed for every formal accessibility complaint filed with the organization.

Maturity Levels

Level 1 – Initial

  • There are minimal or no accessibility policies or standards.
  • There is no specific defined scope for the accessibility policy, if one exists.
  • Accessibility standards, if they exist, may be implemented in specific products or projects on a reactive basis.

Level 2 – Managed

  • A basic accessibility policy defining the organization’s commitment to accessibility covering public facing communications, websites, customer-facing applications, sites and employee facing systems is in place.
    • Policy should account for public facing communications, websites (public and employee facing), customer facing applications, and employee facing systems.
    • Policy should include a strategy for remediating legacy systems and projects currently in place.
  • There is a basic Accessibility Issue Resolution Policy in place, defining how complaints will be handled from receipt to resolution.
  • Basic accessibility standards are in place, covering all core organization technology platforms.
  • Policy and standards are conformed to and used on an ad-hoc basis.
  • Technical standards may be developed on a reactive or project basis, but are not maintained by a central organization.
  • There is no established relationship between the organization’s general disability policy and the accessibility policy.
  • Key Stakeholders have been identified, and there is a clear role for them in specifying requirements.
  • There are plans for consulting persons with disabilities (staff and customers) to gather contributions to the strategy and policy, and report on-going progress.
  • ICT accessibility standards are documented and published for:
    • Customer-facing websites / web based services, and staff-facing websites / intranets / web based services / applications;
    • Content of any kind;
    • Non-web applications (such as accounting, payroll, and other back end systems, back end systems);
    • End user computing (such as Mail, Word processors and spreadsheets) including personalization; and
    • Telecoms and office equipment.

Level 3 – Defined

  • Accessibility standards and policies are:
    • Detailed and extensive;
    • Implemented for all types of product (systems, telecoms etc.);
    • Provide direct support for design, development and QA roles;
    • In regular use; and
    • Actively promoted and communicated to the organization.
  • The Accessibility policy or some other document defines the operational impact of the policy, including details on the following:
    • Scope – The set of systems, technologies, services, and content types that will be covered by the Policy.
    • Timeline – A definition of what types of covered items need to conform to what technical standards by what dates.
    • Exceptions – A definition of types of exceptions that can be provided, and when and how those exceptions apply. Generally, this includes both statutory exceptions, which find their genesis in applicable laws or regulations, and operational exceptions, which find their genesis in operational constraints applied to the organization.
    • Functional Support – A definition of the relevant level of equivalent access provided across specific disabilities types.
  • The Accessibility policy is harmonized with and reconciled against federal, state, and local legal requirements, as well as any other regulatory or accreditation specifications.
  • There is an Intranet site containing on-line documentation providing clear and updated accessibility information.
  • Accessibility policies and standards are treated as mandatory across the entire organization.
  • There are plans for consulting persons with disabilities (staff and customers) to assist the organization in setting / reviewing accessibility direction and priorities, contribute to system design and testing, etc.
  • Supporting documentation and training for accessibility policy and standards is provided to the organization.
  • The Accessibility Program Office actively supports implementation of and conformance to accessibility standards and policies.
  • ICT Accessibility standards teams have a good level of knowledge of the standards and their practical implementation.
  • General ICT teams are trained in standards and in general disability awareness e.g. disability triangle, types of disability, impact of poor design.

Level 4 – Quantitatively Managed

  • Accessibility policy and standards conformance is actively managed and measured across the organization.
  • Accessibility policy and standards are owned by the Accessibility Program Office and reviewed on a regular basis that keeps pace with technical or legal evolution, and updated / republished / re-communicated after updates are completed.
  • Metrics have been defined to measure accessibility implementation and are monitored.
  • There is a lessons learned / process improvement program in place.
  • Lessons learned are captured and provided to senior managers who then use them to update standards / best practices / architecture.
  • There are records / examples of standards, process changes resulting from lessons learned.
  • A feedback loop exists for the progress of implementing the accessibility strategy organization-wide.
  • Accessibility standards and policies are regularly reviewed and updated in accordance with feedback from projects, experience from users and industry best practice.
  • Updated accessibility policies and standards are published and communicated throughout the organization.
  • All staff accessibility training records are retained.
  • An accessibility ‘Center of Excellence’ is open to general staff — library of written material, examples, demonstrations etc.

Level 5 – Optimizing

  • The organization is an influencer / early adopter of new accessibility standards.
  • The organization co-operates with external bodies and contributes to regulations and accessibility standards, such as WCAG or The European Commission’s — Mandate 376
  • The organization’s accessibility standards reflect innovation and design excellence.
  • The organization liaises with accessibility experts in other organizations and attend conferences to ensure standards keep up-to-date with industry best practice.

Coming Up

In my next post I’ll discuss Dimension #4 of DAMM – the Regulatory Dimension – which encompasses all non-HR filings, remediation plans, or other documentation required by statute, regulation, or is part of a settlement agreement, consent decree, or other legal proceeding.