EBSCOed Digital Accessibility Policy

Effective Date: January 2026

Policy Owner: VP Digital Experience

Applies To: All EBSCOed digital products and services

Review Cycle: Annual

Version: 1.1

1. Commitment Statement

EBSCOed is committed to ensuring digital accessibility for all users, including employees, customers, and members of the public with disabilities. We recognize that accessible technology is fundamental to providing equitable access to information and services in the education and workforce development sectors we serve.

Digital accessibility is not an optional feature but a core product requirement and organizational value. We are building the platform with accessibility as a foundational principle from day one, ensuring that accessibility is embedded in our development process rather than retrofitted after launch.

This policy reflects our commitment to:

• Meeting or exceeding applicable accessibility standards and legal requirements
• Providing equal access to digital content and functionality for all users
• Fostering a culture where accessibility is considered at every stage of design, development, and deployment
• Continuously improving our accessibility practices through testing, auditing, and user feedback

2. Scope

This policy applies to:

Digital Products and Services

• The platform (digital credentials, resume builder, career pathways)
• All customer-facing web applications and mobile applications
• Internal tools and systems used by EBSCOed employees
• Third-party integrations and embedded content when under EBSCOed control
• Marketing websites and public-facing content
• Documentation, help systems, and support resources

Content Types

• Web pages and web applications
• Mobile applications (native and web-based)
• Forms, surveys, and interactive tools
• Email communications and newsletters
• Social media content published on official EBSCOed channels

Development Lifecycle

• Requirements gathering and product planning
• User experience and visual design
• Development and quality assurance
• Deployment and maintenance
• Procurement and vendor management

3. Standards and Compliance

Primary Standard

EBSCOed adopts the Web Content Accessibility Guidelines (WCAG) 2.2 Level AA as the minimum accessibility standard for all digital products and content. WCAG 2.2 Level AA is recognized globally as the benchmark for digital accessibility and represents a comprehensive approach to making web content accessible to people with a wide range of disabilities.

Regulatory Compliance

Our accessibility standards are designed to meet or exceed the requirements of:

• Section 508 of the Rehabilitation Act (29 U.S.C. § 794d) - Requirements for federal agencies and their contractors
• Americans with Disabilities Act (ADA), Title II and Title III - Prohibitions against discrimination on the basis of disability
• Section 504 of the Rehabilitation Act - Non-discrimination in federally funded programs
• 21st Century Communications and Video Accessibility Act (CVAA) - Advanced communications and video programming accessibility
• State accessibility laws where applicable to our customers and contracts

Technical Standards

In addition to WCAG 2.2 AA, we reference the following standards:

• WCAG 2.2 Level AA - Primary standard for web content
• ARIA Authoring Practices Guide (APG) - Implementation guidance for accessible rich internet applications
• Section 508 ICT Standards (2017) - Incorporated WCAG 2.0 Level AA; WCAG 2.2 AA conformance satisfies Section 508 requirements due to backward compatibility

4. Governance and Accountability

Leadership and Ownership

The Vice President of Digital Experience serves as the executive sponsor for digital accessibility at EBSCOed and holds ultimate accountability for accessibility decisions and outcomes. This role is responsible for:

• Ensuring accessibility is integrated into product strategy and roadmaps
• Allocating resources for accessibility initiatives
• Approving exceptions to accessibility standards when necessary
• Championing accessibility across the organization

Organizational Structure

EBSCOed operates as part of the larger EBSCO organization and coordinates accessibility efforts accordingly:

• Parent Organization: EBSCO maintains enterprise-wide accessibility resources, including a dedicated accessibility lead (Amber Russell) and centralized accessibility support via accessibility@ebsco.com
• EBSCOed Autonomy: EBSCOed maintains independent authority over product accessibility decisions while leveraging EBSCO's shared resources, expertise, and vendor relationships
• Collaboration: EBSCOed participates in EBSCO-wide accessibility initiatives and shares best practices across the organization

Roles and Responsibilities

Product Managers are responsible for:

• Including accessibility requirements in product specifications
• Prioritizing accessibility issues alongside other product work
• Ensuring accessibility considerations are part of user story acceptance criteria

Designers are responsible for:

• Creating designs that meet WCAG 2.2 AA contrast and visual requirements
• Designing for keyboard navigation and screen reader compatibility
• Documenting accessibility considerations in design specifications

Developers are responsible for:

• Implementing features according to the Accessibility Definition of Done
• Writing semantic HTML and proper ARIA markup
• Testing with automated tools and assistive technologies before code review
• Documenting accessibility patterns in component libraries

QA Engineers are responsible for:

• Verifying accessibility requirements as part of acceptance testing
• Conducting keyboard and screen reader testing
• Reporting accessibility defects with appropriate severity

Content Creators are responsible for:

• Creating accessible content (alt text, proper headings, meaningful link text)
• Following accessibility guidelines for document creation
• Ensuring multimedia content includes captions and transcripts

5. Implementation Requirements

Definition of Done

All features and components must meet the requirements specified in the Accessibility Definition of Done before being considered complete. This checklist ensures consistent accessibility implementation across all development work and includes:

• Automated testing with zero violations
• Keyboard navigation verification
• Screen reader compatibility testing
• Color contrast compliance
• Responsive design and zoom compatibility
• Semantic HTML and ARIA implementation
• Component documentation in Storybook

The complete Definition of Done is maintained as a separate document and updated as standards and tooling evolve.

Automated Testing Requirements

Accessibility testing is integrated into the continuous integration and deployment (CI/CD) pipeline:

• Build Gates: Automated accessibility tests (axe-core, IBM Equal Access Checker) run on every build, achieving zero violations in automated testing. Research indicates automated tools catch approximately 30-40% of accessibility issues, making manual testing and third-party audits essential for the remaining 60-70%.
• Blocking Violations: Builds with automated accessibility violations are prevented from deploying to production
• Component Testing: All UI components include Storybook stories with accessibility testing enabled
• Pre-Deployment Verification: Production deployments require passing all automated accessibility checks

Manual Testing Expectations

Automated testing catches many but not all accessibility issues. Manual testing is required for:

• Keyboard Navigation: Tab order, focus management, keyboard shortcuts
• Screen Reader Testing: Content announcements, ARIA implementation, dynamic updates
• Visual Testing: Color contrast, focus indicators, text scaling
• User Flows: Complete task flows tested with assistive technologies

Developers conduct manual testing during feature development. QA conducts independent verification during acceptance testing. Internal development testing focuses on VoiceOver (macOS/Safari) and includes actual mobile device testing (iOS and Android), not just browser emulation. Third-party audits include testing with NVDA, JAWS, and mobile screen readers to ensure broad compatibility.

Technology Foundation

The platform is built on a technology stack chosen to support accessibility by default:

• Framework: Next.js with React Server Components
• Component Library: shadcn/ui built on Radix UI primitives, which provide accessible implementations of complex interactive patterns
• Testing Tools: axe-core, IBM Equal Access Checker, Storybook accessibility addon
• Code Quality: Biome for linting, with axe-core providing the primary accessibility validation

This architecture ensures accessibility is built into the foundation rather than added as an afterthought.

Cognitive Accessibility

In accordance with WCAG 2.2's expanded focus on cognitive accessibility, the platform:

• Minimizes redundant data entry across workflows (WCAG 3.3.7 Redundant Entry)
• Provides accessible authentication without cognitive function tests (WCAG 3.3.8 Accessible Authentication)
• Supports consistent help mechanisms across the platform (WCAG 3.2.6 Consistent Help)

Motion and Animation Accessibility

The platform respects user motion preferences:

• Supports prefers-reduced-motion media query for users sensitive to motion
• Ensures no content flashes more than three times per second (WCAG 2.3.1 Three Flashes or Below Threshold)
• Provides pause, stop, or hide controls for auto-playing content (WCAG 2.2.2 Pause, Stop, Hide)

Touch and Pointer Accessibility

In accordance with WCAG 2.2's new input modality criteria:

• Interactive elements meet minimum target size of 24x24 CSS pixels (WCAG 2.5.8 Target Size Minimum)
• Functionality available via dragging also supports single-pointer alternatives (WCAG 2.5.7 Dragging Movements)

6. Third-Party Auditing and Verification

External Audit Commitment

EBSCOed commits to regular third-party accessibility audits conducted by qualified accessibility professionals. These audits provide independent verification of conformance and identify issues that automated testing may miss.

Audit Schedule

• Initial Audit: A comprehensive third-party accessibility audit will be completed at least 30 days prior to the platform's production launch to allow time for remediation of any findings
• Regular Audits: Subsequent audits will be conducted at least annually
• Trigger Audits: Additional audits will be conducted after major feature releases or significant platform changes

Audit Vendor

Magic EdTech has been engaged as EBSCOed's third-party accessibility audit vendor. Magic EdTech will:

• Conduct comprehensive manual and automated accessibility testing
• Test with multiple assistive technologies across platforms
• Provide detailed findings with WCAG success criterion mapping
• Offer remediation guidance for identified issues
• Produce Accessibility Conformance Reports (ACRs) using the VPAT template

Accessibility Conformance Reports (ACRs)

Following each third-party audit, EBSCOed will:

• Publish an Accessibility Conformance Report using the ITI VPAT 2.5 template or later
• Make ACRs available to customers and procurement evaluators upon request
• Update ACRs when significant product changes affect accessibility
• Maintain version control to track conformance over time

7. Remediation Process

Issue Prioritization

Accessibility issues are prioritized using the following framework:

Critical (P0) - Immediate remediation required:

• Complete blockers preventing users with disabilities from accessing core functionality
• Legal compliance violations with immediate risk
• Issues affecting multiple WCAG Level A success criteria

High (P1) - Remediate within 30 days:

• Significant barriers affecting task completion for users with disabilities
• WCAG Level AA violations affecting primary user flows
• Issues identified in third-party audits as high-impact

Medium (P2) - Remediate within 90 days:

• Moderate accessibility barriers with workarounds available
• WCAG Level AA violations in secondary features
• Issues affecting user experience but not completely blocking access

Low (P3) - Remediate within next release cycle:

• Minor accessibility improvements beyond minimum compliance
• WCAG Level AAA enhancements
• Documentation and best practice improvements

Remediation Timeline Commitments

EBSCOed commits to the following remediation timelines:

• Critical Issues: Addressed within 5 business days
• High Priority Issues: Remediated within 30 calendar days
• Medium Priority Issues: Remediated within 90 calendar days
• Low Priority Issues: Addressed in the next planned release

Progress on remediation is tracked in our issue management system (Jira) with accessibility-specific labels and reported to stakeholders monthly.

Exception Process

In rare cases where immediate conformance is not technically feasible, exceptions may be requested:

1. Document the specific WCAG success criterion affected
2. Explain the technical or business constraint preventing conformance
3. Propose an alternative accessible solution or timeline
4. Obtain approval from the VP of Digital Experience
5. Create a remediation plan with specific milestones
6. Communicate limitations to affected users via accessibility statement

Exceptions are granted sparingly and require executive approval.

8. Training and Professional Development

Training Requirements

All employees involved in creating digital content or products must receive accessibility training appropriate to their role:

Developers:

• WCAG 2.2 fundamentals and success criteria
• Semantic HTML and ARIA implementation
• Automated and manual testing techniques
• Assistive technology demonstrations
• Annual refresher training

Designers:

• Accessible design principles (color, contrast, typography)
• Designing for keyboard navigation and screen readers
• Inclusive design methodologies
• WCAG visual and interaction requirements

Content Creators:

• Writing accessible content (headings, links, alt text)
• Creating accessible documents and multimedia
• Plain language and readability principles

Product Managers:

• Accessibility requirements and user stories
• Prioritizing accessibility work
• Understanding legal and business implications

Training Delivery

Training is provided through:

• Online courses and certifications (IAAP credentials encouraged)
• Internal workshops and lunch-and-learns
• Documentation and reference materials
• Hands-on practice with assistive technologies
• Conference attendance and external training opportunities

Knowledge Sharing

EBSCOed fosters a culture of accessibility knowledge sharing through:

• Internal accessibility documentation and best practices
• Component library documentation with accessibility guidance
• Regular team discussions of accessibility topics
• Sharing learnings from audits and user testing

9. User Feedback and Accessibility Barriers

Reporting Mechanism

EBSCOed provides multiple channels for users to report accessibility barriers:

• Email: accessibility@ebscoed.com (monitored by accessibility team)
• Customer Support: Issues can be reported to regular support channels and escalated
• Parent Organization: accessibility@ebsco.com for enterprise-wide concerns

Response Commitment

When accessibility barriers are reported:

• We will acknowledge and respond to your report in a timely manner.

Feedback Integration

User-reported accessibility issues inform:

• Product roadmap prioritization
• Testing and audit scope
• Training needs identification
• Policy and process improvements

Accessibility Statement

EBSCOed maintains a public accessibility statement for the platform that includes:

• Our commitment to accessibility
• Conformance status and known limitations
• Contact information for reporting barriers
• Information about assistive technologies we support
• Links to this policy and our Accessibility Conformance Report

The accessibility statement is reviewed and updated quarterly or when significant changes occur.

10. Policy Review and Updates

Review Cadence

This accessibility policy is reviewed and updated on the following schedule:

• Annual Review: Comprehensive policy review every 12 months
• Standard Updates: When WCAG or other referenced standards are updated
• Regulatory Changes: When relevant laws or regulations change
• Organizational Changes: When responsibilities or processes change significantly
• Post-Audit: After major accessibility audits to incorporate learnings

Review Process

Policy reviews include:

1. Assessment of policy effectiveness and compliance
2. Review of accessibility metrics and conformance data
3. Evaluation of industry best practices and peer benchmarks
4. Input from accessibility team and stakeholders
5. Legal and regulatory compliance verification
6. Update approval by VP of Digital Experience

Version Control

Policy changes are:

• Documented with version number and effective date
• Communicated to all affected employees
• Published on internal knowledge base
• Made available to customers and vendors upon request

Metrics and Accountability

Progress toward accessibility goals is measured through:

• Automated Test Results: CI/CD pass rates and violation counts
• Audit Findings: Third-party audit scores and conformance levels
• Remediation Velocity: Time to fix issues by severity level
• User Feedback: Volume and resolution of reported barriers
• Training Completion: Percentage of staff completing required training

These metrics are reported quarterly to leadership and inform continuous improvement efforts.

11. Procurement and Third-Party Content

Vendor Accessibility Requirements

When procuring technology products or services, EBSCOed requires:

• Vendors provide current Accessibility Conformance Reports (ACRs)
• Products meet WCAG 2.2 Level AA or demonstrate a remediation roadmap
• Accessibility is evaluated as part of vendor selection criteria
• Contracts include accessibility conformance language and service level agreements

Third-Party Content Responsibility

EBSCOed recognizes that we remain responsible for the accessibility of our platforms even when incorporating third-party content or services. We:

• Evaluate third-party components for accessibility before integration
• Provide accessible alternatives when third-party content cannot be made accessible
• Monitor third-party content for accessibility issues
• Work with vendors to remediate accessibility barriers

12. Legacy Content and Migration

Platform Transition

EBSCOed is transitioning from a legacy Drupal-based product to a new Next.js-based platform:

• Migration Timeline: Complete transition to new platform prior to contract fulfillment
• Accessibility Commitment: New platform meets WCAG 2.2 AA from launch
• Content Review: Content migrated from legacy system is reviewed for accessibility during migration
• Improvement Opportunity: Migration provides opportunity to remediate historical accessibility issues

Legacy Product Support

During the transition period:

• Accessibility support continues for legacy product
• Critical accessibility issues in legacy product are addressed
• Users are informed of improved accessibility in new platform
• Migration assistance provided for users with disabilities

13. Future Commitments

EBSCO's enterprise organization already employs users with disabilities for testing and has team members with IAAP certifications. EBSCOed's goal is to build similar capabilities within our product team for more direct, ongoing involvement in platform development.

As the platform matures and EBSCOed's accessibility program evolves, we commit to:

• Pursuing formal accessibility certifications for team members (CPACC, WAS, CPWA)
• Expanding assistive technology testing to include a broader range of tools and platforms
• Conducting user testing with people with disabilities to validate accessibility in real-world scenarios
• Contributing to open-source accessibility tools and community knowledge
• Evaluating opportunities to exceed WCAG 2.2 Level AA where it benefits users
• Monitoring emerging standards (WCAG 3.0, ARIA updates) and planning for future adoption

Document Information

Policy Owner: VP Digital Experience, EBSCOed

Approved By: EBSCOed Leadership Team

Effective Date: January 2026

Next Review Date: January 2027

Version: 1.1

Contact Information: EBSCOed Accessibility Team: accessibility@ebscoed.com EBSCO Enterprise Accessibility: accessibility@ebsco.com EBSCO Accessibility Lead: Amber Russell

Related Documents:

• Accessibility Definition of Done

   

This policy demonstrates EBSCOed's organizational commitment to digital accessibility as a core value, legal obligation, and business imperative. We are building the platform to be accessible from the ground up, ensuring that all users, regardless of ability, have equal access to the career development tools and services we provide.