Sustainable accessibility in complex organisations: strategic foundations

Posted on Friday, 7 November 2025 by Henny Swan in Strategy

Whether at the start of your accessibility journey or partway through it, complex organisations often face strategic, organisational, and external barriers that can make scaling accessibility difficult.

These challenges are common, but with the right foundations and committed leadership, accessibility can scale in ways that are both effective and sustainable.

A good starting point for scaling sustainable accessibility is to identify your biggest pain points and look at how to reduce or remove them. These often fall into three areas:

• Strategic foundations
• Organisational realities
• External factors

In this post, we explore strategic foundations, and how clear leadership, defined accountability, and effective governance turns intention into lasting change.

A note on EN 17161: Design for All

If you’re looking for a standards-based framework for embedding accessibility into your organisation, EN 17161: Design for All offers useful guidance. Our post Understanding EN 17161 Design for All explains the standard in more detail and is mapped to each of the sections that follow.

Strategic foundations

Strategic foundations help define how accessibility is led, who is responsible, how progress is governed, and how impact is measured through reporting and metrics.

Leadership

Leadership sets the tone, priority, and direction for accessibility across the organisation. Without visible support from senior leaders, it can be difficult to gain momentum or make progress.

A common challenge for organisations is deciding where accessibility leadership should sit. This can result in accessibility becoming a nomad and being passed around various heads of department or treated as an add-on to another leadership role. This often leads to stalled progress, slower decision-making, delayed budget approvals, and a lack of a clear strategy.

There are different approaches to where accessibility leadership can sit within an organisation; what matters most is that it has the authority, visibility, and influence needed to drive change.

Here are a few models we have seen in organisations we have worked with.

Within a central digital or technology team

An obvious choice is for accessibility leadership to sit within a central digital or technology team, as this puts accessibility at the centre of product development, user experience, design, and engineering. In our experience, accessibility most often falls under User Experience and Design, where it’s seen as part of creating an inclusive user journey.

The only drawback is that accessibility may be seen as solely a technology concern rather than a company-wide responsibility. To avoid this, it’s important to align accessibility leadership with other key functions such as Diversity, Equity and Inclusion (DEI), Human Resources (HR), procurement, legal, and communications.

Within a diversity, equity, and inclusion (DEI) team

By having accessibility sit within a DEI team, it becomes more of a company-wide concern and a mindset. This goes a long way to help build a culture of inclusion across all departments, not just digital.

However, DEI may lack technical or operational influence unless aligned with product teams.

While this model is less common, it can work well when DEI and the central accessibility teams collaborate closely, combining cultural leadership with practical implementation.

Within a central accessibility team

A common location for accessibility leadership to st is within a central accessibility team. This helps build specialist expertise and supports consistency across departments. However, it needs strong executive support and mandates to avoid becoming underused, ignored, or avoided by product teams.

An established central accessibility team is an approach we have seen work well for many of our customers. The most effective examples are where the team focuses on building and maintaining an accessibility framework, rather than spending their time on assessments, design reviews, or day-to-day testing.

This frees the accessibility team up to focus on accessibility documentation, processes, and training that benefit every product team, not just one team. It also helps product teams build accountability and embed accessibility into their everyday work, turning the accessibility team into a strategic partner they can call on when specialist support is needed.

Within legal, risk, or compliance

A less common approach is accessibility leadership as part of legal or compliance. While this reinforces the legal obligation to meet accessibility standards, it risks framing accessibility purely as a compliance issue, rather than a design and user experience opportunity.

This is not a model we tend to see amongst our customers.

Executive leadership

Leadership for accessibility sometimes sits with a member of the executive team, such as the Chief Technology Officer (CTO), Chief Operating Officer (COO), or Chief Executive Officer (CEO). This gives accessibility strategic weight and ensures it is embedded across departments from the top down.

Success, however, depends on the executive’s commitment and ability to balance accessibility with other business goals. This model works best when senior leaders reporting into them handle day-to-day implementation and strategic direction, and can escalate issues to executive leadership when needed.

Mapping leadership to EN 17161: Design for All

Understanding EN 17161 Design for All contains more details of the following clauses:

• Clause 5: Leadership
• Clause 9.3: Management review

Responsibility and accountability

Ownership and accountability clarifies who is responsible for what throughout the product delivery lifecycle. If teams are unsure who is responsible for accessibility, it can result in accessibility being left out of product requirements, leading to products being shipped with poor or no accessibility. This can lead to costly retrofitting, legal risk, and potential reputational damage.

At the product team level, ownership and accountability simply means being responsible for whatever you design, code, write, or test. But this can't happen on trust alone; responsibilities should be communicated and supported.

There are a few ways you can do this.

Job descriptions

Accessibility responsibilities should be clearly outlined in job descriptions, so that expectations are transparent from the start. This helps organisations attract and recruit the best candidates as well as help people understand what the role involves.

Once in post, this reinforces accessibility as integral to the role, helps people prioritise it in their day-to-day work, and ensures accountability during performance reviews. It also makes accessibility part of professional development, encouraging continuous learning and improvement across teams.

Objectives and performance reviews

Accessibility responsibilities should also be reflected in individual objectives and performance reviews. This reinforces that inclusion is a core part of quality work, not an optional extra. It helps embed accessibility into everyday practice, ensures accountability over time, and recognises the contribution people make to improving accessibility across products and processes.

I’ve worked in a central accessibility team at a broadcaster, supporting designers, developers, and their managers to add accessibility into individual objectives that linked back to the organisation’s accessibility roadmap and strategy. This had a huge impact, giving teams a clear way to measure progress at both individual and departmental levels.

Built into workflows and processes

Accessibility should be embedded into existing workflows and processes rather than treated as a separate or one-off task. From design reviews and sprint planning to code reviews and Quality Assurance (QA), accessibility should be part of how work gets done day to day.

Embedding accessibility in this way makes it a shared responsibility rather than a specialist task. It ensures that everyone involved in design and delivery is accountable for their part, whether they are designing, coding, writing, or managing a product. This can be done through adding accessibility to documentation, providing accessibility training, tools, and resources to help people do their jobs confidently and effectively.

Shared team goals

Include accessibility in team-wide goals and planning cycles, such as sprint planning or quarterly targets. This embeds it in everyone’s workflow and shifts the focus from individual effort to collective responsibility. It also creates shared accountability, making the whole team answerable for progress, not just those with accessibility in their title.

Named leads and points of contact

Assign a clear lead for each accessibility focus area, deliverable, or decision. This creates individual responsibility for each area, while keeping the team collectively accountable for outcomes. A named contact also reduces ambiguity, speeds up decision-making, and makes it easier for others to ask questions or escalate issues early.

In product delivery teams, this might mean assigning an accessibility lead within design, development, and quality assurance while working collaboratively. A named lead might also be a product manager who owns accessibility in the roadmap. It could also mean embedding a product accessibility specialist in the team. Their role focuses on supporting a single product, unlike an accessibility lead in a central accessibility team, who supports multiple teams across the organisation.

Mapping responsibility, accountability and EN 17161: Design for All

Understanding EN 17161 Design for All contains more details of the following clauses:

• Clause 5.3: Organisational roles, responsibilities and authorities
• Clause 7.3: Awareness

Governance

Effective governance gives accessibility structure, clarity, and authority. It defines who makes decisions, owns and maintains policy, and provides clear escalation routes when issues arise. This helps ensure that accessibility is considered not only in product delivery, but also in recruitment, procurement, and wider organisational decisions.

In practice, this often takes the form of a central accessibility steering group made up of people from across the organisation, such as product, legal, HR, and procurement. Delivery teams can have nominated accessibility leads who feed into the group, monitor progress in their area, and raise issues when support or decisions are needed.

We’ve seen this work well at a global freight company early in their accessibility journey. A steering group of executive leaders owns accessibility, while leads from user experience and design drive day-to-day implementation and strategy, reporting into the group.

Mapping governance and EN 17161: Design for All

Understanding EN 17161 Design for All contains more details of the following clauses:

• Clause 6: Planning
• Clause 9: Performance evaluation

Reporting and metrics

Reporting and metrics are a key part of effective governance. It allows organisations to track accessibility progress beyond individual projects or teams, providing a clear view of what’s working, which products pose an accessibility risk, and where support is needed. Regular reporting helps hold teams accountable, measure whether commitments are being met, and surface risks early. This, in turn, gives senior leaders the evidence they need to drive change.

Examples of organisational tracking include:

• Accessibility roadmaps: track organisational progress against goals, milestones, and delivery timeline, metrics may include policy compliance rates, team training completion, and progress against organisational accessibility goals
• Risk analysis: identify and log accessibility risks within products or services and link each risk to an owner and mitigation plan
• Executive updates: regular updates as a standing item in quarterly business reviews alongside other key performance indicators with clear RAG (Red/Amber/Green) status, risks, and owner actions
• Performance reviews: these can be used to track not only individual progress but also linked to team objectives for reporting data

Mapping reporting, metrics, and EN 17161: Design for All

Understanding EN 17161 Design for All contains more details of the following clauses:

• Clause 6: Planning
• Clause 8: Operation
• Clause 9: Performance evaluation

In summary

Scaling accessibility in organisations can be complex, but it’s achievable with the right approach. Success depends on strong leadership, clear accountability, effective governance, and consistent metrics supported by a culture that values inclusion and collaboration.

By taking a structured, joined-up approach, combined with careful management of organisational realities and external factors, you can scale accessibility in a way that delivers long-term value for your teams, your business, and your customers.

Next steps

Learn more about how TetraLogical can help your organisation with our Embedded accessibility service and Sustainable accessibility service.