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Web accessibility deserves CIO-level ownership because it determines whether people can independently use an organization’s digital services, and because accessibility requirements are becoming more concrete for some public entities. The phrase “top CIO priority” comes from a CIO feature published April 6, 2022; it is not evidence that accessibility currently ranks near the top of CIO priorities across the industry. The durable case is practical: make accessible experiences part of how digital products are designed, built, tested, and maintained.

Why web accessibility belongs on the CIO agenda

Accessibility is not a cosmetic polish or a final compliance check. It affects whether customers, employees, residents, and other users can get information and complete essential tasks. That makes it a product-quality and service-delivery concern as well as a legal one.

In the 2022 CIO feature, Mark Shapiro, then identified as president of the Bureau of Internet Accessibility, described an accessible experience as one people can use fully and independently, including with the assistive technologies they use to navigate and consume content. That standard is more useful than asking whether a page merely looks right or passes an automated scan.

For CIOs, the organizational implication is ownership: accessibility must reach the teams that control digital strategy, design systems, procurement, engineering, content, quality assurance, and operations. A defect in a form, a vendor portal, or an app can prevent a person from completing the same task others can finish easily.

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What makes a website accessible?

A website is accessible when people with different disabilities can perceive and operate its content, understand what to do, and complete tasks using the methods and assistive technologies they rely on. Those methods can include screen readers, keyboard navigation, on-screen keyboards, voice dictation, and combinations of tools.

Typical barriers include images without meaningful text alternatives, controls that cannot be reached or operated by keyboard, text or interface elements with insufficient contrast, and forms whose labels or error messages are not conveyed to assistive technology. These are examples, not a complete checklist: an apparently accessible page can still fail when its navigation, instructions, or interaction flow breaks down during a real task.

Evaluate the whole journey, not isolated pages. A person should be able to find an entry point, understand available choices, enter information, recover from errors, and receive confirmation. Accessibility is an outcome for users; standards and tools help teams evaluate that outcome but do not replace it.

What the 2022 CIO headline does—and does not—establish

The headline reflects a forward-looking argument made in April 2022: legal developments and a possible market opportunity could make accessibility a priority that year. It should not be read as a current survey result. No newer, directly comparable CIO-priority ranking is established here, so it would be inaccurate to claim that accessibility is now a top priority for CIOs generally.

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The same feature reported that 97.4 percent of the world’s top million websites failed at least some accessibility guidelines, citing a WebAIM study as reported in 2021, and gave 98.1 percent for 2020. These are historical, methodology-specific automated findings, not a current measure of all websites or proof that the same share is unusable. They are not needed to make the operational case: an organization can identify and fix barriers in its own services without generalizing from those figures.

The point for a digital leader is not to treat accessibility as a trend that must be validated by a ranking. It is to ensure that people can use the organization’s services, then determine which technical and legal obligations apply to the organization’s products and jurisdictions.

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What the DOJ Title II rule requires of covered public entities

The U.S. Department of Justice’s ADA Title II web rule establishes WCAG 2.1 Level AA as the technical standard for covered web content and mobile apps of state and local governments. The DOJ says the rule applies to web content a state or local government provides or makes available, including content provided through contractual, licensing, or other arrangements. This is a scoped requirement for covered public entities; it does not automatically make the same technical rule applicable to every private business.

The DOJ’s current materials list compliance dates as follows, following an interim final rule issued April 20, 2026:

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Covered entity Compliance date listed by DOJ
State and local government entities with a population of 50,000 or more April 26, 2027
State and local government entities with a population below 50,000, and special district governments April 26, 2028

The rule includes exceptions, and Title II duties concerning effective communication and equal opportunity continue to matter. A CIO should use the DOJ fact sheet and DOJ first-steps guidance to understand scope and planning, and consult qualified counsel for an entity-specific determination. Do not infer that a page is exempt or covered solely from its technology stack or who authored it.

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WCAG is a set of guidelines published by the W3C Web Accessibility Initiative. The DOJ rule is what makes a specified WCAG level the technical requirement for covered entities within its scope; W3C guidance itself is not a law. The W3C provides information on WCAG 2 conformance and web accessibility laws and policies.

Where do you start?

Start with the services people need to use, the barriers that could prevent task completion, and the teams accountable for fixing them. Then build accessibility into normal product delivery rather than treating it as a one-time cleanup.

  1. Identify high-impact journeys. List core tasks such as finding information, creating an account, submitting a form, making a payment, or using a mobile service. Prioritize based on user impact and service importance, not only the number of pages.
  2. Assign accountable owners. Name a senior sponsor and working owners across product, design, engineering, content, procurement, QA, and operations. Make it clear who decides priorities, who fixes issues, and who verifies the fix.
  3. Evaluate real barriers. Combine automated checks with manual review of keyboard operation, focus order, labels, instructions, errors, contrast, and assistive-technology use. Include people with disabilities where feasible; a scan cannot tell you whether a person can independently finish the task.
  4. Prioritize and remediate. Record each finding with its affected journey, user impact, owner, target date, and acceptance criteria. Address blockers in core workflows first, then track lower-impact defects in the same system used for product work.
  5. Retest and maintain. Verify fixes in context and include accessibility checks in design reviews, component changes, releases, and ongoing monitoring. Revisit third-party content and mobile apps where they are part of the service or applicable legal scope.
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How to assess tools, vendors, and approaches

No single tool can make a website accessible all at once. Automated testing is valuable for finding certain detectable issues consistently, but it cannot establish by itself that a person with a disability can use a service fully and independently. Treat a scan as one input to evaluation, not a conformance guarantee.

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When comparing an internal program, audit provider, or testing platform, ask:

  • Can users complete the organization’s core tasks independently, and how is that assessed?
  • Which disability-related barriers and assistive technologies are covered?
  • Does the approach combine automated checks with manual evaluation and, where feasible, feedback from disabled users?
  • How are findings ranked, assigned to owners, retested, and prevented from recurring?
  • Does the scope include relevant third-party content and mobile applications?
  • What ongoing governance, staff effort, and maintenance are required after the initial assessment?

Ask vendors to define the exact scope of any claimed conformance or coverage, including what was tested and what remains outside it. The organization remains responsible for deciding whether the resulting experience meets its users’ needs and any obligations that apply.

Make accessibility part of digital quality

Accessibility lasts when it is treated as a product value and an operating practice, not a deadline-driven patch. Build requirements into procurement, design systems, content standards, development acceptance criteria, and release checks. Give teams a route to escalate issues and leadership a way to track whether important journeys are improving.

That approach serves users directly and gives CIOs a clearer way to manage risk: understand the applicable rules, focus on meaningful user tasks, and keep accessibility work attached to the systems and teams that deliver those tasks.

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