In Practice Brief | Accessibility as Governance: Designing for Trust at the Digital Front Door
In-Practice Briefs are TL Advisory’s applied governance series—concise, research-based analyses connecting institutional leadership, technology, and accountability. Each brief distills emerging policy trends into practical frameworks for mission-driven organizations.
This brief examines how institutions move beyond accessibility complaince toward governance-driven design—aligning TL Advisory’s Architecture of Governance™ principles into systems that sustain trust at the digital front door.
Each In Practice Brief from TL Advisory examines governance through three stages—Perspective, Practice, and Proof—guided by the principles of Inquiry, Integrity, and Impact. Together, they form a continuous cycle that translates understanding into accountability and accountability into measurable trust.
Executive Summary
The recent release of WCAG 3.0 Draft 4 underscores a shift in how digital accessibility is understood and evaluated. Rather than emphasizing binary compliance, the draft framework reflects growing attention to continuity, usability, and institutional maturity over time.
At the same time, institutions face renewed scrutiny for how they communicate online. Michigan State University’s accessibility initiative and the U.S. Department of Justice’s ADA Title II Web and Mobile Accessibility Rule signal a clear inflection point: accessibility failures increasingly register as governance failures—gaps in organizational capacity, accountability, and public trust.
This In Practice Brief interprets WCAG 3.0 through TL Advisory’s Architecture of Governance™ (AoG)—a five-pillar framework for assessing whether institutions possess the structural capacity, accountability mechanisms, and public-facing practices required to sustain trust in complex digital systems. Applied to accessibility, the framework clarifies how standards translate into durable institutional practice.
Accessibility, in this context, is both infrastructure and the public signal of credibility.
I. Perspective | The Governance Signal
Michigan State University announced a Digital Accessibility Strategic Initiative, pledging to monitor more than 135,000 web pages and 278,000 videos for accessibility compliance.¹ The plan established over 200 digital-accessibility liaisons distributed across colleges and administrative units—an explicit choice to embed accessibility in governance rather than treating it as a purely technical responsibility.
Just months earlier, the U.S. Department of Justice finalized its ADA Title II Web and Mobile Accessibility Rule, requiring all state and local government entities—including public universities—to conform to WCAG 2.1 AA by April 24, 2026.² Together, these developments define accessibility as a measure of institutional accountability: how an organization designs for access now reflects how it governs for trust.
II. Practice | Compliance Isn’t Capacity
Policies alone do not guarantee capability. Michigan State University’s Digital Accessibility Policy defines “information and communication technology” broadly, encompassing websites, applications, and digital media. ³ That scope demands a governance system capable of continuous assurance rather than episodic review.
By naming unit-level liaisons and adopting enterprise-wide scanning tools, MSU is constructing what many organizations lack: clear accountability pathways connecting technical implementation to executive oversight.
This gap is not unique to higher education. A 2025 survey of local governments by CivicPulse found that while 84 percent of leaders viewed web accessibility as “a fundamental component of good governance,” fewer than 30 percent had taken even one of six key implementation actions.⁴ The distance between policy intent and operational reality reveals accessibility failures as governance breakdowns rooted in structure and leadership design.
III. Practice | From Standard to System
WCAG 3.0 reflects a shift from binary compliance toward evaluating how effectively users can access and engage with digital content over time. Rather than asking whether content technically passes a checklist, the draft framework emphasizes continuity, usability, and institutional maturity.
TL Advisory interprets this shift through its Architecture of Governance™ (AoG)—a leadership framework that assesses whether institutions have the capacity, accountability, and transparency required to sustain trust in complex digital systems. WCAG 3.0 functions here as an input to governance rather than a self-contained solution. Its implications become legible when mapped across five interconnected governance pillars:
Organizational Capacity: Accessibility depends on whether institutions have the staffing models, tools, expertise, and resourcing necessary to sustain access at scale. Capacity is demonstrated through training, role definition, and operational readiness—not aspirational policy statements.
Institutional Accountability: Effective accessibility governance clarifies where responsibility sits, how decisions are made, and who is answerable for outcomes. Accountability requires documented ownership, escalation pathways, and leadership visibility beyond technical teams.
Public Trust & Transparency: Accessibility signals credibility at the digital front door. Institutions build trust by communicating their accessibility posture clearly—through public statements, progress reporting, and acknowledgment of limitations—rather than relying on implicit assurances.
Policy-to-Practice Implementation: Standards establish intent; governance determines execution. Accessibility matures when requirements are embedded into procurement, content workflows, platform selection, and review cycles, ensuring consistency across systems and time.
Equity & Inclusion: Accessibility is inseparable from equity. Governance frameworks must account for how design choices affect users with diverse abilities, technologies, and constraints. Inclusive outcomes depend on treating access as a core design obligation rather than a downstream accommodation.
Viewed through these pillars, WCAG 3.0 operates less as a checklist and more as a diagnostic signal—revealing whether institutions have the governance structures required to sustain access, demonstrate care, and earn public confidence over time.
IV. Proof | Comparative Insight
Across higher education, media, and government, accessibility is emerging as a governance benchmark.
Higher Education. MSU’s campus-wide audit demonstrates governance structure in action: defined ownership, scheduled review cycles, and public reporting. By publishing milestones rather than promises, the university converted internal process into visible accountability.
Media and Public Communication. At The Nieman Lab—a Harvard-affiliated institute analyzing journalism and public communication—editors recently challenged news organizations to “stop excusing” inaccessible content. Their argument reframed accessibility as an indicator of institutional ethics and transparency.⁵ The implication extends beyond journalism: accessibility now communicates whether institutions can be trusted to steward public attention responsibly.
Federal and Corporate Benchmarks. At the federal level, the General Services Administration’s 2025 Section 508 Progress Update repositioned accessibility as a governance maturity signal rather than an IT deliverable.⁶ Similarly, organizations reporting under emerging ESG frameworks increasingly disclose accessibility metrics alongside privacy and inclusion indicators, reinforcing access as an operational value.
V. Recommendations | Accessibility Governance Maturity
Applying TL Advisory’s Accessibility Governance Maturity Loop, executives can translate awareness into durable systems that strengthen public trust.
• Define Accountability—Identify where accessibility responsibility resides, how progress is measured, and when results are reviewed. Assign authority at the leadership level so inclusion decisions carry organizational weight.
• Embed Process—Institutionalize accessibility through existing governance channels—budget cycles, policy reviews, procurement, and content approvals. Routine attention signals discipline.
• Operational Stewardship—Extend accessibility expectations across platforms, vendors, and legacy systems. Monitor adherence and resource continuous improvement.
• Communicate Progress—Publish accessibility statements and progress updates in clear, plain language. When gaps are acknowledged and improvements documented, institutions demonstrate stewardship rather than vulnerability.
Each loop reinforces the next. Structure enables process; process produces evidence; evidence sustains transparency. Together, they transform accessibility from compliance obligation into governance practice.
VI. Accessibility Demonstrates Trust
Accessibility is a governance issue before it is a technical one. It tests whether institutions can organize attention, allocate responsibility, and communicate care.
WCAG 3.0 will continue to evolve, but its signal is already clear: credibility depends on governance capacity. Institutions that act now—before regulation forces alignment—demonstrate discipline, foresight, and integrity.
Trust is not declared; it is demonstrated. Accessibility is how that demonstration becomes visible.
The public judges governance by the pages it can’t read.
At TL Advisory, we help organizations translate awareness into structure—building systems where inclusion is measurable, repeatable, and enduring.
Continuity Note: This brief builds on the author’s 2021 Wiley Connect analysis, New Web Content Accessibility Standard, WCAG 3.0, Promises Far-Reaching Impact, which first identified accessibility’s evolution from technical compliance to institutional governance.
Download the In Practice Brief (PDF)
Sources & Citations
¹ Michigan State University, The MSU Quest for Digital Accessibility (Oct. 7, 2025), https://msutoday.msu.edu/news/2025/10/the-msu-quest-for-digital-accessibility.
² Nondiscrimination on the Basis of Disability; Accessibility of Web Information and Services of State and Local Government Entities, 89 Fed. Reg. 17,146 (Mar. 8, 2024) (to be codified at 28 C.F.R. pt. 35), https://www.ada.gov/resources/2024-03-08-web-rule.
³ Michigan State University, Digital Accessibility Policy § 1 (2025), https://webaccess.msu.edu/policy.
⁴ CivicPulse, Web Accessibility in Local Government Survey (2025), https://www.civicpulse.org/research/technology-and-innovation/web-accessibility-local-government-survey.
⁵ The Nieman Lab, We Stop Excusing the Lack of Accessibility in News (Dec. 2024), https://www.niemanlab.org/2024/12/we-stop-excusing-the-lack-of-accessibility-in-news.
⁶ U.S. Gen. Servs. Admin., Government-Wide Section 508 Progress Update (2025), https://www.section508.gov/manage/progress-report.
⁷ See New Web Content Accessibility Standard, WCAG 3.0, Promises Far-Reaching Impact, Wiley Connect (Feb. 3, 2021), https://www.wileyconnect.com/new-web-content-accessibility-standard-wcag-30-promises-far-reaching-impact.