Embedding Accessibility

Project Name
Accessibility governance framework
Headquarters
Utrecht, the Netherlands
Industry
Public sector / Food & Consumer Product Safety
Company Size
2500+ employees
Timeline
9 Months
Understand
At the NVWA, accessibility was formally the responsibility of the communications department. In practice, this meant a small team was tasked with making large volumes of externally produced content compliant with legal standards, often at the very end of the production process. Accessibility was treated as a corrective step rather than a shared principle. Without structural ownership or governance, the work had become reactive, fragmented and increasingly unsustainable.
Observe
In daily practice, documents were often delivered shortly before publication with the request to make them accessible. Many colleagues saw accessibility as a technical formatting task rather than a design principle. PDFs were the default output, templates did not support accessible production, and awareness of inclusive structure or writing was limited. The issue was less about unwillingness and more about a lack of shared understanding, ownership, and practical tools.
Define
The issue was not simply the growing number of non-compliant PDFs, but a structural misalignment between responsibility and control. Accessibility had been positioned within the communications department, while the decisions that shaped accessibility were made much earlier in content creation, tooling, and management priorities.
As long as accessibility remained a downstream task, the organisation would stay in a continuous repair cycle. The real challenge was to address the root cause rather than the visible symptoms.
Ideate
Instead of focusing on fixing over 5,000 inaccessible PDFs, I stepped back to examine the underlying cause. I mapped the process and repeatedly asked why inaccessible documents kept being produced. Who created them? Why were PDFs the default? Why was accessibility considered only at the end? Who felt responsible, and who did not?
By tracing the issue back through the workflow, it became clear that accessibility was positioned in the wrong place within the organisation. This insight shifted the intervention from repairing documents to repositioning responsibility and embedding accessibility earlier in the process.
Prototype
To translate the repositioning into practice, I implemented several interventions. I introduced the W3C Accessibility Maturity Model to assess organisational capability and create a structured improvement path. I delivered accessibility training sessions to increase awareness and practical skills across departments. I advised management to adopt a clear publication principle: HTML by default, PDF only when strictly necessary.
I also proposed embedding accessibility requirements into procurement and collaboration with external partners, ensuring suppliers comply with government standards. Finally, I recommended establishing a centrally positioned Accessibility Officer, reporting at executive level alongside compliance roles such as security and privacy.
Test
Management formally accepted the governance advice, including the principle that accessibility should be positioned beyond the communications department. An explicit intention was expressed to appoint an Accessibility Officer at executive level, placing accessibility alongside other compliance domains such as privacy and security.
The practical accessibility guidelines I developed for the communications team were adopted and integrated into daily workflows. Accessibility checkpoints became part of publication decisions, and the HTML by default principle started guiding content choices. The proposal to strengthen collaboration between communications and other departments was also implemented, with accessibility audits becoming shared responsibilities rather than isolated reports.
Although not every structural change was completed during my time there, accessibility had shifted from a repair task within communications to a recognised organisational responsibility with formal backing.
My role
I initiated and led the repositioning of accessibility within the organisation. I developed practical accessibility guidelines and delivered training across departments. I advised management on governance measures, including procurement requirements and the appointment of an Accessibility Officer at executive level.

