Digital Accessibility Policy

Policy Number: ADMN.303.02.E

Policy Type: External

Authority: Iowa Code 8.77; Iowa Code 8.85

1. Purpose

This policy establishes the State of Iowa's requirement that its Digital Content and Services be accessible to people with disabilities. It sets a single accessibility conformance target so that Iowans and state employees with disabilities have access to and use of state Digital Content and Services comparable to the access afforded to others.

2. Scope

This policy applies to all Enterprise Workers. That includes employees, contractors, vendors, interns, board members, and any individual working for the Department of Management (DOM) or any Supported Entity.

This policy is deliberately broader than the Digital Asset Policy. It governs accessibility across Digital Content and Services, including but not limited to public Websites, so that documents, applications, and procured technology are covered.

3. Accessibility Requirement

3.1 Conformance Target

While Agencies are encouraged to adopt WCAG 2.2 at Level AA as the forward-looking direction for new and substantially revised content, all Digital Content and Services within scope must conform to the Web Content Accessibility Guidelines (WCAG) 2.1 at Level AA, which is the binding conformance target under this policy and aligns with Title II of the Americans with Disabilities Act. This requirement is consistent with the Revised Section 508 Standards. DOM and Supported Entities must meet this conformance target no later than April 26, 2027, consistent with the Title II compliance deadline applicable to the State.

3.2 Procured and Third-Party Technology

Before deployment, any procured, licensed, or third-party product or digital service must be accompanied by a current Accessibility Conformance Report (ACR) for that product: the vendor's completed report, based on the VPAT format, documenting how the product conforms to WCAG 2.1 Level AA (see: https://www.ada.gov/resources/2024-03-08-web-rule/) and, where applicable, the Revised Section 508 Standards. An ACR is evidence about a specific product, supplied by the vendor. Vendor self-assessments carry less weight than ACRs produced through independent, third-party evaluation. This reflects federal Section 508 procurement guidance, which treats a vendor's VPAT-based ACR as a self-disclosure supporting preliminary assessment and directs purchasers to independently validate vendor conformance claims (U.S. General Services Administration, Section508.gov: Understanding vendor claims in accessibility conformance reports, and accessibility in procurement guidance).

3.3 Public Accessibility Statement

Each Public-Facing Website and Web Application must publish an accessibility statement that affirms the agency's commitment to the conformance target in this policy and provides at least one method to report accessibility barriers.

3.4 Roles and Responsibilities

The enterprise accessibility function within the Department maintains this policy, the conformance target, and the supporting testing and quality-assurance methodology. Each agency subject to this policy must coordinate with DOM on conformance, remediation, and vendor accessibility documentation.

4. Exceptions

Enterprise Workers may request clarification or ask for an exception by submitting a new request through Service Desk Plus > New Incident.

5. Authority and Enforcement

Not following this policy may lead to disciplinary action, based on human resources (HR) policy and contractual authority.

Related Policy

Digital Asset Policy (ADMN.302.01.D) governs how websites are built and operated and sets the required Public-Facing Notices, including the accessibility statement that discloses the commitment established in this policy.

Document Owner:  DOM Director

DOM Director Approval Date:  September 1, 2026

Last Revision Date: September 1, 2026