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Accessibility · Governance

Reaching EAA compliance from zero governance

How I took the candidate-facing website of a UK recruitment agency serving EU markets, from no accessibility knowledge to full European Accessibility Act compliance - building the people, process, and proof from scratch.

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  • Hybrid Audit
  • Developer Remediation
  • Sign-off Governance
  • Culture & Upskilling

Section 01 — The Baseline

Starting from absolute zero.

A UK-based recruitment agency serving EU markets needed its primary corporate website, the main place candidates browse job listings and apply, to meet the European Accessibility Act. The starting point was honest and difficult: zero internal accessibility knowledge, no leadership or governance frameworks, and a site built and maintained entirely by an external development agency. With no in-house expertise, I brought in specialised tooling and external eyes to evaluate the site against European standards (EN 301 549 / WCAG 2.2 AA). Early discovery surfaced critical, candidate-facing barriers: job application forms that couldn't be completed by keyboard, and colour-contrast issues that made job descriptions hard to read for visually impaired users.

"You can't manage what you can't measure, so the first job was simply to see clearly."

— The starting principle

Maturity

11 - Zero governance

Starting maturity

1 = No oversight · 5 = Embedded governance

12345
100%candidate-facing

website touchpoints in scope

EN 301 549WCAG 2.2 AA

the compliance benchmark

Zeroto start

internal knowledge or governance

Section 02 — Hybrid Auditing & Remediation

Automation finds it. People prove it.

Because the website was built and maintained by an external agency, fixing the core code meant a direct, structured partnership. I was clear from the start that automation alone could never guarantee a genuinely good experience - so I mandated a hybrid approach and shared findings straight with the developers.

Tooling integration

Crawl first, train later.

We deployed automated accessibility scanning to quickly crawl the website and catalogue technical errors e.g. missing image alt-text, broken form labels, contrast failures - without needing to train internal staff from scratch.

Automated + manual testing

A required hybrid suite.

We mandated that the developers pair automated scanning with a comprehensive set of manual tests e.g. keyboard-only navigation and screen-reader walkthroughs - to catch the complex, interactive bugs automation always misses.

Core site remediation

Fix the structure, not the symptoms.

Findings went directly to the developers, who were tasked with fixing structural layout flaws, form field labels, and visible focus states across every core recruitment page.

"Automated scans catch the obvious. But real people, using keyboards, and screen readers catch what actually breaks the journey."

Section 03 — Data-Driven Monitoring

The Accessibility Score.

To keep accessibility top-of-mind across distinct business units, I introduced monthly performance tracking driven by our automated monitoring tools. The tools generate an objective, site-wide accessibility health score - a single number everyone could rally around.

Site-wide accessibility score

96/100

Trending up

Monthly charts mapping the score were shared directly within the IT and Marketing departments. That cross-departmental transparency let both technical and creative teams see exactly how new code changes or marketing content moved the site's overall score.

Section 04 — Culture, Advocacy & DEI

Move past compliance into mindset.

Rules alone don't make a place inclusive. To move past rigid compliance, we built internal advocacy channels that grew an inclusive mindset from the ground up and gave accessibility a permanent seat at the leadership table.

Step 1 of 3

Step 1

Accessibility Champions Network

We created a voluntary, cross-departmental 'Champions Network' - a space for interested employees to advocate for accessible practices in their day-to-day work, no job title required.

Section 05 — Leadership & Sign-off Governance

No green light without a sign-off.

To fix the total lack of initial leadership, we established a strict gateway process so the website could never quietly regress into non-compliance. Accessibility became a non-negotiable metric for deployment. In short, nothing goes live without formal sign-off.

Gate 01

Design Phase Gate

External design mockups must pass contrast and layout checks before they're approved for development. Inclusive thinking starts at the canvas, not the codebase.

Fails contrast or layout? It doesn't reach the developers.

Assigned ownership

We appointed the Head of Digital Product / Content as the internal owner legally accountable for the website's compliance status, turning shared responsibility into a single, clear line of accountability.

Section 06 — Statements & Complaint Pathways

Transparent by design.

The European Accessibility Act mandates honest, transparent disclosure. So we added clear communication channels directly to the live website, telling candidates exactly where things stand and giving them an easy way to flag problems.

"Compliance isn't a badge you hide. It's a conversation you keep open with the people you serve."

Accessibility Statement in the site footer
PublishedAccessibility Statement in the site footer
Accessible web form + dedicated support email
2 routesAccessible web form + dedicated support email
Feedback routed straight to the product owner
1 ownerFeedback routed straight to the product owner

The statement

We published a legally compliant Accessibility Statement in the footer clearly outlining the current state of compliance, known technical gaps, and the timeline for upcoming developer fixes.

The feedback loop

An accessible web form and a dedicated support email mean that if any candidate hits a digital wall while applying for a job, they can report it in seconds.

Straight to the owner

Every report routes directly to the internal product owner, so barriers are triaged by someone accountable and not lost in a shared inbox.

Section 07 — Role-Based Upskilling

Train the people who touch the site.

Instead of trying to teach the whole company about web accessibility, we localised training to the people who actually create, publish, and support the website - practical skills, right where they're needed.

Content Creators & Marketers

The people publishing day-to-day job content and campaigns.

  • Uploading job descriptions and blog posts with proper heading structure
  • Writing meaningful alternative text for imagery
  • Keeping new marketing content from lowering the score

Operational Teams

The people responsible for getting pages live.

  • Running the automated testing tools before publishing
  • Reading and acting on the monthly Accessibility Score
  • Catching regressions before they reach candidates

Support Staff

The people closest to candidate feedback.

  • Logging candidate accessibility feedback efficiently
  • Funnelling technical bugs to the external dev team
  • Closing the loop so reported barriers get fixed

The Bottom Line

From no oversight to built-in accountability.

Starting with zero knowledge and zero governance, I built accessibility into the recruitment agency's website from the ground up. Hybrid audits to see clearly, a monthly score to stay honest, sign-off gates to prevent regression, a Champions Network to grow culture, transparent statements to stay accountable, and role-based training to make it stick. EAA compliance stopped being a one-off project and became the way the website is built.

Pull-stat

From zero governance to EAA compliance - a 96/100 accessibility score, enforced by sign-off gates and owned by a single accountable lead.

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Accessibility · Governance · EAA Compliance

derekkelly@blokshok.co.uk