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Program accessibility · Retained roles
Most organizations don't have an accessibility department, and most never will. The law doesn't ask for one. It asks for a named person, a short set of documents, a process that works when a request arrives, and a record that shows it did.
Here's what Title II and Section 504 require of the people you already have, what can be performed outside the organization, and how to tell where the program stands today.
No accessibility regulation requires a team. Several require a name.
Title II requires at least one designated employee to coordinate compliance and investigate complaints, with that employee's name, office address and telephone number available to anyone who asks. The same threshold requires a grievance procedure that is adopted and published.
28 CFR 35.107(a) and (b)
Under the HHS and Education Department Section 504 rules, an organization with fifteen or more employees designates at least one person to coordinate compliance and adopts a grievance procedure once either department's money reaches its programs, even through a city, a state or another nonprofit. Each funding agency writes its own Section 504 rule, so the one that funds you sets the exact terms.
45 CFR 84.7; 34 CFR 104.7
No designation, grievance or staffing requirement at any size. The exposure is private litigation, and a demand letter response starts with someone who owns the program.
28 CFR Part 36
Title II says employee. The HHS rule says person. Read the rule that binds you before deciding who is named.
The name carries legal weight. Most of the work behind it doesn't have to be done by the person named.
28 CFR 35.150(a)(3) and (d)(3)
28 CFR 35.105, 35.107(b) and 35.150(d)
The practice performs this work under your designation. It doesn't replace the designee or make the determinations the regulation reserves to the head of the entity.
The W3C Accessibility Maturity Model measures an organization across seven dimensions and four levels: Inactive, Launch, Integrate and Optimize. It was published as a W3C Group Note on November 4, 2025, by the Accessible Platform Architectures Working Group.
It's a benchmark, not a legal standard. No regulation requires it, and the Note is endorsed by the working group that wrote it rather than by W3C as a whole. Its four level names match the Policy-Driven Adoption for Accessibility model that some state and local governments already use.
Without a dedicated team, the practice starts with two dimensions, because both cost little and change what everyone else does: Oversight and Culture, where the program gets an owner, a policy and a budget line, and Procurement, where accessibility requirements go into contracts so the next system arrives conformant. The practice's Accessibility Maturity Assessment scores each dimension with the evidence behind it. Read the W3C Accessibility Maturity Model on w3.org, or download W3C's experimental assessment spreadsheet (Excel, 19 MB).
Each of these has a place. None of them is a designee, a grievance procedure or a record.
Automated testing finds some of the issues a page can have and none of the process failures. It can't tell whether a request was answered, a complaint was investigated or a screen reader user finished the form.
An overlay works on the page. It doesn't answer a request, publish a grievance procedure or keep a record.
No U.S. law requires a website accessibility statement. An accurate one is worth publishing, but it doesn't discharge any duty on its own.
Each step produces something the next one depends on, and each one leaves a document behind.
No regulation requires a team. Title II requires a designated employee at public entities with 50 or more employees, and the HHS Section 504 rule requires a designated person at recipients with fifteen or more. Title III sets no staffing requirement.
28 CFR 35.107(a) and 45 CFR 84.7(a)
The work can. Under Title II the designation must go to an employee, so the entity names its designee and the practice performs the coordinator function under that designation.
28 CFR 35.107(a)
No. A scanner can't establish conformance to WCAG 2.1 AA on its own, and a working request and complaint process is part of the obligation in its own right.
28 CFR 35.107 and 35.200
Not directly. It's a W3C Group Note, not a regulation. It shows where the program stands and what to fix next, while compliance still turns on the rule that binds you.
W3C Group Note, November 2025
A 30-minute call establishes which rule binds you, who is named, which documents exist, and what it would take to run the program without adding headcount.
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