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Retained roles
Every obligation on this site assumes somebody owns it. Most entities do not have that person, cannot get the headcount approved, and would be outbid by a bank if they tried. The function is held on retainer under a credentialed signature, at one of three tiers, for a fraction of a salary line.
Microsoft, Google, Meta, Amazon and the largest U.S. banks all maintain dedicated senior accessibility roles. These are organizations with the deepest legal departments in the country. Not one of them handed the function to a web vendor.
One global bank posted four separate vice-president-level accessibility roles during 2026 alone, covering independent verification testing, program process, testing organization leadership, and access strategy. That is a department, not a line item.
Microsoft's own posting for a senior accessibility compliance program manager describes the role as protecting the company's "license to operate," and notes that in some jurisdictions accessibility standards function as market-access controls, where failure carries legal, commercial and reputational consequences.
Employer language, not vendor language
Substitute federal financial assistance for market access and the sentence reads the same. Section 504 conformance is a condition of continuing to receive federal funding, whichever agency provides it. Title II program access is a condition of lawfully delivering services. It is the same license-to-operate argument, with a different regulator.
45 CFR Part 84 and 28 CFR Part 35
If an entity has no named owner for this function, that is not a leaner operating model than Microsoft's. It is an uncovered one. The obligation exists either way. The only variable is whether anyone is accountable for it.
28 CFR 35.107(a)
These are not adjacent requirements. Two independent employers wrote down the exact credentials they were recruiting for, and the practice already holds them.
A new hire would need a year to obtain what the practice can evidence on day one, with a certificate and an identifier for each.
Published postings, each carrying the employer's own disclosed range. Base salary only, before benefits, pension, recruitment cost and vacancy time. The technology postings note bonus and equity on top.
The comparison that matters is not between the two lists. It is that a town, district or agency recruiting for this function is drawing from the same small pool of credentialed people as the companies in the second list, at roughly half the compensation, with a longer approval cycle.
Retaining the function does not require winning that recruitment. It carries no benefits load, no pension liability, no vacancy period, and it arrives credentialed on the first day.
The obligation is continuous, so the role is built to be retained. When a procurement has to start with a defined project, such as a self-evaluation or a conformance test of the website, that project is scoped to carry straight into the role. What separates the tiers is not volume of work but how much authority the role carries and who it answers to.
Scope and tier are independent. Which statutes bind an organization determines the scope. How much ownership it needs determines the tier. A town may need Title II at Coordinator authority; a health system may need Title II, Section 504 and Title I at executive authority.
Every tier includes regulatory monitoring of the statutes and dockets that bind the organization, reported with the date each was checked. Inside a retained role, assessment work, conformance testing and reporting are part of the engagement rather than bought separately.
Three questions usually settle it, and none of them are about hours.
An organization can start at one tier and move. Most that begin at Tier 1 because a deadline is approaching find the work crosses divisions within two quarters, which is a Tier 2 conversation rather than a bigger Tier 1.
The tier names describe the function. The title carried inside an organization is that organization's own: where the house convention is Executive Director of Accessibility or Director of Accessibility, the role is held under that title while the engagement remains the same tier.
Pricing follows a scoping call, because the tier and the scope together determine it. An engagement at the executive tier costs less annually than every private-sector midpoint in the postings above, and lands alongside a mid-range public-sector role once benefits, pension and payroll taxes are added to base salary. It carries none of those, no recruitment cycle and no vacancy period, and it arrives credentialed.
Titles vary by entity. The obligation underneath them does not. Each of these can be retained in full, or as a defined slice of the function.
Also called: Title II Coordinator, ADA compliance officer
The designated role every public entity with 50 or more employees is required to have. The entity names its designee. The practice performs the coordinator function under that designation, publishes the designee's contact details, administers the grievance procedure and keeps the record.
28 CFR 35.107(a)
Also called: 504 Coordinator, responsible employee
The person an organization with fifteen or more employees designates to coordinate its Section 504 compliance once federal 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 and 84.84 (HHS)
Also called: accommodation program manager, EEO accessibility lead
The interactive process, run as a program rather than a series of one-off decisions. Public postings for this role emphasize case handling, documentation and the interaction between the ADA and leave law.
Title I, Title II and Section 504
Also called: DIO, digital accessibility lead, ADA compliance specialist
The agency's single point of accountability for digital accessibility, and its liaison to central technology and disability offices. This is where manual conformance testing and procurement language meet.
WCAG 2.1 AA and Section 508
Also called: head of accessibility, accessibility program director
Program-level ownership across both halves of the obligation: the technical standard and the organizational practice, with the authority to set policy rather than only report findings.
Program governance
Also called: Executive Director of Accessibility, Director of Accessibility, head of accessibility
Executive accountability without an executive hire. In the W3C resourcing table, only three roles are marked as contributing across all seven maturity dimensions: the Chief Accessibility Officer, the role W3C lists as accessibility consultant or advisor, and employees with disabilities.
W3C Accessibility Maturity Model
When a coordinator leaves, or the seat was never filled, requests keep arriving and the record still has to be kept. For a nonprofit, a college or a public agency, the practice steps in as the outsourced ADA/504 accessibility team, for the months a search takes or for good.
A nonprofit that takes federal money, even through a city or a state, is covered by Section 504 whether or not anyone there is assigned to it. The same team carries the work for them.
The organization names its designee. The practice performs the coordinator function under that designation, so the work doesn't stop while the seat is open, and whoever is hired later inherits a working process instead of a backlog.
While the search runs
Requests keep moving, each one gets a written answer, and the file stays complete from the first day. At handover, the new coordinator receives the open files, the closed ones and the written procedures behind them.
For good
The function stays with the practice at one of the three tiers above, under the designee the organization names. There's no vacancy, no turnover and one accountable signature on the record.
Acting as the organization's ADA and Section 504 compliance officer day to day, under the designee it names.
Rewriting the accommodation, grievance, effective communication and service animal procedures, and the public notice that points to them.
Leading the work: an inventory of sites, applications and documents, manual conformance testing, and accessibility terms in contracts.
Front-line and program staff, managers and faculty, delivered as part of the role rather than bought separately.
A survey of facilities and programs, with a transition plan that schedules each fix and names who owns it.
A review of what was asked, what was decided and what the record can show, with any gaps closed going forward.
The W3C Accessibility Maturity Model, published as a W3C Group Note in November 2025, grades an organization across seven dimensions on four levels. The levels are cumulative: reaching one requires holding the one below it.
Maturity assessment answers a different question than a conformance audit. An audit tells you whether one site passes today. A maturity assessment tells you whether your organization can keep it passing.
A maturity assessment produces a level for each dimension, the evidence behind it, and a corrective action plan with owners and dates. Scoped to the whole organization or to a single division.
Executive sponsorship, funding, written policy, and an exception process with real approval.
Accessibility built into design, development, testing and release rather than audited afterward.
Templates, documents, multimedia and public messaging that reach everyone equally.
Role-based training, skills assessment, and a plan for the gaps that assessment finds.
Hiring, job descriptions, and the lived experience of employees with disabilities informing decisions.
Solicitation and contract language, vendor evaluation, and accessibility as a monitored condition.
Accommodation process for staff, and a working help path for the public.
A 30-minute call establishes which role your entity is missing, what it would own, and what retaining it instead of hiring it would involve.
Running an ADA program without a dedicated team: what stays inside, what the practice performs, and how to measure where the program stands.
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