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Managing Third-Party Accessibility Risks in Your Supply Chain

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Wagner Matthias

Uploaded at

November 4, 2023

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Managing Third-Party Accessibility Risks in Your Supply Chain

Introduction

In today’s digital-first business landscape, accessibility isn’t just a “nice-to-have”—it’s a business imperative. While many organizations work diligently to make their own websites, applications, and digital products accessible, third-party providers can introduce unexpected accessibility risks within the broader digital supply chain.

As companies become more reliant on integrated services—such as CRMs, e-commerce platforms, analytics tools, widgets, and content plug-ins—the chance of inheriting accessibility issues from vendors increases significantly. If these tools aren’t designed with inclusivity in mind, your organization may unknowingly be creating barriers for users with disabilities.

Managing third-party accessibility risks is critical not only for inclusive user experiences but also for aligning with global standards like WCAG, ADA (Americans with Disabilities Act), EAA (European Accessibility Act), and EN 301 549. This article will explore how organizations can identify, mitigate, and manage the accessibility risks that come with utilizing third-party services—and how platforms like allyWay can support these efforts intelligently and efficiently.


Why Third-Party Accessibility Risks Matter

Third-party digital tools and integrations can enrich your digital landscape, but they come with their own codebases and user interfaces. If you embed a third-party script or plugin that hasn’t been optimized for accessibility, the usability of your digital environment may suffer.

This is particularly problematic when:

  • Users rely on assistive technologies like screen readers or keyboard navigation
  • Poor contrast or confusing UI is introduced from a third-party widget
  • Third-party updates affect previously accessible code
  • Accessibility defects are discovered but are outside your immediate control

Without proactive strategies, these risks can compromise your own accessibility goals, introduce legal exposure, and alienate individuals who depend on accessible services.


Understanding the broader legal and regulatory landscape helps identify what’s at stake when accessibility isn’t prioritized—whether internally or across your vendors.

Key Standards That Matter:

✓ WCAG (Web Content Accessibility Guidelines)

Developed by the W3C, WCAG is the global benchmark for digital accessibility. Versions 2.1 and now 2.2 lay out success criteria across four principles: Perceivable, Operable, Understandable, and Robust (POUR). While not law, WCAG is referenced by most legislation worldwide.

✓ ADA (Americans with Disabilities Act)

While the ADA was originally created for physical spaces, courts in the United States have interpreted it to include digital properties. ADA lawsuits relating to inaccessible websites and tools have seen a significant uptick in recent years.

✓ EAA (European Accessibility Act)

The EAA harmonizes accessibility rules across EU member states. It applies to a variety of products and services, including websites, e-commerce, banking, and more, with full enforcement expected from 2025 onward.

✓ EN 301 549

This European standard outlines accessibility requirements for ICT (Information and Communications Technology), including software, websites, and mobile applications. It complements the EAA.

Your organization doesn’t operate in isolation—if your vendors violate these principles, they can inadvertently put your business at risk.


Common Accessibility Pitfalls from Third-Parties

Here are some common third-party components that may compromise accessibility:

Third-Party Type Common Issues Introduced Potential Impact
Chatbots Not keyboard accessible, missing ARIA labels Users with disabilities can’t engage
Video players No captions, inaccessible controls Hearing and mobility impairments excluded
Social media plug-ins Poor contrast, unlabeled icons Screen readers can't interpret them
E-commerce checkout tools Inadequate focus management, confusing tab orders Lost sales from frustrated users
CRM pop-ups or widgets Doesn’t support screen readers, can’t close with keyboard Traps users, increases abandonment

Best Practices for Managing Third-Party Accessibility Risks

Effectively managing third-party accessibility involves a proactive mix of evaluation, contracts, communication, and ongoing audits. Here's how to reduce risk across your digital ecosystem.

1. Conduct Accessibility Vetting During Procurement

Before integrating any third-party service or software, assess its accessibility posture by:

  • Requesting a VPAT (Voluntary Product Accessibility Template)
  • Reviewing WCAG conformance claims
  • Conducting manual and automated testing
  • Evaluating available accessibility documentation

Red Flag: No VPAT provided, vague accessibility documentation, or unwillingness to share testing results.

2. Insert Accessibility Requirements into Vendor Contracts

Aligning expectations contractually helps hold vendors accountable. Contracts should include:

  • Accessibility conformance commitments (aligned to WCAG 2.1 Level AA or relevant regulation)
  • Responsibilities for updates and notifications
  • Remediation timelines for any future accessibility issues

You may also include provisions for termination if accessibility standards are continuously violated.

3. Perform Regular Accessibility Testing

Even if a component was accessible at launch, updates can unintentionally break functionality. Build periodic accessibility testing cycles, covering both your own code and third-party integrations.

Useful testing tools:

  • Manual keyboard navigation audit
  • Screen reader walkthroughs (e.g., NVDA, VoiceOver)
  • Automated testing tools (including AI-powered platforms like allyWay)

How allyWay Helps Support Accessibility Across the Supply Chain

When managing third-party accessibility, you need tools that scale with complexity. allyWay simplifies the process with intelligent, multilingual, and highly configurable support features.

Here’s how allyWay empowers your accessibility journey:

Feature Category allyWay Capabilities
✓ AI-Powered Audits Identify areas of non-conformance with actionable insights
✓ Real-Time Adjustments Over 30 accessibility features that improve UX dynamically
✓ Accessibility Profiles 5 tailored profiles (visual, motor, cognitive, etc.)
✓ Language Coverage Supports over 35 languages for global accessibility inclusion
✓ Integration Support Designed for third-party-heavy web environments
✓ Automated Detection Finds and alerts you to issues introduced by external content

allyWay is not a legal compliance tool, but it does ease the path toward better accessibility practices. It reduces friction, saves time, and improves user experience—especially when dealing with external code you can't completely control.


Practical Steps to Implement an Accessibility Risk Framework

To operationalize your efforts, build a clear accessibility risk framework using this five-step approach:

Step 1: Map Your Digital Supply Chain

Make a list of all third-party tools, APIs, libraries, and plugins you use that interact with your website or application.

Step 2: Score Accessibility Risk

Assign each third-party integration a risk score based on:

  • Role in critical user flows
  • Frequency of use
  • Accessibility documentation/past issues

Step 3: Engage Vendors

Initiate conversations to confirm their accessibility roadmap. Encourage transparency and offer collaboration.

Step 4: Use allyWay for Continuous Monitoring

Incorporate platforms like allyWay to monitor your environment continuously and easily identify changes or issues introduced by third-parties.

Step 5: Update Internal Policies

Ensure your procurement and IT teams are trained to evaluate accessibility during software purchasing and onboarding.


Accessibility Checklist for Third-Party Evaluations

This checklist will help you evaluate any new digital vendor:

  1. ✓ Do they provide a VPAT or accessibility statement?
  2. ✓ Have they tested their product against WCAG 2.1 or EN 301 549?
  3. ✓ Is the interface screen-reader compatible?
  4. ✓ Can all functions be completed with a keyboard?
  5. ✓ Is color contrast sufficient?
  6. ✓ Do they offer regular product updates with accessibility improvements?
  7. ✓ Are they willing to fix accessibility issues within agreed timelines?
  8. ✓ Have you used allyWay to scan the tool in your environment?

If the answer is “no” to 3 or more, consider revisiting your vendor choices.


FAQ: Managing Accessibility in the Digital Supply Chain

Q: Why are third-party tools a risk for digital accessibility?
A: You don’t control third-party code, updates, or design practices. If these tools lack accessibility, they create barriers for users and increase potential legal exposure.

Q: Can I make third-party integrations accessible myself?
A: Sometimes. You can use overlays and accessibility toolkits to improve UX, but it's best when the vendor builds accessibility in from the ground up.

Q: What role does allyWay play in this process?
A: allyWay acts as an intelligent support system. It improves accessibility, assists in identifying potential issues, and reduces the time it takes to manage compliance-ready environments.

Q: Does using allyWay mean my site is compliant with the ADA or EAA?
A: No tool can guarantee compliance. However, allyWay supports your journey toward improved accessibility and helps meet best practices aligned with global standards.

Q: Do accessibility risks from third-party apps often lead to lawsuits?
A: Yes. ADA-related lawsuits that cite inaccessible e-commerce tools, video content, or login systems are increasingly common.


Conclusion: Take Charge of Third-Party Accessibility with allyWay

Accessibility is no longer optional—it’s a standard by which modern digital experiences are judged. As organizations proliferate their use of third-party applications and integrations, the need to manage accessibility risks across the digital supply chain becomes more urgent.

By auditing your tools, engaging with vendors, and using smart technology like allyWay, you can significantly reduce barriers and improve experiences for all users—including those with disabilities.

allyWay is a

This blog is for informational purposes only and does not constitute legal advice. We make no representations or warranties regarding the accuracy, completeness, or applicability of the content. Accessibility requirements may vary by jurisdiction and use case. To the extent permitted by law, we disclaim any liability arising from reliance on the information provided. 

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