Accessibility risk framework at a large loyalty program

Product teams were trying to achieve a clean automated accessibility scan. The scanners surfaced issues large and small, so teams spent substantial time pursuing every finding while the compliance deadline approached. A perfect technical score had become the goal, even though it was not the same as addressing the highest-risk barriers for users.

The organization had multiple digital products, limited remediation capacity, and a regulatory deadline with potential financial consequences. The new model had to be understandable to product teams, legal and compliance partners, and regulators.

I reframed the problem around accessibility risk and co-developed a five-star framework with legal and compliance partners and regulators.

Three stars became the working compliance threshold: no critical or high-severity findings. Higher levels captured continued maturity rather than blocking the deadline on every lower-severity scanner result. The framework gave teams a shared way to assess a product, prioritize remediation, and report progress.

The framework separated compliance risk from the false goal of a perfect automated scan. It focused remediation resources on the highest-severity barriers and helped the organization work toward the compliance deadline without treating every scanner finding as equal.

A clean automated scan is not the same as an accessible product or a defensible risk posture. Severity and user impact should drive remediation.