6. Procurement of digital products, services, and platforms policy

Staff who manage contracts and procure new digital systems and services must make sure that suppliers comply with their obligations under the current legislation; they must also actively manage any identified accessibility limitations until they are resolved. All contracts relating to digital systems and content must include appropriate Digital Accessibility Statements and clauses.  

In addition, staff involved in procurement of digital products and services must: 

  1. Specify WCAG 2.2 AA as the required standard in procurement documents. In exceptional circumstances this may be made non-mandatory (see 6 below). 

  1. Request evidence of product compliance from the supplier (such as a formal WCAG conformance report, VPAT (Voluntary Product Accessibility Template) report or equivalent) and give it a high weighting in the scoring model. This may still have limited impact, where the accessibility requirement is one of many others. 

  1. To give further weight to the accessibility criterion, under ‘Supplier suitability’ require evidence of the supplier’s commitment to developing accessible products – e.g., published accessibility statements, development processes which ensure accessibility, testing, roadmaps, training, etc.  

  1. Before signing contracts, agree with the supplier how accessibility requests will be handled in future to avoid being charged extra fees to make the product accessible after the initial purchase.  

  1. Evaluate the product against the required standard using the evidence provided by the bidder or UCL tests where the evidence is insufficient.  

  1. If a preferred bidder’s product does not fully meet the accessibility criteria, then an accessibility roadmap must be produced. This is a templated form which summarises the timeline for remediating accessibility issues and identifying mitigations or workarounds that can be provided in the meantime.  

  1. The accessibility roadmap must be reviewed by an appropriate authority outside the project (see Roles and Responsibilities). They weigh up the potential user impact, proposed mitigations, and consider the availability of alternative products. They may approve or not; approval may be subject to specific mitigations being implemented as a prerequisite to purchase.  

  1. Publish a UCL Accessibility Statement for the product or service where it can be found easily by users. The Statement should provide information helpful to users with accessibility needs - including accessibility features, known issues/non-compliances, improvement plans and a support contact. The Statement must be reviewed when there is a substantial change to the product or service. 

It is important to note that the accessibility requirements outlined above include both front and back-end interfaces for the benefit of both UCL staff and end users using procured digital products, services, and platforms. 

Advice and support for scrutinising supplier feedback and evidence, testing and writing accessibility statements are available from the Digital Accessibility team: digitalaccessibility@ucl.ac.uk

More information can be found in UCL's Responsible Procurement guidance.

The Accessibility Passport is a collaboration between the University of Westminster, University College London (UCL), RNIB (Royal National Institute of Blind People), and the Global Disability Innovation Hub. The first outputs are procurement guides and templates. These are intended to ensure that we specify the same accessibility requirements in contracts, ask the same questions of suppliers when procuring new digital systems and measure their responses consistently across the sector.

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