EAA reality check, Part 4: 2026 strategic action plan

If your team is still treating accessibility as a periodic clean-up activity, 2026 is the year to change operating model. The EAA environment requires recurring controls, clear ownership, and evidence you can produce quickly.

90-Day Priority Plan

1) Establish legal and technical baseline

  • confirm which products and services are in EAA scope
  • define conformance target (typically WCAG 2.2 AA)
  • assign accountable owners across product, engineering, QA, and legal

2) Stabilize critical user journeys

Start with journeys regulators and users feel first: authentication, purchase/checkout, account recovery, and support contact paths.

  • run manual keyboard and screen-reader passes
  • fix blocking issues on those flows first
  • track remaining issues with dated remediation commitments

3) Build evidence and governance

  • maintain a living accessibility statement
  • create a release-linked remediation log
  • implement regression checks in CI for recurring failure classes
  • define incident response for accessibility complaints

What Good Looks Like By End Of Quarter

You should be able to answer, within hours, not weeks:

  • Which issues are open and who owns them?
  • What was fixed in the last two releases?
  • What evidence supports your conformance claims?
  • What is your timeline for remaining critical issues?

Claim-level Citation Notes