Enterprise Digital Accessibility Policy Exception Request

Learn about exception requests to the Enterprise Digital Accessibility Policy, types of exceptions that will be considered, and documentation you will need to include with your submission

Overview

The Enterprise Digital Accessibility Policy drives ongoing efforts to make Commonwealth executive department Digital Assets accessible and usable as required by state and federal laws. Accordingly, the Commonwealth has adopted the Web Content Accessibility Guidelines (WCAG) version 2.1 level A and AA success criteria as the minimum technical accessibility standard for Commonwealth Digital Assets.

While conformance with the Digital Accessibility Standards is the ultimate goal, there may be specific instances where additional time is needed to bring a Digital Asset into compliance, or where full conformance may not be possible due to technical limitations. The Executive Office of Technology Services and Security (EOTSS) has created this exception request process to document such instances and to support the development of Mitigation Plans by respective executive department agencies. 

What is an Exception Request?

An exception request is a request to temporarily maintain or deploy a Digital Asset that is not fully compliant with the Commonwealth's Digital Accessibility Standards as defined in the Enterprise Digital Accessibility Policy. Note that a policy exception does not inherently remove an agency’s legal liability. An exception granted through this process simply means that an agency has chosen to defer enforcement of a policy requirement in a specific instance. It does not constitute a waiver of legal obligation established by state and federal laws. 

Basis for Exception Request

Exceptions to the Enterprise Digital Accessibility Policy will be considered in the following limited circumstances:

  • Remediation in Progress. Additional time is needed to bring the Digital Asset into compliance with the Digital Accessibility Standards.
  • Technical limitations. The Digital Asset cannot be made fully compliant due to technical limitations. Accessibility Violations are entrenched within the design or underlying code of the application requiring a total redesign or rebuild. Or full compliance  would cause a fundamental alteration of the essential nature of the asset.
  • Minimal Impact. The noncompliance will have a minimal impact on users such that it would not affect the ability of individuals with disabilities to use the agency’s Digital Asset to access the same information, engage in the same interactions, conduct the same transactions, and participate in or benefit from the same services, programs, and activities as individuals without disabilities.
  • Archived Web Content. The Digital Asset (1) was created before April 24, 2026; (2) is retained exclusively for reference, research, or recordkeeping; (3) is not altered or updated after archiving; and (4) Is organized and stored in a dedicated area clearly identified as being archived.
  • Preexisting Conventional Electronic Document Library. A collection of conventional electronic documents that were (1) created before April 24, 2026, and (2) are not currently used to apply for, gain access to, or participate in Commonwealth services, programs, or activities. 

Scope

The exceptions request process applies to internal and external facing Digital Assets currently in use or scheduled for deployment across Executive Department agencies and offices. Digital Assets include those developed internally or delivered by a third-party. 

However, exception requests will not be considered for the following Digital Assets. Such assets are expected to be  fully compliant.

  • Mass.gov content using templates in the EOTSS content management system (CMS)
  • Social media content
  • SharePoint sites
  • Multimedia
  • Individual electronic documents (e.g., MS Word, PowerPoint, Excel, PDF, PDF forms)
  • Emails, newsletters and other forms of digital communication

What Information Do I Need to Include in my Exception Request?

Be prepared to submit the following information with your Exception Request:

  • Commonwealth agency information including Secretariat and name of requester, project owner or business owner.
  • Digital Asset Information including number of users, its function and/or connection to Commonwealth programs, services, or activities, and/or its use by Commonwealth employees.  
  • Noncompliance information including how the agency became aware of the noncompliance, any digital accessibility testing results, any constituent or employee feedback, and the basis of your exception request.
  • If the Digital Asset is a third-party digital product, provide contract execution and expiration dates, a current Accessibility Conformance Report, any Vendor Digital Accessibility Roadmaps, and the name of the vendor’s digital accessibility point of contact.
  • A Mitigation Plan that includes accessibility support measures, Digital Asset remediation and/or replacement plans, , and names of persons responsible for plan execution.
  • The name of the agency's respective ADA Coordinator and acknowledgment that they were made aware of the Digital Asset's noncompliance and consulted on the development of the Mitigation Plan.

Submit an Exception Request

Online form coming soon. 

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