The Accessibility Clause
Northbridge Council is replacing its public benefits portal. The contract is fixed price at £2.8M with a six-month delivery window. The requirements baseline was signed four weeks ago; marketing has since specified an animated onboarding journey and a personalized dashboard. During a late legal review, the council's accessibility lead identifies that the portal must meet WCAG 2.2 AA, including keyboard-only navigation and reduced-motion support, because the service is public and regulated. The baseline contains only a generic accessible design statement. The supplier says the animation and accessibility work together add 19 days and £180k, and that the fixed price cannot absorb it. The business owner wants to keep the animation, remove the personalized dashboard, and deal with accessibility in phase 2. The delivery manager has no traceability from the legal clause to test cases.
1. How should the accessibility requirement be classified, and what is wrong with the business owner's proposal?
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The accessibility requirement is mandatory and regulatory, not a desirable quality attribute that can be deferred. The legal review identifies a specific obligation for a public service, and WCAG 2.2 AA includes keyboard-only navigation and reduced-motion support. Deferring it to phase 2 would mean launching a service that does not meet the stated legal standard.
The business owner's proposal has three flaws. First, it treats accessibility as separable from the animated journey, but reduced-motion support is part of that journey; keeping the animation without it may increase the accessibility defect rather than reduce it. Second, removing the personalized dashboard may be a sensible descope, but it does not offset the mandatory accessibility work. Third, phase 2 is not a valid disposition for a launch requirement unless the council accepts and records the legal risk, which the accessibility lead is unlikely to do.
The requirement should be recorded as mandatory, linked to the legal clause, and assessed through change control. The viable conversation is about which discretionary scope, such as the dashboard or parts of the animation, is removed to fund and schedule the mandatory work - not whether the mandatory work happens.
2. What requirements management actions should the delivery manager complete before the change is approved?
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The delivery manager should rebuild the requirements trail before approval, because the current baseline cannot show what will be tested or paid for. The actions are:
- add the legal clause and the WCAG 2.2 AA criteria to the requirements repository, with a unique identifier and source;
- write testable acceptance criteria for keyboard-only navigation, focus order, reduced-motion behavior, and the specific user journeys affected;
- link each criterion to design components, test cases, and the supplier's statement of work;
- raise a change request that separates mandatory accessibility from discretionary animation and dashboard scope;
- obtain written confirmation from the accessibility lead that the criteria are sufficient, and from the business owner that the descope is acceptable;
- update the contract change note with the 19-day and £180k impact, and record which party bears the cost.
The reasoning is that the dispute is not only about time and money; it is about an untraceable requirement entering late. Without the links, the council cannot verify completion, and the supplier can argue that the work was never in scope. Traceability converts a late legal finding into a controlled baseline change.