Stark Universal Accessibility Framework (SUAF)

Author: Stark Lab, Inc.

Published: October 17, 2023

Last updated: October 17, 2023


Accessibility is a human right. And addressing the issue of accessibility in digital products requires the same level of rigor and prioritization as security and privacy. Since the traditional methods have left us with more than 96% of the internet still being inaccessible, we’re addressing the urgent need to do things differently by bringing the same type of operating model companies use to manage security and privacy compliance to the accessibility space.

We’ve developed the Stark Universal Accessibility Framework (SUAF) as the foundational framework of Stark’s Compliance Center. Drawing from industry data, our own customer research as well as the latest regulatory requirements, we’ve compiled and organized an initial set of 31 controls across 8 dimensions that capture requirements and guidelines to establish a proactive accessibility posture.

One of the core pillars of the Stark Universal Accessibility Framework (SUAF) is that progress is attainable for companies of all sizes. This framework is built on the principle of empowering organizations of all sizes to make meaningful, measurable progress in growing and strengthening their accessibility posture.


We arranged the SUAF dimensions in order of organizational complexity to execute, with controls covering basic actions listed first and more complex controls last. This should allow for easy mapping no matter which size or maturity level your company/organization is at.

Policy and Governance

📌 Start here because accessibility begins at the top. Buy-in from leadership is critical to make meaningful, measurable progress toward both inclusion and compliance; not having these things in place will slow germination of accessibility efforts within the organization.

Organizations need a clear plan to begin their accessibility posture. Leadership needs to communicate to its employees the importance of accessibility to the organization’s success.


  • An accessibility statement has been created.
  • Leadership has reviewed and approved the accessibility statement.
  • Investments towards accessibility efforts have been made.
  • ROI for accessibility efforts is measured and reviewed.
  • Business strategy defines an intentional approach to accessibility.

People and Culture

With buy-in from leadership, a culture of accessibility needs to be established with clearly defined owners. Additionally, external efforts around processes like hiring need to be defined.


  • Recruitment procedures to ensure accessibility are established.
  • Job descriptions are reviewed for diversity and inclusive practices.
  • An accessibility leader and/or office has been established.
  • Employee onboarding documentation highlights the importance of accessibility efforts within the company.
  • Accessibility needs of employees are measured and reviewed.
  • Established guidelines for how to accommodate employee accessibility needs.

Standards and Posture

Companies need a metric to work towards and establishing which standards the organization will adhere to marks the first clear step in being compliant.


  • Quality standards for accessibility that apply to products and services have been identified and documented.
  • Quality standards for accessibility that apply to products and services have been communicated.
  • Standards and procedures for creating inclusive communications are established.

Training and Awareness

📌 People are aware of the org’s efforts and which standards they intend to adhere to, so now it’s time to actually train employees to get them moving towards a strong accessibility posture.

Having a team well-versed in accessibility is a force multiplier for reaching the proactive level. Employees can more easily incorporate accessibility into their workflows throughout the organization when armed with the knowledge of how to do so.


  • Accessibility training is a part of the new employee onboarding process.
  • Accessibility training is required as part of continuous education of existing employees.

Tools and Procurement

📌 Now that your team has been trained on accessibility, it’s time to support them with the right tools to integrate accessibility into their daily workflows.

Arming your team with tools to meet accessibility requirements is critical. It speeds up their workflow and reduces errors. Additionally, procuring accessible tools also ensures internal and external users will get an inclusive experience.


  • Accessibility tooling has been set up as part of the product development process.
  • Latest accessibility standards are met by the vendor product as a requirement for procurement.

Product Development Life Cycle

Accessibility principles are injected into design, research, development and testing processes. To strategically apply the organization’s accessibility vision, these processes must be core to how employees make products.


  • Design practices and tests are in place for accessibility.
  • Development practices and tests are in place for accessibility.
  • QA includes manual testing with people that have disabilities.
  • Inclusive user research practices are established to ensure focus on people with disabilities
  • Controls are in place to restrict movement within the life cycle unless accessibility checks are met.

Marketing, Communications, and Content Creation

Outward facing comms accessibility is often overlooked, but no less critical than the accessibility of the actual product. Teams in this space need to have clear expectations and policy in place to avoid costly mistakes.


  • Policies, guidelines, and practices have been put into place for creating and publishing accessible content.
  • CMS controls are in place for requiring accessible support such as alt-text, captions, etc.
  • Accessible templates for presentations, documents, and marketing materials are available

Continuous Monitoring

To ensure that your product maintains the accessibility your user’s require, continuous monitoring is a must. It keeps you ahead of costly issues and provides clear evidence of your accessibility posture.


  • A solution for continuous monitoring of accessibility compliance across product development is in place.
  • Accessibility leadership is required to regularly review compliance and posture reports.
  • Accessibility issues are tracked in a ticketing/tracking system.
  • Accessibility issues are remediated within 30 days.
  • An accessibility bug bounty and employee whistleblower system is in place.

Maturity Levels

The goal of the Universal Accessibility Framework is to help companies get to a level of maturity where accessibility is monitored and managed proactively. A fully integrated, real-time, and business metrics-centered approach enables companies to build fully accessible products and services efficiently by default.

Rather than attempting to hit abstract levels of a sequential maturity model, it appears to be more effective and efficient to monitor the completion (or lack thereof) of specific controls and map progress to business outcomes such as culture, customer experience, and compliance (the 3 Cs). The levels below describe how completion of controls maps to specific maturity levels in the SUAF.

Once companies can centrally monitor and manage their accessibility posture in a modern, scalable way (just like they do with their security and privacy posture), they have a much more accurate view of their organizations compliance efforts.

Level 1 – Reactive (0-20%)

At this level, the organization has no formal accessibility program or policies. There’s no direction or vision from leadership and it’s likely little to no accessibility posture exists at all. Legal risks at this level are very high.

Level 2 – Active (21%-40%)

An accessibility program exists within the organization, but it’s not well-implemented. While leadership has a shared vision, accessibility efforts are likely scattered throughout teams. Legal risks at this level are high.

Level 3 – Proactive (41%-60%)

A shared vision and a well-implemented accessibility program are hallmarks of organizations at the Proactive level. More work needs to be done to fully integrate into culture and operations. Legal risks at this level are mild.

Level 4 – Advanced (61%-80%)

A fully-fledged accessibility program that runs from product to marketing that is aligned with the organization’s vision for its accessibility posture. Legal risks at this level are low.

Level 5 – Leader (81%-100%)

This organization sets the standard for others in their industry to follow. Innovation in the accessibility space happens naturally and employees brag about the accessibility efforts of the organization. Legal risks at this level are very low to non-existent.