Legal Accessibility Compliance

---
name: legal-accessibility-compliance
description: Map legal accessibility obligations across markets — ADA, Section 508, EAA, UK and Canadian law — with WCAG level, exposure, remediation and a draft accessibility statement. Use when the user sells in several countries and asks which accessibility laws apply in each. Not for one law or the audit; see /compliance-ada-wcag, /compliance-eaa-en301549 or /accessibility-scope.
metadata:
  argument-hint: "[project] [--skip-checks]"
  workflow: legal
  phase: 3
  artifact: 03-comply.md
---

# Accessibility Compliance

Assess legal accessibility requirements for "$ARGUMENTS". Identify applicable accessibility laws, determine WCAG conformance requirements, assess current compliance, and create a remediation plan.

See also `/accessibility-scope` for the audit itself, or `/compliance-ada-wcag` for a single-market (ADA) legal risk assessment, instead of this multi-market legal map.

> **Note:** AI-generated legal content does not constitute legal advice. Consult a qualified attorney.

**Arguments.** `$ARGUMENTS` may contain the project name and optional flags. Take the first token as `<project>` and treat `--skip-checks` as a flag; never include flags in file paths. All paths below use `<project>`. If `--skip-checks` is present, skip the prerequisite check and, **before writing any artifact**, append one line to `.singularskills/log.jsonl`: `{"ts":"<ISO timestamp>","skill":"legal-accessibility-compliance","workflow":"legal","phase":3,"project":"<project>","event":"skipped","artifact":"03-comply.md","note":"<reason or \"none given\">"}`.

## Prerequisites

**Part of a workflow.** This skill is phase 3 (Comply) of the Legal Lifecycle workflow (`legal`); cross-domain workflows run it too. First check `.singularskills/log.jsonl` for an open run for this project: a `run-started` line with `"project":"<project>"` and no later `run-finished` line for the same `workflow` and `project`. If one exists, the conductor is running you: continue here. Otherwise, if the user asked to start, run, continue or resume a process or workflow rather than this one step, do not continue here: invoke the `workflow` skill with the workflow the user asked for, or `legal` when they named none, followed by `<project>`; it runs this phase in order, asks before it writes and records the run. Otherwise continue here: a later phase runs on its own, behind its gate.

Run this skill's gate before writing: `sh <this skill's folder>/scripts/gate.sh <project> <project root>`, where `<project root>` is the folder that contains `.singularskills/` (use `.` when you are already there). If it exits non-zero, stop and tell the user what it printed, unless `--skip-checks` was given (see Arguments). On a refusal, before you stop, append this line to `.singularskills/log.jsonl` (create the folder and file if missing): `{"ts":"<ISO timestamp>","skill":"legal-accessibility-compliance","workflow":"legal","phase":3,"project":"<project>","event":"refused","artifact":"03-comply.md","note":"<what the gate printed>"}`. Once the gate has passed, or under `--skip-checks` once you have appended the `skipped` line, append this line before you start work: `{"ts":"<ISO timestamp>","skill":"legal-accessibility-compliance","workflow":"legal","phase":3,"project":"<project>","event":"started","artifact":"03-comply.md","note":""}`.

Check that `.singularskills/legal/<project>/00-assess.md` exists. If it does not exist, stop and tell the user:

> "Run an Assess skill first (e.g. `/legal-risk-assessment <project>`) to generate the prerequisite assessment artifact."

## Process

1. **Read inputs:**
   - Read `.singularskills/legal/<project>/00-assess.md` for risk, jurisdiction, and data practice context
   - Read any existing accessibility audit or review artifacts in `.singularskills/legal/<project>/` for additional context

2. **Identify applicable accessibility laws by jurisdiction:**
   - **United States:**
     - ADA Title III — public accommodations, DOJ web accessibility guidance, case law trends
     - Section 508 (Rehabilitation Act) — federal agencies and recipients of federal funding
     - State laws (California Unruh Act, New York accessibility requirements, etc.)
   - **European Union:**
     - European Accessibility Act (EAA) — effective June 2025, products and services requirements
     - Web Accessibility Directive — public sector websites and mobile apps
     - EN 301 549 standard
   - **United Kingdom:**
     - Equality Act 2010 — reasonable adjustments obligation
     - Public Sector Bodies Accessibility Regulations 2018
   - **Canada:**
     - Accessibility for Ontarians with Disabilities Act (AODA) — WCAG 2.0 AA for Ontario
     - Accessible Canada Act (ACA) — federal regulated organizations
   - **Other applicable jurisdictions** — document requirements based on assessment context

3. **Determine required WCAG conformance level:**
   - Identify which WCAG version applies (2.0, 2.1, 2.2) per jurisdiction
   - Typically Level AA is required by most regulations
   - Document any Level AAA requirements (rare but some jurisdictions or sectors)
   - Map WCAG success criteria to applicable legal requirements

4. **Assess current compliance status:**
   - Reference existing accessibility audit if available
   - Identify critical barriers by WCAG principle (Perceivable, Operable, Understandable, Robust)
   - Document automated scan results and manual testing findings
   - Catalog assistive technology compatibility (screen readers, keyboard navigation, voice control)

5. **Identify legal exposure:**
   - DOJ enforcement actions and guidance relevant to the business
   - Private litigation trends (ADA demand letters, structured negotiation)
   - EU fines and enforcement mechanisms under EAA and Web Accessibility Directive
   - Industry-specific enforcement (financial services, healthcare, education, government)
   - Insurance coverage considerations

6. **Create remediation priority list:**
   - **Critical barriers** (P1) — complete blockers preventing access (no keyboard access, missing alt text on critical images, inaccessible forms, no captions on essential video)
   - **Major barriers** (P2) — significant difficulty using features (poor contrast, missing form labels, inconsistent navigation)
   - **Minor barriers** (P3) — usability issues that don't block access (focus order anomalies, decorative image alt text, minor contrast issues)
   - Timeline and resource estimates for each priority level

7. **Draft accessibility statement:**
   - Commitment to accessibility and inclusion
   - Standards targeted (WCAG version and level)
   - Current conformance status
   - Known limitations and planned remediation timeline
   - Contact information for accommodation requests and feedback
   - Date of last review and update
   - Enforcement procedure references (where required by law)

8. **Design ongoing monitoring plan:**
   - Automated scanning cadence (recommended: weekly or with each deployment)
   - Manual testing schedule (recommended: quarterly)
   - User testing with people with disabilities (recommended: annually or with major changes)
   - Remediation tracking and reporting
   - Training program for development and content teams
   - Procurement requirements for third-party tools and content

9. **Write the artifact** — append to `.singularskills/legal/<project>/03-comply.md` under a `## Accessibility Compliance` section. Create the file with a `# Comply — <project>` heading if it does not exist; if a `## Accessibility Compliance` section already exists, replace only that section. The section contains:

   - **Applicable Laws** — jurisdiction-by-jurisdiction legal requirements
   - **WCAG Conformance Requirements** — version, level, and success criteria mapping
   - **Current Compliance Status** — assessment findings and barrier inventory
   - **Legal Exposure Analysis** — enforcement risk and litigation trends
   - **Remediation Priority List** — prioritized barriers with timelines
   - **Accessibility Statement** — draft statement for publication
   - **Ongoing Monitoring Plan** — testing cadence and responsibilities
   - **Compliance Gaps** — identified gaps with remediation recommendations

## Output

The accessibility compliance assessment appended to `.singularskills/legal/<project>/03-comply.md`. Present a summary to the user highlighting:
- Applicable accessibility laws and required WCAG level
- Current compliance status (if audit data available)
- Number of barriers identified by priority level
- Key legal exposure areas
- Top remediation priorities and estimated timeline

**Record the run.** After you have written your section, append this line to `.singularskills/log.jsonl` (the `started` line of Prerequisites, with `"event":"finished"`): `{"ts":"<ISO timestamp>","skill":"legal-accessibility-compliance","workflow":"legal","phase":3,"project":"<project>","event":"finished","artifact":"03-comply.md","note":""}`.

This artifact is shared by every skill of phase 3 (Comply). The frontmatter is written once, by whoever creates the file: if you create it, open it with the block below (`skill` is the phase title, `started` the time of that first write; `gate` is `passed` when the gate ran clean and `skipped` under `--skip-checks`); if it already exists, leave the block alone except to update `finished` and to set `gate` to the worst value among the sections (`skipped` over `passed`).

```yaml
---
skill: Comply
workflow: legal
phase: 3
project: <project>
started: <ISO timestamp>
finished: <ISO timestamp>
agent: <the agent you run in, or "unknown">
gate: <passed|skipped>
---
```

Open your `## Accessibility Compliance` section with one italic line, `*<skill name> · <ISO timestamp> · gate: <passed|skipped>*` (your skill name is `legal-accessibility-compliance`).

End your section with `### Decisions` and `### Open questions` (one level under your `## Accessibility Compliance` heading, so the section stays one block), in this shape:

```markdown
### Decisions
- <what was chosen> — <why> — <what was rejected>

### Open questions
- <what the next phase or a reviewer must settle>
```