Phong Trang

EU Accessibility Act Compliance: Managing Risk and Building Capability

*By Phong Trang - Software Product Manager - *thanhphong.trang@gmail.com Dashboard

Overview

When the EU Accessibility Act deadline approached in 2025, Volvo Cars faced a straightforward challenge: ensure volvocars.com meets regulatory requirements across 27 EEA markets before June 28, 2025. As Program Manager for the EU Accessibility Compliance initiative, I coordinated 20 front-end teams to resolve over 14,000 accessibility violations across 7,000+ pages. The work wasn’t particularly dramatic. It required structured governance, clear ownership, and pragmatic solutions to scale remediation across a complex organization. We achieved full compliance ahead of schedule and built a framework to maintain it going forward.

Key Outcomes:

Technical Stack:

Azure Playwright Dashboard —

Why This Mattered

The EU Accessibility Act isn’t optional. Non-compliance carries legal and reputational risk. For a premium automotive brand operating across the European Economic Area, meeting accessibility standards protects both brand standing and business continuity. Beyond regulatory compliance, accessibility improves the digital experience for users with assistive technologies. This aligns with Volvo’s broader commitment to inclusive design and serves customers across 27 markets more effectively. From a business perspective, the project had three objectives:

  1. Risk mitigation: Prevent legal exposure from non-compliance
  2. Operational efficiency: Build scalable processes rather than one-time fixes
  3. Brand alignment: Demonstrate commitment to inclusive design standards

The Challenge

When we assessed volvocars.com’s compliance status, the scope became clear:

The regulatory deadline created urgency. The distributed nature of the violation types—from simple alt-text gaps to complex keyboard navigation issues—meant no single team could resolve everything alone.

The Specific Bottleneck

Manual alt-text creation for 100,000+ assets wasn’t feasible. Local content editors were already managing market rollouts and model updates. Adding accessibility remediation to their workload would either delay compliance or require significant additional hiring. Generative AI offered a potential solution for scaling alt-text generation. However, Volvo Cars’ internal AI governance process required formal approval from the Generative AI Committee before deployment. This process typically took months. We had weeks.

Approach: Program Management and Pragmatic Solutions

As Program Manager, my role centered on three areas: establishing governance structures, coordinating cross-functional remediation, and identifying scalable solutions for the highest-volume problems.

Governance and Stakeholder Alignment

The first step was clarifying ownership. With 20 front-end teams, multiple market organizations, and various platform teams involved, everyone’s responsibility easily becomes no one’s responsibility. I established a steering group with design and product leadership to drive strategy. We created a centralized dashboard integrating Playwright and SiteImprove data, providing a single source of truth for tracking requirements, progress, and blockers. Communication cadence followed a structured approach:

  
"prompt_filter_results": {
  "sexual": {"severity": "safe", "filtered": false},
  "violence": {"severity": "safe", "filtered": false},
  "hate": {"severity": "safe", "filtered": false},
  "self_harm": {"severity": "safe", "filtered": false},
  "profanity": {"detected": false, "filtered": false}
}

This wasn’t about deploying cutting-edge AI. It was about using available technology with clear constraints to solve a specific scaling problem. The validation process ensured outputs met EU Accessibility Act standards before going live. label

Building for Sustainability

Fixing 14,000 violations addressed the immediate deadline. The more important objective was preventing future violations from accumulating. We integrated accessibility checks into the standard development pipeline by coordinating with the Quality & Release Engineering (QRE) team. I developed dashboard requirements and mockups, which the QRE team implemented as an executive dashboard tracking compliance in real-time. label

Beyond tooling, we established a Community of Practice with 20 trained accessibility advocates across teams, a #digital-accessibility Slack channel for peer support, and a central knowledge library for accessibility guidelines. This moved accessibility from a one-time project to an ongoing organizational capability. —

Results

Compliance Achieved:

Cost Prevention:

External Validation:

Ongoing Capability:

lib1 lib2

Program Management Approach

What Worked