Is Website Accessibility a Hidden Risk Across Your Portfolio?

Why accessibility belongs on the value creation agenda, and how sponsors and portfolio leaders can reduce exposure across every company website

An operating partner is reviewing the integration plan for a newly formed platform. The core company has a modern website. The three add on acquisitions are still running the sites they had before the deal.

Then a demand letter arrives. It does not name the platform company. It names a small add on acquired eight months ago, citing a contact form that cannot be completed with a screen reader and images with no text descriptions.

No one on the deal team had looked at that website since diligence. No one owned it.

How many websites sit inside your portfolio today?
Who is responsible for each one?

And if a letter like that arrived tomorrow, could each company show what it has done to make its site accessible?

Accessibility Is a Portfolio Issue, Not a Website Issue

Inside a single company, accessibility can look like a design detail. Across a portfolio, it becomes a pattern of exposure.

Every acquisition brings its own website, its own vendor, and its own history of shortcuts. Add on companies are often the least maintained, precisely because they are small.

Accessibility is also a customer issue.

According to the U.S. Department of Justice, people who are blind may use screen readers, people who are deaf or hard of hearing may rely on captions, and people who cannot easily use a mouse may navigate with a keyboard or voice commands.

The Department compares an inaccessible website to steps at the entrance of a building. The door is open, but not everyone can get through it.

An inaccessible website turns away customers and invites risk at the same time.

Why Sponsors Are Paying Attention

The Americans with Disabilities Act applies to businesses that are open to the public. The Department of Justice has consistently taken the position that the ADA’s requirements apply to the goods and services those businesses offer on the web.

There is no detailed federal regulation spelling out exactly what a business website must do. Instead, the Department points to existing technical standards such as the Web Content Accessibility Guidelines, known as WCAG.

Litigation has grown, and 2026 is on pace to set new highs. Level Access, citing Seyfarth Shaw’s analysis, reports that 3,117 federal web accessibility lawsuits were filed under Title III of the ADA in 2025, a 27 percent increase over 2024. Seyfarth Shaw’s 2026 mid year report counts 5,006 federal ADA Title III lawsuits of all kinds in the first six months of 2026, the highest half year total since 2021, with Florida second among the states at 709. UsableNet, which tracks digital accessibility suits in federal and state courts, projects roughly 6,176 of them in 2026, which would be a record.

For a sponsor, the question is not whether one website has issues. It is how many companies share the same gaps, and whether anyone is measuring them.

This article is not legal advice. Counsel should guide any response to a claim. The operating discipline described here, however, sits squarely with marketing and digital leadership.

What the Standard Actually Asks For

WCAG is organized around four principles. Content should be perceivable, operable, understandable, and robust.

In practice, people should be able to see or hear your content, use your site with the tools they rely on, understand what is happening, and count on it working across devices and assistive technology.

Level Access notes that courts typically reference WCAG 2.1 Level AA as the benchmark, while WCAG 2.2 is considered best practice. The W3C, which publishes WCAG, explains that content meeting WCAG 2.2 also meets the earlier versions.

Five Steps to Reduce Accessibility Risk Across a Portfolio

1. Inventory Every Digital Property

Start with a complete list: every domain, website, landing page, booking tool, and customer portal across every company. Record the platform, the vendor, and the person accountable for each. Many portfolios discover sites no one remembered they owned.

2. Set One Standard for Every Company

Adopt a single target, such as WCAG 2.1 Level AA with WCAG 2.2 as the goal for new work, and apply it to every company.

A shared standard turns dozens of separate debates into one policy, and it gives every vendor the same expectations.

A portfolio standard is cheaper than a portfolio of exceptions.

3. Fix the Paths That Generate Revenue First

Prioritize the pages where customers become revenue: contact forms, quote requests, booking tools, and checkout.

The Department of Justice highlights common barriers that matter most here, including images without text alternatives, poor color contrast, information conveyed by color alone, form fields without labels, navigation that requires a mouse, and video without captions.

4. Be Skeptical of Quick Fixes

Some tools promise compliance with a single line of code. The Department of Justice notes that automated checkers and overlays can be helpful but need to be used carefully, and that a clean automated report does not necessarily mean a site is accessible. UsableNet’s 2026 mid year research found that companies using accessibility widgets were still being sued every month, and that a widget alone does not prevent a lawsuit or show that a site is accessible. Durable progress comes from pairing automated scans with manual review by people who understand accessibility, then fixing the underlying design and code.

5. Write Accessibility Into Contracts and Launch Checklists

Make the standard part of every website vendor agreement, every redesign brief, and every launch checklist. When accessibility is a requirement rather than a request, it stops depending on who happens to be managing the project. Contracts do not move the risk off the company, either. Level Access notes a 2025 Florida case in which a restaurant could not pass its ADA liability to its website vendor.

Make It Part of Diligence and Integration

The cheapest time to understand accessibility exposure is before close. Add a basic review of the target’s primary website to marketing and technology diligence, and include remediation in the integration budget when needed.

When add on companies are folded into a platform brand, rebuild their sites on the platform’s accessible foundation instead of carrying old problems forward.

Keep Accessibility Ongoing

Websites change constantly. New pages, images, forms, and plugins can reintroduce old problems. Level Access points out that businesses which settle a claim with a one time fix are often targeted again when later updates bring issues back.

A few portfolio habits make a meaningful difference:

  • Review accessibility whenever a company launches new pages or features.

  • Require alt text for every meaningful image and captions for every video.

  • Publish an accessibility statement on every site with a clear way to report problems.

  • Report accessibility status alongside other digital metrics each quarter.

The Department of Justice specifically notes that giving the public a way to report accessibility issues helps website owners fix them.

Accessibility is not a project you finish. It is a standard you maintain across every company.

Is Every Website in Your Portfolio Open to Every Customer?

Established in 2016, Queen Bee Digital Media partners with private equity sponsors and their portfolio companies to build, refine, and scale marketing infrastructure across newly formed platforms.

We inventory digital properties across a portfolio, identify the accessibility barriers that matter most, and rebuild websites on a consistent, accessible foundation with labeled forms, readable design, keyboard friendly navigation, descriptive alt text, and captioned video.

Your companies welcome every customer who walks through the door. Their websites should too.

Ready to Evaluate Accessibility Across Your Portfolio?

Schedule a portfolio website accessibility review with Queen Bee Digital Media.

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