Accessibility statement

Out of scope

This statement does not cover content that HLD Group does not control. That includes third-party platforms we merely link to, content published by customers into environments we host but do not edit, archived material no longer maintained and not needed for an active transaction, and pre-recorded third-party media embedded under licence terms that prohibit modification.

Where a customer engages HLD Group to build or maintain a product under their own brand, accessibility obligations are governed by the accessibility requirements in that engagement contract rather than by this statement. Section 15 describes the baseline we contract to.

Australia

• Disability Discrimination Act 1992 (Cth) — sections 5, 6, 23 and 24 make it unlawful to discriminate in the provision of goods, services, and facilities, including services provided online
• Australian Human Rights Commission, World Wide Web Access: Disability Discrimination Act Advisory Notes (version 4.1), which identify WCAG 2.0/2.1 Level AA as the measure of compliance the Commission will apply
• AS EN 301 549:2020, the Australian adoption of the European accessibility requirements for ICT products and services, referenced in Commonwealth and state ICT procurement
• Digital Service Standard criterion 9 (Make it accessible), which mandates WCAG 2.1 Level AA for Australian Government digital services and flows to us as a supplier
• Disability (Access to Premises — Buildings) Standards 2010 and applicable state anti-discrimination legislation, for any physical service touchpoints

United States

• Americans with Disabilities Act of 1990, Titles II and III (42 U.S.C. §§ 12131–12189), as applied to websites and mobile applications of public entities and places of public accommodation
• Department of Justice final rule of 24 April 2024 under ADA Title II (28 CFR Part 35), which adopts WCAG 2.1 Level AA as the technical standard for state and local government web content and mobile apps
• Section 508 of the Rehabilitation Act of 1973, as amended (29 U.S.C. § 794d), and the Revised 508 Standards at 36 CFR Part 1194, which incorporate WCAG 2.0 Level AA by reference for federal procurement
• Section 504 of the Rehabilitation Act, for programs and activities receiving federal financial assistance
• Twenty-First Century Communications and Video Accessibility Act of 2010, for covered communications and video content
• Applicable state law, including the California Unruh Civil Rights Act, New York State Human Rights Law, and state IT accessibility policies

European Union and EEA

• Directive (EU) 2019/882 (European Accessibility Act), applicable to covered products and services placed on the EU market from 28 June 2025
• Directive (EU) 2016/2102 (Web Accessibility Directive) for public sector bodies, together with Commission Implementing Decision (EU) 2018/1523 establishing the model accessibility statement this document follows
• EN 301 549 v3.2.1, the harmonised European standard for ICT accessibility, whose web clauses map directly to WCAG 2.1 Level AA
• Regulation (EU) 2016/679 (GDPR) Articles 12 and 25, insofar as transparency information must be provided in an intelligible and easily accessible form

United Kingdom

• Equality Act 2010, sections 20 and 29, including the anticipatory duty to make reasonable adjustments for service users
• Public Sector Bodies (Websites and Mobile Applications) (No. 2) Accessibility Regulations 2018, which require WCAG 2.1 Level AA and a published accessibility statement
• BS 8878 / ISO 30071-1 as guidance on embedding accessibility into the development lifecycle

Canada and other jurisdictions

• Accessible Canada Act (S.C. 2019, c. 10) and the Accessible Canada Regulations
• Accessibility for Ontarians with Disabilities Act, 2005 and the Integrated Accessibility Standards Regulation (O. Reg. 191/11), section 14
• Canadian Human Rights Act, and provincial accessibility legislation in Manitoba, Nova Scotia, and British Columbia
• United Nations Convention on the Rights of Persons with Disabilities, Article 9 (Accessibility) and Article 21, which underpin the domestic regimes above

Standards applied

• W3C Web Content Accessibility Guidelines (WCAG) 2.1 Level AA — primary conformance target
• W3C Accessible Rich Internet Applications (WAI-ARIA) 1.2 and the ARIA Authoring Practices Guide, for custom interactive components
• W3C Authoring Tool Accessibility Guidelines (ATAG) 2.0 Part B, for our content management and page builder interfaces
• EN 301 549 v3.2.1 clauses 9 (web), 10 (documents), and 11 (software)
• ISO/IEC 40500:2012 and ISO 30071-1:2019 for lifecycle governance

Perceivable

• Text alternatives (1.1.1) — every non-text element carries an accurate text alternative; decorative imagery is marked so assistive technology ignores it
• Time-based media (1.2.1–1.2.5) — captions for pre-recorded audio-visual content, transcripts for audio-only content, and audio description or a media alternative where visual information is essential
• Adaptable (1.3.1–1.3.6) — semantic HTML conveys structure, reading and navigation order is meaningful, instructions do not rely on sensory characteristics alone, content supports both orientations, and input purpose is programmatically identified for autofill
• Distinguishable (1.4.1–1.4.13) — colour is never the sole means of conveying information, text contrast is at least 4.5:1 (3:1 for large text), non-text contrast is at least 3:1, text resizes to 200% without loss of content or function, reflow is supported at 320 CSS pixels, and content on hover or focus is dismissible, hoverable, and persistent

Operable

• Keyboard accessible (2.1.1–2.1.4) — all functionality is available from a keyboard with no keyboard traps, and single-character shortcuts can be turned off or remapped
• Enough time (2.2.1–2.2.2) — time limits can be turned off, adjusted, or extended, and moving, blinking, or auto-updating content can be paused, stopped, or hidden
• Seizures and physical reactions (2.3.1) — nothing flashes more than three times in any one-second period
• Navigable (2.4.1–2.4.7) — a skip link bypasses repeated blocks, pages carry descriptive titles, focus order is logical, link purpose is clear, multiple ways exist to locate a page, headings and labels are descriptive, and keyboard focus is always visible
• Input modalities (2.5.1–2.5.4) — multipoint and path-based gestures have single-pointer alternatives, pointer-down activation can be aborted, visible label text is contained in the accessible name, and motion-actuated functions have conventional alternatives

Understandable

• Readable (3.1.1–3.1.2) — page language and any change of language are programmatically declared
• Predictable (3.2.1–3.2.4) — focus and input do not trigger unexpected context changes, and navigation and component identification stay consistent across the site
• Input assistance (3.3.1–3.3.4) — errors are identified in text, form controls carry persistent labels and instructions, correction suggestions are offered where known, and submissions involving legal or financial commitments are reversible, checked, or confirmed

Robust

• Parsing and compatibility (4.1.1–4.1.3) — markup is valid and free of duplicate identifiers, name, role, and value are exposed for all user interface components, and status messages are announced to assistive technology without moving focus

Build practices

• Semantic HTML first — native elements are used before ARIA, and ARIA is used only to fill genuine gaps
• Landmark regions, a single H1 per page, and a logical heading hierarchy on every route
• A visible "skip to content" control as the first focusable element
• Focus management on route change, modal open and close, and dynamic content insertion, with focus returned to the invoking control
• Colour palettes validated against contrast thresholds at design-token level, so the token system cannot produce a failing pairing
• Respect for the prefers-reduced-motion and prefers-contrast user preferences at the CSS layer
• Forms built with programmatically associated labels, inline error text linked by aria-describedby, and error summaries that receive focus
• Data tables with scoped header cells and captions; layout is never expressed with table markup
• No fixed pixel heights on text containers, so 200% zoom and 400% reflow do not clip content

Testing practices

• Automated checks integrated into continuous integration on every pull request, which we treat as a floor rather than proof of conformance
• Manual keyboard-only traversal of every new or changed interactive flow
• Screen reader verification of new components against the combinations listed in section 9
• Zoom and reflow testing at 200% and 400% at a 320 CSS pixel viewport width
• Contrast verification of final rendered output, including text over imagery and disabled states
• Periodic independent audit by a qualified external assessor, with findings tracked to closure

Accessibility profiles

A profile applies a coordinated set of adjustments in a single action, so a visitor does not have to assemble a configuration control by control.

• Seizure and epilepsy safe — pauses animation and transitions and reduces colour saturation
• Vision impaired — enlarges text, applies high contrast, enlarges the cursor, and highlights links and headings
• Cognitive and learning — applies a readable typeface, increases line height and letter spacing, highlights structure, and stops motion
• ADHD friendly — reduces visual noise, stops motion, and enables a reading guide to anchor the line being read
• Blind users (screen reader optimised) — enables keyboard navigation aids, exposes tooltips, and reinforces heading and link semantics
• Keyboard navigation — enables navigation aids and makes interactive targets and focus position visually prominent
• Motor impaired — enables keyboard navigation, enlarges targets and cursor, and exposes tooltips to reduce precision demands

Individual adjustments

• Text size across six steps, with layout that reflows rather than clipping
• Letter spacing and line height adjustment across four steps each
• Contrast modes — normal, dark, light, and high contrast
• Colour saturation — normal, reduced, increased, and monochrome
• Dyslexia-friendly and readable typeface substitution
• Link and heading highlighting to expose page structure
• Reading guide and reading mask to reduce visual crowding
• Enlarged black or white cursor
• Animation pause and image hiding for reduced sensory load
• Tooltip exposure and keyboard navigation assistance

Important limitations of the interface

HLD Access1 supplements the accessibility of the underlying pages. It does not replace it, and we do not treat it as evidence of conformance. Our WCAG 2.1 Level AA obligations are met in the page markup, semantics, contrast, and keyboard behaviour of the site itself, and every claim in section 3 is assessed with the Access1 interface switched off.

We publish this position deliberately. Accessibility overlays and widgets have been the subject of regulatory criticism and litigation where they were presented as a substitute for accessible source code, and a tool that masks defects rather than fixing them can itself become a barrier. Access1 exists to give visitors control over presentation, not to defer remediation.

Access1 does not modify or override the behaviour of a visitor’s own assistive technology, and it is not required in order to use our sites. All content and functionality is available with the interface disabled, using the visitor’s preferred screen reader, magnifier, switch device, voice control, or browser settings alone. If any Access1 setting conflicts with your assistive technology, please tell us under section 14 and we will treat it as a defect.

Known incompatibilities

Our content is not tested against, and may not function correctly with, browser versions more than two major releases behind current, or with assistive technology released before 2019. Internet Explorer is not supported. If you rely on an untested configuration and encounter a barrier, contact us under section 14 and we will provide the content in an alternative accessible format.

Evidence retained

We retain evaluation reports, remediation tickets, and release gate records for a minimum of three years so that our conformance claim can be substantiated on request by a customer, auditor, or regulator. Requests for an accessibility conformance report, a VPAT, or an EN 301 549 declaration may be made under section 14.

Non-compliance with the accessibility standard

• Legacy PDF documents published before the current review cycle may lack a tagged structure, reading order, and document language, and some are scanned images without a text layer (WCAG 1.1.1, 1.3.1, 4.1.2). Reason: historic authoring practice predating our current standard. Alternative: an accessible HTML or tagged equivalent is provided on request within five business days. Remediation: prioritised by download volume, with high-traffic documents scheduled first and the backlog targeted for closure within the current review cycle
• A small number of complex data visualisations convey trend information visually with a text summary that may be less detailed than the graphic (WCAG 1.1.1). Reason: incomplete long-description coverage. Alternative: the underlying data is available in tabular form on request. Remediation: long descriptions and accessible data tables are being added as each visualisation is next revised
• Some older course media lacks audio description where visual demonstrations carry information not present in the narration (WCAG 1.2.5). Reason: source material recorded without described tracks. Alternative: captions and full transcripts are available for all course media, and a live walkthrough can be arranged on request. Remediation: described versions are produced as modules are re-recorded

Disproportionate burden

We currently claim no exemption on the basis of disproportionate burden. If we ever rely on such an exemption, we will record here the specific content affected, the assessment supporting the claim, and the accessible alternative provided, and we will review the assessment at least annually. An exemption will never be claimed in order to avoid remediating a barrier that blocks a core task.

Content outside the scope of the applicable legislation

• Third-party embedded content such as mapping, video hosting, payment, and scheduling providers, which we neither author nor control
• Content published into hosted environments by customers under their own editorial control
• Archived pages retained for reference that are not updated and are not required for an active transaction
• Pre-recorded third-party media licensed on terms that prohibit modification

How to request an adjustment

Email contact@hldgroup.org with the page address, what you were trying to do, and the format that would work for you. You do not need to identify the WCAG criterion involved or provide evidence of disability. We acknowledge within two business days and supply the alternative format within five business days, or agree a longer timeframe with you where the material is substantial.

Contact

Accessibility feedback and complaints: contact@hldgroup.org. Please include the web address of the page, a description of the barrier, and the browser and assistive technology you were using if you know them. Contact by any other channel we publish is equally valid and will be routed to the same team.

Our response commitments

• Acknowledgement of your report within two business days
• A substantive response, including our assessment and a remediation plan or an alternative accessible format, within ten business days
• Where a barrier blocks a core task or a transaction, an interim workaround provided while the fix is developed
• Notification to you when the remediation is deployed, if you have asked to be told
• Where we cannot resolve the issue within ten business days, an explanation of why, a revised date, and the escalation options below

Escalation and external enforcement

If you are not satisfied with our response, you may escalate internally to compliance@hldgroup.org for review by our compliance function, independent of the team that handled the original report. You may also pursue the external routes below at any time, and nothing in this statement limits your legal rights.

• Australia — a complaint of disability discrimination may be lodged with the Australian Human Rights Commission under the Disability Discrimination Act 1992 (Cth)
• United States — a complaint may be filed with the Department of Justice Civil Rights Division under the ADA, or with the relevant federal agency under Section 508 or Section 504
• European Union and EEA — a complaint may be made to the national enforcement body designated under Directive (EU) 2019/882 or Directive (EU) 2016/2102 in your member state
• United Kingdom — the Equality Advisory and Support Service supports complaints under the Equality Act 2010, and public sector matters may be referred to the Equality and Human Rights Commission
• Canada — a complaint may be made to the Accessibility Commissioner under the Accessible Canada Act or to the relevant provincial authority