PreEmpt.Life Web Accessibility & WCAG Policy

1. Purpose

PreEmpt.Life is committed to making its website and digital content accessible and usable by as wide a range of people as reasonably practicable, including people with disabilities.

This policy establishes the accessibility requirements and development standards that apply to the PreEmpt.Life website and related web content.

PreEmpt.Life uses the Web Content Accessibility Guidelines (WCAG) 2.2 Level AA as its primary accessibility target.

WCAG 2.2 is an internationally recognised W3C accessibility standard covering web content and digital experiences. It is structured around four principles: Perceivable, Operable, Understandable, and Robust (POUR).

2. Scope

This policy applies to:

• The public PreEmpt.Life website.
• Web pages and landing pages operated by PreEmpt.Life.
• Website navigation and user-interface components.
• Online forms and interactive elements.
• Images, videos, audio and multimedia published by PreEmpt.Life.
• Documents and downloadable resources where reasonably applicable.
• New website functionality developed after the effective date of this policy.
• Significant modifications to existing website functionality.
• Third-party components where PreEmpt.Life has reasonable control or influence over their implementation.

Where accessibility depends upon a third-party service or technology outside PreEmpt.Life's direct control, reasonable measures will be taken to select accessible alternatives and identify known limitations.

3. Accessibility Commitment

PreEmpt.Life is committed to:

1. Designing and developing its website with accessibility considered from the beginning of the development lifecycle.
2. Using WCAG 2.2 Level AA as the target accessibility standard.
3. Identifying and addressing accessibility barriers through testing and remediation.
4. Considering accessibility when introducing new website functionality.
5. Providing accessible alternatives where a particular piece of content cannot reasonably be made fully accessible.
6. Monitoring accessibility issues reported by website users.
7. Periodically reviewing this policy and the accessibility of the website.
8. Encouraging developers, designers and content contributors to follow accessibility best practices.

PreEmpt.Life recognises that accessibility is an ongoing process rather than a one-time implementation activity.

4. Accessibility Standard

PreEmpt.Life's target is:

WCAG 2.2 Level AA

WCAG 2.2 defines three conformance levels: Level A, Level AA and Level AAA. Level AA requires satisfaction of all Level A and Level AA success criteria.

PreEmpt.Life does not claim Level AAA conformance as a general website requirement.

WCAG 2.2 contains 13 guidelines organised under the four POUR principles and provides testable success criteria for determining conformance.

5. Accessibility Principles

5.1 Perceivable

Information and user-interface components should be presented in ways that users can perceive.

PreEmpt.Life will seek to provide:

• Meaningful alternative text for relevant images.
• Appropriate text alternatives for non-text content.
• Captions or equivalent alternatives for applicable multimedia.
• Clearly structured headings.
• Semantic HTML where appropriate.
• Sufficient colour contrast.
• Content that remains usable when text is resized.
• Responsive layouts that support different screen sizes.
• Information that is not communicated through colour alone.
• Accessible presentation of visual and multimedia content.

For example, WCAG 2.2 Level AA includes minimum colour-contrast requirements, including a 4.5:1 contrast ratio for normal text in the applicable circumstances.

6. Operable

Website functionality should be usable through different methods of interaction.

PreEmpt.Life will seek to ensure that:

• Core website functionality is available using a keyboard.
• Keyboard focus is visible.
• Users are not trapped within interface components.
• Navigation is consistent.
• Users can identify and access page navigation.
• Interactive elements have appropriately sized targets.
• Drag-only interactions have an accessible alternative where applicable.
• Time limits are avoided where reasonably possible or appropriate controls are provided.
• Moving, blinking or automatically updating content can be controlled where required.
• Content does not introduce avoidable seizure or physical-reaction risks.
• Links and controls have meaningful names.

WCAG 2.2 introduced additional accessibility requirements relating to areas including focus visibility, dragging movements and minimum target size.

7. Understandable

Website information and functionality should be understandable and predictable.

PreEmpt.Life will seek to provide:

• Clear and understandable page content.
• Descriptive headings and labels.
• Consistent navigation.
• Predictable interaction behaviour.
• Clear instructions for forms.
• Accessible error messages.
• Identification of required fields.
• Appropriate error prevention and correction mechanisms.
• Consistent help mechanisms where applicable.
• Accessible authentication mechanisms where applicable.

Where users are required to enter information, the website should provide clear instructions and useful feedback when errors occur.

8. Robust

Website content should work reliably with current and commonly used user agents and assistive technologies.

PreEmpt.Life will seek to:

• Use valid and semantic HTML.
• Use ARIA only where appropriate and necessary.
• Ensure interactive components expose appropriate names, roles and states.
• Maintain compatibility with commonly used browsers.
• Consider compatibility with screen readers and other assistive technologies.
• Avoid unnecessary reliance on proprietary or inaccessible technologies.
• Test dynamically generated content and interactive components for accessibility.

9. Keyboard Accessibility

PreEmpt.Life considers keyboard accessibility an important part of website accessibility.

Users should be able to:

• Navigate interactive controls using the keyboard.
• Access links and buttons.
• Operate applicable menus and controls.
• Identify the current keyboard focus.
• Move through forms logically.
• Submit and interact with applicable forms without requiring a mouse.

Keyboard traps should be avoided.

10. Screen Reader Compatibility

Where reasonably applicable, PreEmpt.Life will test website functionality with screen-reader technologies.

Testing may include:

• Heading navigation.
• Landmark navigation.
• Link identification.
• Form-label association.
• Button and control identification.
• Dynamic content announcements.
• Alternative text.
• Error messages.
• Modal and dialog behaviour.
• Navigation menus.

The website will seek to provide meaningful semantic information to assistive technologies.

11. Visual Accessibility

PreEmpt.Life will consider users with visual impairments and low vision.

Development and design should consider:

• Appropriate colour contrast.
• Text resizing.
• Browser zoom.
• Responsive reflow.
• Visible focus indicators.
• Avoidance of colour-only communication.
• Readable typography.
• Appropriate spacing.
• Meaningful visual hierarchy.
• Accessible icons and controls.

The website should remain usable when users increase page magnification or text size, subject to the applicable WCAG requirements.

12. Forms and User Input

Forms should be designed to be accessible.

Where applicable:

• Every form control should have an associated label.
• Required fields should be clearly identified.
• Instructions should be provided where necessary.
• Validation errors should be understandable.
• Errors should be associated with the relevant controls.
• Users should receive appropriate feedback following successful or unsuccessful submission.
• Form controls should be keyboard accessible.
• CAPTCHA or anti-bot mechanisms should provide an accessible alternative where applicable.

13. Images and Alternative Text

PreEmpt.Life will provide alternative text for meaningful images.

Alternative text should:

• Communicate the purpose or meaning of the image.
• Avoid unnecessary descriptions.
• Not duplicate adjacent text unnecessarily.
• Identify informative graphical content where appropriate.

Decorative images may use appropriate techniques to ensure they are ignored by assistive technologies.

14. Video and Multimedia

Where PreEmpt.Life publishes multimedia content, reasonable accessibility measures will be considered based on the nature of the content.

These may include:

• Captions.
• Transcripts.
• Audio descriptions where applicable.
• Accessible media controls.
• Text alternatives for important information conveyed exclusively through multimedia.

15. Documents and Downloadable Content

Where PreEmpt.Life provides downloadable documents, reasonable efforts will be made to ensure that documents are accessible.

This may include:

• Proper document headings.
• Logical reading order.
• Accessible tables.
• Alternative text for meaningful images.
• Appropriate document metadata.
• Sufficient colour contrast.
• Searchable text.
• Accessible links and navigation.

Where an inaccessible legacy document cannot reasonably be remediated, an accessible alternative may be provided where appropriate.

16. Responsive and Mobile Accessibility

PreEmpt.Life will consider accessibility across supported device types and screen sizes.

Testing should consider:

• Desktop computers.
• Laptops.
• Tablets.
• Mobile devices.
• Different viewport sizes.
• Browser zoom.
• Responsive reflow.
• Touch interaction.
• Keyboard interaction where supported.
• Assistive technology compatibility.

WCAG 2.2 is designed to apply broadly across different web technologies and device contexts.

17. Accessibility Testing

Accessibility testing should form part of the website development and quality-assurance process.

Testing may include both automated and manual evaluation.

Automated testing may include:

• Accessibility scanning.
• Colour-contrast testing.
• Missing alternative-text detection.
• Heading-structure validation.
• Form-label validation.
• ARIA validation.
• HTML and semantic-structure checks.
• Keyboard-focus checks where supported by tooling.

Manual testing may include:

• Keyboard-only navigation.
• Screen-reader testing.
• Browser zoom testing.
• Responsive testing.
• Form interaction testing.
• Focus-order testing.
• Interactive-component testing.
• Error-message testing.
• User-flow testing.

WCAG success criteria are testable requirements, and W3C notes that conformance assessment uses a combination of automated testing and human evaluation.

18. Accessibility Testing Tools

PreEmpt.Life may use appropriate accessibility testing tools as part of its development and QA processes.

Examples include:

• WAVE.
• axe DevTools.
• Lighthouse Accessibility.
• Accessibility Insights.
• Browser developer accessibility tools.
• Screen readers such as NVDA, VoiceOver or other appropriate technologies.

Automated tools should not be treated as the sole method of determining WCAG conformance.

19. Third-Party Content

PreEmpt.Life may use third-party services, libraries, plugins, analytics systems, embedded content or other external technologies.

Where reasonably possible, PreEmpt.Life will:

• Prefer accessible third-party solutions.
• Evaluate accessibility implications before introducing significant third-party components.
• Configure third-party components appropriately.
• Address accessibility problems that are within PreEmpt.Life's control.
• Document material accessibility limitations where appropriate.

Where a third-party service is outside the technical control of PreEmpt.Life, the relevant limitation may remain dependent upon the third-party provider.

20. Accessibility Issues and Remediation

Accessibility issues identified through testing, user feedback, monitoring or development activities should be assessed according to their impact.

Issues may be categorised as:

Critical

Issues that prevent users with disabilities from accessing or completing an essential function.

Target: Prioritised for immediate remediation.

High

Issues that significantly impair accessibility or prevent access to important functionality.

Target: Addressed as part of the next appropriate remediation cycle.

Medium

Issues that create meaningful accessibility barriers but do not prevent access to core functionality.

Target: Addressed through planned development or content updates.

Low

Minor accessibility improvements or best-practice enhancements.

Target: Addressed as part of normal maintenance where practical.

Remediation timelines may vary depending upon technical complexity, business impact and third-party dependencies.

21. Accessibility Feedback

PreEmpt.Life welcomes feedback regarding the accessibility of its website.

Users who encounter an accessibility barrier should be able to report the issue through the website's available contact channels.

When reporting an accessibility issue, users are encouraged to provide:

• The affected page or feature.
• A description of the accessibility problem.
• The device or browser being used, where relevant.
• Assistive technology being used, where relevant.
• Any other information that may help reproduce the issue.

PreEmpt.Life will review accessibility feedback and, where appropriate, incorporate identified issues into its remediation process.

22. Accessibility Governance

Responsibility for accessibility is shared across relevant PreEmpt.Life functions.

Management

Management is responsible for:

• Supporting the accessibility commitment.
• Providing appropriate resources.
• Reviewing material accessibility risks.

Design Team

The design team is responsible for:

• Applying accessible design principles.
• Considering colour contrast, typography and visual hierarchy.
• Designing accessible interaction patterns.

Development Team

The development team is responsible for:

• Implementing accessible frontend components.
• Applying semantic HTML and appropriate ARIA.
• Supporting keyboard navigation.
• Addressing identified accessibility defects.

QA / Testing

The QA function is responsible for:

• Including accessibility checks in appropriate testing cycles.
• Recording accessibility defects.
• Verifying remediation.

Content Team

Content contributors are responsible for:

• Providing meaningful alternative text.
• Using appropriate headings.
• Creating accessible content.
• Considering readability and understandable language.

23. Accessibility in the Software Development Lifecycle

Accessibility should be considered throughout the development lifecycle.

Requirements

Accessibility requirements should be considered when defining new functionality.

Design

Designs should be reviewed for accessibility before implementation where practical.

Development

Developers should implement components according to applicable WCAG 2.2 requirements.

Testing

Accessibility testing should be performed before significant releases.

Release

Material accessibility defects should be reviewed before production deployment.

Maintenance

Accessibility should be reconsidered when functionality, content, frameworks or major design components are changed.

24. Exceptions and Limitations

PreEmpt.Life recognises that some accessibility issues may arise from:

• Legacy content.
• Third-party services.
• External integrations.
• Technical limitations.
• Content supplied by external parties.
• Newly introduced functionality awaiting remediation.

Such limitations do not remove the organisation's commitment to accessibility.

Where full compliance cannot immediately be achieved, PreEmpt.Life will seek to:

1. Identify the accessibility barrier.
2. Assess its impact.
3. Record the issue where appropriate.
4. Identify a remediation approach.
5. Prioritise remediation according to severity.
6. Provide an alternative or workaround where reasonably possible.

25. Conformance Statement

PreEmpt.Life has adopted WCAG 2.2 Level AA as its accessibility target for the website.

This policy should not be interpreted as a blanket claim that every page, document, third-party component or historical piece of content is fully conformant at all times.

Conformance is subject to ongoing testing, remediation, website changes, content updates and third-party dependencies.

Where a formal accessibility audit has been completed, the results of that audit should be maintained as supporting evidence for the applicable website version and assessment period.

PreEmpt.Life's WCAG 2.2 Level A and AA assessment (October 2026) is published as an Accessibility Conformance Report (VPAT®, PDF) (opens in a new tab).

26. Security and Accessibility

PreEmpt.Life recognises that accessibility and security should be considered together during website development.

Accessibility controls should not unnecessarily weaken security controls.

Security mechanisms such as authentication, anti-bot controls, session management and access controls should, where applicable, be designed so that legitimate users can use them with appropriate assistive technologies.

Where accessibility and security requirements appear to conflict, the issue should be reviewed by the relevant technical and security stakeholders and an appropriate solution identified.

27. Compliance and Assurance

This policy provides the organisational framework for PreEmpt.Life's web accessibility approach.

Supporting evidence may include:

• Accessibility audit reports.
• WCAG testing reports.
• Automated accessibility scan results.
• Manual testing records.
• Browser and device testing records.
• Screen-reader testing records.
• Accessibility defect registers.
• Remediation records.
• Release/QA records.
• Accessibility feedback records.
• Website accessibility statements.

These records should be retained in accordance with PreEmpt.Life's applicable information-security and document-retention practices.

28. Policy Review

This policy will be reviewed:

• At least annually.
• Following significant website redesigns.
• Following significant changes to accessibility standards.
• Following significant accessibility incidents.
• Following material changes to website technology.
• Where required by contractual, regulatory or organisational requirements.

The policy owner is responsible for ensuring that the policy remains current.

29. Reference Standard

The primary reference standard for this policy is:

Web Content Accessibility Guidelines (WCAG) 2.2 — W3C Recommendation

WCAG 2.2 is the current W3C Recommendation and was published as a W3C Recommendation on 5 October 2023. It adds nine new success criteria compared with WCAG 2.1.

WCAG 2.2 has also subsequently been approved as ISO/IEC 40500:2025, providing an ISO standard corresponding to WCAG 2.2.

30. Document Control