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Accessibility
by design

Role
Product Designer
Team
1 Product Designer
1 Head of UX
Tools
Figjam, Figma, Quip
Timeline
5 months
Project overview
This initiative outlines how I developed and implemented a scalable accessibility strategy for Amazon Gift Cards. The goal was to shift from reactive fixes to proactive, inclusive design practices. The work included creating audit and reporting mechanisms, scalable SOPs, handoff documentation, and forming a cross-functional team of Accessibility Champions. Aligning Gift Cards with Amazon’s long-term vision for inclusive customer experiences while ensuring sustained compliance with the EAA.
Problem / Opportunity
In 2024, audits by the Gift Cards and Worldwide Stores Accessibility team (Wa11y) found 261 accessibility defects that needed to be fixed in order to comply with the European Accessibility Act (EAA). Fixing these defects to meet the basic bar of accessibility is scheduled to require 30 days of design rework and a total timespan of 279 days to implement and launch. The GC audits each took an hour of training and over 10 hours to complete with 6-10 people. While fixing these defects helps meet the minimum bar for compliance, features that only meet the basic bar of accessibility still limit inexperienced assistive technology (AT) customers from using our products fully.
Currently, The Gift Cards team does not have robust practices that would prevent additional defects from being launched. In 2024, none of the designs handed off to engineering included a complete set of accessibility designs and product BRDs are not required to include accessibility requirements. The GCUX team does not have a way to understand the quality of existing accessibility experiences and is unable to make data-driven decisions on where focus needs to be applied to raise the accessibility experience bar.
Goal
How might we embed accessibility into our design and development workflows so that we reduce new defects by 90%, cut remediation time by 25%, and intentionally design thoughtful, inclusive experiences for the 16% of customers who have historically been underserved.

My role
I led the end-to-end strategy development for embedding accessibility early into the product development lifecycle for Amazon Gift Cards. This included identifying key gaps, designing scalable processes, and defining actionable solutions to integrate accessibility from concept through launch. I collaborated closely with the Head of UX to validate and refine the proposed approaches, and presented the final strategy to senior leadership to secure alignment and support for implementation across teams.
Insights
Customers with disabilities (CWDs) make up 16% of the population and influence $13 trillion in annual income. CWDs shop online twice as often as other customers, with 50% shopping for physical products weekly and 6% daily. The most important factor in choosing where to shop online was the accessibility of the site, eclipsing variety and price . Most CWDs give up on a purchase every year because of accessibility issues. 36% even choose to use a retailer with higher prices over struggling with accessibility issues.

Top reasons customers with disabilities choose an online retailer

Customers who gave up on a purchase due to accessibility issues

Customers facing a decision between lower price and better accessibility
~3%
of Amazon customer rely on screen readers to navigate our websites
Customers facing a decision between lower price and better accessibility
Insights derived from secondary research, utilizing data from Fable alongside internal findings, to better understand the needs of customers with disabilities.
Building a strategy for Accessibility
I proposed adopting an “Accessibility by Design” strategy to ensure Gift Cards are inclusive from the outset. This approach integrates accessibility requirements into each stage of the product development process. While this method requires additional work upfront (estimated 15-20%), it ensures we can design features without accessibility defects that need to be fixed later, ensure that they meet the “Good” bar from the beginning, and reduce the amount of time required for audits.
Key mechanisms of the strategy
Phase 1
Q4’ 24
Phase 2
Q1’ 25
Cross team collaboration
Partnering with Worldwide Stores Accessibility (Wa11y) and Pay Studio to align standards. Regular syncs with Legal, Marketing, and other teams for shared best practices.
Accessibility Champions team building
One Champion per Gift Card discipline to work with Amazon Accessibility Bar-raisers and advocate for customer when there’s a need in their respective areas. Along with regular strategy reviews to adapt and improve.
Accessibility Design Standards
Leverage any existing materials and create any additional training materials. Create blue-line documentation, best practices and design checklist for both VX and UX.
Product development integration
Embedding accessibility in every design stage using checklists and blue lines. 90% of new launches to meet basic bar; 80% to reach good bar. Cross-org SOPs to define roles and cut defect resolution time by 25%. Accessibility reviews with Bar-raisers before design finalisation.
Building Accessibility Report Cards
Conducting audits and user research on all Gift Card features, deep dive to understand auditing tools partnering with global teams. Use Product Evaluation Rubric and discoverability/impact matrix to prioritise defects. Aim to bring all features to the basic bar and fix 75% of below-bar issues by end of 2025.
Communication & Awareness Campaign
Quarterly emails and strategy updates across the org.
Accessibility Metrics & Reporting
Quarterly reportcards to be created and communicated with partnering stakeholders, mediate reviews and ensure accountability and continuous improvement.
Accessibility champions team building
Establishing an Accessibility Champions team was the initial step in our initiative to foster collaboration among individuals dedicated to enhancing products for customers with disabilities. Together with the UX Head, I identified six key champions from various disciplines to join this team, each bringing their unique expertise to drive our mission forward.


Product designer
VX
TPM
Salesforce
Product
Marketing
Building processes and SOPs
Proceeding further, I developed a comprehensive Standard Operating Procedure (SOP) focused on enhancing accessibility within the Gift Card experience. This document will serve as a guide to best practices in accessibility, detailing essential tools and fostering collaboration with the Gift Card Accessibility Champions. Our goal is to ensure adherence to the Web Content Accessibility Guidelines (WCAG) and other pertinent standards, creating an inclusive experience for all users.
Defining roles and responsibilities
During the initial audit phase, our team faced challenges regarding role clarity and task management, which often felt overwhelming as we navigated the complexities of addressing accessibility issues with limited design support. To ensure that all partnering teams understood their responsibilities, I developed a comprehensive documentation outlining roles and responsibilities. This resource clearly defines what each team is accountable for, encouraging ownership and collaboration in their respective areas. I worked with the identified champions to come up with their responsibility chart and scaled up to their respective teams for alignment.
Standard Operating Procedure (SOP) for
GC design Accessibility
Purpose
This document outlines the Standard Operating Procedure (SOP) for ensuring accessibility in design across Gift Card experience. It aims to provide guidance on accessibility best practices, tools, and collaboration with the GC Accessibility Champions to ensure compliance with the Web Content Accessibility Guidelines (WCAG) and other relevant standards.
Scope
This SOP applies to UX/VX designers, Developers, Product managers, and other stakeholders involved in the design and development of customer-facing Gift Card Experiences. The process covers all phases of design and development, including research, wireframes, prototypes, production, and testing.
Definitions
Accessibility: The design and development of products, services, and environments to be usable by people with a wide range of abilities, including those with disabilities.
WCAG: Web Content Accessibility Guidelines, a set of recommendations for making web content more accessible, particularly to people with disabilities.
EAA: The European Accessibility Act (EAA) is a Directive of the European Union (EU) that establishes substantial accessibility requirements for a broad range of consumer products and services. It requires all EU Member States to adopt these requirements in national legislation, and enforce compliance from 28 June 2025. We expect most Amazon businesses will be impacted by the EAA and that many will have significant work to comply.
Inclusive Design: A methodology that ensures products and services are usable and accessible to as many people as possible, regardless of their physical or cognitive abilities.
Roles and Responsibilities
Content Teams
Content teams focus on creating accessible content by using plain language, optimizing for search, and developing content style guides. They ensure that all informational images and links have appropriate alternative text.
Designers and User Experience Teams
Designers and user experience teams approach accessibility as a core part of the user experience, not just a checklist. They design key interactions with accessibility in mind, wire-framing and prototyping for all of the accessibility experiences.
Front-End Web and Mobile Developers
Front-end web and mobile developers ensure content is accessible, navigable, and understandable for all users. They use semantic HTML, ARIA attributes, and consider assistive technology in their implementation.
Leadership and Executives
Leadership and executives support accessibility efforts and promote a culture of inclusion within the organization.
Marketing
Marketing teams are responsible for the accessibility of all brand elements, even those created externally. They collaborate with UX, VX, and development to maintain accessibility when making changes.
Product Managers
Product managers make accessibility a priority, collaborating with teams to evaluate, prioritize, and uphold accessibility standards.
Program Managers
Program managers advocate for accessibility, track progress, and ensure QA teams have the right testing criteria and accessibility audits are up to date.
Testers and Quality Engineers
Testers and quality engineers are responsible for identifying and addressing accessibility issues before release, testing for common accessibility problems.
User Research
User research teams ensure their entire process, from recruitment to data collection, is accessible, and include users with disabilities in their studies.
Visual Designers
The visual design team plays a critical role in creating accessible products. Their responsibilities include ensuring design elements, such as color, typography, and layout, meet accessibility guidelines to enable people with various disabilities to perceive and interact with the content.
Standard Operating Procedure (SOP) for
GC design Accessibility
Purpose
This document outlines the Standard Operating Procedure (SOP) for ensuring accessibility in design across Gift Card experience. It aims to provide guidance on accessibility best practices, tools, and collaboration with the GC Accessibility Champions to ensure compliance with the Web Content Accessibility Guidelines (WCAG) and other relevant standards.
Scope
This SOP applies to UX/VX designers, Developers, Product managers, and other stakeholders involved in the design and development of customer-facing Gift Card Experiences. The process covers all phases of design and development, including research, wireframes, prototypes, production, and testing.
Definitions
Accessibility: The design and development of products, services, and environments to be usable by people with a wide range of abilities, including those with disabilities.
WCAG: Web Content Accessibility Guidelines, a set of recommendations for making web content more accessible, particularly to people with disabilities.
EAA: The European Accessibility Act (EAA) is a Directive of the European Union (EU) that establishes substantial accessibility requirements for a broad range of consumer products and services. It requires all EU Member States to adopt these requirements in national legislation, and enforce compliance from 28 June 2025. We expect most Amazon businesses will be impacted by the EAA and that many will have significant work to comply.
Inclusive Design: A methodology that ensures products and services are usable and accessible to as many people as possible, regardless of their physical or cognitive abilities.
Roles and Responsibilities
Content Teams
Content teams focus on creating accessible content by using plain language, optimizing for search, and developing content style guides. They ensure that all informational images and links have appropriate alternative text.
Designers and User Experience Teams
Designers and user experience teams approach accessibility as a core part of the user experience, not just a checklist. They design key interactions with accessibility in mind, wire-framing and prototyping for all of the accessibility experiences.
Front-End Web and Mobile Developers
Front-end web and mobile developers ensure content is accessible, navigable, and understandable for all users. They use semantic HTML, ARIA attributes, and consider assistive technology in their implementation.
Leadership and Executives
Leadership and executives support accessibility efforts and promote a culture of inclusion within the organization.
Marketing
Marketing teams are responsible for the accessibility of all brand elements, even those created externally. They collaborate with UX, VX, and development to maintain accessibility when making changes.
Product Managers
Product managers make accessibility a priority, collaborating with teams to evaluate, prioritize, and uphold accessibility standards.
Program Managers
Program managers advocate for accessibility, track progress, and ensure QA teams have the right testing criteria and accessibility audits are up to date.
Testers and Quality Engineers
Testers and quality engineers are responsible for identifying and addressing accessibility issues before release, testing for common accessibility problems.
User Research
User research teams ensure their entire process, from recruitment to data collection, is accessible, and include users with disabilities in their studies.
Visual Designers
The visual design team plays a critical role in creating accessible products. Their responsibilities include ensuring design elements, such as color, typography, and layout, meet accessibility guidelines to enable people with various disabilities to perceive and interact with the content.
End-to-End Accessibility Integration Process
I also identified a gap in our approach to integrating accessibility throughout the product development lifecycle. To address this, I developed a comprehensive process overview that outlines each step, from initial planning to launch and subsequent iterations, ensuring that accessibility considerations are woven into every phase.
Process overview
Step 1: Planning
During the product planning phase, all stakeholders should consider accessibility requirements.
Conduct research to understand the needs of users with disabilities.
Engage with the GC Accessibility Champions early to identify potential issues and solutions.
Step 2: Designing
Follow WCAG guidelines when creating wireframes, prototypes, and design systems.
Incorporate accessible color contrasts, typography, and interactive elements.
Ensure that interactive elements are operable via keyboard and are appropriately labeled for assistive technologies
Share and review designs with the GC Accessibility Champions before moving to the development phase.
Step 3: Development
Implement accessible code practices, including semantic HTML and ARIA roles.
Ensure that all forms are properly labeled and can be navigated with a keyboard.
Avoid using inaccessible visual elements like flashing content or elements that rely on color alone to convey meaning.
Step 4: Testing
Perform manual accessibility testing with screen readers and keyboard navigation tools.
Run automated accessibility tests using tools like Accessibility insights and Lighthouse.
Log any accessibility issues and collaborate with the Accessibility Champions and Developers to resolve them.
Step 5: Post-Launch Monitoring
After the launch, continue monitoring the product for accessibility issues.
Set up regular accessibility audits to ensure ongoing compliance.
Track user feedback and use it to inform future improvements.
Step 6: Iteration based on user adoption / feedback
Based on insights, prioritize updates or fixes to address unmet needs or improve usability further.
Process overview
Step 1: Planning
During the product planning phase, all stakeholders should consider accessibility requirements.
Conduct research to understand the needs of users with disabilities.
Engage with the GC Accessibility Champions early to identify potential issues and solutions.
Step 2: Designing
Follow WCAG guidelines when creating wireframes, prototypes, and design systems.
Incorporate accessible color contrasts, typography, and interactive elements.
Ensure that interactive elements are operable via keyboard and are appropriately labeled for assistive technologies
Share and review designs with the GC Accessibility Champions before moving to the development phase.
Step 3: Development
Implement accessible code practices, including semantic HTML and ARIA roles.
Ensure that all forms are properly labeled and can be navigated with a keyboard.
Avoid using inaccessible visual elements like flashing content or elements that rely on color alone to convey meaning.
Step 4: Testing
Perform manual accessibility testing with screen readers and keyboard navigation tools.
Run automated accessibility tests using tools like Accessibility insights and Lighthouse.
Log any accessibility issues and collaborate with the Accessibility Champions and Developers to resolve them.
Step 5: Post-Launch Monitoring
After the launch, continue monitoring the product for accessibility issues.
Set up regular accessibility audits to ensure ongoing compliance.
Track user feedback and use it to inform future improvements.
Step 6: Iteration based on user adoption / feedback
Based on insights, prioritize updates or fixes to address unmet needs or improve usability further.
SOP documentation UX & VX
I then focused on developing the Standard Operating Procedure (SOP) for our design process, seperate ones for UX and VX as the process varies for each, emphasising accessibility for all designers. To enhance clarity, I utilised the RACI framework, which effectively delineated responsibilities at each stage of the design workflow.

Creating a QA checklist for design
I developed a 30+ item QA checklist tailored to Gift Cards by analysing WCAG and Customer Critical Requirements (CCR). This checklist is now embedded into our design QA process to ensure accessibility is thoroughly validated before each launch.


Accessibility Annotations & Blue-Line Guidelines
At this stage, I moved on to creation of comprehensive accessibility annotation guidelines to standardise how designers deliver accessible handoffs. These guidelines cover critical areas such as:
Keyboard Navigation
Reading Order
Focus Order
Component Anatomy and Behavior
To support this, I also built a dedicated annotation library in Figma, tailored for Gift Cards but aligned with global standards. This library references globally recognised accessibility patterns and provides reusable components that reduce design time while increasing accessibility compliance.
These tools empower designers to confidently annotate blue-lines during handoff, ensuring that accessibility is not an afterthought but a foundational part of our design process.







By Q4 2024, As phase1 of this initiative - we finalised our strategy and guidelines, receiving approval from both leadership and our partner teams to implement "Accessibility by Design" in all future projects. Additionally, the design handoff process has begun to align with the checklist provided, ensuring compliance with the established blue-lines for year-end deliverables.
Phase 2 of “Accessibility by design” in Q1 2025
In alignment with the commitments made to our Leadership during the strategy planning phase, we pledged to develop a comprehensive reporting mechanism in Q1 that encompasses the following elements:
Creating a playbook for auditing and guidelines
Analysis of tools that will cater to our needs for auditing
Creating a template to host raw data
Creating a report card data that is scalable and easy to understand
Sharing metrics and reporting
Creating a testing playbook
In Phase 2 of this project, I developed a comprehensive playbook for initiating report cards. The playbook document served as a guide for new testers, ensuring they can easily understand and commence testing. It includes an introduction to audit planning, outlines what is in-scope and out-of-scope for audits based on stakeholder feedback, and features a sample template for report findings formatted as a Quip document. Additionally, I provide classifications for defects and guidelines for accessibility testing, applicable to both manual and automated processes.


Finding the right testing tool
To identify the right tool that catered to GC audit needs, I checked over 5 tools to understand their audit process and the report outputs. Axe Devtools aligned the most with our needs meeting below criteria:
Easy to use tool
Friendly reports that are easy to understand
Aligns with our error classification on reports, lesser after audit work
Also used and recommended by our partnering team, Amazon payments.

Template for Raw audit reports
To effectively store and share raw data for evaluating and addressing accessibility issues, I developed a centralized template on Quip. This template serves as a single repository for all exported data, ensuring easy access and organization. After completing an audit, testers can seamlessly export their report data and input it into the template for future reference. This information will be handed over to developers for resolution and will also be linked to a comprehensive playbook. The template is structured into three key sections: (1) Test Information, (2) Desktop Report, and (3) Mobile Report.

From rough sketches to reporting mechanism
In this section, I present the evolution of the report card design, which underwent several iterations influenced by feedback from both peers and leadership. The primary goal was to create a straightforward interface that effectively communicates the overall health of the page while highlighting any critical issues. After incorporating various critiques from users of the report card, I developed a clean design that briefly showcases the page's status, emphasizes urgent concerns, and provides relevant links for further exploration.



Accessibility audit
I conducted a thorough audit of the key pages related to Gift Cards, as identified by the Product, Marketing, and Tech teams. Each audit took over an hour and often included a combination of manual testing alongside automated testing to ensure a comprehensive evaluation.



Converting the audit results to report cards
The next step was to transform the evaluated results into a clear and concise report card. This effort led to the development of 37 accessibility report cards, each detailing various pages and modules. Out of these, approximately 25 were classified as "Broken," highlighting critical accessibility challenges that demand urgent attention. Meanwhile, around 12 were marked as "Basic," indicating minimal compliance with accessibility standards and presenting opportunities for substantial improvement. Our primary focus will be to tackle the broken issues first, followed by enhancements to the basic ones, collaborating closely with the respective owner teams to address these concerns promptly.





With the audit, it was understood that over 68% of the GC pages are Critical and has inaccessible elements for Customers with disabilities. and 32% of the pages are Basic making it usable but challenging or frustrating for many in the disability cohort.
37
Report Cards
68%
Pages are Critical
32%
Pages are Basic
Broken
The experience is unusable for many customers in the disability cohort.
Basic
The experience is usable, but challenging or frustrating for many in the disability cohort.
Good
The experience is usable without significant frustration or friction for most customers in the disability cohort.
Conclusion
This initiative helped establish a culture of accessibility within the Gift Cards org. From strategy definition to execution, I led efforts that not only reduced friction for customers with disabilities but also built sustainable systems for inclusive product development. This work shaped how accessibility is now operationalised—from audits and report cards to handoff tooling and team ownership.
Key deliverables
Accessibility strategy alignment
Developed and presented a “Accessibility by Design” strategy on how to approach and solve for customers in disability cohort and got alignment from Leadership.
Building a Champions team
Identified and build a champions team, one per Gift Card discipline to advocate for Customers with Disability.
Accessibility design standards
Leverage any existing materials and create any additional training materials required for inclusive design approach.
SOP for accessibility integration
Embedding accessibility in every design stage using checklists and blue lines. 90% of new launches to meet basic bar; 80% to reach good bar. Cross-org SOPs to define roles and cut defect resolution time by 25%.
Blue-line documentation
Blue-lines documentation, Component library creation for blue-lining, Design checklist for both VX and UX.
Creating and delivering report cards
Conducted a thorough audit and produced 37 detailed report cards, enabling GC to assess its progress towards achieving full inclusivity for customers.
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