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A3S - Accessibility as a Service
Vendor Accessibility Evaluation

Accessibility Evaluation
of the Granicus CMS

Summary

Granicus offers several platform products for government websites and public engagement, including its OpenCities CMS. Unlike vendors that rely on a single overlay widget to retrofit accessibility, Granicus emphasises compliance by design - combining automated scans with specialist manual testing, regular accessibility audits, and transparent reporting through Voluntary Product Accessibility Templates (VPATs).

The company's materials make it clear that there is no “set-it-and-forget-it” solution; instead, conformance must be continuously reviewed and documented. Granicus encourages customers to appoint accessibility coordinators, understand local laws and the Web Content Accessibility Guidelines (WCAG), and build internal policies. This evaluation analyses Granicus's commitments, strengths, and limitations based on its publicly available statements and webinars.

Approach

Code-level compliance, no overlays

Standard

WCAG 2.1 AA (2.2 in later materials)

Documentation

VPATs updated biannually

Accessibility Standards and Methodology

WCAG conformance and manual testing

Granicus's OpenCities accessibility statement notes that all platform functionality is "thoroughly tested against the latest accessibility guidelines" using both automated tools and specialist manual checks, and that the platform meets WCAG 2.1 Level AA. The statement encourages customers to achieve the same level of conformance and provides a VPAT for details.

VPAT as a baseline, not a certification

A VPAT is a voluntary template used to show which accessibility standards have been evaluated on a site. Granicus's training materials explain that a VPAT should be posted publicly so users can see where issues remain; it is not required by law but demonstrates that accessibility is a priority. In a 2025 webinar, Granicus said it is creating and updating VPATs for each product, noting that these documents identify known issues and their severity and are updated biannually to reflect product progress. Their blog adds that VPAT reviews are conducted multiple times per year to help IT teams identify and address issues.

Realistic view of compliance

Granicus cautions that no single software solution can guarantee 100% ADA-compliant accessibility because many factors are outside a vendor's control, including content creators, browser updates, operating systems, and changes in assistive technology. The company recommends re-evaluating products every six months, testing each new feature against the relevant WCAG criteria, and incorporating accessibility in the early design and planning stages. During the 2025 webinar, Granicus warned attendees to scrutinize any service-offering certificates or "percent accessible" claims.

Manual and human-centered testing

Granicus advocates a multi-layered testing strategy. Its webinars describe different testing types: screen reader testing, keyboard-only navigation, cognitive evaluations, and automation with "code scrubbers" - and emphasise that automation should not be relied on alone. In its OpenCities statement, the company acknowledges that specialist manual checks complement automated scans.

Education and shared responsibility

Granicus emphasises that accessibility is a shared responsibility between the software provider and the customer. In its blog, the firm notes that success requires balancing IT and content creators and that consultative conversations with a partner who understands government accessibility issues are key. Free online scanners help identify issues but do not create accessibility solutions; a dedicated software partner provides the foundation for compliance. The company's webinars urge agencies to appoint accessibility coordinators, define roles, and develop internal policies.

Strengths

  1. Built-in compliance features

    Granicus designs its platforms to meet WCAG 2.1 (and, in later materials, WCAG 2.2) Level AA and conducts specialist manual testing to verify conformance. The absence of overlay widgets means accessibility enhancements occur within the codebase rather than through after-the-fact scripts.

  2. Transparent documentation

    The company produces VPATs for each product and updates them regularly. This transparency helps governments understand outstanding issues and track remediation progress.

  3. Emphasis on realistic compliance

    Granicus openly acknowledges that there is no 100% accessible solution and warns against vendors offering certificates or percentage scores. This honesty helps set appropriate expectations.

  4. Educational resources

    Granicus provides webinars, blogs, and checklists that train government staff on accessibility policies, testing techniques, and content best practices. The company recommends six-month audits, manual testing of new features, and early integration of accessibility considerations.

Limitations

  1. Self-reported VPATs

    While VPATs are valuable, they are self-assessments, not independent certifications. They indicate where issues exist but do not guarantee that a product or site complies with all WCAG requirements. Governments remain responsible for verifying that the platform meets their specific legal obligations.

  2. Content-level responsibility

    Granicus stresses that many accessibility issues stem from customer-generated content. The platform may start compliant, but agencies must still ensure that the pages, PDFs, videos, and forms they publish are accessible. Without robust internal policies and training, municipalities could still be sued despite using a compliant platform.

  3. Continuous effort is required

    Accessibility needs to be reevaluated every six months, and new features must be manually tested. Agencies that lack the resources or commitment to maintain this schedule may fall out of conformance. Granicus does not claim to shield clients from litigation; it provides tools, but the burden of compliance rests with the customer.

In sum, Granicus's approach to accessibility is built around transparent documentation, manual testing, and continuous improvement. It avoids overlay widgets and instead focuses on code-level compliance. Nevertheless, VPATs are self-reported and content responsibility remains with the municipality, requiring ongoing commitment and expertise from the client.

Where A3S fits in

A3S Complements Granicus with Continuous Monitoring and Legal Defensibility

Granicus acknowledges that its platforms alone cannot guarantee accessibility; organizations must manage their own content, conduct regular audits, and demonstrate ongoing progress. This is where Accessibility-As-A-Service (A3S) can fill the gap. A3S is designed for small government agencies and provides hands-on remediation, monthly reporting, and continuous monitoring, creating a clear record of good-faith compliance and legal defensibility.

Structured workflow with built-in documentation

A3S uses a four-phase workflow that begins with an initial assessment and audit, followed by remediation, validation, and ongoing monitoring. During Phase 2 (Audit & Remediation) the team identifies issues, implements fixes, and delivers monthly progress reports, updated accessibility statements, and documentation of any third-party blockers. After Phase 3, A3S provides complete site validation and an official Accessibility Conformance Report (ACR). Phase 4 then runs continuously, with ongoing site monitoring and proactive issue prevention.

Continuous monitoring and expert remediation

A3S explains that new content, evolving WCAG standards, and third-party integrations can introduce accessibility issues, so continuous monitoring is required. Its program combines automated scans with human-directed manual testing each month; IAAP-certified professionals address complex issues, while the platform scans for regressions in real time. Clients receive weekly progress updates and live tracking links, ensuring they can demonstrate ongoing effort.

Legal documentation and safe harbor protection

A3S's continuous effort approach produces comprehensive legal documentation that shows how issues were identified and remediated over time. The service emphasises that demonstrating good-faith effort and continuous improvement strengthens a client's legal position. In contrast to overlay vendors whose legal support consists primarily of audit reports and upsell services, A3S provides official ACRs, monthly reports, and updated accessibility statements to document compliance.

Manual testing, no reliance on AI

A3S explicitly states that it does not rely on AI to fix accessibility issues; its expert team performs manual testing each month, guided by humans. This aligns with case law requiring manual evaluation and remediation. Monthly updates and real-time tracking provide agencies with evidence of ongoing attention to accessibility.

Tailored for government agencies

A3S markets its program specifically to small governments seeking legal protection; it ensures compliance with WCAG 2.2 AA, Section 508, and ADA Title II, and offers secure storage for accessibility data. By providing a third-party vendor with these capabilities, municipalities can meet Granicus's recommendation that customers take ownership of content and ongoing monitoring.

Case law shows that courts and regulators value documented progress and manual remediation. Three key legal references establish what genuine compliance looks like:

Tribeca Skin Center v. AccessiBe

Experts recommend manual testing and code fixes. Overlay promises are misleading and do not constitute genuine compliance.

Murphy v. Eyebobs

Plaintiffs alleged that the overlay failed to provide full access, and the vendor's own terms warned that it does not prevent lawsuits.

LightHouse v. ADP settlement

Requires manual testing and explicitly states that overlays such as AudioEye and AccessiBe do not suffice to achieve accessibility.

How A3S responds

A3S's program addresses these concerns directly: it combines manual testing with continuous monitoring, provides official VPATs and updated accessibility statements, and documents every fix in monthly and weekly reports. This documentation can be presented in court or during audits to demonstrate good-faith efforts and ongoing compliance. By partnering with A3S alongside Granicus, municipalities can close the gap between platform-level conformance and the continuous, content-level work that courts expect.

Appendix: Source Links

  1. Granicus's OpenCities accessibility statement - explains that all functionality is tested using automated tools and specialist manual checks, that the site meets WCAG 2.1 AA, and that customers are encouraged to reach that level.
  2. Granicus blog "Driving toward digital accessibility compliance" - discusses how VPATs are used, updated multiple times per year, why no software can guarantee 100% compliance, and the importance of balancing IT and content creators.
  3. Granicus webinar "Web and Mobile Accessibility Laws Are Changing" - notes that VPATs show known issues and are updated biannually; warns that accessibility must be consistently evaluated and that certificates or percentage scores should be scrutinized; recommends identifying accessibility coordinators, defining roles, and creating policies.
  4. Granicus webinar "Breaking Barriers: Advancing Digital Accessibility for All" - defines what a VPAT is and its purpose; outlines the high number of ADA lawsuits and stresses the importance of remediation plans; explains that no company can guarantee 100% compliance; recommends six-month audits and early integration of accessibility; describes different testing types and cautions against relying solely on automation.
  5. Tribeca Skin Center v. AccessiBe complaint - emphasises that experts recommend manual testing and code remediation, and alleges that overlay promises are misleading.
  6. Murphy v. Eyebobs complaint - states that an overlay failed to provide full access and that the vendor's terms warn that it does not guarantee claims won't arise.
  7. LightHouse for the Blind v. ADP settlement - declares that overlay solutions like AudioEye and AccessiBe do not suffice to achieve accessibility, requiring manual testing and remediation.
  8. Tribeca complaint (legal support) - notes that the overlay's legal support simply provided an audit report and upsold remediation services, leaving businesses with significant legal fees.
  9. A3S website - details the four-phase workflow, including Phase 2 deliverables (monthly progress reports, updated accessibility statements, and third-party blocker documentation), Phase 3 deliverables (complete site validation, official VPAT documentation, and updated accessibility statements), and Phase 4 continuous monitoring with monthly statement updates.
  10. A3S legal protection section - explains why continuous monitoring is required (dynamic content changes, evolving standards, and third-party dependencies) and how the program provides continuous monitoring, expert remediation, legal documentation, and safe harbor protection.
  11. A3S FAQ - states that the service does not rely on AI; manual testing continues each month, guided by humans; continuous monitoring provides weekly progress updates and live tracking links; VPAT reports are provided to document compliance.
  12. A3S program description - notes that the service is designed for small government organizations seeking legal protection and ensures compliance with WCAG 2.2 AA, Section 508, and ADA Title II; it provides secure storage for accessibility data and compliance reports.

Using Granicus? Close the Compliance Gap.

Granicus builds the foundation. A3S adds continuous monitoring, manual testing, monthly reports, and the legal documentation courts expect - so your municipality can demonstrate real, ongoing compliance.

Important Note: This evaluation is provided for informational purposes only and does not constitute legal advice. For legal counsel specific to your situation, please consult a qualified attorney. A3S provides accessibility consulting, auditing, and remediation services.