- Selective engagement
- Beyond our core sectors
- Client
- A tier-1 Australian bank
Accessibility Uplift & Operating Discipline · Financial Services
Helping one of Australia's largest banks make its digital documents accessible to every customer.
Commonwealth Bank set an ambition to become one of Australia's most accessible banks — and needed the operating discipline to deliver on it across thousands of customer-facing documents. We audited the document estate, coordinated remediation through a specialist partner, designed accessible-publishing SOPs, and trained the teams who would carry the work forward. The work was about accessibility on the surface and operating discipline underneath.
Document estate
Audited & triaged
Customer-facing PDFs assessed against accessibility standards and rationalised
PDF remediation
Coordinated & controlled
Specialist remediation managed under a documented risk framework
Publishing SOPs
Built & embedded
Accessible-publishing standards live in BAU content workflows
Stakeholder training
Delivered
Accessibility capability embedded across relevant publishing teams
CBA
Named client engagement
Commonwealth Bank of Australia
- Why we took this work
Our core sectors are construction, field service and care. We take selective work outside those sectors when the engagement is fundamentally about operating discipline — SOPs, governance, risk frameworks, and the cadence to sustain them. Commonwealth Bank’s accessibility uplift was exactly that kind of work, on a platform where the regulatory stakes were high and the operational discipline mattered.
Client
Commonwealth Bank of Australia
Sector
Financial services (selective)
Practice
Accessibility uplift + Operating discipline
Engagement
~5 months · senior-led
Focus
Audit, remediation, SOPs, training
01
The Situation
An accessibility ambition that needed operating discipline to deliver.
Commonwealth Bank had set a clear ambition: to become one of Australia’s most accessible banks, with digital services and documents that worked for every customer — including those with disability. The ambition was right, the leadership commitment was real, and accessibility expertise was available through specialist partners.
What sat between the ambition and the outcome was the harder part. A large estate of customer-facing PDFs, accumulated over years across multiple business units, with inconsistent accessibility compliance. Legal and reputational risk from publishing inaccessible content. No standard operating procedures to ensure newly created documents stayed compliant. And teams across the bank who needed practical guidance to embed accessibility into business-as-usual publishing rather than treating it as a one-off project.
The bank engaged Infinikey to do what we do across every engagement: turn an ambition into operating discipline. Audit the estate, manage the remediation under a risk framework, build the SOPs that make accessibility part of how content is published, and train the people who will hold the standard going forward.
02
What Was Breaking
Four gaps between ambition and execution.
Each gap below is the same shape we encounter across our core sectors: a recognised standard, real leadership intent, and an operating model that hadn’t yet caught up with either.
01
A large document estate, inconsistently compliant.
Customer-facing PDFs accumulated over years across multiple business units. Some documents met accessibility standards. Many didn't. Without an estate-wide audit, the bank couldn't see the scale of the gap or where the risk was concentrated.
02
Legal and reputational exposure on every publish.
Inaccessible documents continued to be published while the remediation backlog was being worked through. Without a documented interim risk framework, every publish was a judgement call rather than a controlled decision.
03
No standard operating procedures for accessible publishing.
Without documented SOPs, the same content that was being remediated today would re-enter the estate tomorrow as the next set of non-compliant documents. The gap was structural, not historical.
04
Teams needed practical capability, not just policy.
Accessibility responsibilities sat across multiple publishing teams. Without practical training and clear quality gates, accessibility would remain something teams agreed with in principle but didn't always deliver in practice.
03
The Engagement
Run in three deliberate phases.
We sequenced the engagement so that the audit drove the remediation priority, the SOPs were written against the remediated standard, and the training embedded the SOPs as part of how teams actually published content — not as a separate compliance layer.
PHASE 01
Audit the estate & rationalise.
Weeks 1 — 4
We audited the document estate against required accessibility standards, rationalised content by removing outdated or unnecessary documents, and prioritised remediation based on customer impact and risk exposure. The audit reduced the remediation workload before remediation began.
- Accessibility audit across customer-facing PDFs
- Content rationalisation — removed outdated documents
- Remediation priority sequencing by impact and risk
PHASE 02
Coordinate remediation & build SOPs.
Weeks 5 — 14
We coordinated PDF remediation through a specialist vendor partner, established a risk management protocol for documents awaiting remediation, and built SOPs and checklists for content creation, review and publishing — designed to live inside BAU workflows rather than alongside them.
- Specialist vendor remediation coordinated and managed
- Risk framework and interim controls for documents in-flight
- Accessible-publishing SOPs across creation, review, publish
- Governance controls for ongoing compliance and monitoring
PHASE 03
Train teams & embed the practice.
Weeks 15 — 22
SOPs only create results when the people doing the work know how to use them. We designed and delivered training across relevant publishing teams, built alignment around accessibility responsibilities and quality gates, and supported adoption with practical guidance and worked examples.
- Training delivered across relevant publishing teams
- Quality gates embedded into the publishing workflow
- Practical guidance and worked examples for ongoing use
04
The Outcome
Accessibility as an operating rhythm.
Outcomes are described qualitatively at the bank’s request. Specific metrics on document volumes and remediation progress are not published. The substance below is verifiable through the artefacts produced and the operating cadence now in place.
Accessibility posture
Strengthened
Across the audited document estate, against required standards
A more accessible experience for customers with disability.
The audit-and-remediation sequence delivered a meaningful improvement in the accessibility of the published document estate. Customers using screen readers, keyboard navigation and other assistive technology gained reliable access to documents that previously required workarounds. The work moved from a one-off remediation project to a continuous compliance posture as the SOPs and quality gates took hold.
Compliance & reputational risk
Reduced
Through documented SOPs, governance controls and risk framework
Risk decisions became structured, not judgement calls.
The risk management protocol for documents awaiting remediation gave the bank a documented way to decide what to publish, what to hold, and what to flag — rather than relying on individual judgement under pressure. Governance controls and the SOP layer reduced the structural source of compliance and reputational risk: the gap between the standard and the publishing practice.
Operating cadence
Established
For sustaining accessibility compliance in future digital publishing
A repeatable approach beyond the engagement.
The combination of SOPs, governance controls, quality gates and trained teams established a repeatable approach for accessible publishing — one that would continue to operate after the engagement closed. That sustainability outcome is what differentiates operating-discipline work from one-off remediation: the standard now lives in the workflow, not in a project file.
05
What Was Built
The operating architecture that sustains the standard.
Operating-discipline work produces tangible structure. Below is the architecture that remains in use across the bank’s accessible publishing practice.
Published with permission. Specific metrics on document volumes and remediation progress withheld at the bank's request. Engagement substance verifiable through the artefacts produced and the operating cadence now in place.
06
What This Engagement Taught Us
Three lessons that hold whatever the industry.
01
Compliance work is operating-discipline work in disguise. Audits, remediation, SOPs and training are the same shape of engagement whether the standard is WHS, the Aged Care Act, or digital accessibility. The standard changes; the operating discipline behind it doesn’t.
02
Rationalise before you remediate. Removing outdated or unnecessary documents before remediation began materially reduced the workload — and the same principle holds in any compliance estate. The cheapest document to make compliant is the one you don’t need to publish at all.
03
The SOP is the project’s whole point. Remediation cleans up what exists today. SOPs decide what gets published tomorrow. An engagement that ends without the SOPs and the cadence to hold them is an engagement the client will have to repeat in two years.
- Selective engagements · Operating discipline at scale
We focus on construction, field service and care. We take exceptions when the work fits.
The Commonwealth Bank engagement sits outside our three priority sectors. We took it because the work — audit, remediation governance, SOPs, training, audit cadence — is the same operating discipline we bring to every engagement, applied to a regulated platform where the stakes were high.