COTS (Commercial Off-The-Shelf)

What is COTS (Commercial Off-The-Shelf)?

COTS stands for "Commercial Off-The-Shelf" and refers to mainstream software or hardware products that are readily available for purchase and use without custom development. These products are designed for general use across multiple organizations rather than being tailored for a specific buyer's unique requirements.

Common examples of COTS products include:

  • Office productivity suites (Microsoft Office, Google Workspace)
  • Learning Management Systems (Canvas, Blackboard)
  • Customer Relationship Management (CRM) software
  • Enterprise Resource Planning (ERP) systems
  • Video conferencing platforms
  • Web browsers and plugins

COTS and Digital Accessibility

In the context of web accessibility and digital inclusion, COTS products present unique challenges and considerations. Organizations must assess these products for accessibility compliance before implementation, especially when used in:

  • Educational institutions (schools, universities)
  • Government agencies
  • Healthcare facilities
  • Corporate workplaces
  • Public-facing services

Under regulations like the Americans with Disabilities Act (ADA), Section 508, and WCAG guidelines, organizations are responsible for ensuring their digital tools are accessible to users with disabilities, regardless of whether the software was developed in-house or purchased as a COTS solution.

Accessibility Standards and COTS

When evaluating COTS products for accessibility compliance, organizations should reference:

  • WCAG 2.1 AA standards - The international standard for web accessibility
  • Section 508 - US federal accessibility requirements
  • EN 301 549 - European accessibility standard
  • BFSG (Germany) - German Accessibility Strengthening Act

These standards provide benchmarks for measuring whether COTS products meet accessibility requirements for users with visual, auditory, motor, and cognitive disabilities.

Implementation and Procurement Best Practices

Organizations should integrate accessibility evaluation into their COTS procurement process:

Pre-Purchase Evaluation

  • Request Voluntary Product Accessibility Templates (VPATs) from vendors
  • Conduct accessibility audits or request third-party assessments
  • Test products with assistive technologies (screen readers, keyboard navigation)
  • Include accessibility requirements in RFPs and contracts

Post-Implementation

  • Provide accessibility training for end users
  • Establish feedback mechanisms for accessibility issues
  • Monitor for product updates that may affect accessibility
  • Maintain documentation of accessibility compliance efforts

Common Mistakes and Misconceptions

Organizations often make these critical errors when dealing with COTS accessibility:

  • Assuming vendor compliance - Many vendors claim accessibility without proper validation
  • Ignoring user testing - Technical compliance doesn't guarantee usability for people with disabilities
  • Postponing accessibility evaluation - Waiting until after purchase limits options and increases costs
  • Focusing only on obvious disabilities - Overlooking cognitive and temporary disabilities
  • Treating accessibility as optional - Legal requirements apply regardless of product origin

CMS and Platform Considerations

For web-based COTS products and Content Management Systems, additional considerations include:

  • Ensuring content creation tools support accessible markup
  • Verifying that themes and templates meet WCAG guidelines
  • Testing plugin and extension compatibility with assistive technologies
  • Maintaining accessibility when integrating multiple COTS solutions

Best Practice Takeaway

The key to successful COTS accessibility implementation is proactive evaluation and ongoing commitment. Organizations should establish clear accessibility criteria before procurement, maintain regular assessment schedules, and view accessibility as an essential requirement rather than an optional feature. This approach ensures digital inclusion while protecting against legal risks and improving user experience for all stakeholders.

Remember: purchasing COTS products doesn't transfer accessibility responsibility from your organization to the vendor. The end user's experience remains your accountability under accessibility compliance regulations.