DOL's 2024 framework puts accessibility into AI hiring procurement

Write inclusion into the buying question

A request for proposals that asks only about accuracy, speed, integration, and bias testing can still miss whether a candidate with a disability can complete the process. Define the recruiting task, the people affected, the accessibility standard, the accommodation path, and the evidence expected before vendors demonstrate features. Include application, assessment, interview scheduling, communication, identity checks, and support—not just the ranking model. Procurement should be able to compare what a vendor claims, what the employer has tested, which barriers remain, and who can stop use if the system prevents equal participation.

Test with affected people and real workflows

A conformance statement is useful but does not reproduce the candidate journey. Test representative tasks with people who use assistive technologies and with varied disabilities, devices, languages, and connection conditions. Examine time limits, keyboard navigation, screen-reader behavior, captions, color and motion, instructions, error recovery, document upload, proctoring, and the ease of requesting an accommodation. Compensate participants and protect their data. Record the tested version and configuration so a later interface, model, or vendor change does not inherit an accessibility conclusion it has not earned.

Make accommodation a supported route

A footer email address is not an operational accommodation process. Candidates need a visible, timely path that does not require disclosing more health information than necessary or penalize them in the selection workflow. Name the team that receives requests, the response target, available alternatives, escalation owner, and method for reconnecting an accommodated assessment to the correct application. Recruiters and hiring managers should know what the AI system did, what they may override, and how to avoid treating an accommodation or inaccessible result as evidence about job capability.

Monitor access as a hiring outcome

Post-launch review should look beyond aggregate selection rates. Track abandonment, accommodation requests, support contacts, inaccessible-step reports, override patterns, and time to resolution by stage while respecting privacy and avoiding new surveillance. Give candidates a way to report problems and receive a meaningful response. Contract for notice of material changes, access to relevant testing evidence, incident cooperation, and remediation. The 2024 framework helps CHROs structure this work, but the employer still must determine which legal duties, accessibility requirements, labor practices, and data protections apply to the actual hiring process.

Turn this source into a reviewable decision

For AI for CHROs, use this briefing as a dated decision record rather than a substitute for the source. Preserve U.S. Department of Labor, the exact URL, the July 26, 2026 review date, the supported facts above, the editorial interpretation, the limitations, and any buyer-specific evidence. Link that record to the decisions most directly affected: Recruiting and candidate support; HR policy and employee service; Skills intelligence and internal mobility; Workplace AI governance and change. State whether the source changes the scope, evidence requirement, control, sequence, or only the language used to describe the decision.

Before action, name the accountable owner, affected population and workflow, exact offering or configuration, source data and rights, human decision point, exception and appeal path, complete cost, expected benefit, failure and stop conditions, retained evidence, and next review date. Keep official facts, provider statements, buyer observations, representative tests, measured outcomes, editorial inferences, and unknowns visibly separate. Reopen the record when the source, offer, model, integration, data, policy, population, responsible person, or measured result changes.

Limitations and unknowns

This briefing covers a September 2024 DOL news release and the framework it announced. DOL now warns that information in some releases dated before January 20, 2025 may be out of date or may not reflect current policies. The resource is not a product certification or a finding that a particular hiring system is accessible, nondiscriminatory, valid, or legally compliant. Applicable duties depend on jurisdiction, employment context, disability and accessibility law, the tool, its configuration, and the full candidate process.