BeneVets Accessibility Statement

Effective Date: July 4, 2026 Last Updated: July 4, 2026 Document Number: 05 of 18 (BeneVets Legal Document Set)

1. In Plain English: What This Statement Says

BeneVets, Inc. ("BeneVets") is committed to making our website and web application (together, the "Service") usable by every veteran who needs it, including veterans with disabilities. This Statement tells you:

• What we have done. We design and build the Service to meet the Web Content Accessibility Guidelines (WCAG) 2.2 at Level AA, which is the standard that federal courts and the U.S. Department of Justice most often look to when judging whether a website is accessible.
• What we are aiming for. We aim for full conformance with WCAG 2.2 Level AA, and we tell you below where we are not there yet and when we expect to fix it.
• How to tell us about a problem. If something on the Service does not work for you, including with a screen reader, with keyboard-only navigation, with screen magnification, or with any other assistive technology, we want to hear about it. Email accessibility@benevets.org or call the number in Section 18 of this Statement. We will respond within ten (10) business days.
• What this Statement does not do. It does not waive any right you have under the Americans with Disabilities Act (ADA), Section 504 of the Rehabilitation Act, Section 508 of the Rehabilitation Act, California's Unruh Civil Rights Act, or any other federal, state, or local accessibility law.

2. BeneVets's Commitment

BeneVets, Inc. is a California Nonprofit Public Benefit Corporation organized under Cal. Corp. Code § 5110 et seq. and recognized as a tax-exempt public charity under § 501(c)(3) of the Internal Revenue Code. Our mission is to help U.S. military veterans, their spouses and adult dependents, and their authorized representatives navigate U.S. Department of Veterans Affairs ("VA") benefits and related federal, state, and nonprofit programs. That mission cannot be fulfilled if a veteran with a disability cannot use the Service.

BeneVets therefore commits to the following:

1. Standard. BeneVets adopts WCAG 2.2 Level AA as the conformance standard for the Service, including all primary user-facing surfaces, transactional emails, and generated documents.
2. Process. BeneVets integrates accessibility review into design, engineering, and quality assurance. Automated accessibility testing runs in continuous integration. Manual assistive-technology testing runs on a defined cadence (see Section 9).
3. Transparency. BeneVets publishes this Statement, discloses known limitations honestly, and commits to a remediation timeline for each known limitation.
4. Accommodation. BeneVets provides a feedback channel and an accessible-alternative request process. The designated Accessibility Officer is Ian Martin.
5. No-cost remediation. BeneVets does not charge users to receive content in an accessible alternative format.

3. Standards BeneVets Targets

In plain English: We measure ourselves against three accessibility standards: the international web standard (WCAG), the U.S. federal procurement standard (Section 508), and the international accessible-PDF standard (PDF/UA-1).

3.1 Web Content Accessibility Guidelines (WCAG) 2.2, Level AA

BeneVets targets the Web Content Accessibility Guidelines (WCAG) 2.2, W3C Recommendation, 5 October 2023, at Conformance Level AA. WCAG 2.2 organizes accessibility requirements under four principles: Perceivable, Operable, Understandable, and Robust (the "POUR" principles). Each principle contains testable Success Criteria ("SC").

Success Criteria that BeneVets treats as design constraints include, among others:

• SC 1.1.1 Non-text Content (Level A) - every meaningful image carries a text alternative.
• SC 1.3.1 Info and Relationships (Level A) - semantic HTML conveys structure to assistive technology.
• SC 1.3.5 Identify Input Purpose (Level AA) - form fields use autocomplete attributes per the WCAG-defined input purpose taxonomy.
• SC 1.4.3 Contrast (Minimum) (Level AA) - text contrast is at least 4.5:1 for normal text and 3:1 for large text.
• SC 1.4.10 Reflow (Level AA) - content reflows without horizontal scrolling at 320 CSS pixels of width.
• SC 1.4.11 Non-text Contrast (Level AA) - interactive component boundaries and meaningful graphics meet 3:1.
• SC 1.4.12 Text Spacing (Level AA) - content remains usable when users override line height, paragraph spacing, letter spacing, and word spacing per the SC threshold.
• SC 2.1.1 Keyboard (Level A) - every interactive element is operable from a keyboard.
• SC 2.1.4 Character Key Shortcuts (Level A) - single-character key shortcuts can be turned off or remapped.
• SC 2.4.1 Bypass Blocks (Level A) - a persistent "Skip to main content" link is the first focusable element on every page.
• SC 2.4.3 Focus Order (Level A) - focus order matches reading order.
• SC 2.4.7 Focus Visible (Level AA) - focus indicator is visible and meets the SC 2.4.11 minimum (Level AA, new in 2.2) and SC 2.4.13 minimum (Level AAA, treated as a target).
• SC 2.4.11 Focus Not Obscured (Minimum) (Level AA) - focused elements are not entirely covered by sticky headers, footers, or other overlays.
• SC 2.5.7 Dragging Movements (Level AA, new in 2.2) - no operation requires dragging only.
• SC 2.5.8 Target Size (Minimum) (Level AA, new in 2.2) - interactive targets are at least 24 by 24 CSS pixels, with documented exceptions only where the SC allows.
• SC 3.2.6 Consistent Help (Level A, new in 2.2) - help mechanisms (including the feedback channel in Section 11) appear in a consistent order across pages.
• SC 3.3.7 Redundant Entry (Level A, new in 2.2) - information the user has already provided in a process is not requested again, except where re-entry is necessary (e.g., security re-authentication).
• SC 3.3.8 Accessible Authentication (Minimum) (Level AA, new in 2.2) - authentication does not rely on a cognitive function test alone; see Section 6.2 on the multi-factor authentication limitation.
• SC 4.1.2 Name, Role, Value (Level A) - custom interactive components expose accessible name, role, and value to assistive technology, using ARIA only where native semantics are insufficient.
• SC 4.1.3 Status Messages (Level AA) - non-modal status messages are exposed to assistive technology without taking focus.

Subsequent references in this Statement use short form (e.g., "SC 1.4.3").

3.2 Section 508 of the Rehabilitation Act

If BeneVets enters into a federal procurement or grant relationship that triggers Section 508 of the Rehabilitation Act, 29 U.S.C. § 794d, BeneVets will conform to the Revised 508 Standards at 36 C.F.R. Part 1194, which incorporate WCAG 2.0 Level A and Level AA by reference. Because WCAG 2.2 Level AA is a superset of WCAG 2.0 Level AA, WCAG 2.2 Level AA conformance by BeneVets satisfies the WCAG-derived portions of the Revised 508 Standards.

The Functional Performance Criteria at 36 C.F.R. § 1194.5 are addressed in Section 7 below.

3.3 PDF/UA-1 (ISO 14289-1)

BeneVets targets PDF/UA-1 (ISO 14289-1) for all PDFs generated by the Service, including VA form pre-fills and Compensation and Pension ("C&P") examination preparation briefings. As disclosed in Section 6.1, BeneVets is not yet fully conformant with PDF/UA-1 and has scheduled remediation.

4. Conformance Level

In plain English: "Substantial conformance" means we meet WCAG 2.2 Level AA across most of the Service today, with specific exceptions listed in Section 6. We are working toward full conformance.

BeneVets currently self-asserts substantial conformance with WCAG 2.2 Level AA, subject to the known limitations enumerated in Section 6. BeneVets's forward-looking commitment is full conformance with WCAG 2.2 Level AA across all in-scope surfaces, with measurable progress reported in each update to this Statement.

This self-assertion is not a third-party audit. BeneVets commits to commissioning a third-party accessibility audit within twelve (12) months of v1 launch.

5. Scope of This Statement

In plain English: This Statement covers BeneVets's website and web application, transactional emails we send, and PDF documents we generate for you. It does not cover sites we link to or content you upload.

This Statement covers the following surfaces operated by BeneVets, Inc.:

1. The public website at benevets.org (the "Site").
2. The authenticated web application reached from the Site.
3. Transactional email messages sent by BeneVets (account, security, link-state, Intent-to-File reminders, form-related notices).
4. PDF documents generated by the Service, including VA form pre-fills and C&P preparation briefings.
5. Public policy and disclosure pages, including this Statement.

This Statement does not cover:

1. Third-party websites or documents linked from the Service, including primary regulatory sources at va.gov, the eCFR, or other federal, state, or nonprofit sites.
2. Content uploaded by users (e.g., a user's DD-214, profile photos, symptom-log entries). See Section 6.4.
3. Third-party assistive technologies, browsers, or operating systems, the behavior of which BeneVets does not control.
4. The Veterans Crisis Line and other third-party crisis resources referenced in Section 8.

6. Known Limitations and Remediation Timeline

In plain English: Here is what is not yet fully accessible, and when we plan to fix each item. We disclose these honestly so you can decide whether to use the Service and so you can request an accessible alternative if you need one.

6.1 Generated PDFs are not fully PDF/UA-1 tagged

Limitation. PDFs generated by the Service, including VA form pre-fills and C&P preparation briefings, are not yet fully tagged for screen-reader users in conformance with PDF/UA-1 (ISO 14289-1). Reading order, heading semantics, and form-field labels are partially tagged. Some decorative content is not marked as artifact. Some tables lack header associations.

Impact. A screen-reader user may experience inconsistent reading order, missing form-field labels, or unannounced tabular relationships when consuming a generated PDF directly. The underlying VA form, downloaded from VA, may also have its own accessibility limitations outside BeneVets's control.

Workaround available today. A user may request a plain-text or HTML version of any generated document at no cost via the channel in Section 11. BeneVets will provide the alternative within ten (10) business days of the request, or sooner if the request is time-sensitive (e.g., an Intent-to-File deadline under 38 C.F.R. § 3.155).

Remediation target. six (6) months of v1 launch.

6.2 Multi-factor authentication relies on TOTP

Limitation. BeneVets's optional multi-factor authentication ("MFA") relies on the Time-based One-Time Password ("TOTP") standard (RFC 6238). TOTP requires the user to read a six-digit numeric code from an authenticator application and enter it within a 30-second window. This may present challenges for users with cognitive impairments (working-memory load), motor impairments (rapid typing), or low vision (reading small numeric text on a phone screen).

Impact. A user who cannot reliably complete a TOTP challenge may be unable to enroll in or use MFA, reducing account-security options.

Workaround available today. MFA is optional, not required, for account access. Users who enroll in MFA are issued single-use backup codes at enrollment, printable and reusable as account-recovery credentials; backup-code recovery is documented in the in-app Help Center. BeneVets does not gate any core feature on the ability to complete a TOTP challenge.

SC 3.3.8 analysis. WCAG 2.2 SC 3.3.8 Accessible Authentication (Minimum) (Level AA) requires that authentication not depend solely on a cognitive function test. Because BeneVets offers email-plus-password authentication (with password manager autofill) as the baseline, and because MFA is optional and accompanied by backup codes, BeneVets considers this SC to be met. BeneVets is evaluating WebAuthn / passkey support, which would be the preferred accessible MFA path.

Remediation target. WebAuthn / passkey support targeted within nine (9) months of v1 launch.

6.3 Some long-form regulatory content may exceed plain-language reading-level targets

Limitation. Some long-form regulatory content (e.g., direct quotation of VA regulations under 38 C.F.R., recitation of TDIU schedular thresholds under 38 C.F.R. § 4.16(a)) may exceed the Flesch-Kincaid Grade 8 reading-level target that BeneVets applies to plain-English summaries. WCAG 2.2 SC 3.1.5 Reading Level is Level AAA and is not a Level AA conformance requirement, but BeneVets treats it as a quality target.

Impact. A user with limited language, cognitive, or learning abilities may find the formal regulatory text difficult to read.

Workaround available today. Every operative section opens with a plain-English summary box at Grade 8 or below. A glossary of VA acronyms is provided in the Service. Users may request a plain-language explanation of any regulatory passage at no cost via the channel in Section 11.

Remediation target. Plain-English summary coverage of every regulatory section by six (6) months of v1 launch.

6.4 User-supplied content is not subject to BeneVets's alt-text validation

Limitation. Content that users upload to the Service (e.g., profile photos) is not subject to BeneVets's alt-text validation. BeneVets does not generate, edit, or override alt text on user-supplied content.

Impact. A screen-reader user encountering a user-supplied image may not receive descriptive alternative text.

Workaround available today. BeneVets provides in-product documentation of alt-text best practice at the point of upload and prompts the uploader to provide a text description. Users may report missing or inadequate alt text on user-supplied content via the channel in Section 11; BeneVets will work with the original uploader to address.

Remediation target. Required alt-text-on-upload prompt for all user-supplied images by six (6) months of v1 launch. Note that the Service does not host user-generated content beyond profile photos at v1 (per master context Section 2).

6.5 Third-party embeds and external links

Limitation. Some external resources linked from the Service (e.g., the eCFR, va.gov, the Veterans Crisis Line chat at veteranscrisisline.net) are operated by third parties whose accessibility BeneVets does not control.

Impact. A user following an outbound link may encounter accessibility issues outside the scope of this Statement.

Workaround available today. BeneVets flags outbound links in the user interface, summarizes the linked content in plain English where possible, and offers to mediate the request via the channel in Section 11.

7. Functional Performance Criteria (Section 508 Subpart C, 36 C.F.R. § 1194.5)

In plain English: Section 508 asks: can a person with each of these disability profiles actually use the Service? Here is our analysis for each profile.

7.1 Without Vision

BeneVets tests the Service with the following screen readers: NVDA on Microsoft Windows and VoiceOver on Apple macOS and Apple iOS, with additional spot-checks using JAWS on Microsoft Windows. Semantic HTML is used in preference to custom-role ARIA wherever native semantics are available. ARIA is applied per the W3C "ARIA Authoring Practices Guide" and validated to prevent the "first rule of ARIA" violation (do not use ARIA when native HTML suffices). A persistent "Skip to main content" link is the first focusable element on every page (SC 2.4.1). Live regions are announced via aria-live with appropriate politeness. Focus is managed on modal open and close.

7.2 With Limited Vision

The Service supports browser zoom to 200% and 400% without loss of content or functionality (SC 1.4.4 Resize Text, SC 1.4.10 Reflow). Text-spacing accommodations are supported (SC 1.4.12). Color contrast meets the WCAG 2.2 Level AA minimum: 4.5:1 for normal text, 3:1 for large text and non-text contrast (SC 1.4.3, SC 1.4.11). Focus indicators are visible and meet SC 2.4.11 Focus Not Obscured (Minimum). The Service does not rely on color alone to convey information (SC 1.4.1).

7.3 Without Hearing

The Service does not contain audio-only content at v1. Where the Service references the Veterans Crisis Line in Section 8, the crisis affordance is surfaced via text and chat in addition to telephone. Any future audio or video content will carry captions and a transcript (SC 1.2.1, SC 1.2.2).

7.4 With Limited Hearing

Same as Section 7.3. Captioned and transcribed alternatives will accompany any future audio or video content.

7.5 Without Speech

The Service does not require voice input for any operation. Click-to-call affordances (e.g., the Veterans Crisis Line) are accompanied by text and chat alternatives so that a user without speech can reach crisis support without speaking.

7.6 With Limited Manipulation

No interaction in the Service requires a dragging gesture as the sole means of operation (SC 2.5.7 Dragging Movements, new in WCAG 2.2). Interactive target sizes meet SC 2.5.8 Target Size (Minimum) (24 by 24 CSS pixels), with documented spacing exceptions only where the SC allows. The entire Service is operable from a keyboard alone (SC 2.1.1 Keyboard, SC 2.1.2 No Keyboard Trap).

7.7 With Limited Reach and Strength

Same as Section 7.6. No interaction requires sustained pressure or fine motor control beyond standard pointer click or keyboard activation.

7.8 With Limited Language, Cognitive, or Learning Abilities

Every operative section of every public legal document begins with a plain-English summary at Flesch-Kincaid Grade 8 or below. Crisis-adjacent content targets Grade 6. A glossary of VA acronyms (e.g., "C&P," "TDIU," "ITF") is provided. Multi-step processes display step progress and allow back-navigation without data loss (SC 3.3.7 Redundant Entry, new in WCAG 2.2). Error messages identify the field in error and suggest correction in plain language (SC 3.3.1, SC 3.3.3). Timeouts on authenticated sessions disclose duration in advance and offer extension (SC 2.2.1).

8. Crisis Content Accessibility

In plain English: Help is always one keyboard step away. Every page that you can reach, signed in or not, has the Veterans Crisis Line on it, reachable by phone, text, chat, or TTY.

A crisis affordance is persistently surfaced on every authenticated and unauthenticated surface of the Service. The affordance is keyboard-reachable on every page, carries an accurate screen-reader accessible name, and meets SC 1.4.3 contrast and SC 2.5.8 target-size requirements.

The Veterans Crisis Line is a free, confidential service of the U.S. Department of Veterans Affairs, available 24 hours a day, 7 days a week:

• Call: 988, then press 1
• Text: 838255
• Chat: https://www.veteranscrisisline.net/get-help-now/chat/
• TTY: Dial 711, then 988

BeneVets, Inc. does not operate this line.

The call, text, chat, and TTY affordances are presented together so that a user without hearing, without speech, or without the ability to use a touchscreen has at least one usable path to the resource. The chat link opens the Veterans Crisis Line's own chat at veteranscrisisline.net, the accessibility of which is governed by the U.S. Department of Veterans Affairs and is outside the scope of this Statement (see Section 5).

Additional crisis-and-support resources are surfaced where contextually appropriate:

• VA Homeless Veterans Hotline: 1-877-424-3838
• Women Veterans Call Center: 1-855-829-6636
• VA Caregiver Support Line: 1-855-260-3274
• SAMHSA National Helpline: 1-800-662-HELP (4357)

9. Testing Methodology

In plain English: Here is how we actually test the Service for accessibility. We use real assistive technology on real devices, automated tools in our build pipeline, and manual review by trained reviewers.

9.1 Assistive Technology Tested

• NVDA (NV Access) on Microsoft Windows, latest two stable releases.
• VoiceOver on Apple macOS, latest two major OS releases.
• VoiceOver on Apple iOS, latest two major iOS releases.
• TalkBack on Google Android, latest two major Android releases.
• JAWS (Freedom Scientific) on Microsoft Windows, latest stable release, used for spot-check parity with NVDA.

9.2 Browsers Tested

• Google Chrome - latest two major versions.
• Apple Safari - latest two major versions on macOS and iOS.
• Mozilla Firefox - latest two major versions.
• Microsoft Edge - latest two major versions.

9.3 Automated Tools

• axe-core (Deque Systems), integrated via jest-axe in the BeneVets automated test suite. Accessibility unit tests run on every pull request and block merge on regression.
• Lighthouse accessibility audit, integrated into continuous-integration; report archived per release.
• Pa11y for sitewide accessibility crawl on a quarterly cadence.

Automated tools surface a subset of accessibility issues. Manual assistive-technology review remains the authoritative test for conformance.

9.4 Manual Review Cadence

• Per feature. Every new user-facing feature is reviewed against an internal accessibility checklist derived from WCAG 2.2 Level AA before release.
• Quarterly. A full manual assistive-technology pass is performed on the top 20 user journeys.
• Annual. A third-party accessibility audit is commissioned within twelve (12) months of v1 launch and annually thereafter.

[NOTE FOR WALTER: confirm that the AT, browser, and tool inventory above matches what is actually tested today. If any item is aspirational rather than implemented, move it from this Section to a "Planned" subsection.]

10. Voluntary Product Accessibility Template (VPAT)

In plain English: A VPAT is the standard document that organizations use to disclose, line-by-line, how their product measures up against accessibility standards. We will publish one and update it regularly.

BeneVets commits to publishing a VPAT 2.5 Rev 508 within ninety (90) days of v1 launch, and to updating the VPAT on a quarterly cadence thereafter. The VPAT will use the standard Information Technology Industry Council ("ITI") VPAT template and will cover the WCAG 2.2 Level A and Level AA, Revised 508 Standards, and EN 301 549 reporting columns.

Until the first VPAT is published, BeneVets's WCAG 2.2 Success Criterion support is summarized as follows:

11. Feedback and Accommodations Channel

In plain English: If something does not work for you, email us. If you cannot email, call us. We respond in ten business days or less. If you need help right away, say so and we will move faster.

11.1 How to Reach Us

• Email: accessibility@benevets.org
• Telephone: available on request via accessibility@benevets.org
• Postal mail: BeneVets, Inc., Attn: Accessibility Officer, 1441 Pomona Road, Suite 20, Corona, CA 92882
• In-product: A "Report an accessibility problem" link is present in the persistent footer on every page (SC 3.2.6 Consistent Help, new in WCAG 2.2).

11.2 Response SLA

BeneVets commits to:

1. Acknowledgement of every accessibility report within two (2) business days of receipt.
2. Substantive response - including a remediation plan, a workaround, or an accessible alternative - within ten (10) business days of receipt.
3. Time-sensitive escalation. If the report identifies a time-sensitive deadline (e.g., an Intent-to-File deadline under 38 C.F.R. § 3.155, a Notice of Disagreement deadline, or a C&P examination date), BeneVets prioritizes the report and responds with a workaround within two (2) business days.
4. Closure. Each report is tracked to closure. The reporter is notified when remediation ships.

11.3 Accessibility Officer

The designated Accessibility Officer for BeneVets, Inc. is Ian Martin. The Accessibility Officer is responsible for: receiving reports, coordinating remediation, maintaining this Statement, maintaining the VPAT, and reporting to the BeneVets Board of Directors on accessibility metrics on at least an annual basis.

12. Accessible-Alternative Request Process

In plain English: If any content on the Service is not accessible to you, ask us for it in another format. We will provide it within ten business days, at no cost.

A user may request an accessible alternative to any content on the Service. Accessible alternative formats available include:

• Plain-text rendering of any generated PDF (e.g., VA form pre-fill, C&P preparation briefing).
• HTML rendering of any generated PDF.
• Large-print rendering (an inline browser zoom to 200% or 400% is supported natively; a high-contrast print stylesheet is available on request).
• Audio readout via the user's screen reader of choice (BeneVets does not provide a proprietary audio narration but ensures all content is screen-reader accessible).
• Plain-language explanation of any regulatory passage that exceeds the Grade 8 reading-level target.
• Mediated form completion with a BeneVets staff member, by telephone, for any user who cannot complete a form independently due to a disability.

To request an accessible alternative, use any channel in Section 11.1. BeneVets does not charge for accessible alternatives.

13. Language Availability

In plain English: The Service is offered in English. We do not offer the Service in other languages at this time. If you need help in another language, contact us using the channel in Section 11 and we will do our best to assist.

The Service is offered in English only at v1. BeneVets does not currently provide a Spanish-language or other-language version of the Site, application interface, transactional emails, or generated documents.

Title VI / LEP note. If BeneVets receives federal financial assistance, Title VI of the Civil Rights Act of 1964, 42 U.S.C. § 2000d, and Executive Order 13166 (Aug. 11, 2000) may require meaningful access to limited-English-proficient ("LEP") persons, which is commonly satisfied by Spanish-language access in the U.S. veteran population. Title VI scope is tracked alongside the Section 504 trigger discussed in Section 15.

14. ADA Title III Posture

In plain English: The Americans with Disabilities Act says that "places of public accommodation" must be accessible to people with disabilities. Courts have applied this to websites in various ways. We follow WCAG 2.2 Level AA, which is the standard the U.S. Department of Justice and the federal courts most often look to.

BeneVets, Inc. is a private nonprofit organization. The U.S. Department of Justice's April 24, 2024 final rule on web and mobile application accessibility for state and local government entities under Title II of the Americans with Disabilities Act, codified at 28 C.F.R. Part 35, does not apply to BeneVets because BeneVets is not a state or local government entity. That rule mandates WCAG 2.1 Level AA for Title II covered entities.

BeneVets is potentially subject to Title III of the ADA, 42 U.S.C. § 12181 et seq., which prohibits discrimination on the basis of disability by "places of public accommodation." The federal circuits are split on whether a website standing alone is a "place of public accommodation":

• The Ninth Circuit (where California is located) holds that the ADA applies to a website with a nexus to a physical place of public accommodation. Robles v. Domino's Pizza, LLC, 913 F.3d 898, 905 (9th Cir. 2019) ("The ADA applies to the services of a place of public accommodation, not services in a place of public accommodation.") (emphasis in original).
• The Eleventh Circuit has held that a website that is not itself a "place" and lacks a nexus to a physical place is not covered. Gil v. Winn-Dixie Stores, Inc., 21-12997 (11th Cir. Dec. 28, 2021) (en banc rehearing later vacated as moot; underlying panel reasoning withdrawn - citation retained for historical posture).
• The First and Seventh Circuits have applied the ADA to websites without a physical-place nexus.

Whether or not Title III applies as a matter of doctrine, BeneVets adopts WCAG 2.2 Level AA as its conformance standard, consistent with the U.S. Department of Justice's enforcement precedent (including the DOJ's settled position that WCAG is the appropriate benchmark for web accessibility) and with industry practice in the federal-civil-rights private bar. BeneVets's adoption of WCAG 2.2 Level AA is intended to support an affirmative defense and a litigation-readiness posture if any Title III claim is asserted.

BeneVets is also subject to the Unruh Civil Rights Act, Cal. Civ. Code § 51, which incorporates ADA violations as Unruh violations per Cal. Civ. Code § 51(f). BeneVets's WCAG 2.2 Level AA conformance commitment is intended to mitigate Unruh exposure as well.

15. Section 504 of the Rehabilitation Act

In plain English: If BeneVets gets federal money (a grant, for example), another law called Section 504 also applies. We commit to following Section 504 whether or not it currently applies, because the standard is the same.

Section 504 of the Rehabilitation Act, 29 U.S.C. § 794, prohibits disability-based discrimination by any program or activity receiving federal financial assistance. If BeneVets receives federal financial assistance - including any federal grant, federal contract under which BeneVets is the recipient (not merely the vendor of an accessible product), or other federal funding - Section 504 attaches to the Service, and Section 508 may attach to procurement and grant deliverables.

[NOTE FOR WALTER: confirm whether BeneVets currently receives federal financial assistance, or is in active pursuit of federal grants. If yes, Section 504 attaches today, and additional procedural requirements may apply (designation of a Section 504 coordinator, adoption of grievance procedures, self-evaluation under 28 C.F.R. § 41.5). Coordinate with counsel.]

Regardless of Section 504's applicability, BeneVets's WCAG 2.2 Level AA commitment in this Statement applies to the Service.

16. International Accessibility Standards

In plain English: We do not target users outside the United States. If you happen to use the Service from outside the U.S., we still aim for the same standard.

BeneVets does not market the Service to users in the European Economic Area or the United Kingdom. The European Accessibility Act, Directive (EU) 2019/882, applies primarily to products and services offered to consumers in the EU and is being transposed by Member States with compliance dates from June 28, 2025. Because BeneVets does not target EU users (per master context Section 3), the European Accessibility Act is not BeneVets's primary compliance frame. For any incidental EU user, BeneVets's WCAG 2.2 Level AA conformance commitment is the operative standard, which aligns substantially with EN 301 549 v3.2.1 referenced by the European Accessibility Act.

17. Updates to This Statement

In plain English: We will update this Statement as the Service changes, as remediation lands, and at least once a year. The Last Updated date at the top tells you when.

BeneVets reviews this Statement at least annually and updates it when:

1. A new feature ships that changes the accessibility surface of the Service.
2. A known limitation in Section 6 is remediated or closed out.
3. A WCAG version is updated by W3C (e.g., a future WCAG 3.0) and BeneVets adopts the new version.
4. A statutory or regulatory change (e.g., a new DOJ rule, a Section 508 refresh) materially changes BeneVets's obligations.
5. A third-party audit produces findings that change the conformance posture.

The "Effective Date" and "Last Updated" lines at the top of this Statement reflect the most recent update. A change log is maintained on request via the channel in Section 11.

18. Contact Information

Accessibility feedback and accessible-alternative requests:

BeneVets, Inc. Attn: Accessibility Officer 1441 Pomona Road, Suite 20 Riverside County, California

Email: accessibility@benevets.org Telephone: available on request via accessibility@benevets.org

Designated Accessibility Officer: Ian Martin

General BeneVets contact (non-accessibility):

BeneVets, Inc. 1441 Pomona Road, Suite 20, Corona, CA 92882 Riverside County, California Production domain: benevets.org

19. Cross-References to Other BeneVets Legal Documents

This Statement is incorporated by reference into the BeneVets Terms of Service (Document 01) and is referenced by the BeneVets Privacy Policy (Document 02). It does not amend or replace either document.

End of Document 05 - Accessibility Statement.