A look at the European Commission Web Accessibility Action Plan



A look at the European Commission Web Accessibility Action Plan

A few weeks ago, the European Commission (EC) finally published the much-awaited web accessibility action plan 2022-2025. The plan was quietly added to its EU Web Guide, the official European Commission “rulebook” for its web presence, covering editorial, legal, technical, visual, and contractual matters. We had a look to find out how the European Commission plans to make its websites and mobile applications accessible to persons with disabilities.

 

Background

Some will remember that in 2016, the European Ombudsman opened a case on accessibility for persons with disabilities of websites and online tools managed by the European Commission, following the United Nations (UN) Committee on the rights of persons with disabilities first review of the EU’s compliance with the Convention on the Rights of Persons with Disabilities (UNCRPD). In July 2017, the EU Ombudsman decided to open a strategic inquiry to investigate the issues further. During this inquiry, persons with disabilities complained about specific issues, including the accessibility of the Commission’s online tool to register to participate in expert meetings and online platforms to facilitate policy debates and respond to public consultations, such as Have Your Say. The Ombudsman explained that web accessibility was a prerequisite for “full and effective participation in society on an equal basis with others”, as required under the UNCRPD, and that the failure to ensure online tools and platforms meet the highest standards of web accessibility undermined the rights of persons with disabilities.

In its reply to the Ombudsman’s strategic inquiry at the time, the Commission announced that it would adopt an action plan on web accessibility in 2018. The plan was unfortunately not published in 2018; it was announced in the European Strategy on the Rights of Persons with Disability 2021-2030 as an action to be delivered in 2021 but was finally published in the last quarter of 2022.

 

Guiding principles

In the action plan, the Commission says it will strive to ensure that persons with disabilities are able to interact with its digital channels on an equal basis with others. It also says that it aims to make its web presence “helpful and user-friendly for all, regardless of their different abilities, inviting collaboration with all, and, in so doing, reinforcing respect for human dignity and diversity’. It also says it will “actively involve persons with disabilities” when preparing and implementing its actions.

There is a commitment to regularly correct any shortcomings and to adapt to changes in user needs and developments in digital technology and to strive to follow universal design principles and take accessibility into account “from the very beginning for all web products”, from the planning and procurement stages to the design and development processes to ensure that they are accessible “from the outset”. This is welcome, as it is of course far more difficult to retrofit accessibility later on.

 

Actions and timeline

The Commission committed to strengthen and clarify the rules and guidelines on web accessibility in relation to its websites, mobile apps and digital content. To do this, it updated the accessibility section of the Europa Web Guide at the end of 2022 then promises to expand and periodically review its content.

Accessibility statements and feedback mechanism

In line with the provisions of the Web Accessibility Directive, all European Commission websites and mobile apps will have to publish an accessibility statement, based on an official template, for each website and mobile app. The plan states that there will also be a feedback mechanism so that users can flag accessibility problems, request information in an accessible format or make complaints. The Commission also makes a commitment to reply to complaints and carry out the necessary repairs in response to complaints.

The commitment was to publish accessibility statements on the main EC website and to make the technical modifications necessary to add one to all other corporate websites by the end of 2022. We checked: there is indeed an accessibility statement located on the main EC website, though it does not state that inaccessible content can be requested in an accessible format.

The other commitment is to publish accessibility statements on all other EC websites and mobile apps by the end of 2023.

Compliance monitoring

The Commission commits to monitor overall accessibility compliance across its web presence and to regularly evaluate a representative sample of its websites, at least annually, for conformance with the European Standard EN 301 549 (v 3.2.1) and to publish the findings in an annual progress report.

Awareness-raising, communication, and training

The Commission will prepare a plan for internal communication to mainstream accessibility into broader internal communication actions, and also provide accessibility training courses for staff, including those working on websites and mobile apps. Formal web accessibility training courses were expected to be incorporated into the Commission’s official training catalogue, starting this year.

The Commission will also continue to use its existing ICT and communications networks to share best practices to ensure accessibility standards are ‘easier to meet’.

Organisational coordination

In order to achieve the ambitions set out in this action plan, the EC says it will put the necessary structures and systems in place. Here the plan refers to a “task force on web accessibility”, set up in May 2021, to pool internal expertise and resources on web accessibility and define the actions to be taken. The Commission also says it will leverage its network of accessibility correspondents across all departments to help raise awareness of accessibility requirements for staff working on websites or digital tools; allocate clear responsibilities and resources to accessibility and establish an enforcement mechanism to ensure compliance; and regularly report on its progress toward accessibility compliance to the Corporate Communication Steering Committee (CCSC).

However, the timing for setting up the enforcement mechanism isn’t specified, and it is unclear if the progress report will be in the public domain.

So what’s missing?

While we welcome the plan as a helpful starting point, it is somewhat disappointing that some of the core recommendations the EU Ombudsman made to the European Commission 5 years ago appear to have been missed.

A focus on known priorities

The EU Ombudsman encouraged the European Commission to go beyond minimum requirements and stressed that it should be possible to prioritise content which should be provided in a format that meets the highest possible accessibility requirements such as webpages or online tools through which the public interacts with the Commission (e.g. complaint procedures or public consultations) or webpages providing basic information on the Commission’s work, including audio-visual content.

Removing, not adding, barriers to platforms

Furthermore, the Commission now requires authentication with “EU login” to access some online platforms, and this has made access more difficult for users with disabilities, as we explained in our response to the public consultation on the Web Accessibility Directive.

It is disappointing that the Commission’s plan appear to be silent on these well-known issues, not least because we have repeatedly called for improvements to key features of the Commission’s website such as “Have Your Say”, the online tool to participate in expert meetings , or the online platform of the Conference on the Future of Europe, which was a barrier to participation of persons with disabilities in this important democratic exercise. To date, there is still no accessibility statement on any of those websites.

Involving persons with disabilities

We regret the fact that we were not consulted in the preparation of the EC Web Accessibility Action Plan. But we are pleased that some European Commission teams are listening to us and are going beyond minimum requirements to ensure maximum inclusion with great results, as demonstrated in recent public consultations on the Web Accessibility Directive and on passengers’ rights.

We welcome the European Commission finally publishing a plan and hope to be involved when it is reviewed in the future. This will ensure the best possible outcome for millions of citizens with disabilities.

 

Related resources

Read the European Commission web accessibility action plan.

For more information on web accessibility, have a look at Frequently Asked Questions about the Web Accessibility Directive.