[ebu response 4 September 2008] Public consultation on web accessibility and other e-accessibility issues

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[EBU response - 4 September 2008]

Public consultation on web accessibility
and other e-accessibility issues

Disclaimer: the text below is intended solely for consultation purposes. It does not represent the official position of the European Commission, nor does it anticipate any formal proposal from the Commission.


The European Commission wants to explore a common European approach for web accessibility for the three following reasons:

1) Disabled users continue to face great difficulties accessing websites: The development of the information society has led to the creation of websites and online services that are an essential part of daily life for many citizens. Yet significant numbers of people, including people with disabilities, continue to encounter difficulties using these websites due to accessibility barriers, despite technical solutions existing to overcome these barriers.
2) Divergent policy approaches to web accessibility in the Member States are fragmenting the market: An increasing number of countries, including EU Member States, are taking action to improve web accessibility, including through legal obligations. However, the existing divergence of national approaches is leading to increased fragmentation in the internal market. This fragmentation provokes legal uncertainty, particularly for technology providers, and makes it difficult for persons with disabilities to use online services freely across Europe.

3) Previous commitments and current opportunities: The institutions of the European Union have considered web accessibility in recent years1 and EU Member States have committed to improve web accessibility. In particular, the "Ministerial Declaration on an inclusive information society" (Riga, June 2006) included the commitment to make all public websites accessible by 2010. Despite the efforts deployed, we are still far from achieving this target2. It seems therefore appropriate to mobilise the EU Member States and relevant stakeholders to improve the situation, even though there are no web accessibility standards approved at the EU level yet3.

e-Accessibility relates to the use of any Information and Communication Technologies (ICT) by people with disabilities and other people with functional limitations, be they permanent or temporary. Despite various interventions by stakeholders including industry operators, authorities and user organisations, the overall level of e-accessibility in Europe remains relatively poor (e.g. for television, or self-service terminals)4.
In addition therefore to the priority actions on web accessibility, there are critical challenges to be considered in other key e-Accessibility areas.
For these reasons, the Information Society and Media Directorate-General of the European Commission has decided to launch a public consultation to gather opinions on:

    • A common European approach for web accessibility (Section 2);

    • Other aspects of e-accessibility and possible action at European level (Section 3).

Section 1 – common European approach for web accessibility
This section presents possible elements for actions by Member States that collectively would form a common European approach on web accessibility.
For each question, a choice of several possible answers is presented, please delete the answers which are not convenient for you.
A – Your experience of web accessibility
Please fill the questions relevant to your situation.

  • From the perspective of a person with disability

Question 1: What kind of accessibility problems do you encounter when using a website?
- Total inaccessibility

- Partial inaccessibility: I can only use some parts of the websites

- I do not generally have any problems accessing the websites I use

[x] - Other, please specify: you can provide examples of accessibility problems such as interoperability with assistive devices, difficulty to use images, etc.
[The growth and popularity of the internet means that blind and partially sighted people are facing increasing an number of barriers to participation as ever more web content is being produced and web applications being developed by ever wider online communities with little or no awareness of accessibility issues and standards.
EBU has already pointed out in previous responses to consultations that blind and partially sighted people, and indeed others disabled users, simply cannot access websites or use web applications when these are inadequately designed.
Blind and partially sighted people read electronic material in general, and online content in particular, by modifying the way in which it is presented. They may do this through magnification, transformation into synthetic audio or the use of a temporary or 'refreshable' Braille display.
Focus group research carried out in August 2008 by the Royal National Institute of Blind People in the UK shows that the most common accessibility issues for blind and partially sighted users of websites are: the lack of accessible links on webpages, graphic links invisible to screenreaders, small print that cannot be magnified, flash content, drop-down boxes and sponsor links confusing screenreaders.
EBU therefore believes it is essential that websites support the use of assistive technology, provide an alternative to information conveyed through images, and use technological protection measures that are interoperable with assistive technology, and that web applications are accessible.
For instance the use of web security measures such as CAPTCHA, which rely on users being able to see the screen and are intended to prevent non-human access to websites, also block access to screenreader users. The same is true of web-based software applications - for instance rich text editors and application-based emails - which give users increased functionality and the ability to interact with online communities, but are often inaccessible to blind and partially sighted people.]
- I am not concerned

Question 2: Do problems with website accessibility exclude or prevent you from accessing information, facilities and services that are important to you?

[x] - Yes, severely
[For instance, focus group research carried out by RNIB in the UK identified in particular the inaccessibility of social networking websites (for instance facebook) and websites of small businesses, but recognised that online banking and public websites had improved.
In the Netherlands, the requirements put on national public websites to be accessible has given good results and improved access, highlighting the impact of binding legislation: local public websites or online banking services, which are not submitted to these requirements, are still largely inaccessible.]

  • From the perspective of a website owner

Question 3: Are you aware of the issue of accessibility and of the implications for persons with disabilities using your website?

- Yes, I am fully aware

- Yes, I am partially aware

- No, I am not aware

- I am not concerned

Question 4: Have you taken steps to improve the accessibility of your website?

- No

- Yes (please specify what kind of steps you have taken)

- I am not concerned

  • From the perspective of a web technology provider

Question 5: Do you provide accessible technologies/do you include accessibility in your services?

- Yes, we always propose it to our clients

- Yes, when the clients request it

- No, please specify

- I am not concerned

Question 6: What are the main barriers for you when dealing with web accessibility?

- The lack of technical specifications

- The difficulty in implementing the technical specifications

- The lack of harmonised approach at European level

- The lack of demand

- Implementation costs

- [x] Other, please specify:
[Although we are not technology providers ourselves, we are more than aware of the fact that there is a lack of clarity and awareness among web technology providers about which standards and guidelines to use where there is a mixture of media types, integrated web and software applications, and when the supplier has markets in different countries.
There is also a tendency to assume that the WCAG guidelines can be applied to all elements of the web, and therefore to overlook specific guidelines related to website development tools and to the accessibility of software applications, such as the Authoring Tool Accessibility Guidelines (ATAG).
It is also important to note that the delays and the long timescales involved in developing standards and guidelines (see WCAG 1.0 and WCAG 2.0) often push individual countries and producers to develop their own guidelines which meet their current practical needs. Even though these are usually based on existing international standards and guidelines, the divergence leads to a lack of harmonisation across countries.]

- I am not concerned

B – A common European approach
A common approach on web accessibility by EU Member States would aim at ensuring that access to websites for people with disabilities is improved. The Riga Ministerial Declaration target is for 100% of public websites to be accessible for persons with disabilities by 2010. However, according to the study "Measuring e-accessibility in Europe", in 2007 only 5% of public websites and 3% of private websites were accessible.
A common European approach for web accessibility would also aim to stimulate the internal market by:

  1. Enabling more users to access websites and services across Europe,

  2. Offering sellers access to a larger market across the EU, and

  3. Giving providers of web-based ICT solutions access to a more coherent internal market that is not fragmented due to different web accessibility requirements.


If Member States adopt a common approach to improving the accessibility of websites across the European Union, this could:

  • Help all citizens, in particular persons with disabilities, to make use of the Internet to improve their participation in society and the economy, and

  • Improve the competitiveness of European businesses in accessible information and communication technologies by removing barriers to the provision of enabling technologies and services for web accessibility, thereby also stimulating the well functioning of the market of services provided over the internet as well as offering better access for potential online customers across the EU.

Question 7: Do you agree that a common European approach is needed to facilitate a high level of availability of accessible websites?

[x] - Yes
[EBU believes it is crucial that this European approach is developed in coordination with action at the international level, in order to ensure further harmonisation In this respect the "21st Century Communications and Video Accessibility Act" which was tabled in the USA on 19th June 2008 should be kept in mind. Please see the answer to question 25 for more on this Act.
The emerging Accessible Rich Internet Application (ARIA) guidelines, software accessibility standards such as ISO 9241-171, updates to the American Section 508, and the development of standards and guidelines relating to procurement (such as mandate 376), ergonomics and usability all need to be considered alongside pure web guidelines when developing a common European approach.
As technologies and platforms are increasingly converging, leading people to access web content in many different ways, consideration should also be given to international standards and guidelines relating to broadband access, mobile technologies and telecommunications and digital TV.]
Question 8: Do you agree that a common European approach should be motivated by improving the situation of people with disabilities, and at the same time by improving the competitiveness of European companies?

[x] - Yes

C – Websites concerned
Although the Riga Ministerial Declaration focused on public websites only, many other websites are essential for the daily life of European citizens. Websites providing services of general interest such as education, health and social services and telecommunication services, can be provided by both the public and the private sectors5.

If Member States take action to improve accessibility, this could concern public websites, namely websites of public authorities at national, regional and/or local level that provide information or services to citizens, as well as websites intended for the general public and providing online information and interactive services relating to services of general interest to citizens, provided by others than public authorities.
Question 9: Do you agree that if Member States take action, this should cover not only public websites, but also other websites providing services of general interest to citizens?

[x] - I strongly agree

- Please elaborate your response as appropriate

[At the 2006 Riga Ministerial Conference on "ICT for an Inclusive Society", Ministers of the EU Member States decided to ensure accessibility of all public websites by 2010 through compliance with the relevant W3C common web accessibility standards and guidelines, and to enhance web accessibility and usability by fully implementing existing e-Accessibility legislation and reinforcing it.
Although evidence shows that several Member States have started to address web accessibility issues, according to the Riga Dashboard 2007 only 5.3% of government websites are fully compliant with the basic accessibility guidelines. The situation greatly varies from one Member State to another, as some Member States have put in place accessibility requirements for public websites and others haven't. For instance, in the Netherlands, the web guidelines for public authorities cover not only web accessibility but also how to build a website that is easy to maintain use on all platforms.
EBU therefore believes forthcoming legislation should require public authorities, bodies funded or licensed by the public sector, bodies with a remit to serve all citizens (such as entities that provide basic services for the public such as public transport operators, gas/electricity providers, banking, healthcare, social security, education and training providers etc.) and organisations of special relevance to elderly and disabled people, to make their websites accessible by following the Web Accessibility Initiative (WAI) guidelines, possibly AA-level conformance to WCAG 2.0.
As mentioned before, it is crucial that this European approach is developed in coordination with action at the international level, in order to ensure further harmonisation.
In the US, section 508 of the Disabilities Act already requires that all Federal agencies ensure that their electronic and information technology is accessible to disabled people whenever those agencies develop, procure, maintain or use such technology, and is currently being updated.
In the UK, the British Standards Institution (BSI) and former Disability Rights Commission (now EHRC) have also developed a Guide to good practice in commissioning accessible websites (PAS 78).
The emerging Accessible Rich Internet Application (ARIA) guidelines, software accessibility standards such as ISO 9241-171, and the development of standards and guidelines relating to procurement (mandate 376), ergonomics and usability all need to be considered alongside pure web guidelines when developing a common European approach.
Finally, as technologies and platforms are increasingly converging, leading people to access web content in many different ways, consideration should also be given to international standards and guidelines relating to broadband access, mobile technologies and telecommunications and digital TV.]

D - Implementing web accessibility
A common approach on web accessibility would mean that actions are taken by all Member States to prepare for the introduction and implementation of modern specifications on web accessibility.

In order to contribute to a high level of availability of accessible websites by 2010 of the websites of public authorities, Member States are expected to take into account in their actions the work to achieve widely recognised international and European specifications. In particular they should seek alignment with the results of international standards on Web Content Accessibility and comply with the outcomes of the work in the framework of Mandate 376 granted to the European Standardisation Organisations, thereby supporting accessibility of websites deploying modern web technologies and applications.
Specific actions of Member States could comprise:

  • Making available, updating and publishing technical guidance relating to web accessibility requirements, translating where appropriate relevant documentation;

  • Identifying websites concerned, set targets and milestones;

  • Allocating responsibilities for implementing the actions;

  • Providing references for training, schemes for knowledge sharing, and awareness measures;

  • Assessing and monitoring progress and making public progress reporting;

  • Collecting experiences on the implementation of technical guidance for web accessibility.

Member States could also promote the accessibility of intranet websites in line with the Employment Equality Directive.
Similarly, Member States could promote the accessibility of websites from others than public authorities which provide services of general interest to citizens.
Member States could encourage website owners to include an accessibility statement in their websites which provides supporting information such as: main lines of the accessibility policy of the institution concerned; degree of compliance with relevant legislation and/or reference specifications; support foreseen for persons with disabilities, etc.
Question 10a: Do you agree with the following statements?
Please note that for each statement below you have to choose between I strongly agree, I agree, I disagree, I strongly disagree or I don't know. Simply delete the answers as appropriate.
Statement 1: Member States should seek alignment with the results of international standards on Web Content Accessibility and should comply with the outcomes of Mandate 376

[I strongly agree]
Statement 2: The above-mentioned actions will contribute to a high level of availability of accessible websites

[I agree]
Statement 3: Intranet websites should be encouraged to be accessible

[I strongly agree]
Statement 4: Other websites (providing services of general interest) should be encouraged to be accessible

[I strongly agree]
Statement 5: Websites should be encouraged to include an accessibility statement

[I strongly agree]

Question 10b: Do you have any other comments or suggestions for other actions that Member States should take?

Please specify.

[EBU believes a European approach to web accessibility should also seek to drive the creation of a market in accessible tools and support services and to ensure a level-playing field for all stakeholders. In particular, it will be essential for Member States to encourage the training of software developers, web developers and web development teams so that they understand the needs of disabled people and use these standards.
It is important to ensure that developers of content management and other systems providing output for web interfaces have a good level of accessibility knowledge. These systems allow contributions by an increasingly wide range of users. To fail therefore to make them accessible to disabled people would run counter to this widening of access to ICT. EBU believes legislation could make a reference to this.
It is important to note that whatever action is taken to encourage the development of web accessibility, it should not result in the closing down of other information channels, such as telephone, print and over-the-counter information. A multi-channel approach is still needed for all the citizens that do not have access and for those who do not know how to use ICT products and services, or cannot afford them.]

E - Website authoring tools
To best safeguard and efficiently implement web accessibility, website authoring tools can be used to automatically provide for (the larger part of) accessibility. Authoring software tools are any software, or collection of software components, explicitly used to create, design or modify websites.

If Member States pursue web accessibility, they could also address such website authoring tools in order to address the whole process of a website development and operation.


Member States could encourage public administrations to use and procure website authoring tools that are designed to specifically assist with the production and maintenance of accessible websites, in accordance with the public procurement Directives.
Question 11: Do you agree that authoring tools should also be addressed by the common approach of the Member States?

[Yes. This is crucial. If these tools are not accessible and do not facilitate accessible websites, the Internet will continue to be inaccessible to disabled people. ]

F - Accompanying measures
Accompanying measures could aim at strengthening the actions of Member States and spreading their impact more widely by deploying knowledge and awareness of web accessibility at various levels. Training and awareness are essential to ensure that web accessibility is taken into account at the earliest design stage. Training schemes can be put in place at different levels (web managers, web masters, web content developers…) and be deployed at national, regional and local levels. Likewise exchanges of good practices at European level would greatly facilitate a common approach.
A single contact point in each Member State may also be useful to provide information and guidance to users, and to allow information about the state of accessibility to be coherently collected. As accessibility of information and communication technologies is also relevant beyond the web, it may be useful to concentrate e-accessibility information and guidance in one location.

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