Norwegian digital accessibility legislation in 2023

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In 2023 we got some updates to Norwegian accessibility legislation and I try to summarize the newest situation in this short post.

After reading useful post from Lainey Feingold called Digital Accessibility Laws Around the Globe (opens in new window) I decided to write a short update on Norwegian digital accessibility legislation to provide latest info from Norway.

In short all public facing websites and mobile applications need to be accessible, but conformance to standards like WCAG is different for private and for public sector. Now private sector doesn’t really mean each and every website (or app) there is. It has to offer services or information as a primary channel. So majority of private organizations are covered, but if some artist makes a portfolio site for herself it isn’t really covered in the legislation. Official definition about private sector that needs to comply (Norwegian language, opens in new window).

Self-service machines are also required to be accessible, but I will not cover them in this blog post. Official info about self-service machines (opens in new window).

As a general rule, digital solutions in working life are not covered by the requirement. Professional systems that you only have access to as employee of the business are not covered, for example:

  • Content Management System (CMS),
  • case management system,
  • system for time registration and travel invoices,
  • other professional systems.

Online maps and map-based systems are also not covered by the legislation.

Private and public sector have different conformance requirements

Stakeholders had to decide what to do with private sector after the implementation of Web Accessibility Directive into Norwegian legislation. Multiple solutions were suggested (Norwegian language, opens in new window) as conformance with Web Content Accessibility Guidelines (WCAG) version 2.0 on A and AA level (with some success criteria being an exception) was already in place. At the end they landed on different requirements for different sectors.

Private sector still needs to conform to WCAG 2.0 on levels A and AA

Private sector websites and mobile applications need to conform to 35 WCAG 2.0 success criteria besides exceptions:

  • 1.2.3 Audio Description or Media Alternative (Prerecorded) (Level A),
  • 1.2.4 Captions (Live),
  • 1.2.5 Audio Description (Prerecorded) (Level AA).

This applies to both old and new websites and applications from 2021.

Official information about private sector (Norwegian language, opens in new window).

Public sector needs to conform to WCAG 2.1 on levels A and AA

With the implementation of Web Accessibility Directive into Norwegian legislation all public sector websites and mobile applications need to conform to WCAG 2.1 on levels A and AA with some exceptions (actually the legislation defines European standard EN 301 549 v3.2.1 as it’s base, but the standard is based on WCAG 2.1).

Intranet companies’ internal website for employees) is also required to conform in same way, but professional systems mentioned in the beginning are still not required to be accessible (CMS,…).

WCAG success criteria that are exceptions at the moment:

  • 1.2.3 Audio Description or Media Alternative (Prerecorded) (Level A),
  • 1.2.4 Captions (Live),
  • 1.2.5 Audio Description (Prerecorded) (Level AA) – not an exception from 1st of February 2024 (more info below).

Official information about public sector (Norwegian language, opens in new window).

As mentioned are audio description related success criteria currently (!) an exception. This will change after 1st of February 2024, when prerecorded videos published by public sector will have to have audio descriptions (1.2.5 Audio Description (Prerecorded) (Level AA)).

It will be required for all public sector prerecorded videos except those published by primary and secondary school (unless video recording is linked to important web-based administrative functions).

Official information about audio description (Norwegian language, opens in new window).

Conclusion – WCAG 2.1 on A and AA is the actual target

In my experience with organizations from both sectors WCAG 2.1 on A and AA levels is the actual target already now.

Especially for new solutions or parts of them it really doesn’t make sense to stop at WCAG 2.0. And with recent “soon to be ready” signals about WCAG 2.2 I’ve actually detected that some organizations try to implement version 2.2 in some parts as well.

Disclaimer: I am not a lawyer and this is not legal advice. This is for informational purposes only. Please consult official sources provided in this blog post and The Authority for Universal Design of ICT (opens in new window).

Author: Bogdan Cerovac

I am IAAP certified Web Accessibility Specialist (from 2020) and was Google certified Mobile Web Specialist.

Work as digital agency co-owner web developer and accessibility lead.

Sole entrepreneur behind IDEA-lab Cerovac (Inclusion, Diversity, Equity and Accessibility lab) after work. Check out my Accessibility Services if you want me to help your with digital accessibility.

Also head of the expert council at Institute for Digital Accessibility A11Y.si (in Slovenian).

Living and working in Norway (🇳🇴), originally from Slovenia (🇸🇮), loves exploring the globe (🌐).

Nurturing the web from 1999, this blog from 2019.

More about me and how to contact me: