Some thoughts on how I think Web Accessibility Directive can be improved

(Read 162 times)

I am honored to be a part of a group of experts that will provide some feedback to European Union on accessibility and Web Accessibility Directive. This post is a summary of my ideas that will be in the article with some additional thoughts and context.

I’ve been invited to make some improvement suggestions to Web Accessibility Directive that will be summarized in the form of a professional article. I feel quite honored and will make a post about the article when it will be published.

In this post I will summarize my main points and hopefully others will join in the discussion in the future.

Centralized accessibility statement solution

I love the concept from Norwegian authorities that require all public sector webpages to have their accessibility statement saved in central repository (in Norwegian, opens in new tab). To me this is an amazing advantage for authorities, public sector and general public as well.

Some key advantages:

  • unified template / format for all accessibility statements – makes it easier for owners, authorities and general public,
  • centralized quality assurance for authorities that have an always up to date overview of reported failures, update dates, missing accessibility statements and so on,
  • centralized database that makes reporting to European Union as effective as possible,
  • easy to upgrade for future requirements (like for European Accessibility Act (EAA) in private sector).

Data is unfortunately not publicly available and it is unknown if it will be in the future, but that would be another suggestion – to make all reports and statistics publicly available.

I understand that EU doesn’t want to centralize too much but in theory they could provide the same solution for all countries and get even better data if they wanted. I guess politics is/was trying to let each country to be as independent as possible but on the end of the day a centralized solution would save some time (money), dilemmas and make things easier for all parts.

As far as I know there are some other countries with similar centralized solutions and my suggestion would be to at least centralize on a per country level if it’s not possible on whole EU level.

Publicly available accessibility evaluations

Similar as with centralized solution for accessibility statements it would be beneficiary to have a centralized solution that would list all available accessibility evaluations of the entire public sector. Some parts could be fetched from accessibility statements and some from manual and automatic audits that need to be done.

Transparency could engage public sector to be more pro-active and to implement better processes towards accessibility of their webpages and web apps. I guess publicly available scores would motivate stakeholders to invest properly into accessibility.

I stumbled upon publicly available accessibility evaluation data in the Netherlands where they actually have a Digital Accessibility Dashboard (in Dutch, opens in new window). I don’t have the data about how motivational this concept is but I believe it does promote some improvements and maybe even demands to make better efforts and get better scores. I am aware that accessibility is about people and not getting better scores, but at the same time there are some people that need numbers to be convinced, so let’s give them numbers as well.

Extend WAD to critical private sector as soon as possible

WAD is the minimum in EU and each country can go beyond. I loved the fact that Finland actually did that and they require also parts of private sector to have same accessibility requirements as with public sector.

They decided that some critical private sector organizations like for example banks and finance institutions fall under WAD as well.

This is also wise in my opinion and was a strategical move towards earlier implementation of European Accessibility Act in my opinion.

We can argue that EAA will come soon enough, but reality shows that it’s still difficult to make the web accessible and I guess private companies that need to do it before EAA at least have a better chance to do it until EAA. Time will show, and I hope we will have some data publicly available to check this hypothesis out.

Standardized automatic and manual accessibility testing

Automatic accessibility testing has it’s problems, but I still love the speed and effectiveness of tools that can quickly check thousands of webpages for obvious accessibility issues or at least indications of them.

If we need to manually check 50 pages for 50 success criteria and we only use 2 minutes per criteria we arrive to approximately 83 hours needed. Automatic tool can check those 50 pages in approximately 16 minutes (depending on page complexity) and provide us with approximately up to a third of potential WCAG failures.

The main issue here is which tool to use as there are a lot of tools with different methods, different interpretations and therefore also different results. Some tools like to flag potential issues and some like to only flag when the error is certain (no false positives). Some tools are open sourced and totally transparent and some are closed sourced and also not-free. At the same time some open sourced tools don’t have enough attention and have a lot of open bugs that make their results even less valuable.

There are a lot of tools that try to use the same ruleset (Accessibility Conformance Testing rules (ACT-rules) for example), multiple even financed by different EU programs, but majority of states would really like to get a single tool to use and to refer to.

I’ve tried to suggest this in some WAD meetings online but got a feeling that again EU authorities doesn’t want to dictate which tool to use. I guess it’s again an political decision that tries to make things more liberal. At the same time it makes automatic accessibility testing for authorities in countries, for private sector stakeholders and for companies that provide their services to public sector very difficult as they all use different tools and with different results they don’t really know what is right and what is wrong.

I will not suggest a single tool now, but I would like to standardize the choice for all. Some countries, like Denmark decided to use QualWeb (opens in new window) and some, like Ireland) decided to use axe core, the same that I used for my aXeSiA tool.

On a similar note my suggestion would also be to unify the interpretation of WCAG for manual testing as a lot of time and effort goes to that as well. I’ve seen at least 4 different interpretations, all very similar, but at the same time not identical. Norway, Sweden, Germany and France all have their own interpretations and I am not familiar with all the details but I’ve seen some differences in some success criteria.

This makes the situation even more confusing and I would really like that whole EU would use the same tests. This is again, I suspect, a political thing – letting some independence to different countries, but for practical scenarios again a barrier towards better accessibility across EU.

To conclude – standardization and centralization would help a lot

We have standards that are the same in all EU countries and beyond and we have centralized solutions like in the world financial markets, so I don’t really get the tendency to let each and every country come up with their own solutions. Some parts are very technical and should in my opinion be treated like that. Templates, statistics, tools and methods are all very technical and I guess their unification and standardization would for sure save some time, effort and money. I don’t want the bureaucratic rules to dictate everything but in this case I think it would benefit the state of accessibility somehow. Money, time and efforts could be spent in better ways.

It’s the same as with European Mandatory roadworthiness test;

Under EU law, unannounced roadside inspections of commercial vehicles can be carried out in any EU country, whether or not the vehicle is registered in the EU.

An official website of the European Union on Mobility and Transport (opens in new window).

So why shouldn’t we have the same tools and rules in the whole EU?

Author: Bogdan Cerovac

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

Work as Agency co-owner web developer and accessibility lead.

Sole entrepreneur behind IDEA-lab Cerovac (Inclusion, Diversity, Equity and Accessibility lab) after work.

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: