European Accessibility Act requires culture to shift!

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I am a bit biased towards technical parts of accessibility, but when I studied EAA even more, I finally understand why it does not try to be technical.

I focus a lot on the technical details of accessibility, perhaps because it is easier there. At least we have some stability and control.

Sometimes I also write about organizational strategies for accessibility, but I like to have my hands in the code and sometimes design and content. But after studying more about European Accessibility Act (Directive (EU) 2019/882, shortly EAA, opens in new window), I couldn’t avoid wondering why it does not define technical requirements. Where is the reference to EN 301 549 or at least WCAG? Where is the technical requirements part? Well, there is just a reference to the four principles of WCAG and that is it… EAA mentions the four principles of accessibility of websites and mobile applications as used in Web Accessibility Directive (Directive (EU) 2016/2102, shortly WAD), and we know that WAD uses EN 301 549, where Web Content Accessibility Guidelines (WCAG) are essential.

But, it’s not so simple – the EAA also refers to “Design for all”. And Design for All is actually an European standard, called EN 17161:2019 (opens in new window). And it is quite essential in the context of European Accessibility Act.

Design for All – another accessibility standard

Design for All is not a technical standard, at least not when compared with WCAG or EN 301 549. I’ve bought it (it is unfortunately not available for free) and studied the ins and outs.

And I have news for you!

EAA specifies Design for All and Design for All is pretty much talking about a culture shift in organizations with – yes, you’ve guessed – Design for All in the center.

At first I need to say that I was a bit disappointed, but after learning more about it – it totally makes sense – we need first to shift cultures that will then respect the technical standards – in a nutshell.

Design for All does not mention success criteria or anything like that in the terms of engineering. Not a word about semantics and HTML or ARIA. It tries to improve the organization, so that it’s culture shifts and embraces accessibility and beyond – have a design for all, universal design if you want.

So basically – it is a standard for the organizational aspects.

When we think about it – accessibility really starts and ends with people

People that consume and make services and products, in a nutshell. And people that create things need planning, processes, leaders, operations, evaluations and if they really want to succeed – continuous improvement.

And this is what Design for All is all about as a standard.

Leadership is central for change. And even more for cultural change. And we have seen it many times – accessibility can’t be a project. It can’t be a thing that comes at the quality assurance alone. It needs to be integrated into overall processes. Even before we touch design, when we plan for it.

Shifting accessibility left needs to be applied to the whole organization, not only on design, code and content.

Personal reflection

To make such changes in an organization we need leadership support, we need policies, we need trainings, we need awareness, we need top-to-bottom and bottom-to-top motivation. We need change management.

And this is quite covered in the Design for All standard, but not on a low level.

Keep in mind that such changes always need context and it is impossible to prescribe all possible contexts for all types and sizes of organizations. It takes time, experience and innovation to apply such standards to specific organizations.

So – yes – I am basically saying (once again) – it depends – when you will ask “how can we apply Design for All to my organization“? Standard touches that as well, but we will always need to adjust the theoretical parts to your specifics, as always.

After falling into many “rabbit holes”, I am now certain – European Accessibility Act requires Design for all implementation. Perhaps even conformance to technical standards alone will not be enough for some organizations (especially when we know that total conformance is practically impossible for larger organizations).

Embracing (and really living) Design for All will at least communicate our sincere efforts for accessibility and – here is the catch – when we will embrace Design for All – we will also embrace continuous improvement and fix any new barriers with time.

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.

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