Public sector websites are often required by law to have an accessibility statement. With the recent European Accessibility Act (EAA), we can clearly see another spill-over effect of EAA – webpages and mobile apps in both public and private sector got their brand new accessibility statement in place. Some are required to do so because they are in the scope of EAA and some are doing it because they see it as a competitive advantage increasing their chances in the market. Unfortunately we can also quickly see that some are just using it for access- or accessibility washing (term borrowed from greenwashing – the deceptive practice of exaggerating or fabricating a organizations environmental friendliness to appear more sustainable than it actually is). Like we care, because we have the statement (even if the statement is actually not worth the bytes it requires).
Additionally – we can also see that accessibility overlays have an (hypothetical) positive side effect – as many of them also include accessibility statement. But once again – this seems to only be a copy-pasted content meant for showing off – look, we care about accessibility too – an obvious example of accessibility washing as it often just lies that “we care”, especially when we often see the exactly same statement copied on all the sites using the overlay.
When everybody partially conforms
I was curious and checked hundreds of accessibility statements, just to see how they are doing. Almost all stated partial conformance. Some even claimed full conformance (wrongfully). I haven’t found a single one that stated non-conformance (but many should).
Some were using outdated accessibility standards they are “partially conforming” to – I’ve even seen WCAG version 1 used in the statement. Interesting finding. Then there were some WCAG 2.0, which can be fair in some cases, but in Europe it can be a totally wrong standard to use (especially in public sector that “falls” under Web Accessibility Directive (WAD), which requires EN 301 549).
My speculation is that nobody wants to declare they are not conforming. Probably afraid of fines and their competition. But partially conforms as a statement is not very helpful when it can mean that we are close to compliance of when we just don’t know the real state and don’t want to claim we do not conform. Partially conforms can mean everything between totally inaccessible website or app to quite decently accessible one. So – not useful at all.
How can we improve this? Divide and conquer!
I love the Norwegian concept here – where all accessibility statements need to provide the details on the level of WCAG success criteria – basically all public sector organizations (and some private sector ones as well) need to go through the whole list of WCAG on levels A and AA and fill out if success criterion is passing or not. If not – what is not passing and if there are any alternative options.
Sure, we need to be aware that such accessibility statements are not perfect either. I’ve found quite some examples where people didn’t really know what success criteria issues belonged to, mixing 1.1.1 with 1.3.1, for example.
But nevertheless – this requirement of detailed reporting, the need to go on the success criteria level – made them think more than just copy pasting some text from another accessibility statement. And I also see that a lot of organizations reached out to accessibility specialists and organizations of people with disabilities to get help when they did the statements. Because it was obvious to them – you can not have a statement with such details if you do not know the guidelines and accessibility issues on your website or mobile app. And they learned a lot from the audits they usually got that were used as a basis for the statements. Which was kind of the whole point – you can only improve or fix what you know about.
Accessibility statements are too often out-of-sync with the page or app
In my brief research I’ve found statements from years back. And I knew the page was updated a week ago. It was very obvious that such accessibility statements were “set and forget”. Another compliance checkbox checked. The dates are communicating so much as well. In most cases legal requirements are that accessibility statement is updated at least once per year. So we can quickly see organizations actually breaking the law when the date of accessibility statements is long overdue. It’s so obvious. And it really does say a lot about the real state of accessibility efforts.
Updating the accessibility statement is not just updating the date of it
I’ve reached out to some organizations with issues with their accessibility and accessibility statements. Wanting to help. Sometimes wanting to sell my services, but often also just trying to help. And unfortunately I’ve seen quite a lot of examples when they just updated the date of the accessibility statement. Nothing more. The site was still full of accessibility issues, the statement was still lying, but they updated the date correctly.
It’s quite obvious when that happens as well. Especially for people with disabilities that know the page. And for accessibility specialists that see through the empty words of their statements.
Accessibility statement is primarily there for the user
Yet most of them seem to be there just to satisfy compliance and signal to authorities to “please do not fine us”. Totally missing the point. The main reason of accessibility statement should be to help users. Especially people with disabilities. In an ideal world we would not need an accessibility statement, because websites and apps would be accessible. But we know that is not the case, unfortunately. So we need to provide a contact point, and we need to at least try to help with alternatives.
Get your accessibility processes in place
Accessibility statement is just a small part of our accessibility efforts – should actually be a side-effect and not the main task. To make a useful and informative accessibility statement, we need to first know the state of accessibility. To know the state we need to measure it. Currently we do not have better standards and guidelines than European EN 301 549 (incorporating WCAG). Sure, they are not perfect either. And do not guarantee accessibility. But they help to prevent issues. And help to support assistive technologies and user preferences. If you can, you really should co-design with people with disabilities. But these guidelines are still very actual and remain to be. We need them to prevent basic issues, like for example naming interactive elements – that make things work for people, even if they need to use their voice to operate our interfaces.
Having processes in place makes accessibility statement a simple task. If we do not have the processes in place it also leads to accessibility statements that are not helpful, not relevant or even lying. And it then says a lot about our organization. Accessibility statement is not the point, it’s making sure our website or mobile app is as accessible as possible. Conformance does not make things usable for everybody, but is sure helps when basics are working.
Accessibility overlays and some magic artificial intelligence can over promise and under deliver. So please be careful. Overlays often introduce new accessibility issues and can never fix all issues. Because automatic testing and artificial intelligence (AI) can’t detect all issues – it should then be logical that if we can’t detect – we can’t fix. If that changes and AI will be able to detect issues we still have a lot of work and testing to do to make the fixes work. And even then we can still be far from the point where people will actually enjoy using our products.
Accessibility is a journey, continuous improvement and learning. Take action, make proper processes and systems to support it or it will fall out and your site or app will leave some users outside.
