5. Key results and overall implications
5.1 Implications for web accessibility policies
5.1.1 National level approaches
Public service websites are not fully compliant with WCAG 2.0 guidelines in any of the countries covered, even if some countries and/or services show better results than others. All countries would benefit from reinforcing their policy approaches to web accessibility.
Public web managers typically make at least some efforts in this area, some more than others. However, levels of attention and approaches to web accessibility vary considerably, and there are many challenges experienced by web managers in optimally addressing and achieving accessibility.
The availability of national level support/competence structures seems to be very helpful (e.g. as in the case of Germany); all countries could consider developing support structures and processes, such as skills development as well as specific tools to support development of accessible websites.
Most web managers reported that their procurement policies included
requirements on the accessibility of websites. The level of specificity of these requirements varied somewhat, but most referred to WCAG standards. If public procurers incorporate accessibility requirements when procuring for related services (web applications, CMS, external functionalities, forms, documents, etc.), higher levels of accessibility can be achieved.
Based on the web audits and the interviews with web managers, it seems that often accessibility problems arise not because accessibility is not given any attention, but because of structural barriers that constrain web manager
organizations in taking a more structured approach to web accessibility in their day-to-day operations. These include resource restrictions and the need to
balance accessibility requirements with other organisational requirements, deficits in keeping awareness/knowledge at required levels over time, a lack of tools to support staff in achieving/maintaining accessibility on an ongoing basis,
accessibility standards by web managers, and management of the production of content by external content providers.
5.1.2 EU level approaches
Public service websites are not fully compliant with WCAG 2.0 guidelines in any of the countries covered, even if some countries and/or services show better results than others. There are also differences across countries in the aspects of web accessibility being addressed. There is therefore a strong rationale for reinforcing the EU policy approach to web accessibility in order to encourage more harmonised accessibility experiences for public service users across the Member States.
The accessibility analysis of a set of public sector websites across Europe shows that much work has to be done before the websites covered in the proposed Directive meet the requirements of WCAG 2.0 level AA. The list of public website analysed is relatively short (12 key services), but there are a wide range of public services at national, regional and municipal level that are under the umbrella of public websites of key interest for people with disabilities and older people. Therefore, these 12 key services can be a way to foster best practices in accessibility among public websites at large. It is important that EU initiatives involve all public websites regardless of administrative level, even websites in public-private partnerships, websites developed with public funding and commercial websites of public interest.
The importance of public web content makes especially relevant the debate regarding the accessibility of new content (for example, ensuring the production of accessible contents generated by the corporative CMS) and the retrofitting of existing content (for example retrofitting huge volumes of existing PDF
documents). At European level, it is also relevant to provide indicative and feasible deadlines for the public website to meet the requirement of WCAG 2.0 level AA, these should probably differentiate between existing content and new content.
The costs for public service web managers to substantially improve accessibility of websites seems unlikely to be a major issue in most cases. Public web
managers generally consider web accessibility to be part of their public duty and do not give much attention to tracking any costs associated with this. However, economic constraints have put pressures on web development resources in most organisations with implications also for accessibility work. There were also some concerns about potential costs in some areas, such as where large volumes of legacy documents might be required to be made fully accessible.
The availability at national level of support/competence structures seems to be very helpful. Consideration could be given to the development of EU level supports and/or shared approaches across the Member States in this area. Based on the sample of public service web managers covered in this study, there appears to be a reasonable level of openness to a common EU wide monitoring of the accessibility of public websites. Nevertheless, there were some concerns that a monitoring regime might ultimately become a bureaucratic exercise with low value for the web managers’ day-to-day operations and high requirements being placed on the web managers. Various issues around the scope and content of a common monitoring approach were also mentioned. If monitoring was to be used for comparative purposes, then care would be needed to ensure that
comparisons took into account the wide differences that exist in the complexity and scale across public service websites. In general there was a positive attitude to monitoring. In particular is was perceived to be desirable that the monitoring should provide operationally useful feedback to the web managers as opposed to being intended to be used in a negative manner (e.g. as a basis for imposing sanctions).