Equality Julia Taylor Learner Experience Policy & strategy Productivity/assistive technology Quality improvement Uncategorized

Web and app accessibility – make the most of the EU Accessibility directive

On 23rd of September 2018 a new EU Directive  came into force in the UK. The new regulations mean that public sector websites and mobile apps will need to be accessible to all users, especially those with disabilities. The regulations will remain part of UK law regardless of our future relationship with the EU.
So new websites published on or after 23rd of September 2018 will have to be compliant within one year and existing websites within two years. Some organisations and types of content do not need to meet the new standards but FE and HEIs are being defined as ‘public sector bodies’.

“There is more to meeting the ‘Accessibility Requirements’ than filling in a checklist. It could take a year to implement changes so there’s good reason to get started now!” says Julia Taylor, accessibility subject specialist at Jisc.

Checklist being 'ticked off'
Accessibility statements are not just WCAG checklists

Unless your organisation is exempt, and a few small colleges may be, you must both:

  • meet accessibility standards – The Accessibility Requirement to be defined in December 2018
  • publish an accessibility statement – based on a model to be published in December 2018

Meeting Accessibility Requirement

The regulations say you have to make your website or mobile app more accessible for disabled people by making it perceivable, operable, understandable and robust.’

Perceivable means that information and user interface components must be presented to users in ways they can perceive in some way -i.e. it can’t be invisible to all of their senses, or ‘invisible’ if they use an assistive technology.

Operable means that any person must be able to use interface components and navigation – i.e. buttons and forms can’t require interaction that a user can’t perform, for example requiring the use of a mouse because the designer hasn’t taken non-mouse users into account.

Understandable means users must be able to understand any information presented, as well as being able to operate the interface i.e. the content or operation cannot be beyond their understanding. Which has implications for the readability of the accessibility information.

Robust means that the content must be capable of being interpreted reliably by a wide variety of user agents, including assistive technologies such as screen readers – it also means users must be able to access the content as technology changes over time.

Accessibility Statement

Legally, the accessibility statement will need to include:

  • a list of any parts of the website or app that are not accessible, an explanation of why, and links to accessible alternatives where appropriate
  • a way for users to tell if any content does not meet the accessibility requirements, and to request an alternative for any information they are excluded from
  • details of the official enforcement procedure that people can use if they are dissatisfied with the response

Improving Usability

The standard is EN 301 549.53 based on WCAG 2.0 compliance. Reviewing your accessibility statement should be seen as an opportunity to check ‘usability’. All too often the only aim of the accessibility statements has been listing compliance criteria – which in itself is not helpful to users. Many assistive technology users have to navigate the entire page before they can even find it. A good statement will add value for disabled users by giving them practical advice on how to improve their experience right there and then, with web browser features or add-ons, or by explaining how to turn on the captions for videos. Used in this way, the Accessibility Statement can become a resource for students rather than purely a legal document.

Increasing Accountability

One key impact of the directive will be to actively involve users in promoting improvements by enabling a dialogue to take place. You will be required to state your progress and users will be invited to feedback their experiences directly, putting the focus on responsive, practical solutions.

This could be seen as a daunting prospect; with increasingly digital delivery there’s a great deal to monitor and manage. We recommend drawing up an inclusive digital strategy. There are some key considerations to support better usability that will serve as a starting point.

Educate and involve everyone

Educate yourself and colleagues – this is down to teamwork. Involve developers, they should be using WAI-ARIA techniques to make code accessible to assistive technologies. They should know enough about the basics of those technologies, such as screen readers, to be able to validate that the user experience will be good enough.

Test and test again

Automated testing is easy and free with (pa11y and WAVE) but it can only auto-check about 30% of the accessibility (#a11y) issues that disabled uses experience according to accessibility expert (@stevefaulkner). So it’s important that teams don’t rely on these tools alone. ‘Regular’ user testing will be a requirement under the new directive. At Jisc we always advocate user testing in our access and inclusion snapshot reports because this will reflect and help you pre-empt problems users will be asking you to resolve.

Review guidance and standards on styles

Designers will need to re-assess aspects of the design and layout such as colour contrast, page navigation and ‘reflow’.  Editors will have to consider how accessible the written content is, they will need to provide alternative text whenever relevant and (live video is exempt) captions or transcripts for videos. Your organisation’s style guidance will need to be reworked to ensure these new expectations are used as a baseline by everyone who will be creating content now, and into the future; for example, marketing teams will need to ensure that branding does not break colour contrast guidelines.

Creative an effective feedback loop

However, this should not be seen as a finished piece. The directive is intended to encourage continuous improvement. There is specific mention of the requirement to encourage user feedback and a clear expectation that users will be involved in bringing about improvements when and wherever they encounter problems. You will need a clear, easy to access statement, an accessible communication channel (possibly by social media – e.g @fbaccess, @MSFTEnable) and effective responsive systems planned, in advance, to support this process effectively.

Be explicit about what you want

Managers will have to plan for accessibility, so it makes sense to fit accessibility testing into their business processes. They can make both manual and user testing part of the ‘definition-of-done’ that is required to sign-off digital projects. Where content, sites or apps are being commissioned, these criteria will have to become explicit in the procurement process. It will not be enough to rely on no-one reading or understanding the lengthy WCAG requirements because the buck will stop with you not the contractor!

So the strategy is to set clear standards and make your requirements explicit. Jisc Accessibility & Inclusion diagnostic services can help you with that. Speak to your Jisc account manager now –


Accessible virtual learning environments – making the most of the new regulations- All Party Parliamentary Group for assistive technology report

Guidance New accessibility regulations for public sector websites and apps –




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