Cabinet Office
The findings from the survey are clear. Online public services have a long way to go before they are fully accessible and inclusive. However, this research indicates that policy engagement is linked to the eAccessibility of government services and that rapid improvement is achievable through coordinated effort by those who are best placed to effect change – the public policy-makers in the EU, web managers and developers in public sector organisations and web designers in the software industry. We provide 21 detailed recommendations to be adopted by these key stakeholders.
This study is unique in its coverage of web accessibility across the EU’s public sector at the national and EU levels, i.e. central government and European institutions. The results of the policy survey indicated that, whilst there is considerable strategic support for eAccessibility, there is significant diversity in approach and in many instances, little in the way of incentives, training or accreditation. Given the cultural and governmental diversity across EU Member States, this comes as no surprise, but there is much that governments can learn from each other due the variety of approaches taken.
Current incentives range from legal requirements (e.g. in France, Germany, Italy, Ireland) to the less formal, peer-group approach (e.g. in Austria, Denmark, Malta, UK). This report shows that both approaches can prove successful, but a combination of the two approaches brings maximum leverage in realising improved accessibility.
Training was identified as an area of weakness, but it is clearly an activity that needs to run parallel to any hard or soft incentives. In particular, there is a need for the W3C WAI guidelines to be made available in all EU languages. Further training and support documentation also need to be made accessible to all. This could be further enhanced by an EU-wide eAccessibility accreditation programme.
The report defines an index of engagement in policy towards eAccessibility, listing both hard and soft incentives. Countries which reported activities in a high proportion of policy areas were given a higher index. Through statistical analysis, the report shows that a high index of engagement implies greater eAccessibility of public services. Adoption of incentives across the board has shown the strongest link with improvements in eAccessibility.
This study breaks new ground by using a blend of automated and manual techniques for evaluating eAccessibility across the EU. 436 websites were tested against the W3C WAI WCAG 1.0 guidelines and some interesting results were found. The overall picture shows that there is still much work to be done, but this report identifies key areas of concern which, if dealt with, would lead to the situation improving significantly.
The research for this report found that 3% of sites achieved Level A conformance. A further 10% passed the automated testing, but difficulties were identified during manual testing. Many sites continue to omit alternative text for images. Where provided, it was often found to be inappropriate or ineffective. Where frames were used, they often appeared without titles or equivalent alternatives. By addressing these issues alone, the total number of sites achieving a Limited Pass at Level A could increase to 30%.
Several other areas of concern were identified during the manual testing. These include:
These issues also need to be addressed in order to make full Level A conformance a realistic possibility. They also highlight the importance of user testing in the meaningful evaluation of website accessibility. Performing user testing with a range of users with disabilities or working with user organisations to validate website design is an invaluable factor in ensuring both accessibility and usability. It routinely highlights a range of issues that would otherwise have remained unaddressed
No sites were found to achieve Level Double-A conformance. 99% of sites contained invalid HTML; at least 90% did not effectively separate content and presentation; and over 40% of sites failed to properly identify the logical structure of page content. Whereas a stronger programme of training and accreditation would solve many of the issues with Level A conformance, the problems here are strongly affected by the authoring tools used to create web content. Hence, there is a need to build eAccessibility requirements into procurement policies relating to web content and the tools used to manage that content.
From our analysis of the common reasons for failure at Level A and Level Double-A, a set of recommendations for action has been developed to bring as many websites up to Level A as possible in the shortest amount of time. By following this plan, public administrations across Europe will rapidly achieve significantly higher levels of eAccessibility.
Overall, this report confirms that there is a long way to go in making public sector websites accessible to all, but it also gives clear pointers for a number of actions to improve the situation. Engagement and interest is growing, and there are clear examples of organisations already demonstrating much improved practice. If some can get accessibility right, there is no reason why others cannot, given the right support and training. Some concrete improvements are possible for almost all websites evaluated in this exercise, which are easily carried out and have a measurable impact. These form the basis of a number of short-term, tactical recommendations.
In the longer-term, the main policy action should be to aim for Level Double-A. To achieve this it may be necessary to take a series of smaller steps, e.g. focus on Level A for all sites in the very short term, but also progressively, and in a prioritised way, target specific government services to achieve Level Double-A.
However, the effectiveness of policy relies on good feedback and monitoring, especially in an area such as this, which can be confusing to those who are not familiar with different evaluation approaches. We have provided an important snapshot; but this needs to be monitored on an ongoing basis. Effective monitoring needs a combination of automated evaluation, expert manual evaluation, and effective channels for user feedback. Harmonisation of monitoring across the EU would make comparison much easier.
For the medium term, it is crucial to equip content developers and authors with tools that support accessibility and to train them in how to provide content that is accessible. Different roles need different training. Another medium-term objective should be for public sector organisations to implement an explicit procurement policy for tools and content, which might well have a significant effect on the industry.
Finally, we must not forget that the focus of this study is to evaluate eAccessibility in the context of public service websites and the W3C WAI guidelines, but the impact of achieving Level Double-A is much broader. eAccessibility is not only concerned with people who are vision impaired, but with people who are hearing impaired, motor impaired or learning disabled. In principle, the idea is to create ‘a design for all’ enabling everyone to use online public services. If the W3C WAI guidelines are followed, websites can be made accessible to a very wide variety of people with disabilities. In this way the delivery of inclusive government services in a multi-channel context becomes a more achievable objective through an accessible internet channel.
In order to achieve both the specific objective of online services that conform with W3C’s WAI guidelines and the broader objective of inclusive services, recommendations should be focused on the different contributions made by different groups of stakeholders.
Recommendation 1
Set a clear target for making all public sector websites in the EU conform with WCAG 1.0 Level Double-A by 2010 as part of the i2010 strategy to promote an inclusive European information society.
Recommendation 2
Develop feedback mechanisms for closing the information gap between policy planning and actual outcomes across the EU (The European Internet Accessibility Observatory Project (EIAO) may provide a mechanism for such collaboration).
Recommendation 3
In particular, aim to test systematically, and on a regular basis, the progress that should now be made. This may include the revisiting the current study in 12 to 18 months’ time, and should be integrated with ongoing i2010 monitoring activities.
Recommendation 4
Ensure effective liaison with all EU-wide organisations (e.g. EIAO, EDeAN, Support-EAM, eAccessibility Expert Group) to encourage the sharing of best practice and a harmonised approach across the EU so that eAccessibility becomes part of the mainstream for online services, e.g. the link between accessibility and usability.
Recommendation 5
Ensure that EU public procurement policy now builds applicable W3C WAI guideline requirements into all procurements of new website designs, major upgrades, and all outsourced content production (such as reports, publications etc).
Recommendation 6
Carry out a feasibility study in 2006 into the development of an appropriate qualification in accessible websites for developers, managers and content providers (perhaps aligned with the European Computer Driving Licence ).
In line with the strategic objective for 2010 to promote an inclusive European information society, each Member State should produce an implementation plan that will cover at least the following recommendations.
Recommendation 7
Produce by 2006 a short-term public plan that enables a clear measurable improvement for all websites delivering public services.
Recommendation 8
In particular, promote the need for cross-governmental centres of excellence for eAccessibility (within Member States) that will provide special action plans, teams, standards and tools for improving eAccessibility according to clear priorities of ease of execution and impact on service.
Recommendation 9
Review the incentives available to encourage the provision of accessible websites in the public service and, if necessary, consider the need for a strong legislative framework.
Recommendation 10
Produce a plan for improving awareness throughout the country by reviewing all the examples of engagement identified in this survey as ideas for improving awareness of web accessibility.
Recommendation 11
Assess the potential for a practical style guide with common ‘look and feel’ standards for public service websites in line with the Canadian model, involving disabled users.
Recommendation 12
Ensure that government policy now builds applicable W3C WAI guideline requirements into all public procurements of new website designs, major upgrades, and all outsourced content production (such as reports, publications etc). In the case of software procurement, such requirements should apply equally regardless of the licensing model (open or closed-source). Note: This will normally require WCAG 1.0 Level Double-A, and may also include ATAG 1.0 Level Double-A and UAAG 1.0 (with an appropriate conformance profile) where these would also be applicable.
Recommendation 13
Develop feedback mechanisms for closing the information gap between policy planning and actual outcomes so that regular monitoring of performance against eAccessibility is made and communicated.
Recommendation 14
Plan now to get existing sites up to at least Level A in the short term (by the end of 2006) and to achieve Level Double-A in the mid-term (by end of 2008), prioritising carefully work applied to individual sites in order to enable the quickest resolution of the most common problems and thus achieve the biggest impact. In particular,
Recommendation 15
Make sure that all content commissioners and authors are fully trained in the importance of accessible content, and in the means that are made available to them to achieve this.
Recommendation 16
Build applicable W3C WAI guideline requirements into all public procurements of new website designs, major upgrades, and into all outsourced content production (such as reports, publications etc). Web designers in the software industry
Recommendation 17
Produce software tools that conform with Authoring Tool Accessibility Guidelines (ATAG 1.0) to at least Level Double-A, and/or with the User Agent Accessibility Guidelines (UAAG 1.0) as applicable (including open source software).
Recommendation 18
Build the W3C WAI guidelines into industry codes of practice.
Recommendation 19
Train all web designers in both the requirement for, and the techniques to achieve, fully accessible websites.
Recommendation 20
Develop a competence framework for web designers, which includes web accessibility, and use it for personal development schemes and recruitment campaigns.
Finally
Each Member State has to oversee improvements in accessibility for large numbers of websites, measured usually in hundreds, if not thousands, of public sector sites. This is no small task requiring commitment and resources, yet in most cases responsibility will be diffused across a range of stakeholders. These recommendations are likely to fail, unless one overriding recommendation is implemented to ensure full responsibility.
Recommendation 21
Designate a champion (an individual and/ or an institution) for eAccessibility in each Member State with the responsibility and authority to ensure that improvements are made with the long-term target of achieving Level Double-A for all government websites by 2010.