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  • Accessibility of websites and

    mobile apps

    A study on the current practices regarding

    accessibility statements, reporting mechanisms and

    mobile monitoring methodologies

    Draft Final Deliverable

    A study prepared for the European Commission

    DG Communications Networks, Content & Technology


  • Digital



    This study was carried out for the European Commission by

    Capgemini Consulting and Dialogic

    For more information about this paper, please contact: Directorate-General for Communications

    Networks, Content and Technology G – Learning, Multilingualism & Accessibility Unit G.3

    Åsa Barton – Policy Officer E-mail:

    Project team

    Capgemini Consulting

    Niels van der Linden – Principal Consultant

    Executive lead

    E-mail: Remco van der Spiegel – Managing consultant

    Project manager


    Wander Engbers – Consultant


    Christian le Clercq – Senior Consultant


    Sem Enzerink – Consultant



    Robbin te Velde – Principal Researcher

    Quality assurance

    Internal identification

    Contract number: 30-CE-0631083/00-65

    SMART number 2016/0089


    By the European Commission, Directorate-General of Communications Networks, Content & Technology.

    The information and views set out in this publication are those of the author(s) and do not necessarily reflect the

    official opinion of the Commission. The Commission does not guarantee the accuracy of the data included in this

    study. Neither the Commission nor any person acting on the Commission’s behalf may be held responsible for

    the use which may be made of the information contained therein.

    © European Union, 2017. All rights reserved. Certain parts are licensed under conditions to the EU.

    Reproduction is authorised provided the source is acknowledged.

  • 3

    European Commission Accessibility of websites and mobile apps – A study on the current

    practices regarding accessibility statements, reporting mechanisms and mobile monitoring methodologies Luxembourg, Publications Office of the European Union

  • 4

    Executive Summary Technology, in particular connected technology, is rapidly changing our world. It changes every

    industry, organisation and process. It also changes how citizens interact with their (local) public

    sector: how they acquire information or how they use public services. To ensure all citizens, including

    those with a disability, profit from digitisation the European Union enshrined Web Accessibility in its

    legislation. Web Accessibility means that people with disabilities, such as blindness or motoric

    limitations, can perceive, understand, navigate, interact with and contribute to the Web. With the

    Web Accessibility Directive, it becomes mandatory for all Public Sector Bodies to have websites and

    mobile applications adhering this principle.

    Methodology: Examining the current accessibility practices in three studies To ensure that the Member States move towards an accessible web in a similar manner, the

    Directive aims to harmonise accessibility legislation. In anticipation of the implementing acts

    detailing this legislation, this study presents an overview of the current practices in three respective

    fields: accessibility statements (study 1); reporting mechanisms (study 2); and, monitoring

    methodologies for mobile applications (study 3). Based on the analyses of these practices and

    discussions with experts, the study presents recommendations for the development of implementing

    acts. The study collected the information via the following four means:

     Landscaping of the European countries by asking them to participate in a questionnaire and

    complementary interview. In total 28 Member States responded to the questionnaire and 25

    representatives were interviewed.

     Desk research to obtain a sound definition of the state-of-play on web accessibility

    developments and to identify the key stakeholders, experts and interest groups.

     Interviews with 25 international experts from the public, private and NGO sector. In

    particular to discuss the possibilities to monitor the accessibility of mobile applications.

     Survey addressing a global audience to identify existing monitoring initiatives covering the

    accessibility of mobile applications for further examination. The survey did not identify any

    existing initiatives.

    Policy: Moving towards transposition, the currently heterogeneous position of

    web accessibility Transcending the three individual studies, the report first examined the current legal position of web

    accessibility and the (expected) progress in the transposition of the Directive. The legal position of

    web accessibility strongly varies in Europe, ranging from no legislation, to general non-discrimination

    acts, to binding legislation specifically on web accessibility. This heterogeneity affects the maturity of

    the practices and the transposition preparations. To transpose the Directive, 21 countries started

    preparations, ranging from composing commissions to drafting legislation. The countries mention

    time and budget constraints as possible risks for a successful transposition. These constraints are

    either the result of national developments, such as upcoming elections, or because of the absence of

    implementing acts. In 24 of the surveyed countries, interest groups are involved in the policy

    processes regarding digital accessibility. This ranges from ad-hoc advisory roles to executing

    accessibility evaluations.

  • 5

    Study 1: Large variety of practices regarding accessibility statements At the moment, 54% of the reviewed countries have specific policies or regulations on accessibility

    statements (implemented or in preparation). Member States miss overview on the use of statements

    in their country. Only seven Member states could estimate the percentage of statements on public

    sector body websites. Their estimations ranged from less than 25% to over 95%. This underlines that

    the full use of accessibility statements has not been commonly achieved across all Member States.

    Our analysis of 66 accessibility statements showed that statements generally include: a description of

    inaccessible parts, a feedback mechanism, assistive user instructions, a statement date and the

    achieved level of compliance. None of the statements provided a link to enforcement procedures or

    the update frequency. The statements contained information relevant for end-users (35%),

    monitoring purposes 9%) or a combination (16%). In 39% of the cases, the statements did not

    sufficiently provide information to be helpful for end-users nor monitoring purposes.

    The study found six practices how Member States develop (and update) accessibility statements:

    1. Free formats that allow Public Sector Bodies to structure their own accessibility statements.

    2. Content descriptions that prescribe the required topics of the accessibility statement.

    3. Standard templates that define the format and structure of the accessibility statement so a

    public sector body only provides particular content regarding its website.

    4. Common Web Platform incorporations that automatically create an accessibility statement

    within the commonly used (technical) web platform of public sector bodies.

    5. Accessibility generators that collect particular information of the public sector bodies to

    automatically generate an accessibility statement.

    6. Statements based on a label that declare accessibility compliance by showing a logo and

    further information related to that logo.

    We examined the accessibility statement practices on their benefits and concerns, related to:

    scalability, assumed impact, awareness, administrative burden and sustainability. The outcome of

    this examination is displayed in Figure 1.

    Free format (non-


    Content description (non-


    Standard template (standardised)

    CWP incorporation (standardised)

    Statement generator


    Statements based on a label (standardised)

    B e

    n e

    fi ts

     Scalability

     Administrative


     Sustainability

     Scalability

     Awareness

     Administrative


     Sustainability

     Scalability

     Assumed impact

     Administrative


     Sustainability

     Assumed impact  Scalability

     Assumed impact

     Administrative


     Sustainability

     Assumed impact

     Awareness

    C o

    n ce

    rn s

     Assumed


     Awareness