Web Accessibility Directive:
Frequently Asked Questions

These are frequently asked questions and answers on the EU Web Accessibility Directive.

The objective of this website is to support the implementation of the Directive and to provide reliable information and resources to those involved in buying, designing and monitoring websites or mobile applications, as well as users. This website is maintained by the Web Accessibility Initiative - Communities of Practice (WAI-CooP) Project.

4. Can you provide examples of accessible websites and apps?

Unfortunately, it is not possible to provide a list of examples. While a website or an app may be accessible at some point, we cannot guarantee that they will not be later changed in a way that makes them inaccessible.

8. Are there resources on digital accessibility in my language?

There are a range of W3C WAI documents available in languages other than English.

If you want to get involved with translation, you can get in touch with W3C WAI.

12. How do I start implementing digital accessibility?

Make sure you learn about digital accessibility so that you know how persons with disabilities use the web.

The W3C Web Accessibility Initiative (WAI) has a range of resources for designers and developers including tips for designing and tips for developing, as well as resources to make audio and video media accessible.

For mobile applications, there are accessibility guidelines for Android, Apple and Microsoft.

Remember to consider accessibility throughout your project planning.

13. What resources are available to help design accessible websites and mobile applications?

The W3C Web Accessibility Initiative (WAI) has a range of resources for designers and developers including tips for designing and tips for developing, as well as resources to make audio and video media accessible.

Mobile accessibility is covered in existing W3C web content accessibility guidelines. There are no separate guidelines for mobile accessibility.

You can find more information on mobile accessibility, as well as guidance on applying WCAG 2.0 to non-web information and communications technologies (WCAG2ICT) on the W3C Web Accessibility Initiative (WAI) website.

For mobile applications, there are accessibility guidelines for Android, Apple and Microsoft.

14. Where can I find information about web accessibility standards?

The European standard for accessibility requirements for ICT products and services is called EN 301 549. Complying with this standard is a way for public sector bodies to meet the mandatory technical requirements of the Web Accessibility Directive. Annex A of EN 301 549 explains how this can be done.

EN 301 549 is a ‘harmonised standard’. Harmonised standards are a specific category of European standards developed by a European Standardisation Organisation following a request, known as a ‘mandate’, from the European Commission. Harmonised standards establish technical specifications which are considered suitable or sufficient in order to comply with the technical requirements given in EU legislation. Hamonised standards are published in the Official Journal of the European Union.

You can use harmonised standards to prove that a product or service complies with the technical requirements of a relevant EU legislation.

EN 301 549 has evolved over time. The current harmonised version of this standard is EN 301 549 version 3.2.1 (2021-03) [PDF Document]

EN 301 549 version 3.2.1 includes requirements from WC3’s internationally recognised Web Content Accessibility Guidelines version 2.1 (WCAG 2.1).

EN 301 549 version 3.2.1 also includes additional requirements that are not part of WCAG 2.1. Therefore, demonstrating that a website meets all the success criteria of WCAG 2.1 is not sufficient to provide a presumption of conformity with the Web Accessibility Directive.

EN 301 549 is about products and services, so it also includes requirements that are not relevant to the Web Accessibility Directive, for example requirements that apply to hardware.

Read about current EN 301 549 requirements relevant to the Web Accessibility Directive.

New requirements in future versions of EN 301 549 or WCAG will not automatically become legally relevant to the Web Accessibility Directive. This will only be the case if these new requirements are included in Annex A of a new harmonised version of EN 301 549.

15. Where can I find information about accessible software / authoring tools?

Authoring tools are software and services that people use to produce web content. Examples of authoring tools include:

The W3C Web Accessibility Initiative (WAI) develops the standard called Authoring Tool Accessibility Guidelines (ATAG). It is a companion to the Web Content Accessibility Guidelines (WCAG) and can be used to develop and procure accessible authoring tools.

WAI also has some tips on how to choose authoring tools to produce accessible content but warns that there is no single tool that fully supports production of accessible websites.

16. What should I take into account when procuring accessible websites and apps?

When drafting a call for tenders to procure ICT services, you will need to define selection criteria, award criteria and technical specifications, including accessibility requirements.

One way to define accessibility requirements is to refer to the current European harmonised standard 'Accessibility requirement for procurement of ICT products and services' EN 301 549 V3.2.1 (2021-03) [PDF document]. Complying with this standard is a way to meet the mandatory technical requirements of the Web Accessibility Directive. Find out more information about web accessibility standards

You can use the selection criteria to set out your expectations from potential suppliers in terms of capacity to deliver digital accessibility.

You can use the award criteria to encourage suppliers to deliver a more accessible website and/or mobile application by providing additional accessibility features above and beyond what is required in the Web Accessibility Directive, such as those set out in chapter 9.5 of EN 301 549 [PDF document].

19. How to consider accessibility throughout your project plan?

It is important to consider accessibility throughout your project development. Key steps include:

More tips on planning and managing accessibility in a project.

20. What do I need to know about the accessibility statement?

The Web Accessibility Directive requires public sector bodies to provide and regularly update a ‘detailed, comprehensive and clear’ accessibility statement on their website or mobile application.

The accessibility statement must include the following information:

The accessibility statement can also include optional content, for example:

The declarations made in the accessibility statement should be accurate and based on one of the following:

  1. an actual evaluation of the website's or mobile application's compliance with the requirements of the Directive, such as a self-assessment done by the public sector body or an assessment carried out by a third party, for example a certification
  2. any other measures, as deemed appropriate by the Member States, which provide equal assurance that the declarations made in the statement are accurate.

The statement should indicate the method used.

There is a model accessibility statement in an implementing decision published by the European Commission. It provides more detail on mandatory and optional content requirements.

The W3C Web Accessibility Initiative (WAI) has more general information about accessibility statements and why they are helpful, as well as an accessibility statement generator.

24. Is there guidance on involving users with disabilities in design and development?

Involving users early on in project development is really important to understand real-world accessibility issues, such as how people with disabilities and older people use the web with adaptive strategies and assistive technologies.

The W3C Web Accessibility Initiative (WAI) developed resources showing how to involve users with disabilities in design and development, including advice on involving users in web projects and resources to help evaluate web accessibility.

25. How to optimise websites and apps for older people?

Designing products that are easier for older people to use is similar to designing for persons with disabilities.

Guidance on how to make websites and applications accessible for older users is covered in existing web accessibility standards.

Age-related impairments such as declining vision, hearing loss, reduced physical and/or cognitive ability can affect how older people use the web. These issues overlap with the accessibility needs of persons with disabilities. Therefore, websites and applications that are accessible to persons with disabilities are more accessible to older users as well.

More information on the overlaps between accessible design and design for older people.

26. How can we optimise websites and apps for people with cognitive disabilities?

Cognitive disabilities have an impact on how people process information. For example, they can affect people’s perception, comprehension, memory, language, attention and problem solving.

The Web Content Accessibility Guidelines (WCAG) 2.1 include existing requirements that address cognitive accessibility. The W3C Web Accessibility Initiative (WAI) also has additional guidance on making content usable for people with cognitive and learning disabilities.

30. What is the 'disproportionate burden' clause?

The Web Accessibility Directive states that delivering accessibility requirements should not impose a ‘disproportionate burden’ on public sector bodies.

In order to assess the extent to which complying with the accessibility requirements in the directive imposes a disproportionate burden, a public sector body must take account of relevant circumstances, including:

According to the directive, measures that would impose a disproportionate burden should be understood as measures that would impose an ‘excessive organisational or financial burden’ on a public sector body, or would ‘jeopardise the body's capacity to either fulfil its purpose or to publish information needed for or relevant to its tasks and services, while taking into account the likely resulting benefit or detriment for citizens, in particular persons with disabilities’.

Public sector bodies can carry out an initial assessment to decide whether complying with the accessibility requirements in the Web Accessibility Directive constitutes a ‘disproportionate burden’. Only legitimate reasons should be taken into account in any assessment of the extent to which the accessibility requirements cannot be met because they would impose a disproportionate burden. The Web Accessibility Directive states that ‘lack of priority, time or knowledge’ should not be considered legitimate reasons and that there should not be any legitimate reasons for not procuring or developing software systems to manage content on websites and mobile applications in an accessible manner, since sufficient and advisory techniques are available to make those systems meet the accessibility requirements in the directive.

If public sector bodies make use of the ‘disproportionate burden’ clause, they have to explain in the accessibility statement which parts of the accessibility requirements could not be complied with and provide accessible alternatives.

31. What are the exemptions in the Web Accessibility Directive?

There are several exemptions in the Web Accessibility Directive – some are temporary and some are permanent. Some exemptions restrict the scope of the directive and some exemptions focus on specific types of content.

Exemptions are listed in article 1 of the Web Accessibility Directive.

However, it is important to note that Member States can decide to not make use of exemptions.

Exemptions relating to the scope:

Exemptions regarding specific types of content

Users can request access to content that is not accessible through the feedback mechanism available on the accessibility statement of the website or mobile application.

32. Can Member States go beyond the minimum requirements in the Web Accessibility Directive?

Yes, Member States may keep or introduce measures which go beyond the minimum requirements for accessibility of websites and mobile applications established by the Web Accessibility Directive as it is a ‘minimum harmonisation’ directive. This means that it only sets out the absolute minimum requirements that have to be met by public sector bodies for their websites and mobile applications.

If there are better provisions already in place in a Member State, these provisions do not have to be amended.

Governments can decide to implement new provisions that go beyond what is in the directive, for example they can chose a wider scope.

The directive also states that Member States should be encouraged to extend the application of the directive to private entities that offer facilities and services which are open or provided to the public, including in the healthcare, childcare, social inclusion and social security areas, as well as in the transport sector and the electricity, gas, heat, water, electronic communication and postal services, and to maintain or introduce measures which go beyond the minimum requirements for accessibility of websites and mobile applications

33. What does the Web Accessibility Directive say about training and awareness-raising?

The Web Accessibility Directive states that Member States have to ‘promote and facilitate’ training programmes relating to the accessibility of websites and mobile applications for relevant stakeholders and staff of public sector bodies. These training programmes should be designed to train them how to create, manage and update the accessible content of websites and mobile applications.

Relevant stakeholders include organisations representing the interests of persons with disabilities, organisations of older people, as well as others, such as social partners or industry involved in the creation of accessibility software relating to websites and mobile applications.

Member States also have to take necessary measures to raise awareness of the accessibility requirements in the Web Accessibility Directive, of their benefits to users and owners of websites and mobile applications, and of the possibility of giving feedback in the case of any failure to comply with the requirements of the directive.

The directive states that Member States, in close cooperation with the Commission, should promote the use of authoring tools that allow better implementation of the accessibility requirements. Such promotion could take passive forms, such as publishing a list of compatible authoring tools, or active forms, such as the requirement to use compatible authoring tools or to fund their development.

When they report to the European Commission on their monitoring of the implementation of the Web Accessibility Directive, Member States have to provide information about training and awareness-raising activities.

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