Public consultation on the review of the Web Accessibility Directive

Summary report of the public consultation on the review of the Web Accessibility Directive

Disclaimer: This factual summary report presents the views of the respondents who participated in this public consultation, not the views of the European Commission.

1.Objectives of the consultation

The European Commission held a public consultation as part of the review of the application of the Web Accessibility Directive, required under Article 13. The consultation was open for 14 weeks (19 July – 25 October) on the Have your say portal.

The consultation gathered data and stakeholder views to support the evaluation of the Directive and its implementing acts, especially to what extent these:

·have made it easier for people with disabilities to access public services and information, strengthening social and digital inclusion;

·are still relevant and fit for purpose, considering related laws and changes in technology; and

·have harmonised the web accessibility market.

The standard survey was structured around the five formal evaluation criteria: effectiveness, efficiency, relevance, coherence, and EU added value of the Directive. The shorter easy-to-read survey offered a simpler and more accessible way for individuals to give feedback on key aspects of the Directive (e.g., on the level of satisfaction when using public sector websites).

Full survey results and uploaded contributions are available for download in “Contributions to the consultation” section.

2.Who replied to the consultation?

2.1.Breakdown per survey

The two versions of the public consultation surveys received a total of 967 responses.

The easy-to-read survey attracted more than twice as many responses (656) as the standard survey (311).

Figure 1: Number of responses per survey type.

2.2.Breakdown per country

Replies were received from 32 countries – all EU Member States, EFTA/EEA countries (Norway, Switzerland, Liechtenstein), as well as United Kingdom and Albania.

The largest number of responses were submitted from Sweden, Italy, Netherlands, Finland, and Germany. The easy-to-read survey recorded higher response rates in Central and Eastern European countries compared to the standard survey.

Figure 2: Number of replies per country in each survey.

2.3.Breakdown per category

The most represented stakeholder groups in the standard survey (n=311) were citizens (78) and public sector bodies (65), together accounting for 46% of respondents, followed by web accessibility experts (55) and disabled persons organisations (40).

The easy-to-read survey (n=656) collected responses from individual end-users without further categorisation.

Figure 3: Respondent categories in the standard survey.

Other respondent types include contributions from NGOs, equality bodies, consumer organisations, web developers, communication specialists, easy language translators, and educational institutions, to name some examples.

Persons with disabilities were an important demographic for this consultation, as directly targeted by the web accessibility directive. Nearly 40% (354 out of 967) of all respondents to both surveys considered themselves as persons with disabilities or having a recognised disability. About 80% of respondents with disabilities replied to the easy-to-read survey, views which the standard survey alone may have missed.

Figure 4: Respondents in relation to disability in each survey.

3.Findings observed in the replies

3.1.General questions

The main accessibility issues identified when using public services online were navigation and accessing forms, followed by video content (according to both surveys). The findings below refer to the standard survey, complemented with findings from the easy-to-read survey where relevant.

Effectiveness

An overwhelming majority (84%) of respondents covering all stakeholder categories in the standard survey considered the Directive had made online services of public-sector organisations more accessible. While over half of the respondents (61%) consider that online information has become more accessible over the last three years, about the same (57%) do not think that ‘people with disabilities can use online information just as well as others can’.

Regarding mobile apps, one third (33%) of respondents thought apps have become more accessible, while 20% disagreed. Nearly half (48%) consider that people with disabilities cannot use apps just as well as others can.

Opinions on whether the Directive has met the respondent’s expectations concerning the harmonisation of the internal market for accessible websites and mobile applications, are distributed equally: 28% agree, 21% disagree, 27% neither agree nor disagree and 24% are not sure.

In the easy-to-read survey for end-users, while many respondents (57%) observed that the accessibility level has improved in the last three years, thanks to the impact of the Directive, over half (53%) still found government websites difficult or very difficult to use.

Efficiency

Most respondents (58%) could not say whether the objectives of the Directive have been achieved at a reasonable cost, 18% agree and 23% disagree. Many respondents (59%) believe that the benefits of accessible websites and apps outweigh the costs of implementing the Directive.

Relevance

An overwhelming majority of the respondents consider the objectives of the Directive still relevant, with specific elements registering between 95% and 98%.

Coherence

A majority of respondents considered the Directive coherent with other EU (53%) or national legislation (56%) on web accessibility, but a significant proportion were not sure (around 40%).

EU added value

Respondents agreed that, because of the Directive, Member States have ‘made public services more accessible online’ (66% agree and 8% disagree) and have ‘increased the digital inclusion of users, including people with disabilities and older people’ (53% agree and 13% disagree).

3.2.Specific questions

Scope of the Directive

Almost half of the respondents (49%) agreed that the Directive adequately covers online public services to ensure full participation of people with disabilities in digital society. 20% of the participants disagreed with this statement, while 32% opted for a neutral answer or declared not being sure on the matter.

Regarding subject and content types not covered by the Directive (multiple choice), a majority of respondents favoured removing the current exemptions and/or expanding the scope: full inclusion of universities (81%), schools (70%), NGOs (56%), online maps (57%), live videos (53%), extranets/intranets (51%) and third-party content (47%) in view of technological advances.

Respondents identified the following top five technological advancements as relevant for the Directive: ‘artificial intelligence driven assistive technologies’ (60%), ‘accessible authoring tools’ (57%), ‘artificial intelligence and machine learning applied to monitoring, testing tools’ (43%), ‘Internet of Things (IoT) for accessible products and services’ (42%), ‘biometrics for identification and security aspects’ (31%).

Concerning the Harmonised European Standard EN 301 549 (v2.1.2), many respondents (63%) consider the standard has been useful for making public sector websites accessible. This level of agreement drops to 48% for mobile apps, and 25% for cross-border service offering. In all three use cases, the level of disagreement is between 5-10%. Around one third of respondents (32%) agree that the standard still covers all relevant end-user groups, with half (51%) not sure or neutral on the matter, and 17% disagreeing with the statement.

Feedback and complaint mechanisms

While 73% of respondents know about the right to give feedback to public sector organisations about the accessibility of their websites or mobile apps, only 16% have done so often, and nearly half (44%) have never given such feedback. Out of 96 respondents who received an answer to their feedback, 13% were satisfied, 64% were partly satisfied and 24% not satisfied with the answer.

The Directive provides for a possibility to complain to an ombudsperson or similar body about online accessibility: the majority (73%) have never done so.

In the easy-to-read survey, 30% of the respondents have given such feedback at least once. 40% were satisfied and 60% dissatisfied with the answer received.

Success factors and challenges of the Directive

In a multiple-choice question, respondents identified key success factors of the Directive as follows: ‘the accessibility statements’ (39%), ‘harmonisation of minimum accessibility requirements’ (38%), ‘motivation, awareness, and expertise of managers in public sector bodies’ (36%), ‘feedback mechanism’ (34%), ‘public procurement with accessibility criteria’ (32%), ‘alternative formats for inaccessible content’ (29%), ‘complaints mechanism’ (27%) and ‘regular monitoring’ (26%). Low scores were recorded for ‘reduced prices of tools/services’ (14%) and ‘high quality ICT industry offer’ (16%).

The main challenges identified were ‘lack of competences in accessibility within public sector bodies’ (72%), ‘lack of awareness of web managers within public sector bodies’ (57%), ‘lack of budget’ (57%), ‘low level of accessibility knowledge in private sector’ offering accessible websites (50%) or mobile applications (41%).

4.Other consultations

Four targeted consultations were held in November-December 2021 to gain deeper insight and collect further evidence from individuals and key stakeholders in the following groups: (i) public authorities, government associations and educational institutions, (ii) industry players, technology providers, accessibility consultants, (iii) organisations representing persons with disabilities, older people, consumers, and (iv) end-users, persons with disabilities, older people, and carers. Additional in-depth interviews were held with selected stakeholders in early 2022.

5.Next steps

The Commission is now carrying out a deeper analysis of the replies. The results, which are nonbinding for the Commission, together with other consultation activities, will feed into the review of the Directive and inform potential future policy initiatives related to web accessibility.