(EN) Web Accessibility Action Plan 2022–2025

1.        Introduction

In recent years, the European Commission has worked towards increasing the compliance of its web presence with web accessibility standards by taking action at various levels:

• developing a web publishing platform with built-in components and features tested for accessibility and usability;
• defining criteria for testing new websites before they are given the green light for publication;
• defining a methodology for compliance checks and audits to monitor the compliance of the Europa web domain;
• promoting awareness-raising across the organisation; and
• exchanging best practices with other European Union institutions.

As part of the Strategy for the Rights of Persons with Disabilities 2021-2030, the Commission committed to adopting:

‘… an Action Plan on web accessibility, to be shared and promoted in all EU institutions, bodies and agencies in view of ensuring compliance of EU websites, documents published on these websites and online platforms, with European accessibility standards.’

The purpose of this multiannual action plan is to:

• ensure that the European Commission’s web presence (including websites, mobile apps and social media content, both external and internal) is accessible to persons with disabilities;
• support all Commission services in achieving that goal; and
• encourage the exchange and harmonisation of practices across all EU institutions and bodies to aim at compliance of the whole Europa domain with the applicable standards.

The action plan will advance web accessibility in the following areas:

• Rules and guidelines
• Accessibility statements, feedback mechanism
• Compliance monitoring
• Awareness raising and internal communication
• Training
• Organisational coordination.
  
  

This plan covers websites and mobile applications owned and managed by the European Commission, including all content made available on those websites and applications (text, graphics, audiovisual material, etc.).

It covers the period 2022-2025 and contains both ongoing and new initiatives.

2.        Guiding principles

2.1.         Inclusion and equity

We will strive to ensure that persons with disabilities are able to interact with our organisation via digital channels on an equal basis with all other users.

2.2.         An inclusive organisation

We are committed to making our web presence accessible to persons with disabilities, and to working towards compliance with the web accessibility requirements as defined in the applicable standards (see Section 3.1, Rules and guidelines).

2.3.         Independence and collaboration

We aim to make our web presence helpful and user-friendly for all, regardless of their different abilities, inviting collaboration with all, and, in so doing, reinforcing respect for human dignity and diversity. To that end, we will actively involve persons with disabilities when preparing and implementing our actions.

2.4.         Regular review for adaptations

We will regularly review our web presence in order to correct any shortcomings and to adapt to changes in the needs of our users and developments in digital technology.

2.5.         Accessibility by design and continuous improvement

We will strive to follow the principles of universal design, knowing that while accessibility is essential for some people, it is useful for all. We will take accessibility into account from the very beginning for all web products, from the planning and procurement stages to the design and development processes to ensure that they are accessible from the outset. We also commit to implementing an accessibility monitoring process across our web presence.

2.6.         Corporate by default

Under the European Commission Digital Strategy – A digitally transformed, user-focused and data-driven Commission all Commission departments are required to ensure that their digital services are: ‘…inclusive by default, accessible to people with disabilities and cater to different user needs.’ In line with this Communication, Commission departments shall use, wherever possible, corporate solutions that are accessible from the outset.

3.        Areas of action

3.1.         Rules and guidelines

As set out in the Europa Web Guide, the Commission requires its websites to be compliant with the harmonised European standard on accessibility requirements for ICT products and services and the Web Content Accessibility Guidelines (WCAG) 2.1, conformance level ‘AA’, as a minimum. It also requires its websites to follow some provisions of the Web Accessibility Directive and relevant, related implementing decisions.  

3.1.1.        Actions

The Commission will:

• strengthen and clarify the rules and guidelines on web accessibility in relation to its websites, mobile apps and digital content.

To achieve this, it will:

• update, expand and periodically review the accessibility section of the Europa Web Guide, focusing, in particular, on the following areas:
• What is web accessibility?
  • the ways in which persons with different disabilities may interact with our web presence
  • why it is important to meet accessibility requirements
    
    
• Accessibility requirements (legal and policy framework)
  • legal framework
  • preparing and publishing an accessibility statement, including a statement template
  • preparing an accessibility report
  • setting up a complaints and feedback mechanism
  • setting up an enforcement procedure to repair lack of compliance with accessibility
    
    
• Evaluating websites and mobile apps
  • building accessibility into projects from the very beginning
  • specific guidance for existing, new and outsourced websites/mobile apps
  • carrying out basic accessibility checks
  • organising formal accessibility testing, involving persons with disabilities

3.1.2.         Expected outcomes

• Website owners in the Commission understand and are equipped to comply with the accessibility rules they need to follow and have access to step-by-step guidance to help them to do this.
• Consistent and user-friendly implementation of the accessibility statements and feedback mechanisms across the Commission’s web presence.
• Transparency for users on the compliance of the sites making up the Commission’s web presence.
• Clear process for remedial action following complaints or errors reported.
• Higher compliance rate of the Commission’s web presence with accessibility rules.
• Cost efficiency, by ensuring that the web presence is compliant from the outset, the costs of retrofitting projects at a late stage are avoided.
  

3.1.3.        Timeline

• Next substantial update by end 2022.
• Regular reviews and updates of the rules and guidelines published on the Europa Web Guide on an ongoing basis.
  

3.2.         Accessibility statements and feedback mechanism

To align the Commission’s web presence with the provisions of the Web Accessibility Directive, all Commission websites and mobile apps must:

• publish a specific accessibility statement, based on an official template, for each website and mobile app;
• provide a feedback mechanism so that users can flag accessibility problems, request information in an accessible format or make complaints; and
• commit to replying and to carrying out the necessary repairs or remedies in response to complaints.

3.2.1.         Actions

The Commission will:

• provide a template for the accessibility statement for all websites and their content;
• provide guidance for the managers of those sites on how to prepare and publish the accessibility statement;
• publish a website-specific accessibility statement in accessible format, including a feedback mechanism, on the main European Commission website and the interinstitutional EU website;
• require website owners, as a condition for making a site public, to submit a formal accessibility assessment; and
• set up a process to react to complaints and rectify the issues identified.

3.2.2.         Expected outcomes

• The Commission complies with the requirements of the Web Accessibility Directive concerning the statements and feedback mechanism.
• Commission websites have accessibility statements, giving clear information to users on accessibility compliance status and commitments.
• A clear feedback mechanism is in place and helps users to signal, and website owners to correct, any issues identified.
• The reputation of the Commission as an inclusive, transparent and trustworthy institution is improved.
• The accessibility compliance score of the Europa domain improves in a structured and progressive manner.

3.2.3.        Timeline

• Provide a generic template for the accessibility statement and guidelines for how to prepare it by end 2022.
• Publish accessibility statements via the corporate footer on the main European Commission website and interinstitutional EU website by end 2022.
• Make the technical modifications required to add the accessibility statement link to all corporate website footers by end 2022.
• Publish accessibility statements via the corporate footers for all other websites and mobile apps on the Commission’s web presence by end 2023.
  

3.3.         Compliance monitoring

To monitor overall accessibility compliance across its web presence and to guide progress towards full compliance, the Commission will regularly evaluate a representative sample of its websites, at least annually, for conformance with EN 301 549 v3.2.1 and the requirements of the Web Accessibility Directive as defined in the Europa Web Guide. It will publish the findings in an annual ‘progress report’. The monitoring activities will be performed using, in parallel, two principle methods within the meaning of Commission Implementing Decision of 11 October 2018:

• in-depth monitoring (accessibility audit) to verify compliance (e.g. by means of a thorough review of conformance to all the required standards by an accessibility expert); and
• simplified monitoring to detect non-compliance (e.g. checking against a pre‑defined subset of accessibility criteria, including by using an automated tool, such as a crawler, to quickly identify and address known accessibility issues).

3.3.1.        Actions

The Commission will:

• set up a scheme for regular compliance monitoring, based on accessibility checks using a combination of the in-depth and simplified monitoring methods described in the introduction to Section 3.3, ‘Compliance monitoring’;
• introduce a process to systematically check the accessibility conformance of its web presence on an ongoing basis;
• review the accuracy and content of the accessibility statements of a representative sample of accessibility statements across its web presence;
• share the findings of regular accessibility evaluations with the owners of the site or mobile app, along with recommendations on how to remediate any issues identified; and
• continue, in line with the Digital Strategy described in Section 2.6, ‘Corporate by default’, to encourage Commission departments to choose corporate tools and solutions for their websites, their content and mobile apps, which have been pre‑assessed for accessibility compliance.

3.3.2.        Expected outcomes

• Effective prioritisation of corrective actions helps to maximise benefits to users and reduce effort required to make the Commission’s web presence compliant.
• Overall accessibility compliance rate of the Commission’s web presence continually improves.
• Increased uptake of accessible corporate tools, including corporate testing solutions, so reducing overall expenditure on digital solutions.

3.3.3.        Timeline

• Each year, monitor a sample of sites, focusing on those sites that generate the highest traffic of the domain.
• In 2022, set up a proposed scheme for regular compliance monitoring, based on a combination of the in-depth and simplified monitoring methods, including annual scope for the quantity of reports.

 3.4.         Awareness-raising, internal and inter-institutional communication

To meet accessibility standards on the web presence, Commission staff must understand the importance and basic principles of accessibility, as well as how every member of staff can play their part.

In addition to the internal awareness-raising actions within the Commission, exchange of best practices among EU institutions may increase the efficiency of the work at EU level when it comes to improving web accessibility.

3.4.1.        Actions

The Commission will:

• prepare a plan for internal communication in order to mainstream accessibility into broader internal communication actions, including by:
  • sharing success stories on projects and products of best practice on web accessibility;
    
  • providing accessibility training courses, especially, but not exclusively, among staff working on websites and mobile apps;
• leveraging existing networks, in particular in the domains of information and communication technology (ICT) and communication, inter alia, the Communication Network; the MyIntraComm Forum; the Digital Stakeholder Forum; the network of Web Accessibility Correspondents; and the Commission’s Task Force on Equality; and
• sharing best practices among staff and stakeholders both internally and on an inter-institutional level to ensure accessibility standards are easier to meet.

3.4.2.        Expected outcomes

• Accessibility is incorporated into different activity strands.
• Awareness to be raised among all Commission staff of web accessibility and how they can contribute to improving web accessibility in their role.
• New processes and tools are available, making it easier to comply with web accessibility requirements within the organisation.

3.4.3.        Timeline

• Internal communication across the Commission is ongoing. The internal communication plan will be finalised in parallel to the present action plan.
• Accessibility-related presentations in the relevant networks: continuously as of 2021.
  
  

3.5.         Training and professional development

In addition to a broad overview of accessibility and an understanding of its importance, certain Commission staff will also need access to relevant, role-specific training to enable them to acquire the necessary expertise to meet the expected accessibility targets the Commission has set for its web presence.

While this training should include specific training on web accessibility and build on existing training programmes, it is also vital to mainstream both web and general digital accessibility into the Commission’s entire training catalogue wherever it may be relevant and, in particular, into training in the domains of communication, publication and information technology.

3.5.1.        Actions

The Commission will:

• create a training path for different categories of staff to get the necessary level of knowledge related to accessibility requirements (legal, general, technical), incorporating existing training courses;
• establish new training courses to fill any existing gaps in the training catalogue in relation to web accessibility and to make sure staff are able to obtain the practical knowledge required; and
• introduce information sessions on the internal tools and solutions that help to achieve compliance with accessibility requirements for the web presence and the underlying (digital) tools.

3.5.2.        Expected outcomes

• Commission staff are aware of the existing legal requirements and how to achieve compliance.
• Commission staff are able to incorporate these new practices into their daily work.
• New processes and tools can be used and will be further developed, making it easier to comply with accessibility requirements within the organisation.

3.5.3.        Timeline

• Training requirements for web accessibility are identified and described: mid-2022.
• Training paths for specific technical and non-technical roles identified: mid-late 2022.
• Pilot training courses prepared by end 2022.
  
  
• Formal web accessibility training courses incorporated into the Commission’s official training catalogue: from 2023.

 3.6.         Organisational coordination

In order to achieve the ambitions set out in this action plan in an effective and timely manner, it is vital that Commission services work together in a coordinated way, making the best use of the available resources and expertise within the organisation.

To this end, the Commission will put in place the necessary structures and systems to steer its activities in the field of web accessibility and to coordinate the various work strands, keep track of the work undertaken and report on the organisation’s progress towards accessibility compliance.

3.6.1.        Actions

The Commission will:

• operate a task force on web accessibility to pool internal expertise and resources on web accessibility and define the actions to be taken;
• leverage its network of accessibility correspondents across all departments to help raise awareness of accessibility requirements for staff working on the Commission’s web presence or digital tools;
• allocate clear responsibilities and resources to accessibility and establish an enforcement mechanism to ensure compliance; and
• regularly report on its progress toward accessibility compliance to the Corporate Communication Steering Committee (CCSC).

3.6.2.        Expected outcomes

• Activities to improve web accessibility will be planned and implemented in a coordinated way across the organisation.
• Actions to improve web accessibility will be prioritised so as to maximise progress in the time available.
• Compliance with the relevant accessibility requirements will become the norm for any new website or app.
• The Commission will have an accurate overview of accessibility conformance and be able to measure progress towards its goals in a meaningful way.

3.6.3.        Timeline

• Operate the task force on web accessibility set up in May 2021 to discuss and validate proposals for future actions.
• By end 2022: a growing group of practitioners is working in a coordinated and thus more effective manner on the different work tracks.

4.        Conclusion

The European Commission remains committed to removing any accessibility barriers from its web presence and to ensuring that web accessibility considerations are integrated into all its digital projects from the very earliest stages.

This action plan sets out the steps the Commission must take if it is to achieve its stated ambitions and, in particular, ensure that its web presence is fully compliant with the provisions of the Web Accessibility Directive.