https://gds.blog.gov.uk/2019/05/21/accessibility-update-sample-accessibility-statement-monitoring-and-enforcement/

Accessibility update: sample accessibility statement, monitoring and enforcement

The GDS accessibility lab - a blue wall with a table with laptops and other devices on it. A user sitting at the table doing some work.

New regulations mean that public sector websites and mobile apps will soon have a legal duty to meet accessibility requirements. You’ll need to:

  • carry out an evaluation of how accessible your websites and mobile apps are
  • fix accessibility problems (when you’re required to do so)
  • publish a statement saying what’s accessible, what’s not – and why

You’ll need to do this by 23 September 2019 for newer websites (those published later than 22 September 2018). There are later deadlines for older websites and mobile apps.

We’ve blogged about this a few times over the past months; here’s the latest on what’s happening.

Updated guidance on meeting accessibility requirements

We’ve updated the guidance on making your public sector website or app accessible.

We have:

  • split the information that was there into two guides – one that’s focused on understanding your obligations and one that’s focused on the practicalities of making a plan to identify and fix accessibility problems
  • added more detail on evaluating your website or app so you can publish an accessibility statement saying how accessible it is

You will find a link to a sample accessibility statement you can use to help you write your own. Thanks to colleagues at AbilityNet, JISC, Kent County Council, Nomensa, the University of Kent and others for their help putting this together.

A screen shot of the page with the sample accessibility statement. The title of the page is 'Guidance: Sample accessibility statement (for a fictional public sector website'. The first paragraph says: 'This is a sample accessibility statement about a fictional public sector website. It contains sample wording and guidance on what to include in your statement.'

Monitoring and enforcement

We’ve had some questions about how compliance will be monitored and how the regulations will be enforced.

A central monitoring team at GDS will assess a sample of public sector websites and apps. The aim of monitoring is to help and encourage the public sector to make timely improvements to websites and apps – making them accessible to as many people as possible and avoiding the need for enforcement.

The sample will be chosen based on a number of factors, including:

  • how many people risk being excluded
  • where there are known or suspected problems (for example, because there have been complaints)

If the monitoring team discovers accessibility problems with a website or app in the sample, they will notify the website or app owner and signpost them to support to help resolve the problems.

The monitoring team will be overseen by the Cabinet Office and supported by an independent panel of stakeholders.

Assuring compliance with the regulations will, in part, fall within the existing enforcement powers of the Equality Advisory & Support Service, the Equality and Human Rights Commission and the Equality Commission for Northern Ireland.

GDS – acting on behalf of the Minister for the Cabinet Office – will assess whether accessibility statements meet legal requirements.

The Equality Advisory & Support Service provides individuals with information about discrimination and their rights as users of public services.

We’ll publish further information on monitoring and enforcement processes in the future.

What’s next

Most public sector organisations will want to consider getting help from an external accessibility expert to evaluate their websites and apps. But for organisations that genuinely can’t afford to do that, we’re working on a simple approach to self-evaluation. We will aim to publish this soon.

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32 comments

  1. Comment by Nordin Zaoui posted on

    We’ve taken significant steps towards achieving compliance with WCAG 2.1 AA, ensuring that the main structure of our website meets this standard. However we have a large number of documents published on the website since 1998 which have not been checked for accessibility and will constitute a significant disproportionate burden to address retrospectively.
    We'd appreciate clarification on the following:
    • Are we right to assume that the accessibility requirements regarding documents will apply to publications published from the 23rd Sep 2019?
    • Can we apply exemption on the grounds of disproportionate burden on the organisation to retrospectively alter a significant volume of documents?
    Your advice would be appreciated.

    • Replies to Nordin Zaoui>

      Comment by Joseph posted on

      Hi Nordin

      On publications, before you begin the process of disproportionate burden, it is important to note that under Part 1, Regulation 4(2) notes that there are some exceptions for content within websites - Source: http://www.legislation.gov.uk/uksi/2018/952/introduction/made

      Some of these exceptions may be applicable to the publications you mentioned.

      We have guidance on disproportionate burden here: https://www.gov.uk/guidance/accessibility-requirements-for-public-sector-websites-and-apps.

      Generally when making your assessment, you need to think about:

      · your organisation’s size and resources

      · the nature of your organisation (for example, do you have services aimed at people who are likely to have a disability?)

      · how much making things accessible would cost and the impact that would have on your organisation

      · how much users with a disability would benefit from you making things accessible

      Regarding your first clarification on documents, any content on a website/webpage that was published on or after 23 September 2018 will need to meet accessibility standards and publish an accessibility statement by 23 September 2019.

      Any content on a website/webpage that were published before 23 September 2018 need to comply with the regulations by 23 September 2020.

  2. Comment by Alec posted on

    Hi there,
    Is there any update on the guidance?
    Also, say you have some content on your website that isn't accessible, you mention it in your accessibility statement (as well as why and what you're doing to fix this), does this mean you're covered legally?

  3. Comment by Andy posted on

    2 Questions and apologies if they are in the wrong place. If so could someone direct me to the correct one. Thanks.

    How do the regulations apply to the providers of hosted systems we are procuring that are accessed via a browser?

    When putting togehter an ITT how should the WCAG requirement be worded for the above scenario?

    • Replies to Andy>

      Comment by Joseph Jones, GDS posted on

      Hi Andy

      On your first question, your organisation will need to work with your providers to make sure all sites meet the 2018 regulations: https://www.gov.uk/guidance/accessibility-requirements-for-public-sector-websites-and-apps

      Intranets and extranets are exempt until they undergo a substantial revision after 23rd September 2019. But it is your responsibility to ensure, that going forward, any procured systems are accessible.

      Invitations to Tender should include requirements about meeting WCAG 2.1 AA and publishing Accessibility Statements for websites and mobile apps. Suppliers could be asked to provide evidence of meeting the standard in previous projects, their approach to accessibility testing, and integration of accessibility testing in the software release process.

  4. Comment by Adedotun posted on

    This is very nice.

  5. Comment by Peter posted on

    What is your definition of 'intranet'?

    Is it any browser operated system for staff?

    What about if it's externally hosted/supplied?

    Thankss

    • Replies to Peter>

      Comment by Joseph posted on

      Hi Peter

      Under Regulation 4(3)(b) of the Public Sector Bodies (Websites and Mobile Applications) Accessibility Regulations 2018 states that “extranets and intranets” are websites that are only available for a closed group of people and not to the general public; Source: http://www.legislation.gov.uk/uksi/2018/952/introduction/made

      If your intranet/extranet is outsourced or procured, you’ll need to work together to make sure your website meets the 2018 regulations: https://www.gov.uk/guidance/accessibility-requirements-for-public-sector-websites-and-apps

      • Replies to Joseph>

        Comment by Peter posted on

        Thanks Joseph

        There's still some ambiguity here.

        Is it any browser operated system for staff?

        You could have a time recording or finance system for all staff that is operated via a browser. Is that in scope? (as an example)

  6. Comment by Alec posted on

    "But for organisations that genuinely can’t afford to do that, we’re working on a simple approach to self-evaluation. We will aim to publish this soon."

    Any idea when this will be available?

    • Replies to Alec>

      Comment by GDS posted on

      Hi Alec,

      This guidance should be available before the end of the month.

      All the best,
      GDS

      • Replies to GDS>

        Comment by Alec posted on

        Thanks for the reply - look forward to seeing the guidance.

        • Replies to Alec>

          Comment by Alec posted on

          Hi there,
          Is there any update on the guidance?

          • Replies to Alec>

            Comment by Alec posted on

            Also, say you have some content on your website that isn't accessible, you mention it in your accessibility statement (as well as why and what you're doing to fix this), does this mean you're covered legally?

  7. Comment by Charlotte posted on

    Stupid question - Where IS the example accessibility statement?

  8. Comment by Karen Winter posted on

    Please could you clarify if this includes Parish Council websites?

  9. Comment by Anthony Ilona, GDS posted on

    Hi Darren,

    Regulation 4 (2)g makes specific reference to intranets and extranets.

  10. Comment by Tim White B&NES posted on

    Hi
    Does this extend to websites without a .gov.uk domain too? We operate a number of commercial sites with a .co.uk. Are they in scope for this too?

    • Replies to Tim White B&NES>

      Comment by Anthony Ilona, GDS posted on

      Hi Tim,

      It’s more about ownership of the site and its content than the domain name when considering legal compliance. According to the regulations, if third party content is neither funded nor developed by the public sector body concerned nor under its control, it is exempt.

  11. Comment by Stephen Burke posted on

    Hi
    Can you clarify the guidance please.
    If the website was built before 23/09/2018, does the accessibility statement still need to be added to the website before 23/09/2019? Or should we ensure it is added before 23/09/2020?

    So far we have been working on the proviso that the accessibility statement should be added to the website by 23/09/2019 but that the work to meet the standards should be complete by 23/09/2020.

    • Replies to Stephen Burke>

      Comment by Tony Ilona, GDS posted on

      Hi Stephen,

      The regulations state that existing websites (those published before 23 September 2018) must meet the required accessibility standard AND display a compliant accessibility statement on and after 23 September 2020.

      Newly published websites (those published on and after 23 September 2018) are required to meet the same terms by 22 September 2019.

  12. Comment by Charlotte posted on

    Does the EU directive cover Universities? A definitive answer from government would be AWESOME.

    • Replies to Charlotte>

      Comment by Anthony Ilona, GDS posted on

      Hi Charlotte,

      While Universities are generally considered to be in scope of the regulations, we recommend that you seek professional advice for a definitive answer.

      • Replies to Anthony Ilona, GDS>

        Comment by Emma posted on

        Your answer to this question has me confussed?

        'While Universities are generally considered to be in scope of the regulations, we recommend that you seek professional advice for a definitive answer'

        GDS have set these deadlines, how can there be any questions that you can't answer? Who are we supposed to ask for definitive answers if GDS themselves can't answer questions?

  13. Comment by chris_debian posted on

    Is this just public facing, or internal government websites, such as intranets?

    Thanks,

    Chris

    • Replies to chris_debian>

      Comment by Anthony Ilona, GDS posted on

      Hi Chris,

      There are requirements in the regulations that apply to non public-facing websites such as intranets and extranets.

      • Replies to Anthony Ilona, GDS>

        Comment by chris_debian posted on

        Many thanks for the clarification, Anthony.

        Chris.

      • Replies to Anthony Ilona, GDS>

        Comment by Darren posted on

        Which requirements specifically apply to Intranets and Extranets?

      • Replies to Anthony Ilona, GDS>

        Comment by Jason posted on

        Are you sure? Section 4 (2) (g) states "These Regulations do not apply to the following content of a website or mobile application
        of a public sector body...content of extranets and intranets published before 23rd September 2019, until such websites undergo a substantial revision;

        It goes on to say;
        (3) In this regulation—
        (b) “extranets and intranets” means a website that is only available for a closed group of people and not to the general public;

        • Replies to Jason>

          Comment by Alex posted on

          Further to this, does it mean that any new content published on a intranet/extranet from 23 September onwards needs to be fully accessible?

  14. Comment by agtrier posted on

    Good to see that GOV.UK is implementing the new EU accessibility directive. In fact, that's good news for everybody!