On the accessibility statement in more depth

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Requirements of the accessibility statement

Regulations specifying the statement

The accessibility statement is not just any document required by the EU and the Commission, as the directive and the Commission’s enforcement order and local Finnish law have detailed stipulations regarding what the statement must contain, how the content must be verified and how it must be published.

Directive on the accessibility of websites and mobile applications

The requirements are based on Directive (EU) 2016/2102 on the accessibility of the websites and mobile applications of public sector bodies, issued on 26 October 2016.

Article 7 (Additional measures) provides for accessibility statements. The directive sets the following requirements for a statement:

  • the statement must be up-to-date, detailed, comprehensive and clear
  • the statement must be provided in an accessible format
  • the statement must be published on the relevant website
  • the statement must be accessible on every page, e.g. in a header or footer (a standard URL address can be used).
  • the statement must include an explanation concerning those parts of the content that are not accessible
  • the reasons for that inaccessibility
  • the accessible alternatives provided
  • a feedback mechanism (a description of and a link to reporting and requesting omitted information)
  • a legal protection method (a link to the enforcement procedure through which recourse may be had).

Commission Implementing Decision on establishing a model accessibility statement

Commission Implementing Decision (EU) 2018/1523 on establishing a model accessibility statement, issued 11 October 2018, states the following:

  • public sector bodies must provide accessibility statements using a model accessibility statement established by the Commission
  • public sector bodies must review and update their accessibility statements regularly, and at least annually
  • the statement must be accessible from each web page of the website, as well as the mobile application
  • the accessibility statement should be made available, where appropriate, in a machine-readable format
  • the declarations made in the statement, as regards compliance with the requirements, are accurate and based on one of the following:
    • an actual evaluation
      • a self-assessment
      • an audit carried out by a third party
    • any other measures, as deemed appropriate by the Member States, which provide equal assurance that the declarations made in the statement are accurate (such measures do not exist)
  • public sector bodies must provide in their respective statements at least the mandatory content requirements set out in this Implementing Decision
  • Member States may add requirements that go beyond optional content.

A proposal for the statement creation process

Contents of the statement

The EU Directive, the Commission Implementing Decision and the Act on the Provision of Digital Services stipulate that the statement must address accessibility quite comprehensively. Finnish law provides for the requirements for the statement rather narrowly, but it does refer to the Implementing Decision issued in accordance with Section 2 of Article 7 of the EU directive on accessibility, which is in turn referred to by the Decision. The requirements set by these two are listed comprehensively above.

Correctness of the contents of the statement

It is required from the accessibility statement that its claims regarding the implementation or non-implementation of accessibility are provided in detail, including aspects such as which requirement is not met and why, as well as what measures have been taken to resolve the issue.

This requires interpreting the results of certain checks carried out in a self-assessment correctly, as well as the ability to assess the actual meaning of the results. The creators must also be able to verify whether the reports on technical checks have the correct content and interpret the contents of the check reports for the statement, or carry out the corrective remedial measures based on the checks.

Some of the shortcomings reported in automated checks may not be genuine accessibility issues, but they must be verified at least. Errors such as these should be corrected as well, as they have an adverse effect on the operation of the page and external users’ views on the accessibility of the website.

For the aforementioned reason, the following separate sets of instructions have been created:

  • a presentation of different checking tools
  • instructions for interpreting check reports
  • checking accessibility
  • check tools
  • assessment of check results
  • to-do lists for different roles
  • model texts for an accessibility statement.

Creating the statement

Creating an accessibility statement is expert work. There are legally binding stipulations related to the assessment and its creation, and determining its contents requires a certain level of expertise in both accessibility and online technologies.

Creating an accessibility statement is not the duty of everyone working on an online publication. Every organisation and unit must appoint a certain party (division or enterprise) to be responsible for accessibility. This appointed party must also be mentioned in the statement (part of the obligatory information). The division or enterprise will be responsible for creating and maintaining the statement.

Meetings with the auditing organisation are not enough for the work process. Instead, the organisation must learn to maintain and produce everything in an accessible form itself. Accessibility is part of the process.

What creating the statement requires

The requirements set for the contents of the statement are detailed in the Commission Implementing Decision (EU) 2018/1523.

The Commission Implementing Decision states that the claims presented in the statement must be true and based on an actual assessment of the implementation of accessibility. The accessibility requirements are based on the general Web Content Accessibility Guidelines (WCAG) and their updated version. These guidelines list success criteria for contents and technical implementation that must be met.

Assessing accessibility based on these criteria requires that the assessor has sufficient expertise in the general principles of accessibility, the requirements of the WCAG criteria and online technologies. In particular, they must be able to judge the correctness of HTML tags and use of the WAI-ARIA attributes utilised by assistive technologies.

Accessibility assessment

The implementation of accessibility is assessed both with objective gauges and through subjective assessments. The measurable criteria are solutions related to publishing technology, the assessment of which requires accessibility technology know-how. The criteria to be assessed entail interpreting the requirements set for the perceptibility and understandability of contents.

Technical assessment

The technical accessibility of the website can only be assessed legitimately by a person with sufficient knowledge of the operation of the web and assistive technologies. Usually, this person represents the unit responsible for the technical maintenance of the system or is an external expert. The divisions and enterprises will complement the instructions with an operating model.

Assessment of contents

The best person to assess the accessibility of contents is the person responsible for the contents of the publication. A statement on the logicality and understandability of the contents may also be provided by an external expert.

Assessment results

The results of the aforementioned assessments are recorded in the accessibility statement.

Who creates the statement

A person responsible for both the technical implementation and the contents of the publication must take part in the accessibility assessment.

The statement is created by a person or persons appointed for the task. These persons must have sufficient expertise in accessibility requirements and online technologies. The statement or part thereof can also be created by an external expert, but the statement must be approved by the organisation.

Everyone must know the accessibility requirements in their respective work roles.

Take advantage of the Accessibility model statement

You can use the accessibility report of the Accessibility model to support the preparation of your own report, for example for titles and general texts. Language versions Finnish, Swedish, English available.

The accessibility statement of the accessibility model