EN    EN EN 
 
EN    EN  COMMISSION OF THE E UROPEAN COMMUNITIES 
Brussels, 1.12.2008 
SEC(2008) 2916 
COMMISSION STAFF WORKING DOCUMENT 
 
Accompanying document to the 
  
COMMUNICATION FROM THE CO MMISSION TO THE EUROPEAN 
PARLIAMENT, THE COUNCIL, THE EUROPEAN ECONOMIC AND SOCIAL 
COMMITTEE AND THE COMMI TTEE OF THE REGIONS 
 
“Towards an accessible information society” 
 
Status and challenges of e-accessibility in Europe 
  
{COM(2008) 804 final} 
{SEC(2008) 2915} 
 
EN 2   EN TABLE OF CONTENTS 
1. Introduction ................................................................................................................. 3 
1.1. E-accessibility - who is concerned? ....................................................................... 3 
1.2. EU-level policy instruments ..................................................................................... 4 
2. E-accessibility ............................................................................................................ 6 
2.1. E-accessibility state of play ...................................................................................... 6 
2.1.1.  Provision of accessible ICTs – the e-accessibility deficit ............................ 6 
2.1.2.  Non legislative EU level  activities on e-accessibility .................................... 7 
2.1.3.  Legislative approaches ......................................................................................... 9 
2.2. Further actions towards a coherent and effective approach for e-accessibility
............................................................................................................................... ..... 12 
2.2.1.  Increasing coherence and timely  action by cooperation and 
coordination ............................................................................................................ 13 
2.2.2.  Supporting innovation and deployment ......................................................... 14 
2.2.3.  Facilitating standardisation activities .............................................................. 15 
2.2.4.  Legislation ............................................................................................................... 15 
3. Web accessibility ..................................................................................................... 16 
3.1.1.  Relevance and state of play ............................................................................... 16 
3.2. Web accessibility activities ..................................................................................... 18 
3.2.1.  Non legislative activiti es supporting web accessibility ............................. 18 
3.2.2.  Legislative approaches ....................................................................................... 20 
3.3. Further web accessibility actions .......................................................................... 21 
3.3.1.  Rationale for further action on web accessibility ......................................... 21 
3.3.2.  Estimated costs of im plementing web accessibility ................................... 22 
3.3.3.  Accelerating in a common way th e realisation of modern web 
accessibility ............................................................................................................ 24 
 
EN 3   EN 1. I NTRODUCTION  
This staff working paper provides bac kground information on the 2008 Communication 
“Towards an Accessible Information Society”. It deals with both e-accessibility in general and 
web accessibility as a specific priority. This  staff working paper is based upon two study 
reports prepared for the Commission in 20 08 on e-accessibility and web accessibility 
respectively (both with an extensive analysis of  legislation in Member States, USA, and some 
other third countries, and at EU  level), the public consultation held from July — September 
2008, consultation workshops, the impact  assessment of the 2007 e-Inclusion 
Communication, the ‘MEAC’ study1, and a range of other docum ents quoted in the notes. 
The paper first presents general information on e-accessibility (and web accessibility), namely 
who is concerned and which EU-level policy inst ruments are at our disposal. Section 2 of the 
paper deals with e-accessibility  in general, presenting both non-legislative and legislative 
activities, and subsequently providing more background inform ation for the action proposed 
in the Communication to achieve a more cohe rent and effective approach to improving e-
accessibility. 
Section 3 then deals in more detail with web accessi bility. It presents the current state of play 
addressing both non-legislative and legislative activities, and then pr ovides more background 
information on initiatives that are proposed  in the Communication to accelerate web 
accessibility.  
1.1. E-accessibility — who is concerned? 
E-accessibility means overcoming the technical ba rriers and difficulties that people with 
disabilities and others like elde rly people experience when trying to participate on equal terms 
in the information society.2 It potentially concerns a ny type of information and 
communication technology (ICT) us ed by citizens. Full e-accessibi lity is a huge challenge, as 
there is a wide range of di sabilities and ICTs are consta ntly and rapidly evolving.  
E-accessibility is of great importance for many citizens: Up to 15% of the population across the Europe an Union has a disability, such as a visual, 
hearing, speech, cognitive, or motor impairment
3.  
The elderly population is also much concerne d by e-accessibility as disability correlates 
strongly with age. In the EU 27 countries about 16% of the populat ion are over 65, a number 
that is estimated to rise rapidly in the coming years4. 
Many other citizens could also benefit from e-accessibility in adverse or special usage 
environments such as noisy environments, hands-free and poor lighting environments.  
                                                 
1 Study on ‘Accessibility to ICT Products and se rvices by Disabled and Elderly People’ (reports e-
accessibility and web accessibility), ‘M eAC’ study (Measuring progress of e-accessibility in Europe), 
Report from the Public Consulta tion on web accessibility and other e- accessibility issues. All available 
at http://ec.europa.eu/information_society/activities/einclusion/index_en.htm   
2 COM(2005)425 on e-accessibility.  
3 Report of the Inclusive Communications (INCOM) subgroup of the Communications Committee 
(COCOM) COCOM04-08. 
4 Eurostat yearbook 2008. 
 
EN 4   EN The core group of disabled persons for whom e-accessibility is relevant comprises some 84 
million persons in Europe, of which 50 million in the age range 15-64 and 34 million in the age range 65 and above. 
5 
As there is a wide variety of impairments, n eeds are very diverse and likewise a great variety 
of solutions is needed. As shown in Figure 1  there are many barriers to ICT and many ICT-
enabled products and services that may pos e accessibility challenges to persons with 
disabilities, as well as many potential solutions.  
 
Design mainstream ICT products / services so that the visual 
presentation can be adjusted by the users (e.g. displays with adjustable font size, contrast, use of colours)
Provide second audio channel / track
to narrate the visual component of
TV broadcasts / videosEnsure that audio outputs are adjustable in sound volume & quality 
Provide text captions enabling deaf people
to follow the audio component of 
TV broadcasts / videos 
Design ICT products/services so
that they are compatible with
assistive technologies for blind
users such as text-to-speechsoftwareDesign mobile phones to minimise 
interferences with hearing aids 
Provide alternative to speech input in  
interactive voice systems
Provide text telephones & operator relay
services enabling text phone users to communicate with 
voice phone usersDesign public telephones, ticket 
machines, information kiosks,
cash dispensers so that they are 
accessible to wheel chair drivers
Design key pats, touch screens
and other interfaces to cater for people 
with dexterity problems (e.g. less sensitive, 
better spaced, larger  buttons)
Visual impairments Hearing impairments
Speech impairmentsCannot read visual 
displaysBarriers
Cannot see
visual web 
content
Cannot watch
TV broad-castsCannot hear 
voice on telephone
Cannot hear audio 
status signals
Cannot hear 
TV audioCannot see visual   
system status signals
Mobile phones
interfere with
hearing aids
Physical &
mobility impairmentsProvide speech, audio and other outputmodes as alternative to visual displays & status indicators on ICT productsProvide audio & other output modes as alternative 
(e.g. vibrating) to audio signals 
Provide text telephones & operator relay
services enabling text phone users to 
communicate with voice phone users
Design ICT products/services so that
they are compatible with assistive 
technologies for people with dexterity 
impairments (e.g. alternative  input devices)
Cognitive impairmentsDesign online services and otherICT-based products so that they are understandable and usable by
people with cognitive impartment 
(e.g. simple/consistent menu structure,
consistent use of icons , easy language) 
Design online services and other ICT-based
products to accommodate age related changes in information processing capabilities
(e.g. lower reaction speed,  less fine  motorskills, reduced memory capacity)Online content 
too difficult to
understand 
(e.g. complex
language)
Interface / menu  
too complex  
to use
Cannot talk to voice-based 
services & systems such as 
call centres & interactive 
response services Public 
terminals       
unreachable 
in wheelchair
Interfaces 
requiring too fine 
manipulation 
skillsSolutions
Design mainstream ICT products / services so that the visual 
presentation can be adjusted by the users (e.g. displays with adjustable font size, contrast, use of colours)
Provide second audio channel / track
to narrate the visual component of
TV broadcasts / videosEnsure that audio outputs are adjustable in sound volume & quality 
Provide text captions enabling deaf people
to follow the audio component of 
TV broadcasts / videos 
Design ICT products/services so
that they are compatible with
assistive technologies for blind
users such as text-to-speechsoftwareDesign mobile phones to minimise 
interferences with hearing aids 
Provide alternative to speech input in  
interactive voice systems
Provide text telephones & operator relay
services enabling text phone users to communicate with 
voice phone usersDesign public telephones, ticket 
machines, information kiosks,
cash dispensers so that they are 
accessible to wheel chair drivers
Design key pats, touch screens
and other interfaces to cater for people 
with dexterity problems (e.g. less sensitive, 
better spaced, larger  buttons)
Visual impairments Hearing impairments
Speech impairmentsCannot read visual 
displaysBarriers
Cannot see
visual web 
content
Cannot watch
TV broad-castsCannot hear 
voice on telephone
Cannot hear audio 
status signals
Cannot hear 
TV audioCannot see visual   
system status signals
Mobile phones
interfere with
hearing aids
Physical &
mobility impairmentsProvide speech, audio and other outputmodes as alternative to visual displays & status indicators on ICT productsProvide audio & other output modes as alternative 
(e.g. vibrating) to audio signals 
Provide text telephones & operator relay
services enabling text phone users to 
communicate with voice phone users
Design ICT products/services so that
they are compatible with assistive 
technologies for people with dexterity 
impairments (e.g. alternative  input devices)
Cognitive impairmentsDesign online services and otherICT-based products so that they are understandable and usable by
people with cognitive impartment 
(e.g. simple/consistent menu structure,
consistent use of icons , easy language) 
Design online services and other ICT-based
products to accommodate age related changes in information processing capabilities
(e.g. lower reaction speed,  less fine  motorskills, reduced memory capacity)Online content 
too difficult to
understand 
(e.g. complex
language)
Interface / menu  
too complex  
to use
Cannot talk to voice-based 
services & systems such as 
call centres & interactive 
response services Public 
terminals       
unreachable 
in wheelchair
Interfaces 
requiring too fine 
manipulation 
skillsSolutions
 
Figure 1 Barriers to e- accessibility and solutions 
1.2. EU policy instruments 
In the early 90’s e-acce ssibility was addressed through the EU’s Framework programmes for 
research and technological development. Ten years later e-accessibility became part of the broader research theme of e-in clusion, first through telematics for elderly people and people 
with disabilities, then through the 6
th and 7th Framework programmes. Research on e-
accessibility was complemented by work on European standards. 
In the second half of the 90’s e-accessibility gradually became an  integrated part of European 
policy on the Information Society. The polic y approach had several aims, including to 
encourage cooperation of stakeholders (people w ith disabilities and ot her users, ICT industry 
and authorities), to provide political guidance and to benchmark progress.  
In particular a dedicated chap ter on e-Accessibility was availa ble in the eEurope initiative. 
                                                 
5 Based on Eurostat data.  
 
EN 5   EN At the same time, references to e-accessibility started to appear in EU legislation related to the 
ICT sector, notably in the telecommunication Directives (currently called ‘electronic 
communications’ Directives), and the radio & telecommunication terminal equipment directive (R&TTE Directive), as explained in section 2. Non-ICT sector al legislation also 
incorporated explicit and implicit references to persons with disabilities and to e-accessibility, 
notably in the field of copyright, public procur ement and structural f unds regulations. General 
EU legislation on equal rights explicitly covers  disability and implic itly rights of disabled 
people to use ICT, namely the Employment Equa lity Directive and most recently the proposal 
for a Council Directive on “implementing the pr inciple of equal trea tment between persons 
irrespective of religion or beli ef, disability, age or  sexual orientation”. Details on this EU 
legislation are provided in Section 2.1.2.  
For e-accessibility policy in general, and we b accessibility policy in particular, several 
instruments exist at EU level. This  is further developed in section 2.1.2. 
 
EN 6   EN 2. E-ACCESSIBILITY  
2.1. E-accessibility state of play 
This chapter provides a short ov erview of the current state of  provision of accessible ICTs, 
followed by an overview of current non-legisla tive and legislative me asures at EU-level 
regarding e-accessibility. Then a short overview is  given of legislative measures in Member 
States and third countries. Fi nally, an explanation is provided for the action proposed by the 
2008 Communication “Towards an A ccessible Information Society”. 
2.1.1. Provision of accessible ICTs — the e-accessibility deficit 
The ‘MeAC’6 study conducted for the European  Commission in 2006-2008 provides an 
extensive analysis of the e-accessibility situa tion in the Member States and in some third 
countries. One of the main findings is that people with disabilities in Europe continue to 
face many barriers when using everyday ICT products and services  that are now 
essential aspects of social and economic life .  
This lack in e-accessibility can be found across the spectrum of ICT products and services, for 
example telephony, TV, web and self-service termin als. The following striking examples of 
the state of play of e-accessibility (as at end 2007 unless otherwise indicated) point to the 
barriers encountered by pe ople with disabilities: 
Text relay services  (essential for the deaf and speech impa ired) are only available in half of 
the Member States and emergency services ar e directly accessible by text telephone in only 
seven Member States.  
Mobile operators  in only seven Member States provide  dedicated information for customers 
with disabilities on their websites. 
On average, less than one-third of na tional language broadcasts of main public broadcasters  
in Europe were provided with subtitling  (for deaf people) in 2006; there is wide  variability 
(from 95% to none) in the amount of s ubtitling across individual countries. 
On average, less than one-tenth of national language broadcasts of main commercial 
broadcasters  in Europe were provided with subtitling  in 2006; most of this is provided in just 
a few countries. 
Public broadcasters in only five Member St ates provided any of th eir programmes with audio 
description  (for the visually impaired) in 2006 a nd, where they did, the levels provided 
amounted to a very small percentage of their overall programming.  
Only a very small proportion of key government websites  in the Member States meet the 
accepted minimum international standards on a ccessibility (12.5% passed automated testing 
and only 5.3% passed both automatic and manual examination). 
The share of key commercial/sectoral websites  (e.g. railways, TV, newspapers, retail 
banking) providing this minimum level of acce ssibility is even lo wer (only 3.9% passed 
automated testing while not a single site passed both automatic and manual testing). 
Only in six Member States has one of the leading retail banks installed ATMs  with ‘talking’ 
output (enabling self-service for customers with  visual impairments). Across countries, on 
average only 8% of all ATMs installed by the ma in retail banks in the EU of 25 Member 
States provide this output, with the bulk of this provide d in just a few countries.  
                                                 
6 http://ec.europa.eu/information_s ociety/activities/einclusion/library /studies/meac_study/index_en.htm. 
 
EN 7   EN 2.1.2. Non legislative EU action on e-accessibility 
2.1.2.1. Research support 
Sustained R&D in e-accessibility is important , as ICTs evolve rapidly and as new e-
accessibility challenges appear. An example is digital television, whose menus are hard to navigate for people with dexterity or cogn itive impairments or persons with reading 
difficulties (including some of the dyslexic, ill iterate or foreign language speakers that in 
several countries represent a sign ificant portion of the population).  
Equally important, new technologies offer new o pportunities to address participation barriers 
for persons with disabilities. A good example is direct brain- computer interaction by which a 
severely motor-disabled person (e.g. only able to blink an eye) is able to control devices ‘just’ 
by thinking.  
Related to e-accessibility research is the Ambi ent Assisted Living joint research programme, 
(AAL) launched in 2008 to stimulate innovative ICT-based solutions for independent living 
and the prevention and management of chronic conditions of elderly people including their 
related disabilities
 7.  
For several years the approach in EU R&D has b een that accessibility is best not “patched 
onto” existing mainstream technology, but rather  designed into mainstream technology from 
the outset. This universal design  or design for all approach is believed to deliver a double 
benefit: firstly, technology that  nearly anyone can use, including disabled persons; and 
secondly, cheaper e-accessibilit y. Specific research on assist ive technology has also been 
undertaken. Current R&D work on e-accessibility therefore seek s to embed e-accessibility 
into modern mainstream ICT (e.g. mobile communications, naviga tion systems, home 
systems, personal computers and web)8 as well as continued wo rk on assistive technology. 
The mainstreaming approach to e-accessibility also enables a better alignment between 
research and e-accessibility pol icy in general. Notably, resear ch should deliver technical 
specifications that can provide input for formal  or informal standardisation and thus can 
become reference points for “soft” or “har d” legislation. For ex ample current audio-
description9 legislation in the UK is based on research work undert aken in the 90’s with 
European funding under the TIDE programme10. The alignment of e-accessibility research 
and other policy measures (deployment support, standardisation, legislative measures) is not 
always addressed in a systematic way. 
2.1.2.2. Deployment / innovation support 
The ICT Policy Support Programme, a sub- programme of the Competitiveness and 
Innovation Programme (CIP ICT PSP)11 provides support for innovation and deployment in e-
accessibility. It can fund deployment pilots that  validate technology solutions in real-life 
settings and business models in line with Eu ropean policy goals, as well as fund thematic 
networks for cooperation between stakeholders , exchanging best practice and benchmarking. 
                                                 
7 www.aal-europe.eu. 
8 An overview of e-accessibility EU funded R&D pr ojects and related work in independent living of 
elderly which include a strong component  of e-accessibility is available at: 
 http://ec.europa.eu/information_society/activities/einclusion/research/index_en.htm . 
9 A voice-over of television programmes that describes the scenes for better understanding of visually 
impaired persons. 
10 Telematics for the Integration of Disabled and Elderly people.  
11 www.ec.europa.eu/cip . 
 
EN 8   EN As regards e-accessibility, the CIP is potentiall y a very important instrument: since the e-
accessibility market is fragmented, deployment valid ation can deliver the evidence needed for 
industry and authorities to accept e-acce ssibility solutions across the board.  
The CIP work programmes for 2007 and 2008 finance pilot schemes on e-accessibility and 
ICT for ageing.  
2.1.2.3. Standardisation: Mandate 376 
Standards are important to coor dinate e-accessibility efforts across Europe. They are needed 
both in general to ensure a common unders tanding and application of e-accessibility 
principles, and more specifically  to provide a yardstick agains t which e-accessibility can be 
assessed.  
In 2005 the Commission issued a mandate12 to the European Standa rdisation Organisations 
(ESOs) to develop common requirements for ICT in the field of public procurement, 
including conformance assessment mechanisms. Th e ESOs have the duty to establish efficient 
coordination mechanisms and to work in cl ose cooperation with re levant stakeholders. 
The main objectives of this mandate are to ha rmonise the accessibility requirements of public 
procurement of accessible ICT products and services , to identify a set of functional European 
requirements and to deliver European standard s for e-accessibility. Mandate 376 will provide 
an electronic toolkit, enabling public procurers to make use of these harmonised requirements. 
2.1.2.4. Measurement and benchmarking 
An extensive survey of the implementation of  e-accessibility provisi ons in the electronic 
communications Regulatory Framework was unde rtaken in 2006 by INCOM, the Inclusive 
Communication subgroup under the Communications Committee (COCOM).13 A significant 
lack of progress in implementing these e-accessi bility provisions was reported, with a clear 
indication that this was due to their non-mandatory character. This has motivated the Commission to propose a reinforcem ent of the provisions in the c ontext of the revision of the 
Directives. 
The MeAC study (referred to in the introducti on) delivered a major report in 2007 which 
constitutes a primary reference on the current av ailability of accessible ICT and the extent and 
effectiveness of policies across Europe and third c ountries, including the USA. 
The results of the study contributed to the ‘R iga Dashboard’, which measures progress on the 
targets for 2010 in digital inclusion agreed at the Riga Ministerial C onference on e-Inclusion 
in 2006. The first edition of this dashboard was p ublished at the end of 2007 together with the 
Communication on e-Inclusion.
14 
2.1.2.5. Awareness and promotion 
Exchange of best practices is supported through the ePractice portal15. In order to enhance the 
visibility and recognition of good practices, the Commission launched in 2008 an e-Inclusion 
                                                 
12 http://ec.europa.eu/information_s ociety/policy/accessibility/deploy/ pubproc/eso-m376/index_en.htm . 
13 COCOM is the regulatory commi ttee following the implementation of the electronic communication 
directives. INCOM 2006 report is available at: http://ec.europa.eu/information_society/activities/einclusion/groups/index_en.htm
. 
14 http://ec.europa.eu/information_society/activities/einclusion/policy/i2010_initiative/index_en.htm. 
15 http://www.epractice.eu . 
 
EN 9   EN Award scheme16 in which e-accessibility is one of th e 7 categories. The MeAC study created 
a website providing country reports, benchmar king results and other relevant information.17  
Industry, non-profit organisations and authorit ies regularly organise e-accessibility events. 
The European Commission also organises even ts on e-inclusion, including e-accessibility 
aspects, such as the ministerial conference on  e-inclusion, in Vienna , from 30 November — 2 
December 2008.18 
2.1.2.6. Cooperation and coordination 
Several groups collate information and draft pol icy papers in the field of e-accessibility:  
– INCOM addresses the state of play of implem enting e-accessibility provisions in the 
electronic communications framew ork, as previously explained. 
– A sub-group under TCAM19 focused on real-time text, which is essential for hearing and 
speech-impaired users to communicate via te lephone and reach among others emergency 
services. No solution could be agreed upon although the discussions did lead to the Commission proposing a pilot scheme under the ICT-PSP work programme on total 
conversation / accessible emergency services. 
– The e-inclusion subgroup  of the i2010 high-level group
20 held in-depth discussions on e-
accessibility and specific working sessions on web-accessibility. Participants in this subgroup are representatives from Ministries most  concerned with e-inclusion in general.  
– The High level Group on disability that suppor ts the Commission in the implementation of 
the European Disability Action Plan
21 that covers, amongst other ICT, links with 
disability policy in general.  
– User-industry cooperation , notably on accessible digita l television involved amongst 
others EDF, AGE and EICTA22. An example was the e-Inclusion Partnership23, an 
informal gathering of user organisations and ICT industry organi sed by the Commission. 
Despite the above mentioned activities, system atic coordination and cooperation at European 
level that brings together all stakeholders and that addresses e-accessibility in a prospective 
rather than retrospectiv e way is still lacking.  
2.1.3. Legislative approaches  
2.1.3.1.  EU level  
There is no specific EU legislation on e-acce ssibility. Nevertheless, there is sectoral 
legislation that, whilst e-accessibility is not th e principal aim, does explicitly or implicitly 
include some e-accessibility-related provisions. However, coverage is limited as some sectors are not (clearly) covered by EU legislation: websites, mobile telephony services, TV 
equipment, computer hardware and software, consumer electronics, assistive technologies. Relevant sectoral EU legislation includes:  
                                                
 
16 http://ec.europa.eu/information_society /newsroom/cf/itemdetail.cfm?item_id=4387 . 
17 http://www.eaccessibility-progress.eu/project . 
18 http://ec.europa.eu/information_society/events/e-inclusion/2008/index_en.htm . 
19 TCAM is the group created under the terminal equipment Directive (1999/5/EC). 
20 http://ec.europa.eu/information_society/eeurope/i2010/high_level_group/index_en.htm . 
21 http://eur-lex.europa.eu/LexUriServ/LexU riServ.do?uri=COM:2007:0738:FIN:EN:PDF . 
22 European Disability Forum (EDF), the European Older People’s Platform (AGE) and the European 
digital technology industry Association (EICTA). 
23 http://ec.europa.eu/information_society/activities/einclusion/events/partnership_1206/index_en.htm . 
 
EN 10   EN Electronic Communications Regulatory Framework 
The Framework Directive24 on electronic communication requires national regulatory 
authorities to promote equal choice, price and quality, and access to uni versal service for all 
users, including disabled users.  The Universal Service Directive25 addresses a number of 
issues relevant to e-accessibility of fixed te lephony services, such as specific measures to 
ensure access and affordability for all, wher e appropriate; access to op erator and directory 
services; access to emergency calls; avai lability/access to public payphones and special 
tariffs.  
These provisions are limited in two regards: they only cover fixed telephony services (not 
mobile telephony or telephone equipment) and th ey are not compulsory. In practice, Member 
States have made limited use of these provisions.  
In the context of the current revision of th e EU Electronic Communica tions Directives, the 
Commission has proposed strengthening existing provisions (see section 2.2.4). 
Terminal equipment covered by the R&TTE Directive26  
Article 3.3.f of the Directive entitles the Co mmission to propose an EC  Decision establishing 
that some equipment should support certain features  to facilitate use by users with a disability. 
So far, this option has not been used. This  Directive is currently being reviewed.  
Broadcast TV covered by the Audiovisual Media Services Directive27  
Article 3.c of the Audiovisual Media Services Directive states  that Member States shall 
encourage media service providers to ensure th at audio-visual media services are gradually 
made accessible to people with a visual or h earing disability. The Commission follows up on 
this provision with Member States and encourages its implementation.  
Digital content covered by the copyright Directive28 
Article 5.3.b. of the copyright Directive allows Member Stat es to make exceptions to 
copyright rules and protections to facilitate access for disabled people. A recently published 
Green Paper29 shows that, although Member States seem  to have implemented the exceptions 
to some extent, there is considerable variati on across countries in th e disabilities that are 
covered and requirements for some form of co mpensation to those holding the rights to use 
the works subject to the exception.  
                                                 
24 Directive 2002/21/EC. 
25 Directive 2002/22/EC. 
26 Directive 1999/5/EC. 
27 Directive 2007/65/EC. 
28 Directive 2001/29/EC. 
29 COM(2008) 466 final. 
 
EN 11   EN Goods and services covered by the Public Procurement Directive30 
The EU Public Procurement Directives of 2004 include provisions that encourage 
accessibility and design-for-all requirements to  be included in public procurement. Practice 
shows that there is very little inclusion of accessibility requireme nts in public procurements of 
ICTs in Europe to date.  
The Commission issued a mandate to the Europ ean Standardisation Organisations (see section 
2.1.2.3) to draft standards and a toolkit to help  public procurers (and suppliers) in Europe 
address e-accessibility requirements. 
Equality legislation31 
Article 5 of the Employment Equality Dir ective requires employers to take reasonable 
measures to ensure equality of access to employ ment for people with disabilities, unless such 
measures impose a disproportionate burden on the em ployer. Accessibility to ICT is indirectly 
concerned as an adaptation to equi pment ensuring access to employment.  
In addition, the Commission has recently adopt ed a proposal for a horizontal Directive on 
equal treatment among others on access to and supply of goods and se rvices, also covering 
(even if not mentioned explic itly) ICT goods and services.32 Article 4 of this proposal for a 
Directive deals with effective and non discrimi natory access for person s with disabilities and 
it is an important aspect of the EU’s work towards implementation of the United Nations 
Convention on persons with disabilities33.  
Other legislation  
Other pieces of EU legislation contain provisions on ICT and peopl e with disabilities, such as 
legislation on value added ta x and state aid exemptions.34  
2.1.3.2.  Member State and third country legislation 
The previously mentioned study carried out in 2008 on accessibility of ICT products and 
services for disabled and elde rly people provides a comprehens ive view of the legislative 
landscape across the Member States , and in some third countries. 
Sectors covered by legislation  
The pattern of sectoral covera ge of e-accessibility legislation across the Member States 
closely mirrors that at EU level, with by fa r the most commonly covered sectors being fixed 
telephony services, TV broadcasting and public websites. All other s ectors (e.g. private 
websites and mobile telephony) have only sparse  coverage, with just a few examples of 
legislation addressing these se ctors in some Member States. Looking at third countries, it is 
noteworthy that both Australia a nd the United States, and particul arly the latter, have a much 
wider sectoral coverage than most EU Member States.  
Almost all Member States have implemented the revised EU public procurement directives, 
the employment equality directive and the digital copyright directive.  
                                                 
30 Directive 2004/18/EC. 
31 Directive 2000/78/EC. 
32 COM (2008) 426. 
33 http://www.un.org/disabilities/convention/conventionfull.shtml . 
34 Commission Regulation 800/2008 and COM(2008) 428. 
 
EN 12   EN Apart from this, in the absence of any EU legisl ation to date, a number of Member States have 
implemented anti-discrimination legislation in the field of goods and services, which address 
the accessibility of at least some commercial websites.  
More generally, almost all Member  States have some assistive technology legislation and / or 
public service provision in pl ace to help people with disa bilities acquire assistive 
technologies.  
Horizontal or non-sector -specific legislation 
Apart from legislation regulating specific ICT sectors, there are also examples of cross-
sectoral and/or non-sector-speci fic approaches in some Member  States, covering a number of 
ICT sectors within a single e-accessibility pol icy framework or measure. However, such 
approaches are not widespread amongst Member States. At EU-level, th ere is no such cross-
sectoral measure in place.  
There are two different types of  cross-cutting legislative approaches in Member States and 
third countries, namely laws that make specific reference to ICTs in general and/or e-accessibility in particular and laws on broader di sability (equality) themes, with an implicit e-
accessibility component. 
E-accessibility an explicit focus 
Non-sectoral legislation that explicitly addresses e-accessibilit y issues can be found in some 
European countries, sometimes inspired by EU regulation such as the ‘employment equality’ 
Directive.35 Several countries have in troduced equality or other legislation that explicitly 
addresses e-accessibility issues in a more cros s-cutting manner. According to the different 
jurisdictions within which such legislation has been enacted, they vary in terms of scope and 
other legal characteristics. No uniform approach  is apparent, and the various approaches each 
have their strengths and weaknesse s. Aspects of various approach es might serve as models of 
good practice, but no single approach yet appear s to provide a comprehensive and effective 
horizontal approach.  
In the USA the ‘Section 508’ of the Reha bilitation Act is a key reference point.36 
Implicit coverage of e-accessibility 
Although equality legislation may not necessar ily make explicit reference to ICTs, it may 
nevertheless have an impact on e-accessibi lity. Examples are legislation encouraging 
accessibility in general, and legislation prov iding for active involvement of NGOs in 
oversight and enforcement mechanisms. In the USA the prime example of such legislation is the Americans with Disabilities Act. 
2.2. Further action towards a cohere nt and effective approach for e-
accessibility  
E-accessibility has become a high priority on th e EU policy agenda, with recognition of its 
importance not only to achieve th e social objectives of the Uni on but also its competitiveness 
and internal market objectives. However, the impact assessment accompanying the e-inclusion Communication of 2007
37 concluded that the fiel d of e-accessibility was 
inadequately addressed across Europe in terms of efficiency and effectiveness, coherence and 
                                                 
35 Directive 2000/78/EC of 27 November 2000. 
36 http://www.section508.gov . 
37 COM(2007)694. 
 
EN 13   EN completeness of existing measures and the de gree to which existing measures are future-
proof. There is no reason to assume that this  situation has drastica lly improved since 2007. 
Reinforcement of a general approach to e-accessi bility would therefore still have to aim for 
further improvement in these criteria. 
The range of policy measures, illustrating the need for coh erence and for cooperation and 
coordination  is shown in the diagram below. 
 
Policy guidance
-Communications
- Declarations
- ResolutionsLegislation
-e-communications
-R & T T E
- public procurement
- anti-discrimination
Awareness
-Best practice
-Benchmarking
-EventsDeployment
-CIP ICT PSP
-Structural fundsGeneral policy approach to e-accessibility
Overview of instruments
R&D
-Framework 
Programme-AAL 169
Standardi-
sation
-ESOs. M376
- W3C, industryCooperation
-i2010, disability policy groups
- Legal, standards committees
- Industry & users dialogues
 
Figure 2 General approach to e-accessib ility — overview of policy instruments 
A coherent and timely policy approach is proposed by the 2008 Communication “Towards an 
Accessible Information Society”. Coherence is needed  because of the multi-sectoral and 
multi-dimensional range of issues to be addres sed, as traditional boundaries blur, new themes 
emerge and technologies and mark ets change over time. A timely  response is needed because 
ICT-based products and services continue to pr esent major barriers to participation for large 
numbers of Europeans. In additi on, the trend in fragmentation in  the regulatory requirements 
being introduced across Member States ma y soon pose significant threats to the smooth 
functioning of the in ternal market.  
An overall coherent e-a ccessibility approach would be desira ble to address all such aspects. 
This is also strongly supported by the publ ic consultation on e-accessibility and web 
accessibility. The approach consists of a mix of sector-specific measures and general e-
accessibility measures. Background to these measures is provided in the remaining sections of 
this chapter and in chapter 3 on web accessibility.  
2.2.1. Increasing coherence and timely action by cooperation and coordination 
To ensure coherent and effective management  and coordination of bot h web accessibility and 
e-accessibility issues, existing s upport for co-operation with a nd between stakeholders should 
be stepped up. 
• A dedicated ad–hoc high leve l e-accessibility group  is proposed in the Communication. 
This would provide guidance for a coherent approach to e-accessibility at European level, 
 
EN 14   EN and define priority action to improve e-accessibility. Represen tatives of key actors would 
collate work on existing priorities so that there is coherence between the necessary components (research and innovati on, standardisation, legislati on etc). Priority areas of 
work based on the public consultation and ongoing work are web acces sibility, accessible 
digital TV, total conversation/accessible em ergency services. PCs and self-service 
terminals are other priorities. This e-accessibility group will be reporting to the i2010 High 
Level Group, and financed th rough the budget foreseen fo r this in the CIP ICT PSP 
programme. Budget only concerns  a few meetings per year for about 20 experts.  
• This group could receive input from and provide guidance to exis ting relevant groups,  i.e. 
i2010 e-inclusion subgroup, mandate 376, INCOM, TCAM, and the Disability High level 
group.  
• As the measures proposed are not mandatory , there is a strong appeal for users and 
industry to take efforts to step up cooperation. 
• Moreover, continued monitoring of both web accessibility and general e-accessibility 
progress and implementation mechanisms is necessary. Studies in 2009 are due to produce e-accessibility implementation reports  as well as further details  on costs and benefits of e-
accessibility. 
• Under the 2009 CIP-ICT Policy support programme, a new thematic network on e-
accessibility and web accessibility, as proposed by the Comm unication, will further 
enhance and support stakeholder cooperation and the collation of experience and good 
practices.  
• There is clearly a lack of awareness of possibilities and user needs. The 2008 public 
consultation indicated strong support for information meas ures and exchanging best 
practice. The ePractice good practice exchange network  on e-government, e-health and e-
Inclusion, has already amassed much expertis e on e-accessibility. Furt her support for this 
portal is proposed.  
2.2.2. Supporting innovation and deployment  
The Commission proposes to actively continue supporting e-accessibility  and ICT for 
independent living of elderly and disabled peop le through the EU research programme with a 
further call for proposals in 2009.  
In addition to the CIP pilot schemes on accessible digital TV, which began started in 2008, 
and on total conversation/accessible ‘112’ emer gency call (expected to start in 2009), the 
Commission proposes for 2009 that the CIP conti nues to support e-acces sibility and ICT for 
ageing well (notably as mentioned before, th rough a network to exchange best practice, 
cooperate and measure e-accessibility and web accessibility). With the proposed schemes the 
mainstreaming approach to research and inno vation will continue to be the red line of a 
common European approach.  
The Structural Funds’ Regulation38 requires that "accessibility fo r disabled persons shall be 
one of the criteria to be observed in defini ng operations co-financed by the Funds and to be 
taken into account during the various stag es of implementation" (Article 16).  
                                                 
38 Council Regulation (EC) No 1083/2006 of 11 July 2006 laying down general provisions on the 
European Regional Development Fund, the European Social Fund and the Cohesion Fund and repealing 
Regulation (EC) No 1260/1999 
 
EN 15   EN 2.2.3. Facilitating standardisation activities  
More than 90% of respondents to the public consultation c onsidered standardisation and 
technical specifications a high or  relevant priority for future EU action on e-accessibility. 
Internationally, in particular, standards cooperation can be furt her pursued, notably with the 
US, in the context of the review of ‘Section 508’ of the US Rehabilitation Act (dealing with 
ICT) and the EU’s work on Mandate 376.  
2.2.4. Legislation  
The ‘MEAC’ study shows a clear correlation at  national level between the existence of 
legislation and the current leve l of progress on e-accessibility.39 Studies also point to the risks 
of legal fragmentation in the EU due to diffe rent legislative measur es. Based on this, and 
building on the 2005 Communication on e-acce ssibility and the 2007 Communication on e-
Inclusion, the Commission has explored a more ge neral legislative approa ch to e-accessibility.  
However, given the vast, complex and evolving nature of e-accessibilit y, there is not yet a 
clear consensus on EU legislation specifically targeting e-accessibility. In the public consultation, 90% of user organisations consid ered binding legislation a high priority, versus 
only 33% of industry and public authorities.  
There are also many open questions on the aspects of EU legislation on e-accessibility such as 
its scope, standards, compliance mechanisms, li nks to existing legislat ion, mix of bottom-up 
and top-down approach
40, mix of sectoral and general le gislative action. A particularly 
relevant development is the recent proposal fo r a directive on equal treatment. Furthermore, 
although there is a clear consensus on the need to act jointly to impr ove e-accessibility, there 
are different views on the ne xt priorities to tackle.  
The 2008 Communication “Towards an Accessibl e Information Society” emphasises the 
various options under current EU legislation th at remain under-used. In addition it stresses the 
need to explore the options for improving e-accessibility through several pieces of EU 
legislation that are, or will be soon, under revi ew, or have recently been proposed, notably: 
• Directive 1999/5/EC on terminal  equipment is under review: he re the issue is whether to 
activate Article 3.3.f for adopting spec ific accessibility  provisions.  
• The Commission recently tabled a proposal for a directive on equal trea tment, which refers 
to access to and supply of goods and services which are available to the public and whose 
Article 4 guarantees compliance of the principl e of equal treatment in relation to persons 
with disabilities. The final adoption of this Di rective will contribute to the implementation 
of some provisions of the United Nation C onvention on the rights  of persons with 
disabilities.  
• Legislative proposals for elect ronic communications include provisions on disabled users 
in relation to: setting binding national comm itments, emergency services, conditions to 
authorise service provision and representation of  user interests in bodies responsible for 
implementation of legislation. These proposals are now in the process of adoption by the Council and European Parliament. 
                                                
 
39 See the MeAC study and the study on accessibility to ICT products and se rvices by disabled and elderly 
people. 
40 Top down legislation imposes positive e-accessib ility obligations, while bottom up legislation give 
rights of redress/complain ts on accessibility grounds. 
 
EN 16   EN 3. W EB ACCESSIBILITY  
3.1.1. Relevance and state of play 
a) Relevance of web accessibility  
Web accessibility gives people with disabilitie s the opportunity to perceive, understand, 
navigate, interact and contribute to the We b. The lack of web accessibility affects many 
people: people with disabiliti es; elderly people; people with dyslexia, low literacy or not 
fluent in the language; people with low-bandwid th connections, older t echnologies or devices 
with limited display or interaction capabilities and new web users. When web accessibility is 
implemented it also benefits pe ople whose abilities change as they age. These persons can 
only make use of websites if they are properly designed and if they meet their specific needs 
(see Figure 3 ).  
Web accessibility has become particularly impor tant because of the explosive growth in on-
line information and interactive services provided on the web, from online banking and 
shopping, dealing with government and public services to communicating with distant 
relatives. If web accessibility is not achieved, ma ny people are at risk of being partially or 
totally excluded from the information society. 
Use flexible layouts that can be adapted by users to viewing needs 
(e.g. size, formatting, colour and background colour of text)Provide volume control when using sounds, background music, 
videos with sound etc.
Provide sign-language alternatives of all textual content for users that 
only speak sign-language, e.g. signing videos or animations
Provide elements (like buttons, 
menu items, form fields)  of 
sufficient size and with sufficient 
margin to adjacent elementsVisual impairments Hearing impairments
Layout not adaptable to    
users viewing needs (e.g. 
font-size, contrast)Barriers
Cannot see visual 
content (images / 
multimedia)Dexterity 
impairmentsProvide textual descriptions of images, graphs and animations (so-
called “alt” text) that can be read by screen reader software
Cognitive 
impairments
Unable to response
in given time limitStructure large amounts of texts, 
e.g. by using headings and sub-
headings or by breaking down 
into several pages 
Provide easy, clearly structured menus, using 
labels that are familiar to usersAvoid user alerts that are only based on 
sound and provide a visual alternative
Avoid unnecessarily complicated language and jargon, provide 
alternative easier descriptions and explanations of jargon or 
abbreviationsUse images, icons or graphs in 
a sensible manner to illustrate 
textual contentProvide audio description of the visual part of multimedia content such as videos
Difficulties hitting   
small elements on 
the screen with 
mouse
Cannot  read textual 
content due to illiteracy 
(some deaf)Cannot hear sound 
at all or at usual 
volume
Confused by unintuitive / 
badly structured menusDifficult to 
understand large 
amounts of   
unstructured text
Confused by complicated 
language, jargonConfused 
by animations, 
sounds etc.Cannot use   
keyboard instead 
of mouseProvide content in a way that it can 
be read by screen reader software, 
e.g. by using valid HTML code
Avoid confusing, fast moving, 
flashing animations and unexpected, loud, 
out-of-context soundsProvide text alternatives of all relevant audio, 
e.g. sub-titles / captioning for videos
Alternatively, use flexible layouts 
that allow users to control the size 
and formatting of those elements
Provide full support for keyboard-only 
users, e.g. by defining keyboard 
shortcuts
Avoid response mechanisms (like 
pressing a button) that impose time 
limits or ensure that time limits 
are not too restricted
Low literacy
Slow connections, small displays etc .Long loading times 
due to large 
amounts of data
Make reasonable efforts to ensure that a website remains 
usable when the transmission of images and multimedia content 
has been turned off by the user in order to save bandwidthViewing needs require 
adaptation of layout 
(small display)
Use flexible layouts that can be adapted by users to viewing needs
Solutions
Use flexible layouts that can be adapted by users to viewing needs 
(e.g. size, formatting, colour and background colour of text)Provide volume control when using sounds, background music, 
videos with sound etc.
Provide sign-language alternatives of all textual content for users that 
only speak sign-language, e.g. signing videos or animations
Provide elements (like buttons, 
menu items, form fields)  of 
sufficient size and with sufficient 
margin to adjacent elementsVisual impairments Hearing impairments
Layout not adaptable to    
users viewing needs (e.g. 
font-size, contrast)Barriers
Cannot see visual 
content (images / 
multimedia)Dexterity 
impairmentsProvide textual descriptions of images, graphs and animations (so-
called “alt” text) that can be read by screen reader software
Cognitive 
impairments
Unable to response
in given time limitStructure large amounts of texts, 
e.g. by using headings and sub-
headings or by breaking down 
into several pages 
Provide easy, clearly structured menus, using 
labels that are familiar to usersAvoid user alerts that are only based on 
sound and provide a visual alternative
Avoid unnecessarily complicated language and jargon, provide 
alternative easier descriptions and explanations of jargon or 
abbreviationsUse images, icons or graphs in 
a sensible manner to illustrate 
textual contentProvide audio description of the visual part of multimedia content such as videos
Difficulties hitting   
small elements on 
the screen with 
mouse
Cannot  read textual 
content due to illiteracy 
(some deaf)Cannot hear sound 
at all or at usual 
volume
Confused by unintuitive / 
badly structured menusDifficult to 
understand large 
amounts of   
unstructured text
Confused by complicated 
language, jargonConfused 
by animations, 
sounds etc.Cannot use   
keyboard instead 
of mouseProvide content in a way that it can 
be read by screen reader software, 
e.g. by using valid HTML code
Avoid confusing, fast moving, 
flashing animations and unexpected, loud, 
out-of-context soundsProvide text alternatives of all relevant audio, 
e.g. sub-titles / captioning for videos
Alternatively, use flexible layouts 
that allow users to control the size 
and formatting of those elements
Provide full support for keyboard-only 
users, e.g. by defining keyboard 
shortcuts
Avoid response mechanisms (like 
pressing a button) that impose time 
limits or ensure that time limits 
are not too restricted
Low literacy
Slow connections, small displays etc .Long loading times 
due to large 
amounts of data
Make reasonable efforts to ensure that a website remains 
usable when the transmission of images and multimedia content 
has been turned off by the user in order to save bandwidthViewing needs require 
adaptation of layout 
(small display)
Use flexible layouts that can be adapted by users to viewing needs
Solutions
 
Figure 3: Some web-related e-acce ssibility challenges and solutions 
 
EN 17   EN b) EU policy measures  
The importance of web accessibility has been recognised for many years by the European 
Institutions and Member States: 
– In 2001 the Commission adopt ed a Communication on web accessibility, encouraging 
Member States to endorse the Web Accessibility Initiative Guidelines41.  
– In two Resolutions adopted in 2002 and 200342, the Council stressed the need to 
increase efforts to speed accessibilit y to the web and its content.  
– The European Parliament suggested in 2002 th at all public websites be fully accessible 
to disabled persons by 2003, the European Year of Disabled Persons43.  
– In 2005, the Commission Communication on e-accessibility44 again drew attention to 
the importance of EU-level policies in this field and the Ministerial Declaration on eInclusion at Riga in 2006 set as one of its priorities the promotion of inclusive 
eGovernment by ensuring accessibility of  all public website s by 2010. However 
despite increasing awareness of authori ties and other schemes, progress on web 
accessibility remains unsatisfactory. It was al ready clear at the end of 2007 that this 
objective would not be met, as only around 5% of public websites and only 3% of 
commercial websites across the EU were sufficiently accessible.  
– The Communication on e-Inclusion in 2007
45 called upon Member States to agree by 
mid 2008 on a roadmap for accessibility of public websites.  
c) Websites accessibility in Member States  
When the MeAC study tested a sample of ke y public and sectoral/c ommercial websites in 
each Member State, only a very small percenta ge were found to meet accepted international 
accessibility standards.  
– 12.5% and 5.3% of government websites we re accessible for automated and manual 
testing respectively46.  
– For sectoral/commercial websites, just 3.9% passed the automated test and none 
passed the manual test.  
– These results mean that only a small pr oportion of key public websites (national 
governments, national parliament, and key mi nistries such as social, employment, 
health and education) meet the accessibility standards and the situ ation is even worse 
for key sectoral/commercial websites (e.g. ra ilways, TC, newspapers, retail banking). 
In a few countries, the majority  of the public websites tested  met the standards, but in 
many none of them did. 
Across the Member States the most common in struments used to promote and improve web 
accessibility are detailed technical guidance,  support training schemes, monitoring and 
                                                 
41 COM (2001)529. 
42 2002/C 8602 and 2003/C 39/03. 
43 C5-0074/2002-2002/2032(COS). 
44 COM2005(425). 
45 COM (2007) 694 final. 
46 The automated test uses a soft ware tool Test Accessibilidad We b (TAW) of the Spanish Fondacion 
CTIC ( http://www.tawdis.net/taw3/cms/en ). Sites that passed Level A from this automated test were 
then subjected to a human (manual) a ssessment by web-acc essibility experts. 
 
EN 18   EN assessment of websites, various awarenes s campaigns, coordination with relevant 
stakeholders and research activities both at national and European level. 
The public consultation showed that the majority  of the respondents indi cated that the above 
mentioned actions would contribute to a high le vel of availability of accessible web sites. 
(83.4% generally agreed, whilst 38.5% strongly agreed and only 4.9% disagreed). About one 
in ten respondents (11.8%) had no opinion. Also, a clear majority of respondents perceived 
the need to encourage intranet websites to be  accessible. In additi on, 94.3% of respondents 
agreed with the statement that  Member States should seek alignment with international 
standards.  
3.2. Web accessibility activities  
3.2.1. Non legislative activities supporting web accessibility 
a) Research support 
An example of EU R&D input to technology de velopments is the link between the W3C Web 
Accessibility and Ageing Task Forces47, supported for data collec tion and dissemination by 
the WAI-Age project48 funded under the 6th Framework Programme. This action aims at 
better understanding the needs of  the ageing community in the context of existing web 
accessibility guidelines. To this end, it provid es a contribution from the ageing community 
into the work of the W3C in revising and complementing educational materials to better reflect the needs of the elderly and to pursue  standards coordination in order to promote 
adoption and implementation of a common set of guidelines.  
A cluster of research projects funded under the 6
th Framework Programme also investigated 
the harmonisation of web accessibility measur ement, resulting in an assessment methodology 
(UWEM)49, a CEN Workshop Agreement on Specifi cations for a Web Accessibility 
Conformity Assessment Scheme and a Web Accessibility Quality Mark50. 
b) Deployment / innovation support 
In relation to deployment and innovation sup port, support can also come from the CIP 
programme. However, in the first two years of  this programme (2007-2008), web accessibility 
was not singled out for funding. 
c) Web accessibility standardisation  
As regards web content, the current de facto  standard is version 1 of the Web Content 
Accessibility Guidelines (WCAG 1.0) from W3C, although this is not a European standard. 
W3C has been working on version 2 of the gui delines (WCAG 2.0) for several years and is 
about to officially adopt it. Th ese guidelines are the result of  a long process involving many 
                                                 
47 World Wide Web Consortium: A vendor-neutral forum for the creation of de-facto standards for the 
web. www.w3.org/WAI/EO/2008/wai-age-tf.html . 
48 www.w3.org/WAI/WAI-AGE . 
49 Uniform Web-accessibility Evaluation Methodology ( http://www.wabcluster.org/uwem ), to be used 
both when reviewing a web site, attributing quality marks or im plementing an automatic surveillance 
observatory. Specifications fo r statistical indicators: 
http://www.eiao.net/publications/Indi cator_refinement_ FINAL_v1.31.pdf . 
50 CEN workshop agreement: 
ftp://ftp.cenorm.be/PUBLIC/CWAs/e-E urope/WAC/CWA15554 -00-2006-Jun.pdf . 
 
EN 19   EN specialised bodies and, when adopted, it will become the international reference for web 
accessibility.  
W3C has developed three sets of guideline s to ensure web accessibility: Web content 
accessibility guidelines (WCAG), authoring tool s accessibility guidelines (ATAG), and User 
agents’ accessibility guidelines (UAAG)51, addressing website owners, providers of authoring 
tools and providers of user agents (web browsers and related assistive technologies) 
respectively.  
At European level, work continues on the Ma ndate 376, which closely follows the work of 
W3C/WAI.  
Strong support was given for the coordination of  web accessibility efforts across Europe in 
the public consultation. 
Many Member States have developed national standards or regulations based on these W3C 
WAI guidelines. 
d) Measurement and coordination 
Both at national and European levels substa ntial measurement and benchmarking are being 
carried out. One of the most recent is the Me AC study, which reported at the end of 2007 the 
finding of a severe lack of web accessibility, as mentioned above.52  
e) Awareness and promotion 
In the specific field of we b accessibility, the Commission s upports the Web Accessibility 
Benchmarking (WAB) Cluster of projects.53 The cluster is developing an EU-harmonised 
assessment methodology for Web accessibility, ba sed on W3C/WAI and to be synchronised 
with the planned migration fr om WCAG1.0 to WCAG2.0. This s hould ensure that evaluation 
tools and methods developed fo r global monitoring or for lo cal evaluation are mutually 
compatible and coherent (and with WAI).  
Awareness and promotion campaigns are carried out in many countries. At European level, 
awareness and promotion campaigns were launch ed at Ministerial conferences and related 
exhibitions (Riga 2006, Lisbon 2007 and Vienna  2008), and the 2008 e-Inclusion Award in 
which e-accessibility, including web accessibility, is one of 7 best practice award categories. 
Best practices in web accessibility ar e promoted through the ePractice portal. 
However, there remains a lack of awarenes s and promotion of web accessibility issues. 
Results from the public consultation confirm th is: a large majority of  respondents (over 90%) 
are in favour of more schemes to train releva nt bodies, exchange best  practice and provide 
information and guidance to people with disabilities. 
                                                 
51 www.w3c.org/WAI . 
52 Another study was done in 2007 by Cap Gemini as part of the e-Government benchmark into 
availability of online pub lic services. In that case the presence of a web accessibility compliance mark 
was measured. National level measurement activities are extensively reported in the web accessibility 
study report. 
53 http://www.wabcluster.org/ . 
 
EN 20   EN 3.2.2. Legislative approaches 
a) At European level 
There are no specific web accessibility legisla tive measures at European level. However, 
some of the legislation on e- accessibility mentioned in section 2.1.3 also applies to web 
accessibility. 
b) At Member States and third country level  
In Member States, accessibility of public webs ites has received policy attention in recent 
years. However, there is considerable variatio n in terms of the type  and nature of policy 
approaches implemented. The st udy report on web accessibility mentioned in the introduction 
gives a detailed overview of the situation an d identifies key differences between Member 
States, e.g. in terms of: 
Type of approach:  
Six Member States have direct legislation on web accessibility (AT, DE, CZ, ES, FI, IT, SK), 
while others have indirect legislation (e.g. equa l rights legislation) on web accessibility (F, IE, 
MT, UK). Other Member States have addres sed web accessibility through non-legislative 
approaches of various types. 
Websites covered:  
The majority of Member States focus only on pub lic websites in their direct measures on web 
accessibility. The available evidence indicates th at the scope of coverage of public websites 
varies; some Member States include all levels  of government and public entities, whereas 
others only directly cover central government . One country (DE) explicitly covers the 
intranets of public bodies. In th e few cases where commercial we bsites are directly covered 
(DE, IT, PT), this tends to be done through ‘encouragement’ measures.  
Timeframe for web accessibility:  
About half of the Member States have implem ented a specific timefra me within which web 
accessibility is be achieved, with time horizons ranging from 2005 to 2010. In some countries 
(NL, SK, UK) new websites are given an imme diate deadline whereas existing websites are 
given some time to adapt. 
Accessibility requirements:  
W3C’s Web Content Accessibility Guidelines (WCAG 1.0) represent a major reference point 
in almost all Member States that have put in  place some type of measure. A few countries 
have developed variants, base d on national norms and/or the US section 508 standards (CZ, 
IT, NL, SE). Most countries re fer to WCAG 1.0 single A and/or double A requirements; triple 
A requirements are referenced to a lesser exte nt. The forthcoming WCAG 2.0 guidelines seem 
to have been formally addresse d by only one Member State (DE). 
Support for web owners:  
The evidence available suggest that the countries (AT, DE, DK, UK) that have adopted 
dedicated measures to support web owners in implementing accessi bility-related policies 
focus on three key aspects: awareness rising, netw orking of relevant acto rs and organisational 
capacity building. 
 
EN 21   EN Enforcement:  
Enforcement is not very vi sible in the majority of countries. Where it is the case, it tends to be 
based on persuasion (e.g. through award schemes, “naming and shaming”). Penalties for non-compliance are only apparent in a few countries (ES, FR, IT, SK). 
Conformity assessment:
 
In the majority of countries conformity asse ssment schemes have not been put in place; only 
in three Member States have these schemes so far been set up as part of a dedicated government policy (AT, NL, IT). In some coun tries voluntary web accessibility labelling 
schemes have emerged, operated by NGOs or commercial parties. 
Monitoring:
 
Benchmarking of accessibility of web sites has been  identified in less than  half of the Member 
States; where it happens, a nnual benchmarking has remained an exception. The various 
monitoring efforts pursued so far vary greatly in terms of scope (e.g. number and types of 
websites sampled) and methods applied (e.g. accessi bility criteria applie d, self-evaluation vs. 
external evaluation); it is thus difficult to compare outcomes across countries. 
As regards third countries, it is important to mention the USA: Section 508 of the 
Rehabilitation Act specifically provides that federal agency websites must be accessible to 
federal employees and the general public. Fede ral contractors also are bound by this mandate. 
The obvious strength of Section 508  is its clear applic ability to federal websites as provided 
by statute. Its weakness lies in the reliance on individuals with disabi lities to bring about 
enforcement by filing complaints. 
3.3. Further web accessibility actions 
3.3.1. Rationale for further action on web accessibility 
There is clear consensus on the importance of accessing the internet, the modest achievements 
to date as regards web accessibility, and the n eed for further action to improve the situation.  
Since there are no EU legislative provisions on web accessibility, the ma in responsibility for 
improving web accessibility remains with the Member States and individual service providers. Nevertheless, as explained in the Communication “Towards an Accessible 
Information Society” further acti on can also be taken at EU le vel. The overall goal would be, 
by better coordinating Member States’ action, to reinforce, accelerate and extend existing 
efforts to remove accessibility barriers that prevent citize ns, government and business in 
Europe from realising the full potential of the web.  
The key objective would then be to accelerate we b accessibility (in order to fulfil the Riga 
target of accessibility of 100%  of public websites by 2010). A second objective would be to 
overcome fragmentation in web accessibility specifications caused by uncoordinated approaches in Member States over the years. In this respect the timing is right given the move 
to new web specifications. Specifically, two important future developments in web 
accessibility are the official adoption by W3C of WCAG 2.0, expected in the near future and 
the establishment of a European standard on web accessibility as an outcome of Mandate 376.  
Preparing the ground for these — in  a way that avoids the fragme ntation of the past — would 
mean jointly anticipating compliance and prepar ing migration towards the modern technical 
requirements for accessible websites by Member  States, website owners, authoring tools 
providers and providers of user agents. Currently  the best reference point for these technical 
 
EN 22   EN requirements — in absence of a European stan dard — is WCAG 2.0 as the guidelines are not 
yet approved.54 
While binding web-accessibility legislation might be expected to have a stronger and more 
consistent impact across the Member States, fo r practical purposes su ch legislation would 
require the availability of the relevant standard. For this reason the schemes in the Communication, for which additional backgr ound is presented below, focus on the 
preparation for a swift implem entation of the new standard. 
3.3.2. Estimated benefits and costs of implementing web accessibility 
There is no definitive picture available of th e costs of web accessibility for websites owners. 
Part of the reason for this is that costs vary according to many different factors. However, it is 
generally accepted that costs ar e typically much lower at the design stage than the costs of 
retrofitting accessibility for existing websites. Co sts are likely to increase with increasing size 
and complexity of websites, particularly for retrofitting existing websites. The evidence suggests that costs are often overestimated a nd they have tended not to be considered 
excessive by the courts when action is taken by disabled people on grounds of 
inaccessibility
55. 
Despite the likely variability in costs according to the circumstances, the available evidence to 
date suggests that costs of accessibility woul d not represent an undue burden for web owners 
in most cases.  
Alongside costs, benefits should also be taken into account. The study on ‘the accessibility to 
ICT products and services for disabled and el derly people’ (mentioned in the introduction) 
provides a detailed model of the cost-benefits of investment in web accessibility linked to 
transaction cost savings from citizens using eGovernment services. Based on the available evidence, the model takes a range of estimates for the additional costs associated with making 
public websites accessible in the Member St ates and examines how the cost-benefit 
implications vary with increasing ‘reach’ to  the disabled and older people, who would 
otherwise be excluded through lack of accessibility.  
The model makes a number of assumptions:  (1) The costs of annual spending on online public we b sites are extrapolated from UK data 
from 2004 to 2007 and from the EU-25, correctin g for the actual online public services 
availability of each country. The empirical data available on the additional costs for 
making a website accessible are limited. Theref ore the model allows these costs to be 
taken as a variable (see the column headings  in the table below, with additional costs 
varying from 2% to 30%).  
(2) The additional costs are the same for all gove rnment websites (which is in fact very 
unlikely as it is estimated that at least 40% of current government websites may be 
quite close to being accessible and relatively  easily made accessible so that even 20% 
would be a reasonable upper limit to  costs at this point in time). 
                                                
 
54 WCAG 2.0 was published as a W3C Proposed Recommendation on 3 November 2008.  
55 For example, in Australia in the context of a judgm ent in favour of a complaint against the 
inaccessibility of the Sydney Olympics website th e courts brought in expert witnesses and a 
commission determined that it would co st relatively little (and a lot less than was originally estimated) 
to make the site accessible. The site’s creator es timated for instance that fixes would cost around 
US$2.2 million. Experts’ cost estimates were $29 450.00. C. f: Olympic Failure: Tom Worthington: A 
Case for Making the Web Accessible. 
 
EN 23   EN (3) There is the same level of recurring cost s per annum. This also is a conservative 
assumption as in many cases the costs of ma intaining accessibility should be a lot 
lower than the initial (retrofit) costs, esp ecially if good design prin ciples are adopted at 
an early stage. 
(4) Government cost savings per transacti on of €18.22, which is a conservative estimate 
(based on data from the UK).  
(5) On average an online citizen will use onlin e government services (of any type) twice a 
year.  
(6) Consumer benefits are calculated taking av erage time savings of 69 minutes by using 
online instead of ‘traditional’ services (data from EU-15, Norway, Iceland). Time 
savings are valued on the basis of actual consumer wages in each country. Consumer 
costs of PC and Internet connection are not  taken into account (as these are likely not 
specifically incurred for consumers carry ing out transactions  with government). 
The analysis shows that the overall cost-benefit return becomes increasingly positive as cost 
estimates for accessibility go down and additio nal reach percentages go up. Most cost/reach 
scenarios are positive for governments and only the highest cost and lowest reach ones are 
negative.  
Additional costs to achieve website accessibility Reach 
amongst 
target 
group Economic costs-benefit 
categories 2% 5% 15% 30% 
government costs for e-accessibility -24,256,800 -60,641,999 -181,925,997  -363,851,994 
government transaction cost savings 158,223,882 158,223,882 158,223,882  158,223,882 
net government costs/benefits 133,967,082 97,581,883 -23,702,115  -205,628,112 
consumer benefits 153,112,707 153,112,707 153,112,707  153,112,707 5% 
total cost/benefit 287,079,790 250,694,590 129,410,592  -52,515,405 
government costs for e-accessibility -24,256,800 -60,641,999 -181,925,997  -363,851,994 
government transaction cost savings 316,447,764 316,447,764 316,447,764  316,447,764 
net government costs/benefits 292,190,964 255,805,765 134,521,767  -47,404,230 
consumer benefits 306,225,415 306,225,415 306,225,415  306,225,415 10% 
total cost/benefit 598,416,379 562,031,180 440,747,181  258,821,184 
government costs for e-accessibility -24,256,800 -60,641,999 -181,925,997  -363,851,994 
government transaction cost savings 632,895,528 632,895,528 632,895,528  632,895,528 
net government costs/benefits 608,638,729 572,253,529 450,969,531  269,043,534 
consumer benefits 612,450,829 612,450,829 612,450,829  612,450,829 20% 
total cost/benefit 1,221,089,558 1,184,704,358 1,063,420,360  881,494,363 
 
Table 1 Cost-benefit modelling for accessible eGover nment: net cost-benefit p.a. (in €, EU 25) 
The overall cost-benefit (for gove rnments and users) is only negative in the least favourable 
cost-reach scenario (30% additional costs for achieving web accessibility and 5% increase in 
reach). In the most favourable scenario (2% additional costs for web accessibility and a 20% 
increase in reach) the model suggests total estimated benefi t of more than €1.2 billion. 
In addition to the benefits of reaching core gr oups (people with disabilities and older people 
with functional limitations) there are also the benefits of reaching an d/or providing better 
usage experiences for other groups, such as those using low bandwidth connections, using 
mobile phones or other small display devices and the like. Other tangible benefits can also be 
 
EN 24   EN achieved because accessible design requi res attention to good design principles56. These 
include increased search engine optimisation, e nhanced usability for all users and technical 
benefits such as lower site maintenance costs, reduced server load, improved interoperability and preparation for advanced te chnologies. These bene fits can result in substantial economic 
benefits in terms of increas ed business reach and direct cost savings through reduced 
personnel costs, amount of server capacity needed  and avoiding the need for multiple versions 
of a site for different user devices
57. 
3.3.3. Accelerating in a common way the realisation of modern web accessibility 
A common approach for web accessibility at  European level is supported by 96% of 
respondents to the public consu ltation. Success of a common Europ ean approach relies mainly 
on Member States, individual service provi ders and the Commissi on. A common approach 
should address accelerated and coherent (joint) preparati on for the new international 
guidelines WCAG 2.0 and the outco me of Mandate 376 as well as awareness and promotion. 
There is broad consensus that WCAG 2.0 guidelines  are the technical speci fications to be met 
for web accessibility. Once W3C reaches agreement on the guidelines, European Standardisation can be completed with in the framework of Mandate 376.  
To prepare for a swift incorpor ation of the new specifications
 into national rules and actively 
promote their implementation, Member Stat es should take the following steps:  
– Update the rules to take account of the new specifications (or adopt rules where 
accessibility requirements do not yet exist).  
– Ensure the requirements are made public and visible (e.g. through a single contact 
point, see below).  
– Translate the specificati ons and accompanying documentation to ensure a proper 
understanding and implementation at national level.  
– Follow the same timeline for updating and publication, so that Member States are in 
a position to compare their choices for as pects of the WCAG 2.0 specification and 
Mandate 376 results and seek alignment in  order to avoid fragmentation and reduce 
efforts (economies of scale).  
To improve implementation of web accessibility , it is suggested that Member States set up a 
list of the websites from their national aut horities that should be accessible by 2010. As soon 
as this list is available, the websites concerne d can begin preparations. By comparing the lists 
fragmentation can be addressed. Together with th is list Member States would be expected to 
set targets (such as the level of  accessibility to reach) and mile stones (i.e. deadlines). Again, 
this is also information that should be ma de public. By making their intranets accessible 
Member States also are in a better positi on to comply with the Employment Equality 
Directive, which requires employers to take reasonable measures to ensure employment of 
persons with disability in the cases wher e accessible intranets would be part of the 
accommodation required. 
To better leverage awareness and information , Member States can play an active role by 
supporting training schemes which are essential for bodies such as websites designers, ICT 
                                                 
56 Shawn Lawton Henry (2006) Understanding web accessibility. In: Thatcher et al (2006) Web 
Accessibility, Web Standards and Regulatory Compliance. 
57 Customer Respect Group (2008): Acce ssibility and Busine ss Value Study. 
 
EN 25   EN tools providers, web content prov iders, etc. In such training schemes direct involvement of 
persons with disabilities is desirable to understand their needs and expectations.  
Member States can also encourage non public we bsites providing servic es of general interest  
to be made accessible. 93% of respondents to  the public consultation agree that the common 
European approach should not merely addr ess public websites but also other websites 
providing services of gene ral interest. The aim here is to ensu re that people with disabilities 
are not excluded from essential se rvices (see the detailed explan ation of servi ces of general 
interest in the related Communication58).  
In terms of supporting th e exchange of practices , a role can be played by the ePractice portal 
as the one stop shop to exchange advice, experiences and events on practices of e-
Government, e-Health and e-Incl usion. ePractice offers the mo st complete information and 
exchange opportunities for these areas in Europe . Real life cases, insight and lessons learnt 
are shared. It represents a real bridge between  these communities, as there is a wealth of 
interesting lessons to be learnt.  
An important task is to improve the aw areness and understanding of web accessibility . 
Problems of accessibility often stem from a l ack of proper information. Member States can 
make sure that persons with disabilities re ceive sufficient and clear information on web 
accessibility. This should also include informa tion on how to use assistive technology in 
relation to websites.  
For better visibility and support , an accessibility statement on a website can provide useful 
information such as the accessibility policy of the website, compliance with relevant 
specifications and support for persons with disa bilities. It can be presented in the way 
“privacy statements” or other “legal informati on” is available in many websites today. It can 
of course be linked to a certifi cation and labelling scheme if th at exists. The general level of 
agreement in the public consultation in favour of such a statement was 89%.  
Reporting on web accessibility implementation  is crucial to assess the situation and progress 
made and to decide on further steps. In or der to reduce fragmentation Member States can 
work together to develop a common asse ssment and monitoring methodology. Assessment 
and reporting should then also concern complian ce and costs for web accessibility. Likewise, 
collecting user input is key to comprehensivel y assess the situation and better understand their 
needs and expectations.  
Lastly, a single na tional contact point  has already been raised as a one stop shop to find web 
accessibility related information and a single entry point for stakeholders. It can simply take the form of a website.  
The Commission uses an Information Provider’s Guide
59 which is mandatory for webmasters, 
editors, content providers and others dealing with websites in the Commission. This set of 
standards and guidelines includes a chapter on e-accessibility that currently makes direct 
reference to WCAG 1.0 from W3C. Action fr om the Commission includes updating the Guide 
and strengthening the internal policy towards web accessibility.  
Although Member States have the prime respons ibility of ensuring swift implementation of 
modern accessibility requirements, this does not prevent the Co mmission from proposing 
legislative measures at a later stage where necessary. 
                                                 
58 COM(2007) 725. 
59 http://ec.europa.eu /ipg/index_en.htm