EN    EN EN 
 
EN    EN  COMMISSION OF THE E UROPEAN COMMUNITIES 
Brussels, 1.12.2008 
SEC(2008) 2915 
  
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” 
  
Report on the 
Public Consultation on web accessib ility and other e-accessibility issues 
 
 
{COM(2008) 804 final} 
{SEC(2008) 2916} 
 
EN 2   EN TABLE OF CONTENTS 
1. Executive summary ................................................................................................ 3 
2. Introduction .............................................................................................................. 4 
3. Profile of respondents ........................................................................................... 5 
4. Opinion on a common European approach to web-accessibility .............. 7 
4.1. Experience of web accessibility .............................................................................. 7 
4.2. A common European Approach .............................................................................. 9 
4.3. Websites concerned ............................................................................................... 11 
4.4. Implementing web accessibility ............................................................................. 13 
4.5. Website authoring tools .......................................................................................... 15 
4.6. Accompanying measures ....................................................................................... 16 
4.7. Cooperation .............................................................................................................. 18 
5. Opinion on other aspects of e-Acces sibility and action at European 
level ........................................................................................................................... 19 
5.1. Experience of e-Accessibility ................................................................................. 20 
5.2. Priority areas for EU action .................................................................................... 23 
5.3. Preferred approach ................................................................................................. 25 
5.4. Legislative action ..................................................................................................... 28 
5.5. Expected impact ...................................................................................................... 31 
6. Closing remarks .................................................................................................... 32 
 
EN 3   EN Public consultation on web acce ssibility and other e-accessibility 
issues  
1. E XECUTIVE SUMMARY  
The issue of accessibility of information a nd communication technologies (ICTs), and of 
public websites in particular for people with di sabilities and other groups who are affected in 
general has had high EU-level policy visibility and attention for a number of years. In 2005, 
the Commission Communication on e-accessibility1 drew attention to the importance of EU 
policies in this field and took st ock of the overall situation in Europe. It concluded that the 
level of accessibility of ICTs in Europe remained unsatisfactory and that to redress this, 
existing measures should be built upon and new measures should be considered, including the 
prospect of new legislation. 
Reflecting on the outcomes  of a benchmarking study,2 the Commission’s 2007 
Communication on eInclusion concluded that insufficient progress had been made on e-
accessibility in Europe and that further steps were needed. In particular, the Communication called on Member States to agree on a roadmap for accessibility of publi c websites and stated 
that it would assess the need to propose new legislation in 2008. The prospect of horizontal 
legislation on e-accessibility was also considered. 
A public consultation was launched on 2 Ju ly 2008 through the European Commission’s 
interactive Internet platform “Your voice”. It  closed on 7 September 2008 and focused on two 
core themes: firstly, to explore a common Eu ropean approach to web accessibility and 
secondly to elicit public opinion on other aspect s of e-accessibility th at go beyond the World 
Wide Web and possible acti on at European level.  
Overall, 161 responses were received. They represent various stake holder groups, including 
individual citizens with and without disabiliti es (12% each), research experts and centres 
(30%), public authorities (1 4%), business and industry a ssociations (16%) and user 
organisations (12%). Some stakehol ders also sent position papers.
3 
Among those who responded to this consul tation, the support for a common European 
approach to web accessibility was almost una nimous. Overall, 96.9% of respondents agreed 
that a common approach was needed to facilitate  a high level of availa bility of accessible web 
sites, and 95.6% stated  that this should be equally motiv ated by the desire to improve the 
situation of people with disa bilities and the competitivene ss of European companies. 
Concerning the type of websites that should be covered by a common European approach, a 
clear majority (93%) agreed th at such an approach should not  merely cover public websites 
but also other websites providing services of ge neral interest to citizens, although industry and 
public authority respondents were somewhat less affirmative. 94.9% of respondents agreed 
                                                 
1 COM(2005) 425. 
2 Study on Measuring Progress of  e-accessibility in Europe (referre d to as MeAC), Report on the 
assessment of the Status of e-acce ssibility in Europe, available at 
http://ec.europa.eu/information_s ociety/activities/einclusion/libra ry/studies/meac_study/index_en.htm . 
3 Such as UMIC, ONCE, ANEC-EDF, BSkyB, RNIB, Te chnosite. The position papers are available at: 
http://ec.europa.eu/einclusion . 
 
EN 4   EN that intranet websites should also be accessible. Accordin g to 87% of respondents, web 
content authoring tools should also be cove red by a common European approach to web 
accessibility.  
More than nine out of ten respondents (94.3 %) agreed that Member States should seek 
alignment with international web accessibility standards. The majority would also welcome 
accompanying measures. These concern capacity building by supply side actors (95.6%), provision of information and guidance to users (94.3%), exchanging best  practice (95.6%) and 
collation of user input (94.9%). Regarding the perceived need to establish national contact 
points for web accessibility issues, there was overall agreement by 83.2% of respondents, 
with industry being less positive at 60%. 
In relation to ICT domains other than the we b, again a majority would welcome further EU 
action. Less than one out of ten respondents stat ed that none of the ICT domains mentioned to 
the respondents should be covered by EU acti on. Regarding the question as to how these 
should be addressed, a more diverse picture emerged from the responses received. Binding 
legislation was considered a high priority approach by 55.3%, whilst non-binding legislation 
was given high priority by 24.2%. High support for binding legislation was given by only 
30% of industry and public aut hority respondents, whilst 64% ove rall considered this a high 
priority. 
Apart from legislation, 67.7% of the respondents stated that standard isation and technical 
specifications should be high priority. 48.4% cited benchmarking and good practice 
specification as high priority, whereas 52.1% and 56.5% respectively stated  that high priority 
should be given to further support for research and deployment. 
Overall, the outcomes of the public consultati on indicate a strong level of support for a more 
cross-cutting EU approach to e-accessibilit y. The high number of comments made revealed, 
however, considerably different views of respondents when it come s to expectations 
associated with such an approach. This concerns , for instance, particular issues to be covered 
by the various ICT domains and the specific means by which these should be addressed. 
2. I NTRODUCTION  
The aim of the first part of the public cons ultation launched in mid 2008 was to explore a 
common European approach to web accessi bility, for the following reasons.  
Disabled users continue to face great difficu lties in accessing websites.  The development of 
the information society has led to the creation of websites and online services that are an 
essential part of daily life for citizens, yet significant numbers of people, including people with disabilities, still face difficulties in usi ng these websites due to accessibility barriers, 
despite current technical solutions  to overcome these barriers.  
Different policy approaches to web accessibility in the Member States are fragmenting the 
market: an increasing number of countries a nd EU Member States are taking action to 
improve web accessibility, including through legal obligations. However, a patchwork of national approaches is leading to increased frag mentation in the internal market. This causes 
legal uncertainty, particularly for technology provi ders, and makes it difficult for persons with 
disabilities to use online serv ices freely across Europe.  
 
EN 5   EN Regarding previous commitments and current opportunities, European institutions have 
debated web accessibility in recent years and EU Member States have committed to improving web accessibility. In particular, the “Ministerial Declaration on an inclusive information society” (Riga, June 2006) include d the commitment to make all public websites 
accessible by 2010.  
The aim of the second part of the public consultation was to e licit public opinion on other 
aspects of e-accessibility th at go beyond the World Wide Web and possible action at 
European level. This aim stems from the fact that e-accessibility challenges clearly go beyond 
providing access to websites. Despite various sc hemes by stakeholders  (including industry 
operators, authorities and user organisations) the overall level of  e-accessibility in Europe 
remains relatively poor (e.g. for digital television, or self -service terminals
4). 
Although European legislation contains a numbe r of provisions on e-acc essibility, it does not 
deal with the issue in a comprehensive way. Th us the secondary aim of the consultation was 
to explore the potential for extending curren t EU-level measures to promote overall e-
accessibility (while taking into account that further EU action on e-accessibility may be 
constrained by existing obligations, such as legal obligations on copyright).  
The results of the publ ic consultation are set out below. It starts with a brief description of the 
respondents’ profile and goes on to set out the responses received on a common European 
approach to web accessibility. The feedback received in relation to  other aspects of e-
accessibility and action at EU level is then presented and further inputs are described. Lastly, a conclusive summary statement is provided. 
3. P ROFILE OF RESPONDENTS  
Overall, 161 responses we re received. As summarised below,  the survey cove red a wide range 
of stakeholder groups. Research experts in th e field of ICT and disa bilities comprised the 
largest group of respondents at 30%, followed by industry associations and business. Together 
the latter groups cover 16% of the respondents. Almost all of these are active in the ICT 
domain ( Table 1 ). Only one response was received from a business not providing any ICT 
product and or service. Public au thorities are represented to a si milar extent (1 4%). With 12% 
each, individual citizens with and without disabi lities and user organisa tions are represented 
equally.  
                                                 
4 As seen in the MeAC report ( op.cit .) . 
 
EN 6   EN  
Expert or academic on disability and/or 
ICT; 48; 30%  
Industry/Enterprise; 
25; 16%
Other; 6; 4%Person with 
disability; 19; 12%  Person without 
disability ; 20; 12%  Public authority; 23;  14%  
 User organization ; 
20; 12%  
 
Table 1: Profile of respondents (n=161) 
• Private individuals 24,2%  
 among which...  Persons with disability  48,7% 
   Persons without disability   51,3% 
     
 Institutional respondents (Academics, organisations, public 
authorities, Industry/Enterprises)  72%  
   
 Academics 29,8%  
 among which...  An expert/ academic on disability and/ or 
ICT    81,3% 
   An academic institution or research centre    18,8% 
 Organisations of ICT users 12,4%  
 among which...  An organisation of users with disability   85% 
   An organisation of ICT users in general   15% 
 Industry/Enterprises 15,5%  
 among which...  An enterprise (providing ICT 
products/services)   80% 
   An enterprise (non ICT)   4% 
   An industry association (of  ICT providers)   16% 
   An industry association (non ICT)   --- 
 Public authorities 14,3%  
   
 Others 3,7%  
  
In terms of geographic coverage, respondents we re located in 18 European Members States, 
Israel and the United States. In addition, responses were received from European 
organisations (Table 2) 
 
EN 7   EN Table 2: Location of respondents (n=92) 
European level Eight contributions 
More than 10 contributions United Kingdom, Italy 
More than 5 contributions France, Germany, Spain, Ireland 
More than 2 contributions Slovenia, Belgium, Greece, United States, 
Austria, Portugal 
One contribution Sweden, Slovakia, Israel, Malta, Cyprus, 
Netherlands, Denmark, Lithuania 
  
Note: This table covers the responses that could be assigned to a geographic location (which was not 
compulsory).  
4. O PINION ON A COMMON EUROPEAN APPROACH TO WEB ACCESSIBILITY  
Responses received in relation to a common Eu ropean approach to web accessibility are set 
out below, according to the sub-themes specifi ed in the public consultation. These include:  
• Experience of web accessibility 
• A European approach 
• Websites concerned 
• Implementing web accessibility 
• Website authoring tools 
• Accompanying measures 
• Cooperation with stakeholders 
4.1. Experience of web accessibility 
The public consultation included a question on problems encountered in web accessibility 
from the perspective of a person with disability  and the extent to whic h such problems act as 
a barrier to using websites for one’s own purpos es. The majority of respondents stated that 
websites were either to tally (10.4%) or partially (47.9%) inaccessible.  
Regarding the impact of no accessibility, 72.6% st ated that it would result in exclusion from 
important information, facilities or services, either severely (29.7%) or moderately (42.9%). 
About 7% stated they would find other ways to access relevant information, facilities and 
services.  
 
EN 8   EN Table 3: Web accessibility experienced from th e perspective of a person with disability 
What kind of accessibility problems do you encounter when using a website?  (n=96) 
• Total inaccessibility 10,4% 
• Partial inaccessibility: I can only use some parts of the websites 47,9% 
• I do not generally have any problems accessing the websites I use 28,1% 
• Other 13,5% 
  
Do problems with website accessibility exclude or prevent you from accessing 
information, facilities and services that are important to you? (n=91) 
• Yes, severely 29,7% 
• Yes, moderately 42,9% 
• No, I find other ways to access the information, facilities or services  6,6% 
• No, the websites I visit are accessible 19,8% 
• No, I don't use the internet 1,1% 
 
Note: The percentages apply to all respondents who did not answer “not concerned” 
From the perspective of a website owner , questions were asked abou t the level of awareness 
of the issue of accessibility and its implications for users, as well as concrete steps taken to 
improve accessibility of their websites. 82% of respondents stated they were fully aware of 
these issues and14.8% reported at least partial awareness. As fo r steps taken to improve the 
accessibility of their websites, 90.5% of respondents stated that they had taken concrete steps. 
The comments submitted suggest that the we b content accessibility guidelines (WCAG 1.0) 
developed by the W3C consortium are widely used as a key reference point for this purpose. 
Table 4: Web accessibility from th e perspective of a website owner 
Are you aware of the issue of accessibility and of the implications for persons 
with disabilities using your website? (n=126) 
• Yes, I am fully aware 82% 
• Yes, I am partially aware 14,8% 
• No, I am not aware 3,1% 
  
Have you taken steps to improve the accessibility of your website? (n=126) 
• Yes 90,5% 
• No 9,5% 
 
Note: The percentages apply to all respondents who did not answer “not concerned”  
 
From a technology provider’s perspective , the consultation included a question on the current 
provision of technologies or services that are acc essible to people with disabilities. 86.4% of 
respondents stated that they provided accessibl e solutions, either as a standard offering 
(69.1%) or on request (17.3%). When it comes to  barriers experienced when dealing with 
accessibility issues from the perspective of a technology provider, l ack of demand (23.7%) 
and lack of a harmonised European approach to web accessibility (21.7%) were equally cited.  
In addition, 29.6% reported practical difficult ies in implementing tec hnical specifications 
concerning web accessibility as  a barrier, while 10.3% menti oned the lack of suitable 
technical specifications. Implementation co sts were cited as a barrier by 9.3%. 
 
EN 9   EN Table 5: Web accessibility from the pers pective of a web technology provider 
Do you provide accessible technologies/do you include accessibility in your 
services? (n=81) 
• Yes, we always propose it to our clients 69,1% 
• Yes, when the clients request it 17,3% 
• No 13,6% 
  
What is the main barrier for you wh en dealing with web accessibility? (n=97) 
• The lack of demand 23,7% 
• The lack of harmonised approach at European level 21,7% 
• The difficulty in implementing the technical specifications 19,6% 
• The lack of technical specifications 10,3% 
• The extra costs  9,3% 
• Other 15,5% 
 
Note: The percentages apply to all respondents who did not answer “not concerned”  
4.2. A common European Approach 
As specified in the public consultation, the ai m of a common approach to web accessibility by 
EU Member States is to impr ove access to websites for people with disabilities. The Riga 
Ministerial Declaration target was for 100% of public websites to be accessible for persons 
with disabilities by 2010. However, according to the study “Measuring e-accessibility in 
Europe”, in 2007 only 5% of public websites and 3% of private websites were accessible.  
As it was also stated in the consultation, a common European a pproach to web accessibility 
would also aim to stimulate the internal market by:  
• Enabling more users to access websites and services across Europe; 
• Offering sellers access to a larger market across the EU and  
• Giving providers of web-based ICT solutions  access to a more coherent internal 
market that is not fragmented due to different web accessibility requirements. 
If Member States adopt a common approach to  improving the accessibility of websites across 
the European Union, this could: 
• Help all citizens, in particular persons with  disabilities, use the Internet to improve 
their participation in so ciety and the economy and  
• Improve the competitiveness of European businesses in accessible information 
and communication technologies by rem oving barriers to the provision of 
enabling technologies and services for web accessibility, thereby also stimulating 
the market in services provided over the in ternet as well as offering better access 
for potential online customers across the EU. 
Following these comments, the consultation as ked questions on the perceived need for a 
common European approach to web accessibility.  
 
EN 10   EN A clear majority of the respondents agreed that  a common European approach was needed to 
facilitate a high level of availability of accessi ble websites (Table 6). Merely 3.1% held that 
this was not the case. This opinion was widely shared across the different respondent groups 
(Table 7). 
Table 6: A European Approach 
Do you agree that a common European approach is needed to facilitate a high 
level of availability of accessible websites? (n=161) 
• No 3,1% 
• Yes 96,9% 
  
Do you agree that a common European approach should be motivated by 
improving the situation of people with disabilities, and at the same time by 
improving the competitiveness of European companies? (n=161) 
• No 4,4% 
• Yes 95,6% 
 
Also, a clear majority (95.6%) stated that a co mmon European approach in the field of web 
accessibility should be motivated by the aim to  improve the situation of people with 
disabilities and — at the same time — to improve the competitiveness of European 
companies. Again, this opinion was widely shared among the different respondent groups 
(table 8).  
Table 7: Agreement that a common European approach is  needed to facilitate a high level of availability 
of accessible websites accord ing to respondents groups 
Do you agree that a common European approach is needed to facilitate a high level of 
availability of accessible websites? 
 
Person with 
disability 
Person 
without 
disability  
Academic 
User 
organisation 
Public 
authority  
Industry/ 
Enterprise 
Other 
Total 
No 0% 0% 4,2% 0% 0% 12% 0% 3,1% 
Yes 100% 100% 95,8% 100% 100% 88% 100% 96,9% 
Total (n) 19 20 48 20 23 25 6 161 
  
 
EN 11   EN Table 8: Agreement that a common European approach should be motivated by improving the situation 
of people with disabilities, and at the same time by  improving the competitiven ess of European companies 
according to respondents groups 
Do you agree that a common European approach should be motivated by improving the 
situation of people with disabilities, and at the same time by improving the competitiveness of 
European companies? 
 
Person with 
disability 
Person 
without 
disability  
Academic 
User 
organisation 
Public 
authority  
Industry/ 
Enterprise 
Other 
Total 
No 0% 10% 2,1% 0% 8,7% 8% 0% 4,4% 
Yes 100% 90% 97,9% 100% 91,3% 92% 100% 95,7% 
Total (n) 19 20 48 20 23 25 6 161 
  
4.3. Websites concerned 
As stated in the consultation, although the Ri ga Ministerial Declara tion focused on public 
websites only, many other websites are essential for the daily life of European citizens. 
Websites providing services of gene ral interest such as educati on, health and so cial services 
and telecommunication services can be provide d by both the public and the private sectors.5  
If Member States take action to improve acces sibility, it could cover public websites, namely 
websites of public authorities at national, region al and/or local level that provide information 
or services to citizens, as well as website s intended for the general public and providing 
online information and interactive services relating to services of general interest to citizens, 
whether or not provided by public authorities. 
Respondents were then asked for their opinion  on the range of webs ites that should be 
covered by policy intervention. Overall, most re spondents held that if Member States take 
action in this regard, it shoul d cover not only public websites , but also other websites 
providing services of ge neral interest to citizens (Chart  2). In total, seven out of ten 
respondents strongly agreed with this statement, whilst 23% ag reed and only 7% disagreed. 
                                                 
5 See Commission Communication on Services of general interest (COM (2007) 725). 
 
EN 12   EN Chart 2: Do you agree that if Member States take action, this should cover not only public 
websites, but also other websites providing serv ices of general interest to citizens? (n=161) 
 
I Agree; 37; 23%
I Disagree; 8; 5%
I strongly agree; 113; 
70% I strongly disagree; 3; 
2%
 
Table 9: Type of web sites to be addressed by a common European approach according to stake holder 
groups 
Do you agree that if Member States take action, this should cover not only public websites, but 
also other websites providing services of general interest to citizens? 
 
Person with 
disability 
Person 
without 
disability  
Academic 
User 
organisation 
Public 
authority  
Industry/ 
Enterprise 
Other 
Total 
I Strongly agree 89,5% 75% 79,2% 95% 34,8% 40% 100% 70,2% 
I Agree 5,3% 25% 20,9% 5% 47,8% 36% 0% 23% 
I Disagree 5,3% 0% 0% 0% 13% 16% 0% 5% 
I Strongly disagree 0% 0% 0% 0% 4,4% 8% 0% 1,9% 
Total (n) 19 20 48 20 23 25 6 161 
 
As regards individual stakeholde r groups, the responses received from public authorities and 
business were clearly more nega tive about covering other website s as well (Table 9). 24% of 
businesses disagreed or even strongly disagr eed. 17.4% of public au thorities disagreed.  
Position papers revealed that many respondents felt that people with disabilities should in 
principle be able to access the same range of websites as the av erage user and derive the same 
benefits from the Internet. On the other hand, it was stressed by some respondents that business should not be forced by legislation to make their webs ites accessible but rather be 
incentivised and stimulated to do so on a vol untary basis, e.g. following good practice in the 
public sector. 
 
EN 13   EN 4.4. Implementing web accessibility 
As stated in the consultation, a common approach  to web accessibility w ould mean that action 
is taken by all Member States to prepare for the introduction and impl ementation of modern 
specifications on web accessibility.  
In order to contribute to making the webs ites of public authorities accessible by 2010, 
Member States are expected to take into accoun t in their schemes the work to achieve widely 
recognised international and European specificati ons. In particular they should seek alignment 
with the results of international standards on Web Content Accessibility and follow the 
outcomes of the work on Mandate 376 granted to  the European Standard isation Organisations, 
thereby supporting accessibility of website s deploying modern web technologies and 
applications. 
Specific schemes for the Memb er States could comprise: 
• making available, updating and publishing techni cal guidance relating to web accessibility 
requirements, translating where a ppropriate relevant documentation; 
• identifying websites concerned, se tting targets and milestones; 
• allocating responsibilities fo r implementing the schemes; 
• providing references for trai ning, schemes for knowledge sharing and awareness measures; 
• assessing and monitoring progre ss and publishing progress reports; 
• pooling experience in the implementation of technical guidance for web accessibility;  
• promoting the accessibility of intranet websit es in line with the Employment Equality 
Directive. 
Similarly, Member States could promote the acce ssibility of websites th at are not provided by 
public authorities that provide services  of general interest to citizens. 
Member States could encourage website owners to include an accessibili ty statement in their 
websites which provides supporting information su ch as an outline of the accessibility policy 
of the institution concerned; de gree of compliance with relevant  legislation and/or reference 
specifications and support for pe rsons with disabilities.  
The feedback received on these comments rev eals that most respondents agreed that the 
above-mentioned action would contribute to a hi gh level of availability of accessible web 
sites. While 83.4% generally agreed with this statement (38.5% strongl y agreed), only 4.9% 
disagreed. However about one in ten respondent s (11.8%) had no opinion on this (Chart 3). 
 
EN 14   EN Chart 3: Agreement to Statements regarding implementation of web accessibility (n=161) 
0% 20% 40% 60% 80% 100%The above-mentioned actions will contribute to a high
level of availability of accessible websitesWebsites should be encouraged to include an
accessibility statementMember States should seek alignment with the results of
international standards on Web Content Accessibility
and should comply with the outcomes of Mandate 376Intranet websites should be encouraged to be
accessibleOther websites (providing services of general interest)
should be encouraged to be accessible
I strongly agree I agree I disagree I strongly disagree I don't know
Question: Do you agree with the following statements? 
A clear majority of the respondents also perceive d the need to encourag e the accessibility of 
intranet websites. Here overall agreement reached 94.9%, 67% strongly agreed, only 1.8% disagreed and 3.1% had no opinion.  
All in all, 94.3% of the responde nts agreed with the st atement that Member States should seek 
alignment with international standards. Here, more than half (59.6%) agreed strongly while 
only 1.2% disagreed. All in all, 4.3% did not have an opinion.  
The response was similar on the pe rceived need to encourage we bsites to post an accessibility 
statement. Here, overall agreement reac hed 88.2%, 55.9% strongl y agreed and 7.1% 
disagreed.  
Comments from position papers received in th is context were manifold. To sum up, the 
following common threads can be identified: 
• Some comments concerned the issue of appr opriateness of legal intervention when it 
comes to different types of website owners. It is for instance stressed that compliance with 
compulsory accessibility requirements may cause an undue burden for some website owners, such as small organisations. Also, it is  stressed that retrof itting accessibility into 
existing websites may become very costly in certain cases. Various op tions are proposed to 
cater for such situations, e.g. helping particular parties, such as small companies, to comply 
with accessibility requirements by means of tax incentives or requ iring only new content 
and features to be accessible rather than old content. Also concerns were raised that e-
 
EN 15   EN accessibility may be problematic for some services and hinder the interaction of other 
users. 
• Another set of comments addres sed the type of intervention n eeded to achieve the desired 
outcomes. The argument was put forward th at binding legisla tion and appropriate 
enforcement mechanisms (e.g. clearly specified  deadlines, fines for non-compliance, black 
lists and refusal of public funding) would yi eld real results. Also , the value of an 
accessibility statement posted on a website was questioned in some comments, at least whilst the website owner had no cause to the consequences of non-compliance the statement. 
• Another set of statements concerned the genera l thrust of provisions that intervention could 
include. Here it was stressed that any downloa dable documents such as PDF-files should 
also be accessible. Moreover it was argued  that web accessibility required a holistic 
approach balancing standards compliance with  understanding of user  needs, e.g. through 
disabled user testing — or at least assist ive technology testing — adding code compliance 
to the web accessibility guidelines. Some  respondents expressed concern over the 
complexity of current web accessibility guidelines (and forthcoming WCAG 2.0) and that more practical guidance was needed, while othe rs argued that there was need to create a 
market for accessible tools and support services  and ensure a level playing field for all 
stakeholders. Other respondents highlighted th e need for capacity bu ilding among different 
stakeholder groups (e.g. website developers , website owners, tool developers and 
government agencies). 
• Lastly some comments concerned the sustaina bility of intervention. This concerns, for 
instance, a perceived need to consider accessi bility requirements, as  a general principle, 
when developing new technol ogies and applications. 
4.5. Website authoring tools 
As specified in the consultation, to best  safeguard and efficiently implement web 
accessibility, website authoring tools can be used to automatically provide (most) accessibility. Authoring software tools are any software, or collection of software components, explicitly used to create, design or update websites. If Member States target web 
accessibility, they could also tackle website au thoring tools in order to address the whole 
process of website development and operation.  
Member States could encourage public administ rations to use and proc ure website authoring 
tools that are designed to speci fically assist with the producti on and maintenance of accessible 
websites, in accordance with the public procurement Directives.  
Table 10: Authoring tools 
Agreement that authoring tools should also be addressed by the common 
approach of the Member States  (n=161) 
• No 11,8% 
• Yes 87% 
• No reply 1,3% 
 
In response to this statement, a clear majority of respondents  (87%) held that if Member 
 
EN 16   EN States target web accessibility, they should also  tackle website authoring tools in order to 
address the whole process of a website development and operati on (Table 10). However, one 
in four (25%) respondents representing industr y associations or busin ess thought that this 
should not be the case (Table 11). A simila r number of public aut horities,17.4%, disagreed. 
Table 11: Agreement that authoring tools should also  be addressed by the common approach of the 
Member States 
Should authoring tools also be addressed by the common approach of the Member States? 
 
Person with 
disability 
Person 
without 
disability  
Academic 
User 
organisation 
Public 
authority  
Industry/ 
Enterprise 
Other 
Total 
No 10,5% 0% 14,6% 0% 17,4% 25% 0%  
Yes 84,2% 100% 85,4% 100% 82,6% 75% 100%  
No reply 5,3% 0% 0% 0% 0% 0% 0% 0,6% 
Total (n) 19 20 48 20 23 24 6 160 
  
4.6. Accompanying measures 
As described in the consultation, accompanying  measures could aim at stepping up action by 
the Member States and extending their impact  by sharing knowledge and awareness of web 
accessibility at various levels. Training and aw areness are essential to ensure that web 
accessibility is taken into account at the earliest design stage. Training schemes can be put in 
place at different levels (web managers, we b masters, web content developers…) and 
deployed at national , regional and local levels. Likewise  exchanges of good practices at 
European level would greatly fa cilitate a common approach.  
A single contact point in each Member State may also be useful to provide information and 
guidance to users, and to allow information on accessibility to be coherently collected. As accessibility of information and communication t echnologies is also relevant beyond the web, 
it may be useful to concentrate e-accessibili ty information and guidance in one location.  
Thus accompanying measures of Member States could include: 
• Supporting training schemes for those involved in web accessi bility, whenever possible 
directly involving pers ons with disabilities. 
• Providing information and guidance to person s with disabilities on accessibility of 
websites and, where relevant, assistive tec hnologies (assistive tec hnology means any ICT 
equipment, product, system, hardware software or  service that is used to increase, maintain 
or improve functional capabilities  of people with disabilities, in close interoperation with a 
user agent). 
• Supporting exchange and pub lication of best practices for stakeholders. 
• Collecting input from users, including through surveys of their experience of accessibility. 
 
EN 17   EN • Assigning a national Contact Point for web a ccessibility that can take up the above-
described functions. This Contact Point could al so be used for other relevant accessibility 
issues concerning the information society. 
Overall, a clear majority of  the respondents would welcom e the implementation of the 
measures set out in the introductory statement to  the online consultation (Chart 4). In relation 
to capacity building on the supply side, 95.6% agr eed with the provision of training for those 
involved, 67.7% agreed strongl y and only 3.1% disagreed.  
A similar picture emerges in relation to exch anging best practice. Here 95.6% agreed, 65.2% 
agreed strongly and only 1.2%  expressed disagreement.  
On the user side, 94.3% agreed wi th the provision of informati on and guidance to people with 
disabilities, 60.8% agreed st rongly and 4.3% disagreed.  
Measures to pool user experiences, e.g. through surveys, received strong support. Here 94.9% 
agreed, 63.9% agreed and only 1.8% disagreed. 
Chart 4: Agreement to Statements regar ding accompanying measures (n=161) 
0% 20% 40% 60% 80% 100%Providing information and guidance to persons with disabilities
on accessibility of websites and, where relevant, about
assistive technologiesCollecting input from users, including through surveys, about
their experience of accessibilitySupporting exchange and publication of best practices for the
various stakeholdersSupporting training schemes for relevant actors involved in
web accessibility, whenever possible with a direct involvement
of persons with disabilities
I strongly agree I agree I disagree I strongly disagree I don't know
Question Do you agree with the following accompanying measures of Member States? 
When compared with these measures, there is slightly less overall s upport for establishing 
national web accessibility contact points, at 83.2% (T able 12). It is striking that the share of 
respondents not supporting this op tion is comparatively high among business (40%), though 
still a minority. 
 
EN 18   EN Table 12: Support for the creation of a national contact point 
Do you support the creation of a national web accessibility contact point? 
 
Person with 
disability 
Person 
without 
disability  
Academic 
User 
organisation 
Public 
authority  
Industry/ 
Enterprise 
Other 
Total 
No 10,5% 20% 8,3% 5% 26,1% 40% 0% 16,8% 
Yes 89,5% 80% 91,7% 95% 73,9% 60% 100% 83,2% 
Total (n) 19 20 48 20 23 25 6 161 
 
Concerns were expressed regard ing various aspects such as: 
• the risk of shifting responsibilities fro m website owners to a centralised body; 
• the danger of overlapping responsibilities, part icularly in countries where information and 
guidance is already provided by NGOs, government agencies and the like; 
• the risk of increasing bur eaucratic overheads, lo bbying and profiteering; 
• assignment of higher value to facilitate and support an ongoing dialogue  between all levels 
of government, industry, NGOs and consumers. 
Apart from this, a large number  of comments were received regarding further issues that 
could be addressed by accompanying measures . The common threads are set out below: 
• A number of comments concerned the issue of awareness rising and capacity building. 
Different bodies would need to be addr essed (e.g. content producers, publishers, 
technicians, web developers, us ers) and a European award sche me could help raise current 
levels of awareness. There is also a need for employers to be able to measure and recognise 
web-accessibility related skills.  
• Other comments concerned user involvement,  confidence and empowerment. For instance, 
a proposal was put forward to launch a system  similar to the European Consumer Centres 
Network (ECC-Net) which — as a network of consumer advice centres — helps consumers specifically with cross-border di sputes. Other proposals concern launching joint 
projects and involving users in functionality  testing and certifica tion on a voluntary basis 
(because of the costs involved). 
• A further set of statements concerned mentoring of achievements and the need for 
continuous monitoring.  
4.7. Cooperation 
As mentioned in the consultation, cooperation be tween Member States and other stakeholders 
could include: 
 
EN 19   EN • Supporting European cooperation with industry and users to follow and obtaining advice 
on the changes to accessibility requirements and implementing web accessibility in the 
Member States. 
• Contributing to the collation and establishm ent of best practices  in web accessibility 
measurement, monitoring, training, assessmen t and certification at  European level, 
involving both users and industry. 
Overall, the responses received indicate a high level of support when it comes to the need for 
stakeholder cooperation. While 90% agreed, only 2% of respondents disagreed and 8% had no 
opinion. 
5. O PINION ON OTHER ASPECTS OF E -ACCESSIBILITY AND ACTION AT 
EUROPEAN LEVEL  
As described in the public consultation, e-accessibility challenges go beyond web accessibility. Disabled persons have reported  difficulties in accessing and using television, 
mobile or fixed phones, public announcement syst ems, self-service terminals such as cash-
dispensing and ticketing machines, hea lth monitoring devices and more.  
European legislation contains some provisions on e-accessibility, but it does not deal with the 
issue in a comprehensive way. Europe also su pports research and innovation, promotes best 
practices and stakeholder cooperation. E-accessi bility is also dealt with by some ICT 
providers who have taken action to include accessibility featur es early in the ICT design 
process through inclusive uni versal design or ‘design for all’ approaches.  
The MeAC study reported that the overall level of  e-accessibility in Europe remains relatively 
poor and progress is rather limited, as analys ed in the recent European Communication on e-
Inclusion. Given these observations, and ta king into account the recent United Nations 
Convention on the rights of persons with disa bilities and the proposals of the European 
Commission for a Renewed Social Agenda, this part of the consultation explores the need for 
further EU action on e-accessibility in general (beyond web accessibility as covered in the 
first part of this consultation). 
As the consultation also menti oned, the purpose of this part of  the consultation was not to 
review existing European action, but  rather to explore the potential for furt her action to better 
promote overall e-accessibility (whilst acknowle dging that it may be constrained by existing 
obligations, such as legal obligations on copyright). 
The responses received in relation to a European  approach to other aspe cts of e-accessibility 
are set out below by sub-theme, including:  
• Experiences of e-accessibility, 
• Priority areas for EU action, 
• Preferred approach, 
• Legislative action, 
 
EN 20   EN • Expected impacts.  
5.1. Experience of e-accessibility 
Respondents were asked for their opinion on a number of statements outlining perceived 
barriers to e-accessibility from the perspective of a person with disability . As shown in Chart 
5 below, more than three out of five responde nts agreed that lack of awareness among ICT 
providers (62.6%) acts as a barrier, whilst 5.5% did not agree and 31.6% had no opinion.  
Regarding the lack of information on the ava ilability of accessible ICT among users, 61.5% 
agreed that it acts as a ba rrier to e-accessibility, whilst 8% disagreed and 30.5% had no 
opinion.  
A similar picture emerges in relation to inform ation on how to use accessibility features that 
are, in principle, available. Here, a lack of instructions was perceive d by 58.9% as a barrier, 
whilst 10.6% disagreed and 30.4% had no opinion.  
A more diverse picture emerges concerning th e question of extra co sts of accessible ICTs 
being a concern for the user. Overall, 54.6% of respondents agreed with this statement, whilst 
12.5% disagreed and 32.9% had no clear opinion. 
In total 55.5% of respondents agreed with the statement that a lack of interoperability of 
mainstream ICTs and assistiv e technology would constitute a barrier and 7.3% disagreed. 
The statement that ICT does not have features to deal with accessibility challenges received 
the lowest level of agreement (41.6%). Here  24.8% explicitly disagreed and 33.6% had no 
opinion. 
A closer look at the distribution of responses  across different groups of respondents reveals 
that user organisations in particular are comp aratively critical of e- accessibility features 
provided by current ICTs (Table 13 ). 75% of user organisations ag reed with the statement that 
ICT does not have features to deal wi th disability challenges (Table 13). 
 
EN 21   EN Chart 5: Perceived main barriers to  e-Accessibility from the perspect ive of a person with disability 
(n=161) 
0% 20% 40% 60% 80% 100%  The ICT does not have
features to deal with
accessibility challengesavailability of accessible ICTsLack of instructions about how
to use accessibility featuresLack of interoperability with
assistive technologiesExtra cost of accessible ICT is
a concern for the use rLittle awareness of ICT
providers on accessibility
I strongly agree I agree I disagree I strongly disagree I don't know  Lack of information about the
 
Question: What are the main barriers to e-accessibility? 
Table 13: The ICT does not have features  to deal with accessibility challenges? 
The ICT does not have features to deal with accessibility challenges? 
 
Person with 
disability 
Person 
without 
disability  
Academic 
User 
organisation 
Public 
authority  
Industry/ 
Enterprise 
Other 
Total 
Strongly agree 26.3% 35.0% 14.6% 65.0% 4.3% 0.0% 16.7% 21.1%
Agree 10.5% 10.0% 33.3% 20.0% 21.7% 16.0% 0.0% 20.5%
Disagree 31.6% 5.0% 22.9% 5.0% 21.7% 16.0% 16.7% 18.0%
Strongly disagree 10.5% 10.0% 4.2% 0.0% 8.7% 12.0% 0.0% 6.8%
Don’t’ know 21.1% 40.0% 25.0% 10.0% 43.5% 56.0% 66.7% 33.5%
Total (n) 19 20 48 20 23 25 6 161
 
Over and above these aspects, further issues th at may warrant attention were indicated in the 
comments made. Some common threads are given below:  
• Some comments concerned unequal considerati on of different types of disability and a 
perceived lack of sufficiently deep knowle dge of the user situation and related 
requirements. 
 
EN 22   EN • Other statements concerned specific ICTs th at are perceived as being particularly 
inaccessible, such as mobile/handheld devi ces and devices with visual interfaces. 
• A number of statements concerned an additi onal cost burden for disabled users, e.g. 
assistive technology. Apart from affordability, the lack of information on the availability of 
upgrades and lacking skills to use th ese is also perceived as a barrier. 
From the perspective of an ICT provider , questions were asked on the current provision of 
accessible products and services, and on the main  barriers when addressing e-accessibility 
issues. As summarised below (Table 14), a clear majority of respondents stated that accessible 
products and services were on offer, either as  a standard feature ( 65.3%) or on request by the 
client (17.4%). 
When asked about the factors acting as a barri er to addressing e-accessibility from the 
perspective of an ICT provider,  by comparison responses were quite evenly distributed across 
the various options give n to respondents. These were extr a costs (20.8%), lack of demand 
(19.7%), difficulty to implement technical sp ecifications (18.0%), lack of a harmonised 
European approach (16.4%) and lack of  technical specifications (13.7%).  
Table 14: eAccessibility from the perspective of an ICT provider 
Do you provide accessible technologies/do you include accessibility in your 
services? (n=98) 
• Yes, we always propose it to our clients 65,3% 
• Yes, when the clients request it 17,4% 
• No, because there are few requests from the clients   7,1% 
• No, we don't have accessible solutions 10,2% 
  
What are the main barriers for you when dealing with e-accessibility? 
(multiple answers possible) (n=96) 
• The lack of technical specifications 26,0% 
• The difficulty to implement technical specifications 34,4% 
• The lack of harmonised approach at European level 31,3% 
• The lack of demand 37,5% 
• The extra cost 39,6% 
• Other barrier 21,9% 
 
Note: The percentages relate to all respondents that have not answered “not concerned” 
The comments submitted by some respondents menti oned a number of other aspects that may 
merit attention when it comes to identifying ba rriers to addressing e-accessibility from a 
supply-side perspective. Some common threads are given below: 
• Lack of clarity about the bus iness case for accessibility; 
• Lack of open standards; 
• Lack of intra-organisati onal knowledge and capacities concerning e-accessibility; 
• Lack of design tools that are easy to use; 
• Difficulties in evaluating conformity  with accessibility requirements. 
 
EN 23   EN From the perspective of an organisation applying ICT  for the purposes of its own 
operations, the online consultation included qu estions about the level of awareness and 
perception of main barriers to address e-accessibility issues. The level of awareness of 
respondents was comparatively high as summarise d in Table 15. Only 4.8% stated that they 
were not aware of e-accessibility issues and imp lications for people with disabilities using 
goods and services.  
When asked about the factors acting as a barrier to addressing e-accessibility, responses were 
again quite evenly distributed ac ross the various options. Slightly  more than one out of three 
(36%) respondents considered that the costs of accessible ICT were a barrier. Lack of 
interoperability of accessible ICTs with other technologies was cited as a barrier by 29% 
whilst 25.4% considered lack of availabil ity of accessible ICT as a major barrier. 
In addition to these barriers, the corresponding co mments revealed that the lack of awareness 
and knowledge among the various parties involve d in organisations was a major barrier to 
extending the deployment of accessible ICT within organisations. 
Table 15: E-accessibility as a co mpany/organisation using ICT 
Are you aware of the issue of e-accessibil ity and of the implications for persons 
with disabilities using your goods/services? (n=124) 
• Yes, I am fully aware 74,2% 
• Yes, I am partially aware 21% 
• No, I am not aware 4,8% 
  
What is the main barrier/difficulty to use accessible ICTs in your products and 
services? (n=114) 
• Lack of availability of accessible ICT 25,4% 
• Cost of accessible ICT 36% 
• Lack of interoperability of accessible ICT with other technologies 29% 
• Other 9,7% 
 
Note: The percentages apply to all respondents who did not answer “not concerned” 
5.2. Priority areas for EU action 
As mentioned in the consultation, many IC T-enabled products and services may pose 
accessibility challenges to persons with disabil ities. As regards prioritising ICT sectors for 
further policy intervention at Euro pean level, 85.7% stated that high priority should be given 
to the Internet in general and the Worl d Wide Web in particular (Chart 6). 
Mobile communications should be given high prio rity according to 65.2 % of respondents and 
personal computers were cited by 59% as a high priority ICT domain. 48.4%  stated that self-
service terminals should receiv e high priority attention and 47.2% stated that domestic 
equipment was a high priority domain. ICT in ge neral should be high priority according to 
45.9%. According to 39.7%, digital TV should be  high priority for EU  policy intervention. 
It is striking that less than one out of ten re spondents stated that no attention at all should be 
given to any of these ICT domains. Although the internet would appear to be a priority for 
most respondents, the comments  received indicate a widely pe rceived need for EU action to 
cover various ICT domains. Common thread s to the comments are given below:  
 
EN 24   EN • Many responses highlighted that a range of ICT based products and services would play an 
important role in daily life for an increasing share of the population. 
• Some comments concerned the trend in techno logical convergence and the risk that any 
legislation based on today’s technolo gy divides may soon become obsolete. 
• Some comments highlighted accessibility ch allenges perceived in specific ICT domains 
such as mobile communications and e-books. 
• On the other hand, it was stressed that cons iderable action was being taken on market-
driven standards concerning ICTs, meaning that further action might become redundant. 
Chart 6: Opinion for which technologies/equipmen t possible further action  at European level 
should be a priority (n=161)  
 
0% 20% 40% 60% 80% 100%Fixed communicationsDigital TVICT in generalDomestic equipmentSelf-service terminalsPersonal computersMobile communicationsInternet / web
High priority Relevant priority Low priority No priority I don't know
Question: For which technologies/equipment should possible further action at European level be a 
priority and why?  
In addition to the ICT sectors discussed above , a specific question was asked on prioritising 
particular ICT-based services in the framew ork of EU policy (Chart 7). Here again a 
comparatively small proportion of respondents stated  that no priority at all should be given to 
any of the service domains mentioned. 
Consumer banking was considered to be an ar ea for high priority attention according to 
66.4%, and 53.4% said so for consumer retail se rvices. Audiovisual se rvices and travel 
services were considered by 49.6% and 41.6%  respectively to me rit high priority.  
 
EN 25   EN Similarly to ICT product domains, many comments received concerned IC T-based services to 
be considered for further EU acti on, such as the following aspects:  
• service domains in addition to  those mentioned above, such as education and professional 
guidance services, social serv ices, e.g. linked to family a nd health matters and social 
networking services. 
• Some comments stressed the lack of accessibil ity of particular services as currently 
provided, e.g. in broadcasting and banking. 
Chart 7: Opinion for which services that is based on ICT possible further action at European level 
should be a priority (n=161) 
 
0% 20% 40% 60% 80% 100%Travel, tourism
servicesServices in general
(that use ICT)Audio-visual content
servicesConsumer retail
servicesConsumer banking,
financial services
High priority I don't know Low priority No priority Relevant priority
 
Question: For which services that are based on ICT should possible further action at European level 
be a priority and why? 
5.3. Preferred approach 
As explained in the consultation, action at European level to pr omote e-accessibility can take 
many forms. It is necessary to define the mo st effective and necessary action, such as binding 
legislation, non-binding legi slation (recommendations), st andardisation and reference 
technical specifications, enhanced benchmarki ng and good practice exch ange and increased 
support for R&D and innovation. 
 
EN 26   EN Binding legislation was considered a high pr iority approach by 55.3%, whilst non-binding 
legislation was highly prioritised by 24.2%. However, it is intere sting to note that 40% of the 
businesses that participated in this consultation regarded binding legislation as an approach to 
which no priority should be given at all. On the other hand, 90% of  user organisations 
regarded binding legislation as  a high priority approach. Re garding non-binding legislation, 
the responses received were even more varied . Overall, no more than 43% assigned high 
priority to this approach fr om any of the respondent groups. 
Table 16: Opinion whether priority should  be given to non binding legislation  
Should non binding legislation be a priority at EU level?  
 
Academic 
Industry/Ent
erprise 
Other 
Person with 
disability 
Person 
without 
disability  
Public 
authority  
User 
organisation 
Total 
High priority 26.3% 30.0% 18.8% 43.5% 10.0% 20.0% 33.3% 24.2%
Relevant priority 42.1% 30.0% 37.5% 43.5% 10.0% 32.0% 33.3% 33.5%
Low priority 15.8% 25.0% 29.2% 13.0% 75.0% 24.0% 33.3% 29.8%
No priority 10.5% 10.0% 8.3% 0.0% 5.0% 20.0% 0.0% 8.7%
Don’t’ know 5.3% 5.0% 6.3% 0.0% 0.0% 4.0% 0.0% 3.7%
Total (n) 48 25 6 19 20 23 20 161
  
Other than legislation, 67.7% of respondents stated that standard isation and technical 
specifications should be a high priority. Benchmarking and good practice specifications were 
given high priority by 48.4%, whilst 52.1% and 56.5%  stated that high priority should be 
given to increased support for res earch and deployment respectively. 
 
EN 27   EN Chart 8: Opinion on possible future EU action for e-accessibility (n=161) 
 
0% 20% 40% 60% 80% 100%Non-binding legislation
such as
recommendationsBenchmarking and
good practice
reportingIncreased research
supportBinding legislationIncreased innovation /
deployment supportStandardisation;
technical specifications
High priority Relevant priority Low priority No priority I don't know
 
Question: What should be the possible future EU action for e-accessibility? 
A wide range of comments were received on this issue. Some common threads are given 
below: 
• A number of comments concer ned the perceived need for a binding legislative approach 
(e.g. an EU Directive) that w ould need to be enforced to yield the desired impact (e.g. 
broader implementation of e-accessibility, leve l playing field for actors involved). On the 
other hand, some respondents expressed their c oncerns that the intr oduction of binding 
legislation would have rather ne gative effects, e.g. due to perceived difficulties to agree on 
e-accessibility or because some  organisations (or countries) may not have the capacity to 
actually comply with compulsory requirements. 
• Another common theme that emerged concer ns e-accessibility standards. Some 
respondents stressed the need for relying on common international/global standards where 
they exist. Some comments highlighted a perc eived need to involve disabled users in the 
development of standards, while others stre ssed that the focus should be on encouraging 
the use of existing standards and the developm ent of appropriate market-lead and voluntary 
standards were necessary. 
• Some comments concerned the perceived need for open source solutions and the role the 
EU can play in this re gard, e.g. by RTD funding. 
 
EN 28   EN • Also some comments addressed a perceived need  for a more holistic approach to the issue 
of non-access to ICTs for people with disabilities, e.g. by stre ssing that technology features 
are only one aspect of supporting a user-orien ted approach to accessibility. More generally, 
a perceived lack of a common unde rstanding of concepts and te rms that are used in the e-
accessibility debate was also cited. 
5.4. Legislative action 
As explained in the communication, a number of  countries have legislation in place to 
promote e-accessibility. Some legal provisions on e-accessibility also already exist at EU 
level. If further legislation is considered at EU level, without prejudice to the current acquis 
communautaire , several questions must be addressed, fi rst and foremost which e-accessibility 
requirements to comply with and the criteria fo r selecting the ICT tec hnologies and services 
concerned. 
The consultation then asked a question on the rele vance of different type s of e-accessibility 
requirements to further EU policy intervention. 
As shown in Chart 9, 67% regarded complian ce with e-accessibility standards as a very 
important requirement, which is comparatively high. Apart from this, in teroperability with 
assistive technology is a very important require ment according to 60.8%  and 55.2% agreed on 
interoperability with other ICTs to ensure en d-to-end accessibility. Over all, 55.9% stated that 
offering alternative ways of user interaction (e .g. audio output next to text) would be very 
relevant, and 49% stated that provision of in formation on e-accessibilit y features was very 
relevant. Offering at least one accessible model within a product range was regarded as very 
relevant by 47.8% of responde nts. At 34.1%, comparatively few respondents felt that the 
provision of alternativ e solutions to the standard produc t/services (e.g. operator assistance) 
was an important requirement. 
Only 6.2% of the respondents considered a ll of these requirements as irrelevant. 
 
EN 29   EN Chart 9: Most relevant types of e-accessibility requirements (n=161) 
 
0% 20% 40% 60% 80% 100%Offering an alternative solution to the
product/service (e.g. operator assistance)Offering at least one accessible model
within the product rangeProviding information on the e-accessibility
featuresInteroperability with other ICTs to ensure
end-to-end accessibilityOffering alternative ways of user
interaction (e.g. audio output next to text)Interoperability with assistive technologiesCompliance with e-accessibility standards,
where these exist
Very relevant Relevant Somewhat relevant Irrelevant I don't know
 
Question: Which types of e-accessibili ty requirements ar e most relevant?  
As regards the criteria that could be used to select specific products, the responses received 
were more varied (Chart 10).  68.3% considered it very relevant to cover technologies, 
products and services that are of particular importance to pa rticipate in society and the 
economy, which is comparatively high. Simila rly, 59.6% and 52.1% considered technologies, 
products and services that are e ssential for personal safety and se rvices to be of particular 
public interest. A very small minority, less than 1%, regarded these criteria as being entirely 
irrelevant. 
The fact that a particular te chnology or service has widely spread among the general public 
was regarded by 34.2% of the respondents as a ve ry relevant selectio n criterion. The same 
response was given by 24.8% for the relative amount of costs for e-accessibility features when 
compared with the over all cost/price of the product and services in question. 3.6% and 11.8% 
respectively considered these crite ria as entirely irrelevant.  
Regarding the expected lifetime of a product (e.g. when compared  to the time needed to add 
accessibility features) or service and nove lty (e.g. imposing requirements only on new 
products), overall 19.3% and 14.9% respectively cons idered these aspects to be very relevant 
selection criteria. Similarly, 14.9% and 14.9% of  respondents considered these criteria as 
entirely irrelevant. 
 
EN 30   EN Chart 10: Criteria relevant to guide the selection of products, technologies and services that need to 
comply with e-accessibility requirements (n=161) 
 
0% 20% 40% 60% 80% 100%
Product/service is important for participation in society and
economy
Product/service is essential for the personal safety of the
user
Service is of public interest
Product or service is widely spread amongst the population
in general
Development and deployment cost or sales prices of the
product or service are much higher than the cost of the e-
accessibility features
Novelty of product or service, e.g. imposing accessibility
requirements on new models only
Expected lifetime of the product or service is much longer
than the time needed to add the e-accessibility features
Very relevant Relevant Somewhat relevant Irrelevant I don't know
 
Question: Which criteria are relevant to guide the selection of products, technologies and services 
that need to comply with e-accessibility requirements? 
The comments received reveal some common thread s in relation to furthe r EU legal action to 
improve e-accessibility in general: 
• A number of comments focused on the need to address ICT domains that are currently not 
covered by existing EU legislation, e.g. by mean s of a general e-acce ssibility Directive. 
Also the need for horizontal approach was st ressed in relation to the ongoing blurring of 
existing domain boundaries, due in part to the convergence of current technologies and 
services.  
• Other comments referred to the perceived need to enforce and supervise the 
implementation of any new legislation, e.g. by setting up an independent agency 
specifically responsible. 
• Some comments concerned the risk of fragme ntation due to the perceived emergence of 
differing guidelines and requirements, with negative impacts on the mainstreaming of 
design for all and the economic viability of accessible solutions. 
 
EN 31   EN 5.5. Expected impact 
The final subsection of the consultation provide d free text space to respondents to explain in 
more detail the potential impact in terms of cost s and benefits of a more  general EU approach 
to e-accessibility. Although the comments received in this regard were quite diverse, some 
common threads can be identified as follows:  
• Some comments highlighted a range of potentia l benefits of a more general EU approach 
for people with disabilities and other users who are unable to participate equally in all 
aspects of social, econom ic and cultural life.  
• Other respondents highlighted the benefits for society as a whole from better access to ICT 
for people with disabilities, su ch as realising thei r creative and economic  potential and less 
effort required for other forms of support. However it should be noted that several respondents stressed that policies on e-accessi bility should not be driven solely by a 
cost/benefit consideration but as an issue of  equal rights, as reflected in existing EU 
policies such as the Lisbon Strategy.  
• Some comments concerned the benefits for th e ICT industry, e.g. competitive advantages 
through improved overall usability , extended outreach of serv ices, extended markets and 
skills pool and soft factors such as improve d image. On the other hand, some respondents 
expressed doubts as to whether commercial comp anies would be able to draw sufficient 
economic benefits from making their products accessible to people with  disabilities, so 
they need to be duly incentivised. 
• A number of comments conc erned additional costs in connection with general e-
accessibility legislation. Some respondents expr essed their concern that additional costs 
would be substantial, e.g. when it comes to meeting the needs of small user populations, 
legal costs, cost for certification and th e like. Other comments highlighted that any 
additional costs involved in implementing e-acce ssibility would need to be offset against 
benefits gained at individual and societal level (e.g. through increas ed participation in 
common cultural, social and economic proce sses). Some comments concerned possible 
incentives for those unable to bear additional costs, e.g. public subsidies, while others referred to potential savings stemming from international harmonisa tion of e-accessibility 
policy and standardisation. 
 
EN 32   EN 6. C LOSING REMARKS  
Overall, a common European approach to web accessibility received very strong 
support.  Almost unanimously, respondents agreed that this approach was needed to facilitate 
a high level of availability of accessible web site s, and it should be equally motivated by the 
desire to improve the situation of people with disabilities and improve the competitiveness of 
European companies. When it comes to particular  types of websites that should be covered by 
a common European approach, a clear majority ag reed that this approa ch should not merely 
concern public websites  but also other websites providing services of general interest to 
the citizen.  Also, there was strong support for making intranet  websites  accessible and web 
content authoring tools  should also be covered by a common European approach to web 
accessibility. In doing so, meeting international standa rds was deemed important by a clear 
majority. Finally, a clear ma jority would also welcome accompanying measures . 
In relation to other ICT domains, again a clear majority would welcome further EU-level 
action . Regarding how this should be addressed, the responses received were more varied. 
About half of the respondents co nsidered binding legislation as  a high priority approach, 
whereas non-binding legislati on was highly prioritised by a bout one quarter. Other than 
legislation, various other measures such as  standardisation, benc hmarking, exchanging good 
practice and research received comparably  high levels of support from respondents. 
Overall, the results of the public consultation indicate strong support for a more cross-
cutting EU-level approach to e-accessibility . From the large number of comments received 
it emerges, however, that respondents hold very  different views concerning expectations on 
this approach, in terms of the particular issues  to cover in relation to various ICT domains and 
specifically how these issu es would be addressed.