Opinion of the Economic and Social Committee on the "Communication from the Commission to the Council, the European Parliament, the Economic and Social Committee and the Committee of the Regions on eEurope 2002: Accessibility of Public Web Sites and their Content"
Date: 2002-02-20
Institutions: European Economic and Social Committee
Subjects: Internet, access to information, disabled person, dissemination of EU information, public service

18.4.2002

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Official Journal of the European Communities

C 94/9

Opinion of the Economic and Social Committee on the ‘Communication from the Commission
to the Council, the European Parliament, the Economic and Social Committee and the Committee
of the Regions on eEurope 2002: Accessibility of Public Web Sites and their Content’

(2002/C 94/04)

On 25 September 2001 the European Commission decided to consult the Economic and Social
Committee, under Article 262 of the Treaty establishing the European Community, on the above-
mentioned communication.

The Section for Transport, Energy, Infrastructure and the Information Society, which was responsible for
preparing the Committee’s work on the subject, adopted its opinion on 31 January 2002. The rapporteur
was Mr Cabra de Luna.

At its 388th plenary session of 20 and 21 February 2002 (meeting of 20 February) the Committee
adopted the following opinion by 117 votes with one abstention.

1.

Introduction

ing practical measures to ensure non-discrimination. It is a real
practical tool for putting into practice the principle of equal
access to information for all.

1.1.
Access to information and telecommunication con-
tinues to be a challenge for 37 million people with disabilities
in the European Union but also for people with special needs.

1.2.
Lack of accessibility is one of the main features of the
so-called digital divide, which has been met in several EU
documents, in particular the eInclusion report (1). Already in
the document on Towards a Barrier-free Europe for persons
with disabilities (2) the issue of barriers to access to information
technology was raised by the Commission.

1.3.
The EC Commission document on accessibility of
Public Web sites and their content will provide a first step
towards following up previous declarations with concrete
measures. On one hand there is a greater awareness towards
disabled people’s problems as shown by for instance the
European Barometer (3), on the other hand solutions for
disabled people will be of benefit also for other groups.

1.4.
The Committee believes that for disabled people access
to information is a fundamental human right in the absence of
which they cannot enjoy any social and political rights;
therefore a global and coherent strategy is required to ensure
an actual developmental and inclusive policy towards people
with special needs. This initiative will make the access to
information much easier, recognizing the fact that lack of
information causes a high degree of exclusion.

1.5.
The Communication is a good example of how the
Trans-Atlantic dialogue has benefited disabled people concern-

2. Summary of the Commission Communication

The eEurope Action Plan 2002, adopted by the Feira
2.1.
European Council in June 2000 (4) aims at speeding up and
extending the use of the Internet to all sectors of European
society, allowing European citizens to participate in and benefit
from the possibilities offered by digital technologies. One of
the specific targets of the action plan is to improve access to
the Web for people with disabilities: this is the main subject of
the Communication and its recommendations.

Accessing Internet Web pages and their content presents a
variety of problems for many of the 37 million European
citizens with a disability. In particular with the development
of governmental on-line services, there is a serious risk of
social exclusion of a large percentage of the population.

2.2.
The European approach to ensuring the availability of
accessible information on public Web sites is incorporated in
the eEurope Action Plan 2002 agreed by the Feira Council in
June 2000. Under its Objective 2c, the action plan includes
five targets for promoting ‘Participation for all in the know-
ledge-based society’, the action plan emphasises that, ‘... Public
sector Web sites and their content in Member States and in the
European institutions must be designed to be accessible to
ensure that citizens with disabilities can access information
and take full advantage of the potential for e-government’,
through the adoption of the Web Accessibility Initiative (WAI)
Guidelines for public Web sites by the end of 2001.

(1) SEC(2001) 1428.
(2) COM(2000) 284 fin, 12.5.2000.
(3) Eurobarometer No 55, 2.6.2001.

(4) Council and Commission of EU ‘e-Europe 2002 an Information

Society for All: Action Plan’ of 14 June 2000.

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2.3.
This initiative is one of the five domains of the World
Wide Web Consortium (also known as the W3C), which is
made up of over 500 member organisations and includes
participants from over 30 countries. The Web Accessibility
Initiative (WAI) has developed a number of guidelines, with
the participation of
industry, research, governments, and
disability organisations.

The eAccessibility expert group has provided a review of
progress of the adoption and implementation of the Guidelines
by Member States. It has also organised a monitoring exercise
among the 15 Member States, identifying examples of good
practice.

Web accessibility guidelines have been developed with the
financial support of the European Commission in the Fourth
Framework Programme ‘Telematics Applications Programme
(TAP)’, various governments, and other organisations. These
guidelines are more precisely known as the World Wide Web
Consortium/Web Accessibility Initiative (W3C/WAI) Web
Content Accessibility Guidelines version 1.0 (WCAG 1.0) (or
WAI/W3C WCAG 1.0).
In the Communication they are
referred to as the Guidelines. They are recognised as a de facto
global standard for the design of accessible Web sites. However,
the evolution of technology and tools will determine the
implementation of new versions and of guidelines for other
domains.

2.4.
The guidelines are based on a consensus developed
among a broad range of sector actors and they provide a
voluntary mechanism for public information providers to
conform to a set of informal rules which take the form of
principles, tools and methods. Information managers, Web
designers and developers should therefore be able to make
public Web sites accessible. The Guidelines should represent a
dynamic and evolving set of rules which seek to keep pace
with and anticipate the latest technological developments.

2.5.
The eEurope Action Plan 2002 proposes adoption of
the Guidelines as an initial step towards making European
public Web sites and their content accessible to people with
disabilities. The adoption of the Guidelines should also show
the commitment from the Member States and the European
institutions to the goal of integrating Web accessibility within
their policies for public information services and standards,
including eGovernment.

In connection with the implementation of the eEurope
2.6.
in
Action Plan 2002 in the area of ‘Participation for all
the knowledge-based society’,
the High Level Group on
Employment and the Social Dimension of the Information
Society (ESDIS), which is composed of representatives from
all
the Member States, was mandated to monitor these
developments. An eAccessibility expert group was set up to
support the work of the High Level Group.

2.7.
In connection with the planned upgrading of the
Commission’s Internet-based services, it is envisaged that the
so-called EUROPA II will be implemented in the period 2001-
2004.

Within this context, the accessibility of the Web sites of the
European institutions is currently under revision, so as to
respect the target of adoption of the Guidelines by the end of
the year 2001.

Complementing and supporting European policy develop-
ments, research and technology development work has taken
place over the past ten years that has addressed the needs and
requirements of disabled people.

One of the projects which was given financial support by
the European Commission in the 1994-1998 Telematics
Applications Research and Development Programme (TAP)
was the Web Accessibility Initiative (WAI) project, which
contributed to the work of producing the Guidelines and other
specifications and tools for the promotion of access to the
Web.

Within the Fifth FP Information Society Technologies pro-
gramme the European Commission gives financial support to
the project entitled Web Accessibility Initiative-Design for
All (WAI-DA). More and more research and technological
development projects within this programme are using the
Guidelines developed by the Web Accessibility Initiative.

2.8.
Finally, the Commission outlines some developments
outside the European Union. Web accessibility is an integral
part of public information policies, for example, in Australia,
Canada, and the United States. In some countries, legislation
provides an important framework for achieving the accessi-
bility of Web sites. In particular, Federal Web sites in the
United States are required to be accessible by law since the
amendment of section 508 of the Rehabilitation Act in August
1998 which became effective in June 2001. This legislation
also has important considerations for the public procurement
of information technologies that are accessible to persons with
a disability.

The European Disability Forum, which is the voice of the
organised disability movement in Europe, has been invited to
participate in the activities of this expert group with observer
status.

The European ministerial conference held in Warsaw in May
2000 underlined the importance of complementing European
Union political commitments by creating an eEurope-like
action plan (eEurope+) by and for the candidate countries

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seeking membership of
the European Union. eEurope+
addresses the issue of web accessibility and recommends the
adoption of the WAI guidelines (1).

— Organisations receiving public funding from the Euro-
pean institutions or the Member States should be encour-
aged to make their Web sites accessible.

2.9.
The Communication aims at being an example of the
concerted effort which is required to remove access barriers
— social, environmental, cultural, technical and others — that
hinder the full participation of persons with disabilities, to
secure inclusive society with equality of opportunities for all in
Europe and to ensure that future technologies and information
systems do not create new additional difficulties for people
with disabilities.

The Communication then presents a set of observations which
can be drawn from the experiences to date of adopting the
guidelines in the Member States and the European Institutions.

The most important are the following:

— The Member States and the European Institutions have
agreed to exchange information and to benchmark their
progress to be based on mutually agreed criteria in the
areas of adoption and implementation of the Guidelines.
The resulting accessibility of public Web sites should be
monitored and best practices identified. The Commission
will compile and disseminate the results of this action.

— National administrations

should seek constantly to
improve the accessibility of their Web pages and explore
new and better ways to deliver Web content and services
as new technologies and new versions of the Guidelines
are developed.

— Member States should take appropriate measures so that
not only national, but also local and regional public
websites comply with the Guidelines.

— The Commission will propose to the other European
institutions the establishment of an inter-institutional
group to promote and ensure the adoption, implemen-
tation, and regular updating of the Guidelines within the
European institutions.

— Measures for awareness-raising, dissemination, education,
and especially training in Web accessibility should be
promoted in both the European institutions and the
Member States.

— There should be a major initiative devoted to achieving
overall accessibility of both public and private Web sites
during the year 2003, the European Year of Disabled
People.

— The Member States and European institutions should
develop an ongoing dialogue with persons with disabili-
ties and their representatives in order to ensure regular
and consistent feedback on these issues.

3. General comments

3.1.
The Committee welcomes this proposal for a European
policy towards making public Web sites and their contents in
the European Union accessible for disabled people.
is
appropriate that this initiative is taken at a time when more
and more information is made available electronically and the
risks of social exclusion are significantly higher for those
excluded from accessing such information.

It

The initiative should secure in the Member States and
3.2.
on EU level the full access for everyone to public information
and thus the right of all to act as full citizens in society. The
Committee underlines the importance of referring to the rights
of non-discrimination and of integration of persons with
disabilities as laid down in Articles 21 and 26 of the Charter
of Fundamental Rights of the European Union. Access to the
Internet should not imply extra costs for users with disabilities.
States should allocate appropriate funding for user awareness
training as well as for the purchase of adaptive and assistive
technical devices whenever they are required.

The Committee considers that it is urgent to face the
3.3.
challenges to public information that technical and financial
barriers set against the full involvement of disabled users. The
EU has emphasised the importance of creating favourable
conditions for all European citizens’ active and democratic
participation in the decision-making processes, in the con-
clusions of both the Lisbon and the Stockholm summaries,
and through the eEurope initiative. For the Committee it
is vital that such strategies also encompass persons with
disabilities.

(1) eEurope+2003: Action Plan prepared by Candidates countries
with the assistance of the European Commission, June 2001,
p. 18.

3.4.
Active participation in community life will also offer
persons with disabilities a better possibility to apply for jobs
in the public administration and benefit from employment
services. Access to public Web sites will also increase the

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information on political development and increase partici-
pation of disabled people in politics and as a consequence
their involvement in the democratic process of our society.

3.5.
The eEurope+ initiative is likewise important because
the issues of access to public information and rights to
participation for disabled people in the Accession Countries
will also be focused upon.

Although being a voluntary instrument the implemen-
3.6.
tation of the proposals will introduce a standardisation on
access that will give disabled people the possibility to make
better use of assistive technology. It will also enable the use of
easy-to-use instruments for accessibility, through a European-
wide accessibility system following the same criteria all over
the Union.

One of the main challenges of the implementation of
3.7.
the WAI guidelines would be to reach out to all citizens
including disabled and elderly people and to involve not only
national governments, but also regional and local adminis-
trations that are closer to the citizen’s priority needs. The
implementation of the Guidelines and a methodical bench-
marking and monitoring system could also entail a desirable
simplification of norms and procedures that would make the
access to internet based information easier for all.

3.8.
The Committee also hopes that a major initiative as
proposed in connection with the European Year of Disabled
People in 2003 will contribute to make not only public but
also private Web sites accessible for disabled people.

The Committee welcomes the involvement of the
3.9.
European Disability Forum, to ensure a two-way interactive
dialogue between the European institutions and the organis-
ations of and for disabled people in Europe as well as with
individual experts with disabilities.

3.10.
The Committee points out that accessibility is para-
mount also for elderly persons, especially for those who have
been marginalized as a consequence of the technological
development.

Active use of research programmes of the European
3.11.
Union should be made to increase accessibility of Web sites
for disabled and elderly people. The Committee refers to other
relevant initiatives of the European Union, in particular the
reference to e-inclusion in the Proposal for the 6th Framework
Programme for Research and Development 2002-2006 (1).
The programme states that research activities on ‘e-inclusion’
will concentrate on systems enabling access for all, on barrier-

free technologies for full participation in the information
society and on assistive systems that will restore functions or
compensate for disabilities thereby ensuring a higher quality
of life for citizens with special needs and their carers. The
Committee stresses the need to incorporate the WAI guidelines
in the IDA programme for data interchange and interoperabi-
lity through electronic infrastructures (2), especially in view of
the greater importance which recently is being attached to the
end users, particularly disabled and elderly people.

The Committee would furthermore propose a specific pro-
gramme for joint training activities of developers of Web sites
and representatives of disabled users. Better co-ordination
between EU programmes, for instance on web security, must
be ensured to mainstream the interests of disabled people.

4. Specific comments

4.1.
The Committee deems appropriate that the issues
dealt with in the Communication should be the subject of
mandatory legislation; nevertheless, it meanwhile recognizes
the present approach based on voluntary commitment of the
public administrations at the various levels and expects the
Member States to carry into effect without delay all measures
provided for in the Communication and to establish a
methodical monitoring system of their implementation. States
should also set up a systematic benchmarking procedure for
the Lisbon strategy.

4.2.
The Committee will emphasise the importance of
disseminating and encouraging the use of the WAI guidelines
also among other organisations,
like trade unions and
employer organisations.

4.3.
The Committee commits itself to make its own Web
site accessible and user friendly as to ensure a better access to
information and to public debate for all citizens with special
needs. This initiative should be implemented before 2003, the
European Year of Disabled People, complying with the WAI
Guidelines as set forth in the Communication and, if necessary,
with the support of the European Commission. This should
constitute an example of good practice of the accessibility
principles.

(1) COM(2001) 279 final.

(2) CES 25/2002, 16.1.2002.

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4.4.
The Committee will point out that the increasingly
important field of eCommerce and disabled people should be
covered by the Communication. Disabled consumers’ interests
are affected by the growing importance of eCommerce through
inaccessible commercial Web pages, questions of protection
of personal data, integrity etc.

The Committee urges the Commission as well as the
4.5.
other EU institutions to make their own public Web pages
accessible through adaptation of the WAI guidelines.

The communication will be a strong encouragement
4.6.
to public authorities to extend their accessibility initiatives to
other areas than public Web sites. This is not only limited to
national, but also regional and local authorities. It does also
concern the introduction of Design for All principle in general
didactic programmes for education on ICT, etc.

4.7.
Using the principle of Web accessibility at European
level, the European citizens with disabilities can feel a stronger
sense of ownership to the idea of European integration, which
has hitherto been inaccessible for many, due to barriers against
assessing such information on EU Web sites.

Non-accessible public Web sites do indeed discriminate
4.8.
against people unable to use them and thus assess the
information therein. The Committee recommends that in
connection with the forthcoming European Year of Disabled
People 2003 a clause against this specific kind of discrimi-

Brussels, 20 February 2002.

nation should be included in the proposed disability specific
directive. The Committee has already recommended that such
a directive be adopted for the European Year of Disabled
People in its Opinion on the Proposal for a Council Decision
on the European Year of People with Disabilities 2003 (1).

4.9.
The Committee understands that the primary goal for
the Commission initiative is to secure access to public Web
sites for disabled people across all sectors and policy areas,
and that the access to public Web sites can provide a means to
integrate disabled people across all policy and programme
areas. As part of such a process the initiative may lead to an
open method for coordination of policies and exchange of
best practice across the EU Member States. In many Member
States the objection has been raised that the process of
implementation of the WAI guidelines will constitute an
excessive financial engagement. This assumption is simply
wrong, because implementing the accessibility guidelines is just
at the beginning a little more expensive than not implementing
them. The Committee believes that the national governments
should earmark funding for the implementation of the objec-
tives of the Communication taking into account all aspects
and all activities, including professional training of their staff
and increasing the efficiency of the public administrations.

Special attention should be paid to the setting up of
4.10.
accessible electronic terminals in all places where disabled
people are likely to make use of them.

(1) COM(2001) 271 final — 2001/0116 (CNS).

The President

of the Economic and Social Committee

Göke FRERICHS