Commission staff working document - Accompanying document to the Communication from the Commission to the European Parliament, the Council, the European Economic and Social Committee and the Committee of the Regions : “Towards an accessible information society” - Report on the Public Consultation on web accessibility and other e-accessibility issues {COM(2008) 804 final} {SEC(2008) 2916}
Date: 2008-12-01
Institutions: European Commission
Subjects: Internet, access to information, austerity policy, information technology, learning, teaching curriculum

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COMMISSION OF THE EUROPEAN COMMUNITIES 

Brussels, 1.12.2008 
SEC(2008) 2915 

COMMISSION STAFF WORKING DOCUMENT 

Accompanying document to the 

COMMUNICATION FROM THE COMMISSION TO THE EUROPEAN 
PARLIAMENT, THE COUNCIL, THE EUROPEAN ECONOMIC AND SOCIAL 
COMMITTEE AND THE COMMITTEE OF THE REGIONS 

“Towards an accessible information society” 

Report on the 
Public Consultation on web accessibility and other e-accessibility issues 

{COM(2008) 804 final} 
{SEC(2008) 2916} 

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TABLE OF CONTENTS 

1. 

2. 

3. 

4. 

Executive summary ................................................................................................ 3 

Introduction .............................................................................................................. 4 

Profile of respondents ........................................................................................... 5 

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-Accessibility 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 

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Public  consultation  on  web  accessibility  and  other  e-accessibility 
issues 

1.  EXECUTIVE SUMMARY 

The  issue  of  accessibility  of  information  and  communication  technologies  (ICTs),  and  of 
public websites in particular for people with disabilities 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  stock  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. 

the  outcomes  of  a  benchmarking  study,2 

Reflecting  on 
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 public 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  July  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  European  approach  to  web  accessibility  and 
secondly to elicit public opinion on other aspects of e-accessibility that go beyond the World 
Wide Web and possible action at European level.  

Overall,  161  responses  were  received.  They  represent  various  stakeholder  groups,  including 
individual  citizens  with  and  without  disabilities  (12%  each),  research  experts  and  centres 
(30%),  public  authorities  (14%),  business  and  industry  associations  (16%)  and  user 
organisations (12%). Some stakeholders also sent position papers.3 

Among  those  who  responded  to  this  consultation,  the  support  for  a  common  European 
approach to web accessibility was almost unanimous. Overall, 96.9% of respondents agreed 
that a common approach was needed to facilitate a high level of availability of accessible web 
sites,  and  95.6%  stated  that  this  should  be  equally  motivated  by  the  desire  to  improve  the 
situation of people with disabilities and the competitiveness of European companies. 

Concerning the type of websites that should be covered by a common European approach, a 
clear majority (93%) agreed that such an approach should not merely cover public websites 
but also other websites providing services of general interest to citizens, although industry and 
public  authority  respondents  were  somewhat  less  affirmative.  94.9%  of  respondents  agreed 

1 
2 

3 

COM(2005) 425. 
Study on Measuring Progress of e-accessibility in Europe (referred to as MeAC), Report on the 
assessment of the Status of e-accessibility in Europe, available at 
http://ec.europa.eu/information_society/activities/einclusion/library/studies/meac_study/index_en.htm. 
Such as UMIC, ONCE, ANEC-EDF, BSkyB, RNIB, Technosite. The position papers are available at: 
http://ec.europa.eu/einclusion. 

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that  intranet  websites  should  also  be  accessible.  According  to  87%  of  respondents,  web 
content  authoring  tools  should  also  be  covered  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 web, again a majority would welcome further EU 
action. Less than one out of ten respondents stated that none of the ICT domains mentioned to 
the  respondents  should  be  covered  by  EU  action.  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 authority respondents, whilst 64% overall considered this a high 
priority. 

Apart  from  legislation,  67.7%  of  the  respondents  stated  that  standardisation  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 consultation indicate a strong level of support for a more 
cross-cutting EU approach to e-accessibility. The high number of comments made revealed, 
however,  considerably  different  views  of  respondents  when  it  comes  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.  INTRODUCTION 

The  aim  of  the  first  part  of  the  public  consultation  launched  in  mid  2008  was  to  explore  a 
common European approach to web accessibility, for the following reasons.  

Disabled users continue to face great difficulties 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  using  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  and  EU  Member  States  are  taking  action  to 
improve  web  accessibility,  including  through  legal  obligations.  However,  a  patchwork  of 
national approaches is leading to increased fragmentation in the internal market. This causes 
legal uncertainty, particularly for technology providers, and makes it difficult for persons with 
disabilities to use online services freely across Europe.  

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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) included the commitment to make all public websites 
accessible by 2010.  

The  aim  of  the  second  part  of  the  public  consultation  was  to  elicit  public  opinion  on  other 
aspects  of  e-accessibility  that  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  schemes  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 terminals4). 

Although European legislation contains a number of provisions on e-accessibility, it does not 
deal with the issue in a comprehensive way. Thus the secondary aim of the consultation was 
to  explore  the  potential  for  extending  current  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 public 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.  PROFILE OF RESPONDENTS 

Overall, 161 responses were received. As summarised below, the survey covered a wide range 
of  stakeholder  groups.  Research  experts  in  the  field  of  ICT  and  disabilities  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 authorities are represented to a similar extent (14%). With 12% 
each, individual citizens with and without disabilities and user organisations are represented 
equally.  

4 

As seen in the MeAC report (op.cit.) 

. 

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User organization; 
20; 12% 

Public authority; 23;  14% 

Expert or academic on disability and/or 
ICT; 48; 30% 

Person without 
disability ; 20; 12% 

Person with 
disability; 19; 12% 

Other; 6; 4%

Industry/Enterprise; 

25; 16%

Table 1: Profile of respondents (n=161) 

•  Private individuals 

among which... 

(cid:131)  Persons with disability 
(cid:131)  Persons without disability  

24,2% 

48,7% 
51,3% 

(cid:131) 

Institutional 
authorities, Industry/Enterprises)  

respondents 

(Academics, 

organisations, 

public 

72% 

(cid:131)  Academics 

among which... 

(cid:131)  An  expert/  academic  on  disability  and/  or 

ICT   

(cid:131)  An academic institution or research centre   

(cid:131)  Organisations of ICT users 

among which... 

(cid:131)  An organisation of users with disability  
(cid:131)  An organisation of ICT users in general  

29,8% 

12,4% 

(cid:131) 

Industry/Enterprises 

among which... 

(cid:131)  An 

enterprise 
products/services)  
(cid:131)  An enterprise (non ICT)  

(providing 

15,5% 

ICT 

(cid:131)  An industry association (of  ICT providers)  

(cid:131)  An industry association (non ICT)  

(cid:131)  Public authorities 

(cid:131)  Others 

14,3% 

3,7% 

81,3% 

18,8% 

85% 
15% 

80% 

4% 

16% 

--- 

In terms of geographic coverage, respondents were located in 18 European Members States, 
Israel  and  the  United  States.  In  addition,  responses  were  received  from  European 
organisations (Table 2) 

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Table 2: Location of respondents (n=92) 

European level 

More than 10 contributions 

More than 5 contributions 

More than 2 contributions 

One contribution 

Eight contributions 

United Kingdom , Italy 

France, Germ any, Spain, Ireland 

Slovenia,  Belgium ,  Greece,  United  States, 
Austria, Portugal 
Sweden,  Slovakia, 
Netherlands, Denm ark, Lithuania 

Israel,  Malta,  Cyprus, 

Note:  This  table  covers  the  responses  that  could  be  assigned  to  a  geographic  location  (which  was  not 
compulsory).  

4.  OPINION ON A COMMON EUROPEAN APPROACH TO WEB ACCESSIBILITY 

Responses received in relation to a common European approach to web accessibility are set 
out below, according to the sub-themes specified 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 which such problems act as 
a  barrier  to  using  websites  for  one’s  own  purposes.  The  majority  of  respondents  stated  that 
websites were either totally (10.4%) or partially (47.9%) inaccessible.  

Regarding the impact of no accessibility, 72.6% stated 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.  

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Table 3: Web accessibility experienced from the perspective of a person with disability 

What kind of accessibility problems do you encounter when using a website?  

•  Total inaccessibility 
•  Partial inaccessibility: I can only use some parts of the websites 
• 
•  Other 

I do not generally have any problems accessing the websites I use 

Do  problems  with  website  accessibility  exclude  or  prevent  you  from  accessing 
information, facilities and services that are important to you? 

•  Yes, severely 
•  Yes, moderately 
•  No, I find other ways to access the information, facilities or services  
•  No, the websites I visit are accessible 
•  No, I don't use the internet 

Note:  The percentages apply to all respondents who did not answer “not concerned” 

(n=96) 
10,4% 
47,9% 
28,1% 
13,5% 

(n=91) 

29,7% 
42,9% 
6,6% 
19,8% 
1,1% 

From the perspective of a website owner, questions were asked about 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 for 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 web 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 the 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 
•  Yes, I am partially aware 
•  No, I am not aware 

Have you taken steps to improve the accessibility of your website? 

•  Yes 
•  No 

Note:  The percentages apply to all respondents who did not answer “not concerned” 

82% 
14,8% 
3,1% 

(n=126) 
90,5% 
9,5% 

From a technology provider’s perspective, the consultation included a question on the current 
provision of technologies or services that are accessible to people with disabilities. 86.4% of 
respondents  stated  that  they  provided  accessible  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,  lack  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  difficulties  in  implementing  technical  specifications 
concerning  web  accessibility  as  a  barrier,  while  10.3%  mentioned  the  lack  of  suitable 
technical specifications. Implementation costs were cited as a barrier by 9.3%. 

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Table 5: Web accessibility from the perspective of a web technology provider 

Do  you  provide  accessible  technologies/do  you  include  accessibility  in  your 
services? 

•  Yes, we always propose it to our clients 
•  Yes, when the clients request it 
•  No 

What is the main barrier for you when dealing with web accessibility? 

•  The lack of demand 
•  The lack of harmonised approach at European level 
•  The difficulty in implementing the technical specifications 
•  The lack of technical specifications 
•  The extra costs  
•  Other 

Note:  The percentages apply to all respondents who did not answer “not concerned” 

4.2. 

A common European Approach 

(n=81) 

69,1% 
17,3% 
13,6% 

(n=97) 
23,7% 
21,7% 
19,6% 
10,3% 
9,3% 
15,5% 

As specified in the public consultation, the aim of a common approach to web accessibility by 
EU  Member  States  is  to  improve  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 approach 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 society and the economy and  

•  Improve  the  competitiveness  of  European  businesses  in  accessible  information 
and  communication  technologies  by  removing  barriers  to  the  provision  of 
enabling technologies and services for web accessibility, thereby also stimulating 
the market in services provided over the internet as well as offering better access 
for potential online customers across the EU. 

Following  these  comments,  the  consultation  asked  questions  on  the  perceived  need  for  a 
common European approach to web accessibility.  

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A clear majority of the respondents agreed that a common European approach was needed to 
facilitate a high level of availability of accessible 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 
•  Yes 

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? 

•  No 
•  Yes 

3,1% 
96,9% 

(n=161) 

4,4% 
95,6% 

Also, a clear majority (95.6%) stated that a common 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 according to respondents groups 

Do  you  agree  that  a  common  European  approach  is  needed  to  facilitate  a  high  level  of 
availability of accessible websites? 

h
t
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0% 
100% 
19 

0% 
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20 

4,2% 
95,8% 
48 

0% 
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20 

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25 

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0% 
100% 
6 

l
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T
3,1% 
96,9% 
161 

No 
Yes 
Total (n) 

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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 competitiveness 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? 

h
t
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0% 
100% 
19 

10% 
90% 
20 

2,1% 
97,9% 
48 

0% 
100% 
20 

8,7% 
91,3% 
23 

8% 
92% 
25 

r
e
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t
O

0% 
100% 
6 

l
a
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T
4,4% 
95,7% 
161 

No 
Yes 
Total (n) 

4.3.  Websites concerned 

As  stated  in  the  consultation,  although  the  Riga  Ministerial  Declaration  focused  on  public 
websites  only,  many  other  websites  are  essential  for  the  daily  life  of  European  citizens. 
Websites providing services of general interest such as education, health and social services 
and telecommunication services can be provided by both the public and the private sectors.5  

If Member States take action to improve accessibility, it could cover public websites, namely 
websites of public authorities at national, regional and/or local level that provide information 
or  services  to  citizens,  as  well  as  websites  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  websites  that  should  be 
covered  by  policy  intervention.  Overall,  most  respondents  held  that  if  Member  States  take 
action  in  this  regard,  it  should  cover  not  only  public  websites,  but  also  other  websites 
providing  services  of  general  interest  to  citizens  (Chart  2).  In  total,  seven  out  of  ten 
respondents strongly agreed with this statement, whilst 23% agreed and only 7% disagreed. 

5 

See Commission Communication on Services of general interest (COM (2007) 725). 

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Chart 2: 
websites, but also other websites providing services of general interest to citizens? (n=161) 

Do  you  agree  that  if  Member  States  take  action,  this  should  cover  not  only  public 

I strongly disagree; 3; 
2%

I Agree; 37; 23%

I Disagree; 8; 5%

I strongly agree; 113; 
70% 

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? 

h
t
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P

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b
a
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89,5% 
5,3% 
5,3% 
0% 
19 

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c
i
m
e
d
a
c
A

75% 
25% 
0% 
0% 
20 

79,2% 
20,9% 
0% 
0% 
48 

n
o
i
t
a
s
i
n
a
g
r
o

r
e
s
U

95% 
5% 
0% 
0% 
20 

y
t
i
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o
h
t
u
a

c
i
l

b
u
P

34,8% 
47,8% 
13% 
4,4% 
23 

e
s
i
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p
r
e
t
n
E

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t
s
u
d
n

I

40% 
36% 
16% 
8% 
25 

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e
h
t
O

100% 
0% 
0% 
0% 
6 

l
a
t
o
T
70,2% 
23% 
5% 
1,9% 
161 

I Strongly agree 
I Agree 
I Disagree 
I Strongly disagree 

Total (n) 

As regards individual stakeholder groups, the responses received from public authorities and 
business were clearly more negative about covering other websites as well (Table 9). 24% of 
businesses disagreed or even strongly disagreed. 17.4% of public authorities 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 average 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  websites  accessible  but  rather  be 
incentivised and stimulated to do so on a voluntary basis, e.g. following good practice in the 
public sector. 

EN 

12 

   EN 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
4.4. 

Implementing web accessibility 

As stated in the consultation, a common approach to web accessibility would mean that action 
is taken by all Member States to prepare for the introduction and implementation of modern 
specifications on web accessibility.  

In  order  to  contribute  to  making  the  websites  of  public  authorities  accessible  by  2010, 
Member States are expected to take into account in their schemes the work to achieve widely 
recognised international and European specifications. 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 Standardisation Organisations, 
thereby  supporting  accessibility  of  websites  deploying  modern  web  technologies  and 
applications. 

Specific schemes for the Member States could comprise: 

•  making available, updating and publishing technical guidance relating to web accessibility 

requirements, translating where appropriate relevant documentation; 

•  identifying websites concerned, setting targets and milestones; 

•  allocating responsibilities for implementing the schemes; 

•  providing references for training, schemes for knowledge sharing and awareness measures; 

•  assessing and monitoring progress and publishing progress reports; 

•  pooling experience in the implementation of technical guidance for web accessibility;  

•  promoting  the  accessibility  of  intranet  websites  in  line  with  the  Employment  Equality 

Directive. 

Similarly, Member States could promote the accessibility of websites that are not provided by 
public authorities that provide services of general interest to citizens. 

Member States could encourage website owners to include an accessibility statement in their 
websites which provides supporting information such as an outline of the accessibility policy 
of the institution concerned; degree of compliance with relevant legislation and/or reference 
specifications and support for persons with disabilities.  

The  feedback  received  on  these  comments  reveals  that  most  respondents  agreed  that  the 
above-mentioned  action  would  contribute  to  a  high  level  of  availability  of  accessible  web 
sites. While 83.4% generally agreed with this statement (38.5% strongly agreed), only 4.9% 
disagreed. However about one in ten respondents (11.8%) had no opinion on this (Chart 3). 

EN 

13 

   EN 

 
Chart 3: Agreement to Statements regarding implementation of web accessibility (n=161) 

Other websites (providing services of general interest)
should be encouraged to be accessible

Intranet websites should be encouraged to be
accessible

Member States should seek alignment with the results of
international standards on Web Content Accessibility
and should comply with the outcomes of Mandate 376

Websites should be encouraged to include an
accessibility statement

The above-mentioned actions will contribute to a high
level of availability of accessible websites

I strongly agree

I agree

I disagree

I strongly disagree

I don't know

Question: 

Do you agree with the following statements? 

0%

20%

40%

60%

80%

100%

A clear majority of the respondents also perceived the need to encourage 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 respondents agreed with the statement 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 perceived need to encourage websites to post an accessibility 
statement.  Here,  overall  agreement  reached  88.2%,  55.9%  strongly  agreed  and  7.1% 
disagreed.  

Comments  from  position  papers  received  in  this  context  were  manifold.  To  sum  up,  the 
following common threads can be identified: 

•  Some  comments  concerned  the  issue  of  appropriateness  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 retrofitting accessibility into 
existing websites may become very costly in certain cases. Various options 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 requiring only new content 
and  features  to  be  accessible  rather  than  old  content.  Also  concerns  were  raised  that  e-

EN 

14 

   EN 

 
accessibility  may  be  problematic  for  some  services  and  hinder  the  interaction  of  other 
users. 

•  Another set of comments addressed the type of intervention needed to achieve the desired 
outcomes.  The  argument  was  put  forward  that  binding  legislation  and  appropriate 
enforcement mechanisms (e.g. clearly specified deadlines, fines for non-compliance, black 
lists  and  refusal  of  public  funding)  would  yield  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 general thrust of provisions that intervention could 
include. Here it was stressed that any downloadable 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 assistive 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  others  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 the need for capacity building among different 
stakeholder  groups  (e.g.  website  developers,  website  owners,  tool  developers  and 
government agencies). 

•  Lastly  some  comments  concerned  the  sustainability  of  intervention.  This  concerns,  for 
instance,  a  perceived  need  to  consider  accessibility  requirements,  as  a  general  principle, 
when developing new technologies 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  authoring  tools  in  order  to  address  the  whole 
process of website development and operation.  

Member States could encourage public administrations to use and procure website authoring 
tools that are designed to specifically assist with the production 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 
•  Yes 
•  No reply 

11,8% 
87% 
1,3% 

In  response  to  this  statement,  a  clear  majority  of  respondents  (87%)  held  that  if  Member 

EN 

15 

   EN 

 
 
States  target  web  accessibility,  they  should  also  tackle  website  authoring  tools  in  order  to 
address the whole process of a website development and operation (Table 10). However, one 
in  four  (25%)  respondents  representing  industry  associations  or  business  thought  that  this 
should not be the case (Table 11). A similar number of public authorities,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? 

h
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n
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y
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a
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i

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a
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i
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e
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A

10,5% 
84,2% 
5,3% 
19 

0% 
100% 
0% 
20 

14,6% 
85,4% 
0% 
48 

n
o
i
t
a
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i
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a
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r
o

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s
U

0% 
100% 
0% 
20 

y
t
i
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h
t
u
a

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i
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b
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17,4% 
82,6% 
0% 
23 

e
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i
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p
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e
t
n
E

/
y
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I

25% 
75% 
0% 
24 

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e
h
t
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0% 
100% 
0% 
6 

l
a
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o
T

0,6% 
160 

No 
Yes 
No reply 
Total (n) 

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  awareness  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,  web  masters,  web  content  developers…)  and 
deployed  at  national,  regional  and  local  levels.  Likewise  exchanges  of  good  practices  at 
European level would greatly facilitate 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 technologies is also relevant beyond the web, 
it may be useful to concentrate e-accessibility information and guidance in one location.  

Thus accompanying measures of Member States could include: 

•  Supporting  training  schemes  for  those  involved  in  web  accessibility,  whenever  possible 

directly involving persons with disabilities. 

•  Providing  information  and  guidance  to  persons  with  disabilities  on  accessibility  of 
websites and, where relevant, assistive technologies (assistive technology 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 publication of best practices for stakeholders. 

•  Collecting input from users, including through surveys of their experience of accessibility. 

EN 

16 

   EN 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
•  Assigning  a  national  Contact  Point  for  web  accessibility  that  can  take  up  the  above-
described functions. This Contact Point could also be used for other relevant accessibility 
issues concerning the information society. 

Overall,  a  clear  majority  of  the  respondents  would  welcome  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% agreed with the provision of training for those 
involved, 67.7% agreed strongly and only 3.1% disagreed.  

A similar picture emerges in relation to exchanging best practice. Here 95.6% agreed, 65.2% 
agreed strongly and only 1.2% expressed disagreement.  

On the user side, 94.3% agreed with the provision of information and guidance to people with 
disabilities, 60.8% agreed strongly 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 regarding accompanying measures (n=161) 

Supporting training schemes for relevant actors involved in
web accessibility, whenever possible with a direct involvement
of persons with disabilities

Supporting exchange and publication of best practices for the
various stakeholders

Collecting input from users, including through surveys, about
their experience of accessibility

Providing information and guidance to persons with disabilities
on accessibility of websites and, where relevant, about
assistive technologies

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? 

0%

20%

40%

60%

80%

100%

When  compared  with  these  measures,  there  is  slightly  less  overall  support  for  establishing 
national web accessibility contact points, at 83.2% (Table 12). It is striking that the share of 
respondents not supporting this option is comparatively high among business (40%), though 
still a minority. 

EN 

17 

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Table 12: Support for the creation of a national contact point 

Do you support the creation of a national web accessibility contact point? 

h
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A

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/
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No 
Yes 
Total (n) 

10,5% 
89,5% 
19 

20% 
80% 
20 

8,3% 
91,7% 
48 

5% 
95% 
20 

26,1% 
73,9% 
23 

40% 
60% 
25 

Concerns were expressed regarding various aspects such as: 

r
e
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0% 
100% 
6 

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16,8% 
83,2% 
161 

•  the risk of shifting responsibilities from website owners to a centralised body; 

•  the danger of overlapping responsibilities, particularly in countries where information and 

guidance is already provided by NGOs, government agencies and the like; 

•  the risk of increasing bureaucratic overheads, lobbying 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  addressed  (e.g.  content  producers,  publishers, 
technicians, web developers, users) and a European award scheme 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 disputes. Other proposals concern launching joint 
projects and involving users in functionality testing and certification 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 between Member States and other stakeholders 
could include: 

EN 

18 

   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  establishment  of  best  practices  in  web  accessibility 
measurement,  monitoring,  training,  assessment  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.  OPINION  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  systems,  self-service  terminals  such  as  cash-
dispensing and ticketing machines, health 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 supports research and innovation, promotes best 
practices  and  stakeholder  cooperation.  E-accessibility  is  also  dealt  with  by  some  ICT 
providers  who  have  taken  action  to  include  accessibility  features  early  in  the  ICT  design 
process through inclusive universal 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 analysed in the recent European Communication on e-
Inclusion.  Given  these  observations,  and  taking  into  account  the  recent  United  Nations 
Convention  on  the  rights  of  persons  with  disabilities  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  mentioned,  the  purpose  of  this  part  of  the  consultation  was  not  to 
review existing European action, but rather to explore the potential for further action to better 
promote overall e-accessibility (whilst acknowledging 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 aspects of e-accessibility 
are set out below by sub-theme, including:  

•  Experiences of e-accessibility, 

•  Priority areas for EU action, 

•  Preferred approach, 

•  Legislative action, 

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19 

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•  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  respondents 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 availability of accessible ICT among users, 61.5% 
agreed  that  it  acts  as  a  barrier  to  e-accessibility,  whilst  8%  disagreed  and  30.5%  had  no 
opinion.  

A similar picture emerges in relation to information on how to use accessibility features that 
are, in principle, available. Here, a lack of instructions was perceived by 58.9% as a barrier, 
whilst 10.6% disagreed and 30.4% had no opinion.  

A  more  diverse  picture  emerges  concerning  the  question  of  extra  costs  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 assistive 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  comparatively  critical  of  e-accessibility  features 
provided by current ICTs (Table 13). 75% of user organisations agreed with the statement that 
ICT does not have features to deal with disability challenges (Table 13). 

EN 

20 

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Chart 5: 
(n=161) 

Perceived main barriers to e-Accessibility from the perspective of a person with disability 

Little awareness of ICT
providers on accessibility

Extra cost of accessible ICT is
a concern for the user

Lack of interoperability with
assistive technologies

Lack of instructions about how
to use accessibility features

Lack of information about the
availability of accessible ICTs

The ICT does not have
features to deal with
accessibility challenges

0%

20%

40%

60%

80%

100% 

I strongly agree

I agree

I disagree

I strongly disagree

I don't know 

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? 

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26.3% 
10.5% 
31.6% 
10.5% 
21.1% 
19 

Strongly agree 
Agree 
Disagree 
Strongly disagree 
Don’t’ know 
Total (n) 

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4.3%

5.0% 22.9%
4.2%

35.0% 14.6% 65.0%
0.0% 
10.0% 33.3% 20.0% 21.7% 16.0% 
5.0% 21.7% 16.0% 
10.0%
8.7% 12.0% 
0.0%
40.0% 25.0% 10.0% 43.5% 56.0% 
25 

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0.0% 
16.7% 
0.0% 
66.7% 
6 

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21.1%
20.5%
18.0%
6.8%
33.5%
161

Over and above these aspects, further issues that may warrant attention were indicated in the 
comments made. Some common threads are given below:  

•  Some  comments  concerned  unequal  consideration  of  different  types  of  disability  and  a 
perceived  lack  of  sufficiently  deep  knowledge  of  the  user  situation  and  related 
requirements. 

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•  Other  statements  concerned  specific  ICTs  that  are  perceived  as  being  particularly 

inaccessible, such as mobile/handheld devices and devices with visual interfaces. 

•  A  number  of  statements  concerned  an  additional  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 these 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  barrier  to  addressing  e-accessibility  from  the 
perspective of an ICT provider, by comparison responses were quite evenly distributed across 
the  various  options  given  to  respondents.  These  were  extra  costs  (20.8%),  lack  of  demand 
(19.7%),  difficulty  to  implement  technical  specifications  (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? 

•  Yes, we always propose it to our clients 
•  Yes, when the clients request it 
•  No, because there are few requests from the clients 
•  No, we don't have accessible solutions 

What are the main barriers for you when dealing with e-accessibility? 

(multiple answers possible) 

•  The lack of technical specifications 
•  The difficulty to implement technical specifications 
•  The lack of harmonised approach at European level 
•  The lack of demand 
•  The extra cost 
•  Other barrier 

(n=98) 

65,3% 
17,4% 
  7,1% 
10,2% 

(n=96) 

26,0% 
34,4% 
31,3% 
37,5% 
39,6% 
21,9% 

Note:  The percentages relate to all respondents that have not answered “not concerned” 

The comments submitted by some respondents mentioned a number of other aspects that may 
merit  attention  when  it  comes  to  identifying  barriers  to  addressing  e-accessibility  from  a 
supply-side perspective. Some common threads are given below: 

•  Lack of clarity about the business case for accessibility; 

•  Lack of open standards; 

•  Lack of intra-organisational knowledge and capacities concerning e-accessibility; 

•  Lack of design tools that are easy to use; 

•  Difficulties in evaluating conformity with accessibility requirements. 

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From  the  perspective  of  an  organisation  applying  ICT  for  the  purposes  of  its  own 
operations,  the  online  consultation  included  questions  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 summarised in Table 15. Only 4.8% stated that they 
were  not  aware  of  e-accessibility  issues  and  implications  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 across 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 availability of accessible ICT as a major barrier. 

In addition to these barriers, the corresponding comments revealed that the lack of awareness 
and  knowledge  among  the  various  parties  involved  in  organisations  was  a  major  barrier  to 
extending the deployment of accessible ICT within organisations. 

Table 15: 

E-accessibility as a company/organisation using ICT 

Are you aware of the issue of e-accessibility and of the implications for persons 
with disabilities using your goods/services? 

(n=124) 

•  Yes, I am fully aware 
•  Yes, I am partially aware 
•  No, I am not aware 

74,2% 
21% 
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 
•  Cost of accessible ICT 
•  Lack of interoperability of accessible ICT with other technologies 
•  Other 

25,4% 
36% 
29% 
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  ICT-enabled  products  and  services  may  pose 
accessibility  challenges  to  persons  with  disabilities.  As  regards  prioritising  ICT  sectors  for 
further policy intervention at European level, 85.7% stated that high priority should be given 
to the Internet in general and the World Wide Web in particular (Chart 6). 

Mobile communications should be given high priority 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  receive  high  priority  attention  and  47.2%  stated  that  domestic 
equipment  was  a  high  priority  domain.  ICT  in  general  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 respondents 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 perceived need for EU action to 
cover various ICT domains. Common threads to the comments are given below:  

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•  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  technological  convergence  and  the  risk  that  any 

legislation based on today’s technology divides may soon become obsolete. 

•  Some  comments  highlighted  accessibility  challenges  perceived  in  specific  ICT  domains 

such as mobile communications and e-books. 

•  On  the  other  hand,  it  was  stressed  that  considerable  action  was  being  taken  on  market-
driven standards concerning ICTs, meaning that further action might become redundant. 

Chart 6: 
should be a priority (n=161)  

Opinion  for  which  technologies/equipment  possible  further  action  at  European  level 

Internet / web

Mobile communications

Personal computers

Self-service terminals

Domestic equipment

ICT in general

Digital TV

Fixed communications

0%

20%

40%

60%

80%

100%

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  framework  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  area  for  high  priority  attention  according  to 
66.4%,  and  53.4%  said  so  for  consumer  retail  services.  Audiovisual  services  and  travel 
services were considered by 49.6% and 41.6% respectively to merit high priority.  

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Similarly to ICT product domains, many comments received concerned ICT-based services to 
be considered for further EU action, such as the following aspects:  

•  service domains in addition to those mentioned above, such as education and professional 
guidance  services,  social  services,  e.g.  linked  to  family  and  health  matters  and  social 
networking services. 

•  Some  comments  stressed  the  lack  of  accessibility  of  particular  services  as  currently 

provided, e.g. in broadcasting and banking. 

Chart 7: 
should be a priority (n=161) 

Opinion for which services that is based on ICT possible further action at European level 

Consumer banking,
financial services

Consumer retail
services

Audio-visual content
services

Services in general
(that use ICT)

Travel, tourism
services

0%

20%

40%

60%

80%

100%

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 promote e-accessibility can take 
many forms. It is necessary to define the most effective and necessary action, such as binding 
legislation,  non-binding 
legislation  (recommendations),  standardisation  and  reference 
technical  specifications,  enhanced  benchmarking  and  good  practice  exchange  and  increased 
support for R&D and innovation. 

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Binding  legislation  was  considered  a  high  priority  approach  by  55.3%,  whilst  non-binding 
legislation was highly prioritised by 24.2%. However, it is interesting 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.  Regarding  non-binding  legislation, 
the  responses  received  were  even  more  varied.  Overall,  no  more  than  43%  assigned  high 
priority to this approach from 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?  

c
i
m
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d
a
c
A

t
n
E
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r
t
s
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e

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n
o
s
r
e
P

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t
i
l
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a
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i
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o
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e
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t
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t
i

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y
t
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b
a
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i
d

y
t
i
r
o
h
t
u
a

c
i
l

b
u
P

26.3% 
42.1% 
15.8% 
10.5% 
5.3% 
48 

30.0% 18.8% 43.5% 10.0% 20.0% 
30.0% 37.5% 43.5% 10.0% 32.0% 
25.0% 29.2% 13.0% 75.0% 24.0% 
5.0% 20.0% 
0.0%
10.0%
4.0% 
0.0%
0.0%
5.0%
23 
20
19
25

8.3%
6.3%
6

n
o
i
t
a
s
i
n
a
g
r
o

r
e
s
U

33.3% 
33.3% 
33.3% 
0.0% 
0.0% 
20 

l
a
t
o
T
24.2%
33.5%
29.8%
8.7%
3.7%
161

High priority 
Relevant priority 
Low priority 
No priority 
Don’t’ know 
Total (n) 

Other  than  legislation,  67.7%  of  respondents  stated  that  standardisation  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 research and deployment respectively. 

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Chart 8: Opinion on possible future EU action for e-accessibility (n=161) 

Standardisation;
technical specifications

Increased innovation /
deployment support

Binding legislation

Increased research
support

Benchmarking and
good practice
reporting

Non-binding legislation
such as
recommendations

0%

20%

40%

60%

80%

100%

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  concerned  the  perceived  need  for  a  binding  legislative  approach 
(e.g.  an  EU  Directive)  that  would  need  to  be  enforced  to  yield  the  desired  impact  (e.g. 
broader implementation of e-accessibility, level playing field for actors involved). On the 
other  hand,  some  respondents  expressed  their  concerns  that  the  introduction  of  binding 
legislation would have rather negative 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  concerns  e-accessibility  standards.  Some 
respondents stressed the need for relying on common international/global standards where 
they exist. Some comments highlighted a perceived need to involve disabled users in the 
development  of  standards,  while  others  stressed  that  the  focus  should  be  on  encouraging 
the use of existing standards and the development 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 regard, e.g. by RTD funding. 

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•  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 stressing that technology features 
are only one aspect of supporting a user-oriented approach to accessibility. More generally, 
a perceived lack of a common understanding of concepts and terms 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, first and foremost which e-accessibility 
requirements to comply with and the criteria for selecting the ICT technologies and services 
concerned. 

The consultation then asked a question on the relevance  of different types of  e-accessibility 
requirements to further EU policy intervention. 

As  shown  in  Chart  9,  67%  regarded  compliance  with  e-accessibility  standards  as  a  very 
important  requirement,  which  is  comparatively  high.  Apart  from  this,  interoperability  with 
assistive technology is a very important requirement according to 60.8% and 55.2% agreed on 
interoperability with other ICTs to ensure end-to-end accessibility. Overall, 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  information  on  e-accessibility  features  was  very 
relevant. Offering at least one accessible model within a product range was regarded as very 
relevant  by  47.8%  of  respondents.  At  34.1%,  comparatively  few  respondents  felt  that  the 
provision  of  alternative  solutions  to  the  standard  product/services  (e.g.  operator  assistance) 
was an important requirement. 

Only 6.2% of the respondents considered all of these requirements as irrelevant. 

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Chart 9: 

Most relevant types of e-accessibility requirements (n=161) 

Compliance with e-accessibility standards,
where these exist

Interoperability with assistive technologies

Offering alternative ways of user
interaction (e.g. audio output next to text)

Interoperability with other ICTs to ensure
end-to-end accessibility

Providing information on the e-accessibility
features

Offering at least one accessible model
within the product range

Offering an alternative solution to the
product/service (e.g. operator assistance)

Very relevant Relevant

Somewhat relevant

Irrelevant

I don't know

0% 20% 40% 60% 80% 100%

Question: 

Which types of e-accessibility requirements are 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  participate  in  society  and  the 
economy, which is comparatively high. Similarly, 59.6% and 52.1% considered technologies, 
products  and  services  that  are  essential  for  personal  safety  and  services  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 technology or service has widely spread among the general public 
was  regarded  by  34.2%  of  the  respondents  as  a  very  relevant  selection  criterion.  The  same 
response was given by 24.8% for the relative amount of costs for e-accessibility features when 
compared with the overall cost/price of the product and services in question. 3.6% and 11.8% 
respectively considered these criteria 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  novelty  (e.g.  imposing  requirements  only  on  new 
products), overall 19.3% and 14.9% respectively considered these aspects to be very relevant 
selection  criteria.  Similarly,  14.9%  and  14.9%  of  respondents  considered  these  criteria  as 
entirely irrelevant. 

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Chart 10: 
comply with e-accessibility requirements (n=161) 

Criteria relevant to guide the selection of products, technologies and services that need to 

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 threads in relation to further 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  means  of  a  general  e-accessibility  Directive. 
Also the need for horizontal approach was stressed in relation to the ongoing blurring of 
existing  domain  boundaries,  due  in  part  to  the  convergence  of  current  technologies  and 
services.  

•  Other  comments  referred 

the 
the  perceived  need 
implementation  of  any  new  legislation,  e.g.  by  setting  up  an  independent  agency 
specifically responsible. 

to  enforce  and  supervise 

to 

•  Some  comments  concerned  the  risk  of  fragmentation  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. 

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5.5.  Expected impact 

The final subsection of the consultation provided free text space to respondents to explain in 
more detail the potential impact in terms of costs 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 potential 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, economic and cultural life.  

•  Other respondents highlighted the benefits for society as a whole from better access to ICT 
for people with disabilities, such as realising their 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-accessibility  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 the ICT industry, e.g. competitive advantages 
through  improved  overall  usability,  extended  outreach  of  services,  extended  markets  and 
skills pool and soft factors such as improved image. On the other hand, some respondents 
expressed  doubts  as  to  whether  commercial  companies  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  concerned  additional  costs  in  connection  with  general  e-
accessibility  legislation.  Some  respondents  expressed  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  the  like.  Other  comments  highlighted  that  any 
additional costs involved  in  implementing e-accessibility would need to be offset against 
benefits  gained  at  individual  and  societal  level  (e.g.  through  increased  participation  in 
common  cultural,  social  and  economic  processes).  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 harmonisation of e-accessibility 
policy and standardisation. 

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6.  CLOSING 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 sites, 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 agreed that this approach 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 standards was deemed important by a clear 
majority. Finally, a clear majority 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  considered  binding  legislation  as  a  high  priority  approach, 
whereas  non-binding  legislation  was  highly  prioritised  by  about  one  quarter.  Other  than 
legislation, various other measures such as standardisation, benchmarking, 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 issues would be addressed. 

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