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” - Status and challenges of e-accessibility in Europe {COM(2008) 804 final} {SEC(2008) 2915}
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) 2916 

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” 

Status and challenges of e-accessibility in Europe 

{COM(2008) 804 final} 
{SEC(2008) 2915} 

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TABLE OF CONTENTS 

1. 

1.1. 

1.2. 

2. 

Introduction................................................................................................................. 3 

E-accessibility - who is concerned? ....................................................................... 3 

EU-level policy instruments ..................................................................................... 4 

E-accessibility ............................................................................................................ 6 

2.1. 

E-accessibility state of play...................................................................................... 6 

2.1.1.  Provision of accessible ICTs – the e-accessibility deficit............................ 6 

2.1.2.  Non legislative EU level activities on e-accessibility .................................... 7 

2.1.3.  Legislative approaches ......................................................................................... 9 

2.2. 

Further actions towards a coherent and effective approach for e-accessibility
.................................................................................................................................... 12 

2.2.1. 

Increasing coherence and timely action by cooperation and 
coordination............................................................................................................ 13 

2.2.2.  Supporting innovation and deployment ......................................................... 14 

2.2.3.  Facilitating standardisation activities.............................................................. 15 

2.2.4.  Legislation............................................................................................................... 15 

3. 

Web accessibility ..................................................................................................... 16 

3.1.1.  Relevance and state of play ............................................................................... 16 

3.2.  Web accessibility activities..................................................................................... 18 

3.2.1.  Non legislative activities supporting web accessibility ............................. 18 

3.2.2.  Legislative approaches ....................................................................................... 20 

3.3. 

Further web accessibility actions .......................................................................... 21 

3.3.1.  Rationale for further action on web accessibility......................................... 21 

3.3.2.  Estimated costs of implementing web accessibility ................................... 22 

3.3.3.  Accelerating in a common way the realisation of modern web 

accessibility............................................................................................................ 24 

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1. 

INTRODUCTION 

This  staff  working  paper  provides  background  information  on  the  2008  Communication 
“Towards an Accessible Information Society”. It deals with both e-accessibility in general and 
web  accessibility  as  a  specific  priority.  This  staff  working  paper  is  based  upon  two  study 
reports  prepared  for  the  Commission  in  2008  on  e-accessibility  and  web  accessibility 
respectively (both with an extensive analysis of legislation in Member States, USA, and some 
other third countries, and at EU level), the public consultation held from July — September 
the  2007  e-Inclusion 
2008,  consultation  workshops, 
Communication, the ‘MEAC’ study1, and a range of other documents quoted in the notes. 

impact  assessment  of 

the 

The paper first presents general information on e-accessibility (and web accessibility), namely 
who is concerned and which EU-level policy instruments are at our disposal. Section 2 of the 
paper  deals  with  e-accessibility  in  general,  presenting  both  non-legislative  and  legislative 
activities, and subsequently providing more background information for the action proposed 
in  the  Communication  to  achieve  a  more  coherent  and  effective  approach  to  improving  e-
accessibility. 

Section 3 then deals in more detail with web accessibility. It presents the current state of play 
addressing both non-legislative and legislative activities, and then provides more background 
information  on  initiatives  that  are  proposed  in  the  Communication  to  accelerate  web 
accessibility.  

1.1.  E-accessibility — who is concerned? 

E-accessibility  means  overcoming  the  technical  barriers  and  difficulties  that  people  with 
disabilities and others like elderly people experience when trying to participate on equal terms 
in 
information  and 
communication technology (ICT) used by citizens. Full e-accessibility is a huge challenge, as 
there is a wide range of disabilities and ICTs are constantly and rapidly evolving.  

information  society.2  It  potentially  concerns  any 

type  of 

the 

E-accessibility is of great importance for many citizens: 

Up  to  15%  of  the  population  across  the  European  Union  has  a  disability,  such  as  a  visual, 
hearing, speech, cognitive, or motor impairment3.  

The  elderly  population  is  also  much  concerned  by  e-accessibility  as  disability  correlates 
strongly with age. In the EU 27 countries about 16% of the population are over 65, a number 
that is estimated to rise rapidly in the coming years4. 

Many  other  citizens  could  also  benefit  from  e-accessibility  in  adverse  or  special  usage 
environments such as noisy environments, hands-free and poor lighting environments.  

1 

2 
3 

4 

Study  on  ‘Accessibility  to  ICT  Products  and  services  by  Disabled  and  Elderly  People’  (reports  e-
accessibility and web accessibility), ‘MeAC’ study (Measuring progress of e-accessibility in Europe), 
Report from the Public Consultation on web accessibility and other e-accessibility issues. All available 
at http://ec.europa.eu/information_society/activities/einclusion/index_en.htm  
COM(2005)425 on e-accessibility.  
Report  of  the  Inclusive  Communications  (INCOM)  subgroup  of  the  Communications  Committee 
(COCOM) COCOM04-08. 
Eurostat yearbook 2008. 

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The core group of disabled persons for whom e-accessibility is relevant comprises some 84 
million persons in Europe, of which 50 million in the age range 15-64 and 34 million in the 
age range 65 and above. 5 

As there is a wide variety of impairments, needs are very diverse and likewise a great variety 
of solutions is needed. As shown in Figure 1 there are many barriers to ICT and many ICT-
enabled  products  and  services  that  may  pose  accessibility  challenges  to  persons  with 
disabilities, as well as many potential solutions.  

Visual impairments
Visual impairments

Solutions
Solutions

Hearing impairments
Hearing impairments

Ensure that audio outputs are adjustable in sound volume & quality 
Ensure that audio outputs are adjustable in sound volume & quality 

Design mainstream ICT products / services so that the visual 
Design mainstream ICT products / services so that the visual 
presentation can be adjusted by the users (e.g. displays with 
presentation can be adjusted by the users (e.g. displays with 
adjustable font size, contrast, use of colours)
adjustable font size, contrast, use of colours)

Provide speech, audio and other output
Provide speech, audio and other output
modes as alternative to visual displays 
modes as alternative to visual displays 
& status indicators on ICT products
& status indicators on ICT products

Barriers
Barriers

Cannot read visual 
Cannot read visual 

displays
displays

Cannot hear 
Cannot hear 
voice on telephone
voice on telephone

Cannot see visual   
Cannot see visual   

system status signals
system status signals

Cannot hear audio 
Cannot hear audio 

status signals
status signals

Cannot see
Cannot see

visual web 
visual web 

content
content

Mobile phones
Mobile phones
interfere with
interfere with
hearing aids
hearing aids

Provide second audio channel / track
Provide second audio channel / track
to narrate the visual component of
to narrate the visual component of
TV broadcasts / videos
TV broadcasts / videos

Design ICT products/services so
Design ICT products/services so
that they are compatible with
that they are compatible with
assistive technologies for blind
assistive technologies for blind
users such as text-to-speech
users such as text-to-speech
software
software

Cannot watch
Cannot watch
TV broad-
TV broad-
casts
casts

Online content 
Online content 
too difficult to
too difficult to
understand 
understand 
(e.g. complex
(e.g. complex
language)
language)

Design online services and other
Design online services and other
ICT-based products so that they 
ICT-based products so that they 
are understandable and usable by
are understandable and usable by
people with cognitive impartment 
people with cognitive impartment 
(e.g. simple/consistent menu structure,
(e.g. simple/consistent menu structure,
consistent use of icons , easy language) 
consistent use of icons , easy language) 

Interface / menu  
Interface / menu  
too complex  
too complex  
to use
to use

Design online services and other ICT-based
Design online services and other ICT-based
products to accommodate age related 
products to accommodate age related 
changes in information processing capabilities
changes in information processing capabilities
(e.g. lower reaction speed,  less fine  motor
(e.g. lower reaction speed,  less fine  motor
skills, reduced memory capacity)
skills, reduced memory capacity)

Cannot talk to voice-based 
Cannot talk to voice-based 
services & systems such as 
services & systems such as 
call centres & interactive 
call centres & interactive 
response services 
response services 

Provide alternative to speech input in  
Provide alternative to speech input in  
interactive voice systems
interactive voice systems

Interfaces 
Interfaces 
requiring too fine 
requiring too fine 
manipulation 
manipulation 
skills
skills

Provide audio & other output modes as alternative 
Provide audio & other output modes as alternative 
(e.g. vibrating) to audio signals 
(e.g. vibrating) to audio signals 

Provide text captions enabling deaf people
Provide text captions enabling deaf people
to follow the audio component of 
to follow the audio component of 
TV broadcasts / videos 
TV broadcasts / videos 

Provide text telephones & operator relay
Provide text telephones & operator relay
services enabling text phone users to 
services enabling text phone users to 
communicate with voice phone users
communicate with voice phone users

Cannot hear 
Cannot hear 
TV audio
TV audio

Public 
Public 
terminals       
terminals       

unreachable 
unreachable 

in wheelchair
in wheelchair

Design mobile phones to minimise 
Design mobile phones to minimise 
interferences with hearing aids 
interferences with hearing aids 

Design public telephones, ticket 
Design public telephones, ticket 
machines, information kiosks,
machines, information kiosks,
cash dispensers so that they are 
cash dispensers so that they are 
accessible to wheel chair drivers
accessible to wheel chair drivers

Design key pats, touch screens
Design key pats, touch screens
and other interfaces to cater for people 
and other interfaces to cater for people 
with dexterity problems (e.g. less sensitive, 
with dexterity problems (e.g. less sensitive, 
better spaced, larger  buttons)
better spaced, larger  buttons)

Design ICT products/services so that
Design ICT products/services so that
they are compatible with assistive 
they are compatible with assistive 
technologies for people with dexterity 
technologies for people with dexterity 
impairments (e.g. alternative  input devices)
impairments (e.g. alternative  input devices)

Provide text telephones & operator relay
Provide text telephones & operator relay
services enabling text phone users to communicate with 
services enabling text phone users to communicate with 
voice phone users
voice phone users

Cognitive impairments
Cognitive impairments

Speech impairments
Speech impairments

Physical &
Physical &
mobility impairments
mobility impairments

Figure 1 Barriers to e-accessibility and solutions 

1.2.  EU policy instruments 

In the early 90’s e-accessibility was addressed through the EU’s Framework programmes for 
research  and  technological  development.  Ten  years  later  e-accessibility  became  part  of  the 
broader research theme of e-inclusion, first through telematics for elderly people and people 
with  disabilities,  then  through  the  6th  and  7th  Framework  programmes.  Research  on  e-
accessibility was complemented by work on European standards. 

In the second half of the 90’s e-accessibility gradually became an integrated part of European 
policy  on  the  Information  Society.  The  policy  approach  had  several  aims,  including  to 
encourage cooperation of stakeholders (people with disabilities and other users, ICT industry 
and authorities), to provide political guidance and to benchmark progress.  

In particular a dedicated chapter on e-Accessibility was available in the eEurope initiative. 

5 

Based on Eurostat data.  

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At the same time, references to e-accessibility started to appear in EU legislation related to the 
ICT  sector,  notably  in  the  telecommunication  Directives  (currently  called  ‘electronic 
communications’  Directives),  and  the  radio  &  telecommunication  terminal  equipment 
directive  (R&TTE  Directive),  as  explained  in  section  2.  Non-ICT  sectoral  legislation  also 
incorporated explicit and implicit references to persons with disabilities and to e-accessibility, 
notably in the field of copyright, public procurement and structural funds regulations. General 
EU  legislation  on  equal  rights  explicitly  covers  disability  and  implicitly  rights  of  disabled 
people to use ICT, namely the Employment Equality Directive and most recently the proposal 
for  a  Council  Directive  on  “implementing  the  principle  of  equal  treatment  between  persons 
irrespective  of  religion  or  belief,  disability,  age  or  sexual  orientation”.  Details  on  this  EU 
legislation are provided in Section 2.1.2.  

For  e-accessibility  policy  in  general,  and  web  accessibility  policy  in  particular,  several 
instruments exist at EU level. This is further developed in section 2.1.2. 

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2.  E-ACCESSIBILITY 

2.1.  E-accessibility state of play 

This  chapter  provides  a  short  overview  of  the  current  state  of  provision  of  accessible  ICTs, 
followed  by  an  overview  of  current  non-legislative  and  legislative  measures  at  EU-level 
regarding e-accessibility. Then a short overview is given of legislative measures in Member 
States and third countries. Finally, an explanation is provided for the action proposed by the 
2008 Communication “Towards an Accessible Information Society”. 

2.1.1.  Provision of accessible ICTs — the e-accessibility deficit 
The  ‘MeAC’6  study  conducted  for  the  European  Commission  in  2006-2008  provides  an 
extensive  analysis  of  the  e-accessibility  situation  in  the  Member  States  and  in  some  third 
countries. One of the main findings is that people with disabilities in Europe continue to 
face  many  barriers  when  using  everyday  ICT  products  and  services  that  are  now 
essential aspects of social and economic life.  

This lack in e-accessibility can be found across the spectrum of ICT products and services, for 
example telephony, TV, web and self-service terminals. The  following striking examples of 
the  state  of  play  of  e-accessibility  (as  at  end  2007  unless  otherwise  indicated)  point  to  the 
barriers encountered by people with disabilities: 

Text relay services (essential for the deaf and speech impaired) are only available in half of 
the Member States and emergency services are directly accessible by text telephone in only 
seven Member States.  

Mobile operators in only seven Member States provide dedicated information for customers 
with disabilities on their websites. 

On average, less than one-third of national language broadcasts of main public broadcasters 
in  Europe  were  provided  with  subtitling  (for  deaf  people)  in  2006;  there  is  wide  variability 
(from 95% to none) in the amount of subtitling across individual countries. 

On  average,  less  than  one-tenth  of  national  language  broadcasts  of  main  commercial 
broadcasters in Europe were provided with subtitling in 2006; most of this is provided in just 
a few countries. 

Public broadcasters in only five Member States provided any of their programmes with audio 
description  (for  the  visually  impaired)  in  2006  and,  where  they  did,  the  levels  provided 
amounted to a very small percentage of their overall programming.  

Only  a  very  small  proportion  of  key  government  websites  in  the  Member  States  meet  the 
accepted  minimum  international  standards  on  accessibility  (12.5%  passed  automated  testing 
and only 5.3% passed both automatic and manual examination). 

The  share  of  key  commercial/sectoral  websites  (e.g.  railways,  TV,  newspapers,  retail 
banking)  providing  this  minimum  level  of  accessibility  is  even  lower  (only  3.9%  passed 
automated testing while not a single site passed both automatic and manual testing). 

Only in six Member States has one of the leading retail banks installed ATMs with ‘talking’ 
output  (enabling  self-service  for  customers  with  visual  impairments).  Across  countries,  on 
average  only  8%  of  all  ATMs  installed  by  the  main  retail  banks  in  the  EU  of  25  Member 
States provide this output, with the bulk of this provided in just a few countries.  

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http://ec.europa.eu/information_society/activities/einclusion/library/studies/meac_study/index_en.htm. 

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2.1.2.  Non legislative EU action on e-accessibility 

2.1.2.1.  Research support 

Sustained  R&D  in  e-accessibility  is  important,  as  ICTs  evolve  rapidly  and  as  new  e-
accessibility  challenges  appear.  An  example  is  digital  television,  whose  menus  are  hard  to 
navigate  for  people  with  dexterity  or  cognitive  impairments  or  persons  with  reading 
difficulties  (including  some  of  the  dyslexic,  illiterate  or  foreign  language  speakers  that  in 
several countries represent a significant portion of the population).  

Equally important, new technologies offer new opportunities to address participation barriers 
for persons with disabilities. A good example is direct brain-computer interaction by which a 
severely motor-disabled person (e.g. only able to blink an eye) is able to control devices ‘just’ 
by thinking.  

Related to e-accessibility research is the Ambient Assisted Living joint research programme, 
(AAL) launched in 2008 to stimulate innovative ICT-based solutions for independent living 
and  the  prevention  and  management  of  chronic  conditions  of  elderly  people  including  their 
related disabilities 7.  

For  several  years  the  approach  in  EU  R&D  has  been  that  accessibility  is  best  not  “patched 
onto” existing mainstream technology, but rather designed into mainstream technology from 
the  outset.  This  universal  design  or  design  for  all  approach  is  believed  to  deliver  a  double 
benefit:  firstly,  technology  that  nearly  anyone  can  use,  including  disabled  persons;  and 
secondly,  cheaper  e-accessibility.  Specific  research  on  assistive  technology  has  also  been 
undertaken.  Current  R&D  work  on  e-accessibility  therefore  seeks  to  embed  e-accessibility 
into  modern  mainstream  ICT  (e.g.  mobile  communications,  navigation  systems,  home 
systems, personal computers and web)8 as well as continued work on assistive technology. 

The  mainstreaming  approach  to  e-accessibility  also  enables  a  better  alignment  between 
research  and  e-accessibility  policy  in  general.  Notably,  research  should  deliver  technical 
specifications  that  can  provide  input  for  formal  or  informal  standardisation  and  thus  can 
become  reference  points  for  “soft”  or  “hard”  legislation.  For  example  current  audio-
description9  legislation  in  the  UK  is  based  on  research  work  undertaken  in  the  90’s  with 
European  funding  under  the  TIDE  programme10.  The  alignment  of  e-accessibility  research 
and other policy measures (deployment support, standardisation, legislative measures) is not 
always addressed in a systematic way. 

2.1.2.2.  Deployment / innovation support 

The  ICT  Policy  Support  Programme,  a  sub-programme  of  the  Competitiveness  and 
Innovation Programme (CIP ICT PSP)11 provides support for innovation and deployment in e-
accessibility.  It  can  fund  deployment  pilots  that  validate  technology  solutions  in  real-life 
settings  and  business  models  in  line  with  European  policy  goals,  as  well  as  fund  thematic 
networks for cooperation between stakeholders, exchanging best practice and benchmarking. 

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10 
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www.aal-europe.eu. 
An  overview  of  e-accessibility  EU  funded  R&D  projects  and  related  work  in  independent  living  of 
elderly which include a strong component of e-accessibility is available at: 
http://ec.europa.eu/information_society/activities/einclusion/research/index_en.htm. 
A  voice-over  of  television  programmes  that  describes  the  scenes  for  better  understanding  of  visually 
impaired persons. 
Telematics for the Integration of Disabled and Elderly people.  
www.ec.europa.eu/cip. 

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As  regards  e-accessibility,  the  CIP  is  potentially  a  very  important  instrument:  since  the  e-
accessibility market is fragmented, deployment validation can deliver the evidence needed for 
industry and authorities to accept e-accessibility solutions across the board.  

The  CIP  work  programmes  for  2007  and  2008  finance  pilot  schemes  on  e-accessibility  and 
ICT for ageing.  

2.1.2.3.  Standardisation: Mandate 376 

Standards are important to coordinate e-accessibility efforts across Europe. They are needed 
both  in  general  to  ensure  a  common  understanding  and  application  of  e-accessibility 
principles,  and  more  specifically  to  provide  a  yardstick  against  which  e-accessibility  can  be 
assessed.  
In  2005  the  Commission  issued  a  mandate12  to  the  European  Standardisation  Organisations 
(ESOs)  to  develop  common  requirements  for  ICT  in  the  field  of  public  procurement, 
including conformance assessment mechanisms. The ESOs have the duty to establish efficient 
coordination mechanisms and to work in close cooperation with relevant stakeholders. 

The main objectives of this mandate are to harmonise the accessibility requirements of public 
procurement of accessible ICT products and services, to identify a set of functional European 
requirements and to deliver European standards for e-accessibility. Mandate 376 will provide 
an electronic toolkit, enabling public procurers to make use of these harmonised requirements. 

2.1.2.4.  Measurement and benchmarking 

An  extensive  survey  of  the  implementation  of  e-accessibility  provisions  in  the  electronic 
communications  Regulatory  Framework  was  undertaken  in  2006  by  INCOM,  the  Inclusive 
Communication subgroup under the Communications Committee (COCOM).13 A significant 
lack  of  progress  in  implementing  these  e-accessibility  provisions  was  reported,  with  a  clear 
indication  that  this  was  due  to  their  non-mandatory  character.  This  has  motivated  the 
Commission to propose a reinforcement of the provisions in the context of the revision of the 
Directives. 

The  MeAC  study  (referred  to  in  the  introduction)  delivered  a  major  report  in  2007  which 
constitutes a primary reference on the current availability of accessible ICT and the extent and 
effectiveness of policies across Europe and third countries, including the USA. 

The results of the study contributed to the ‘Riga Dashboard’, which measures progress on the 
targets for 2010 in digital inclusion agreed at the Riga Ministerial Conference on e-Inclusion 
in 2006. The first edition of this dashboard was published at the end of 2007 together with the 
Communication on e-Inclusion.14 

2.1.2.5.  Awareness and promotion 
Exchange of best practices is supported through the ePractice portal15. In order to enhance the 
visibility and recognition of good practices, the Commission launched in 2008 an e-Inclusion 

12 
13 

14 
15 

http://ec.europa.eu/information_society/policy/accessibility/deploy/pubproc/eso-m376/index_en.htm. 
COCOM is the regulatory committee following the implementation of the electronic communication 
directives. INCOM 2006 report is available at: 
http://ec.europa.eu/information_society/activities/einclusion/groups/index_en.htm. 
http://ec.europa.eu/information_society/activities/einclusion/policy/i2010_initiative/index_en.htm. 
http://www.epractice.eu. 

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Award scheme16 in which e-accessibility is one of the 7 categories. The MeAC study created 
a website providing country reports, benchmarking results and other relevant information.17  

Industry,  non-profit  organisations  and  authorities  regularly  organise  e-accessibility  events. 
The  European  Commission  also  organises  events  on  e-inclusion,  including  e-accessibility 
aspects, such as the ministerial conference on e-inclusion, in Vienna, from 30 November — 2 
December 2008.18 

2.1.2.6.  Cooperation and coordination 

Several groups collate information and draft policy papers in the field of e-accessibility:  

–  INCOM  addresses  the  state  of  play  of  implementing  e-accessibility  provisions  in  the 

electronic communications framework, as previously explained. 

–  A sub-group under TCAM19 focused on real-time text, which is essential for hearing and 
speech-impaired  users  to  communicate  via  telephone  and  reach  among  others  emergency 
services.  No  solution  could  be  agreed  upon  although  the  discussions  did  lead  to  the 
Commission  proposing  a  pilot  scheme  under  the  ICT-PSP  work  programme  on  total 
conversation / accessible emergency services. 

–  The e-inclusion subgroup of the i2010 high-level group20 held in-depth discussions on e-
accessibility  and  specific  working  sessions  on  web-accessibility.  Participants  in  this 
subgroup are representatives from Ministries most concerned with e-inclusion in general.  

–  The High level Group on disability that supports the Commission in the implementation of 
the  European  Disability  Action  Plan21  that  covers,  amongst  other  ICT,  links  with 
disability policy in general.  

–  User-industry  cooperation,  notably  on  accessible  digital  television  involved  amongst 
others  EDF,  AGE  and  EICTA22.  An  example  was  the  e-Inclusion  Partnership23,  an 
informal gathering of user organisations and ICT industry organised by the Commission. 

Despite the above mentioned activities, systematic coordination and cooperation at European 
level  that  brings  together  all  stakeholders  and that  addresses  e-accessibility  in  a  prospective 
rather than retrospective way is still lacking.  

2.1.3.  Legislative approaches  

2.1.3.1.  EU level  

There  is  no  specific  EU  legislation  on  e-accessibility.  Nevertheless,  there  is  sectoral 
legislation  that,  whilst  e-accessibility  is  not  the  principal  aim,  does  explicitly  or  implicitly 
include some e-accessibility-related provisions. However, coverage is limited as some sectors 
are  not  (clearly)  covered  by  EU  legislation:  websites,  mobile  telephony  services,  TV 
equipment,  computer  hardware  and  software,  consumer  electronics,  assistive  technologies. 
Relevant sectoral EU legislation includes:  

16 
17 
18 
19 
20 
21 
22 

23 

http://ec.europa.eu/information_society/newsroom/cf/itemdetail.cfm?item_id=4387. 
http://www.eaccessibility-progress.eu/project. 
http://ec.europa.eu/information_society/events/e-inclusion/2008/index_en.htm. 
TCAM is the group created under the terminal equipment Directive (1999/5/EC). 
http://ec.europa.eu/information_society/eeurope/i2010/high_level_group/index_en.htm. 
http://eur-lex.europa.eu/LexUriServ/LexUriServ.do?uri=COM:2007:0738:FIN:EN:PDF. 
European  Disability  Forum  (EDF),  the  European  Older  People’s  Platform  (AGE)  and  the  European 
digital technology industry Association (EICTA). 
http://ec.europa.eu/information_society/activities/einclusion/events/partnership_1206/index_en.htm. 

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Electronic Communications Regulatory Framework 

The  Framework  Directive24  on  electronic  communication  requires  national  regulatory 
authorities to promote equal choice, price and quality, and access to universal service for all 
users,  including  disabled  users.  The  Universal  Service  Directive25  addresses  a  number  of 
issues  relevant  to  e-accessibility  of  fixed  telephony  services,  such  as  specific  measures  to 
ensure  access  and  affordability  for  all,  where  appropriate;  access  to  operator  and  directory 
services;  access  to  emergency  calls;  availability/access  to  public  payphones  and  special 
tariffs.  

These  provisions  are  limited  in  two  regards:  they  only  cover  fixed  telephony  services  (not 
mobile telephony or telephone equipment) and they are not compulsory. In practice, Member 
States have made limited use of these provisions.  

In  the  context  of  the  current  revision  of  the  EU  Electronic  Communications  Directives,  the 
Commission has proposed strengthening existing provisions (see section 2.2.4). 

Terminal equipment covered by the R&TTE Directive26  

Article 3.3.f of the Directive entitles the Commission to propose an EC Decision establishing 
that some equipment should support certain features to facilitate use by users with a disability. 
So far, this option has not been used. This Directive is currently being reviewed.  

Broadcast TV covered by the Audiovisual Media Services Directive27  

Article  3.c  of  the  Audiovisual  Media  Services  Directive  states  that  Member  States  shall 
encourage  media  service  providers  to  ensure  that  audio-visual  media  services  are  gradually 
made accessible to people with a visual or hearing disability. The Commission follows up on 
this provision with Member States and encourages its implementation.  

Digital content covered by the copyright Directive28 

Article  5.3.b.  of  the  copyright  Directive  allows  Member  States  to  make  exceptions  to 
copyright rules and protections to facilitate access for disabled people. A recently published 
Green Paper29 shows that, although Member States seem to have implemented the exceptions 
to  some  extent,  there  is  considerable  variation  across  countries  in  the  disabilities  that  are 
covered and requirements for some form of compensation to those holding the rights to use 
the works subject to the exception.  

24 
25 
26 
27 
28 
29 

Directive 2002/21/EC. 
Directive 2002/22/EC. 
Directive 1999/5/EC. 
Directive 2007/65/EC. 
Directive 2001/29/EC. 
COM(2008) 466 final. 

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Goods and services covered by the Public Procurement Directive30 

The  EU  Public  Procurement  Directives  of  2004  include  provisions  that  encourage 
accessibility  and  design-for-all  requirements  to  be  included  in  public  procurement.  Practice 
shows that there is very little inclusion of accessibility requirements in public procurements of 
ICTs in Europe to date.  

The Commission issued a mandate to the European Standardisation Organisations (see section 
2.1.2.3)  to  draft  standards  and  a  toolkit  to  help  public  procurers  (and  suppliers)  in  Europe 
address e-accessibility requirements. 

Equality legislation31 

Article  5  of  the  Employment  Equality  Directive  requires  employers  to  take  reasonable 
measures to ensure equality of access to employment for people with disabilities, unless such 
measures impose a disproportionate burden on the employer. Accessibility to ICT is indirectly 
concerned as an adaptation to equipment ensuring access to employment.  

In  addition,  the  Commission  has  recently  adopted  a  proposal  for  a  horizontal  Directive  on 
equal  treatment  among  others  on  access  to  and  supply  of  goods  and  services,  also  covering 
(even if not mentioned explicitly) ICT goods and services.32 Article 4 of this proposal for a 
Directive deals with effective and non discriminatory access for persons with disabilities and 
it  is  an  important  aspect  of  the  EU’s  work  towards  implementation  of  the  United  Nations 
Convention on persons with disabilities33.  

Other legislation  

Other pieces of EU legislation contain provisions on ICT and people with disabilities, such as 
legislation on value added tax and state aid exemptions.34  

2.1.3.2.  Member State and third country legislation 

The  previously  mentioned  study  carried  out  in  2008  on  accessibility  of  ICT  products  and 
services  for  disabled  and  elderly  people  provides  a  comprehensive  view  of  the  legislative 
landscape across the Member States, and in some third countries. 

Sectors covered by legislation  

The  pattern  of  sectoral  coverage  of  e-accessibility  legislation  across  the  Member  States 
closely mirrors that at EU level, with by far the most commonly covered sectors being fixed 
telephony  services,  TV  broadcasting  and  public  websites.  All  other  sectors  (e.g.  private 
websites  and  mobile  telephony)  have  only  sparse  coverage,  with  just  a  few  examples  of 
legislation addressing these sectors in some Member States.  Looking at third countries, it is 
noteworthy that both Australia and the United States, and particularly the latter, have a much 
wider sectoral coverage than most EU Member States.  

Almost all Member States have implemented the revised EU public procurement directives, 
the employment equality directive and the digital copyright directive.  

30 
31 
32 
33 
34 

Directive 2004/18/EC. 
Directive 2000/78/EC. 
COM (2008) 426. 
http://www.un.org/disabilities/convention/conventionfull.shtml. 
Commission Regulation 800/2008 and COM(2008) 428. 

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Apart from this, in the absence of any EU legislation to date, a number of Member States have 
implemented anti-discrimination legislation in the field of goods and services, which address 
the accessibility of at least some commercial websites.  

More generally, almost all Member States have some assistive technology legislation and / or 
public  service  provision  in  place  to  help  people  with  disabilities  acquire  assistive 
technologies.  

Horizontal or non-sector-specific legislation 

Apart  from  legislation  regulating  specific  ICT  sectors,  there  are  also  examples  of  cross-
sectoral and/or non-sector-specific approaches in some Member States, covering a number of 
ICT  sectors  within  a  single  e-accessibility  policy  framework  or  measure.  However,  such 
approaches are not widespread amongst Member States. At EU-level, there is no such cross-
sectoral measure in place.  

There  are  two  different  types  of  cross-cutting  legislative  approaches  in  Member  States  and 
third  countries,  namely  laws  that  make  specific  reference  to  ICTs  in  general  and/or  e-
accessibility in particular and laws on broader disability (equality) themes, with an implicit e-
accessibility component. 

E-accessibility an explicit focus 

Non-sectoral legislation that explicitly addresses e-accessibility issues can be found in some 
European countries, sometimes inspired by EU regulation such as the ‘employment equality’ 
Directive.35  Several  countries  have  introduced  equality  or  other  legislation  that  explicitly 
addresses  e-accessibility  issues  in  a  more  cross-cutting  manner.  According  to  the  different 
jurisdictions within which such legislation has been enacted, they vary in terms of scope and 
other legal characteristics. No uniform approach is apparent, and the various approaches each 
have their strengths and weaknesses. Aspects of various approaches might serve as models of 
good practice, but no single approach yet appears to provide a comprehensive and effective 
horizontal approach.  
In the USA the ‘Section 508’ of the Rehabilitation Act is a key reference point.36 

Implicit coverage of e-accessibility 

Although  equality  legislation  may  not  necessarily  make  explicit  reference  to  ICTs,  it  may 
nevertheless  have  an  impact  on  e-accessibility.  Examples  are  legislation  encouraging 
accessibility  in  general,  and  legislation  providing  for  active  involvement  of  NGOs  in 
oversight and enforcement mechanisms. In the USA the prime example of such legislation is 
the Americans with Disabilities Act. 

2.2.  Further  action  towards  a  coherent  and  effective  approach  for  e-

accessibility  

E-accessibility  has  become  a  high  priority  on  the  EU  policy  agenda,  with  recognition  of  its 
importance not only to achieve the social objectives of the Union but also its competitiveness 
and  internal  market  objectives.  However,  the  impact  assessment  accompanying  the  e-
inclusion  Communication  of  200737  concluded  that  the  field  of  e-accessibility  was 
inadequately addressed across Europe in terms of efficiency and effectiveness, coherence and 

35 
36 
37 

Directive 2000/78/EC of 27 November 2000. 
http://www.section508.gov. 
COM(2007)694. 

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completeness  of  existing  measures  and  the  degree  to  which  existing  measures  are  future-
proof.  There  is  no  reason  to  assume  that  this  situation  has  drastically  improved  since  2007. 
Reinforcement of a general approach to e-accessibility would therefore still have to aim for 
further improvement in these criteria. 

The range of policy measures, illustrating the need for coherence and for cooperation and 
coordination is shown in the diagram below. 

General policy approach to e-accessibility
Overview of instruments

Policy guidance
- Communications
- Declarations
- Resolutions

R&D
-Framework 
Programme
-AAL 169

Legislation
- e-communications
- R&TTE
- public procurement
- anti-discrimination

Cooperation
- i2010, disability policy groups
- Legal, standards committees
- Industry & users dialogues

Deployment
-CIP ICT PSP
-Structural funds

Standardi-
sation
-ESOs. M376
- W3C, industry

Awareness

-Best practice
-Benchmarking
-Events

Figure 2 General approach to e-accessibility — overview of policy instruments 

A coherent and timely policy approach is proposed by the 2008 Communication “Towards an 
Accessible  Information  Society”.  Coherence  is  needed  because  of  the  multi-sectoral  and 
multi-dimensional range of issues to be addressed, as traditional boundaries blur, new themes 
emerge and technologies and markets change over time. A timely response is needed because 
ICT-based products and services continue to present major barriers to participation for large 
numbers of Europeans. In addition, the trend in fragmentation in the regulatory requirements 
being  introduced  across  Member  States  may  soon  pose  significant  threats  to  the  smooth 
functioning of the internal market.  

An overall coherent e-accessibility approach would be desirable to address all such aspects. 
This  is  also  strongly  supported  by  the  public  consultation  on  e-accessibility  and  web 
accessibility.  The  approach  consists  of  a  mix  of  sector-specific  measures  and  general  e-
accessibility measures. Background to these measures is provided in the remaining sections of 
this chapter and in chapter 3 on web accessibility.  

2.2.1. 

Increasing coherence and timely action by cooperation and coordination 

To ensure coherent and effective management and coordination of both web accessibility and 
e-accessibility issues, existing support for co-operation with and between stakeholders should 
be stepped up. 

•  A  dedicated  ad–hoc  high  level  e-accessibility  group  is  proposed  in  the  Communication. 
This would provide guidance for a coherent approach to e-accessibility at European level, 

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and define priority action to improve e-accessibility. Representatives of key actors would 
collate  work  on  existing  priorities  so  that  there  is  coherence  between  the  necessary 
components  (research  and  innovation,  standardisation,  legislation  etc).  Priority  areas  of 
work based on the public consultation and ongoing work are web accessibility, accessible 
digital  TV,  total  conversation/accessible  emergency  services.  PCs  and  self-service 
terminals are other priorities. This e-accessibility group will be reporting to the i2010 High 
Level  Group,  and  financed  through  the  budget  foreseen  for  this  in  the  CIP  ICT  PSP 
programme. Budget only concerns a few meetings per year for about 20 experts.  

•  This group could receive input from and provide guidance to existing relevant groups, i.e. 
i2010 e-inclusion subgroup, mandate 376, INCOM, TCAM, and the Disability High level 
group.  

•  As  the  measures  proposed  are  not  mandatory,  there  is  a  strong  appeal  for  users  and 

industry to take efforts to step up cooperation. 

•  Moreover,  continued  monitoring  of  both  web  accessibility  and  general  e-accessibility 
progress and implementation mechanisms is necessary. Studies in 2009 are due to produce 
e-accessibility implementation reports as well as further details on costs and benefits of e-
accessibility. 

•  Under  the  2009  CIP-ICT  Policy  support  programme,  a  new  thematic  network  on  e-
accessibility  and  web  accessibility,  as  proposed  by  the  Communication,  will  further 
enhance  and  support  stakeholder  cooperation  and  the  collation  of  experience  and  good 
practices.  

•  There  is  clearly  a  lack  of  awareness  of  possibilities  and  user  needs.  The  2008  public 
consultation  indicated  strong  support  for  information  measures  and  exchanging  best 
practice. The ePractice good practice exchange network on e-government, e-health and e-
Inclusion, has already amassed much expertise on e-accessibility. Further support for this 
portal is proposed.  

2.2.2.  Supporting innovation and deployment  

The  Commission  proposes  to  actively  continue  supporting  e-accessibility  and  ICT  for 
independent living of elderly and disabled people through the EU research programme with a 
further call for proposals in 2009.  

In addition to the CIP pilot schemes on accessible digital TV, which began started in 2008, 
and  on  total  conversation/accessible  ‘112’  emergency  call  (expected  to  start  in  2009),  the 
Commission proposes for 2009 that the CIP continues to support e-accessibility and ICT for 
ageing  well  (notably  as  mentioned  before,  through  a  network  to  exchange  best  practice, 
cooperate and measure e-accessibility and web accessibility). With the proposed schemes the 
mainstreaming  approach  to  research  and  innovation  will  continue  to  be  the  red  line  of  a 
common European approach.  
The  Structural  Funds’  Regulation38  requires  that  "accessibility  for  disabled  persons  shall  be 
one of the criteria to be observed in defining operations co-financed by the Funds and to be 
taken into account during the various stages of implementation" (Article 16).  

38 

Council  Regulation  (EC)  No  1083/2006  of  11  July  2006  laying  down  general  provisions  on  the 
European Regional Development Fund, the European Social Fund and the Cohesion Fund and repealing 
Regulation (EC) No 1260/1999 

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2.2.3.  Facilitating standardisation activities  

More  than  90%  of  respondents  to  the  public  consultation  considered  standardisation  and 
technical specifications a high or relevant priority for future EU action on e-accessibility. 

Internationally, in  particular, standards cooperation can be further pursued, notably with the 
US, in the context of the review of ‘Section 508’ of the US Rehabilitation Act (dealing with 
ICT) and the EU’s work on Mandate 376.  

2.2.4.  Legislation  

The  ‘MEAC’  study  shows  a  clear  correlation  at  national  level  between  the  existence  of 
legislation and the current level of progress on e-accessibility.39 Studies also point to the risks 
of  legal  fragmentation  in  the  EU  due  to  different  legislative  measures.  Based  on  this,  and 
building on the 2005 Communication on e-accessibility and the 2007 Communication on e-
Inclusion, the Commission has explored a more general legislative approach to e-accessibility.  

However,  given  the  vast,  complex  and  evolving  nature  of  e-accessibility,  there  is  not  yet  a 
clear  consensus  on  EU  legislation  specifically  targeting  e-accessibility.  In  the  public 
consultation, 90% of user organisations considered binding legislation a high priority, versus 
only 33% of industry and public authorities.  

There are also many open questions on the aspects of EU legislation on e-accessibility such as 
its scope, standards, compliance mechanisms, links to existing legislation, mix of bottom-up 
and  top-down  approach40,  mix  of  sectoral  and  general  legislative  action.  A  particularly 
relevant development is the recent proposal for a directive on equal treatment. Furthermore, 
although there is a clear consensus on the need to act jointly to improve e-accessibility, there 
are different views on the next priorities to tackle.  

The  2008  Communication  “Towards  an  Accessible  Information  Society”  emphasises  the 
various options under current EU legislation that remain under-used. In addition it stresses the 
need  to  explore  the  options  for  improving  e-accessibility  through  several  pieces  of  EU 
legislation that are, or will be soon, under review, or have recently been proposed, notably: 

•  Directive 1999/5/EC on terminal equipment is under review: here the issue is whether to 

activate Article 3.3.f for adopting specific accessibility provisions.  

•  The Commission recently tabled a proposal for a directive on equal treatment, which refers 
to access to and supply of goods and services which are available to the public and whose 
Article 4 guarantees compliance of the principle of equal treatment in relation to persons 
with disabilities. The final adoption of this Directive will contribute to the implementation 
of  some  provisions  of  the  United  Nation  Convention  on  the  rights  of  persons  with 
disabilities.  

•  Legislative proposals for electronic communications include provisions on disabled users 
in  relation  to:  setting  binding  national  commitments,  emergency  services,  conditions  to 
authorise  service  provision  and  representation  of  user  interests  in  bodies  responsible  for 
implementation of legislation. These proposals are now in the process of adoption by the 
Council and European Parliament. 

39 

40 

See the MeAC study and the study on accessibility to ICT products and services by disabled and elderly 
people. 
Top  down  legislation  imposes  positive  e-accessibility  obligations,  while  bottom  up  legislation  give 
rights of redress/complaints on accessibility grounds. 

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3.  WEB ACCESSIBILITY 

3.1.1.  Relevance and state of play 

a) Relevance of web accessibility  

Web  accessibility  gives  people  with  disabilities  the  opportunity  to  perceive,  understand, 
navigate,  interact  and  contribute  to  the  Web.  The  lack  of  web  accessibility  affects  many 
people:  people  with  disabilities;  elderly  people;  people  with  dyslexia,  low  literacy  or  not 
fluent in the language; people with low-bandwidth connections, older technologies or devices 
with limited display or interaction capabilities and new web users. When web accessibility is 
implemented  it  also  benefits  people  whose  abilities  change  as  they  age.  These  persons  can 
only make use of websites if they are properly designed and if they meet their specific needs 
(see Figure 3).  

Web accessibility has become particularly important because of the explosive growth in on-
line  information  and  interactive  services  provided  on  the  web,  from  online  banking  and 
shopping,  dealing  with  government  and  public  services  to  communicating  with  distant 
relatives.  If  web  accessibility  is  not  achieved,  many  people  are  at  risk  of  being  partially  or 
totally excluded from the information society. 

Visual impairments
Visual impairments

Solutions
Solutions

Hearing impairments
Hearing impairments

Use flexible layouts that can be adapted by users to viewing needs 
Use flexible layouts that can be adapted by users to viewing needs 
(e.g. size, formatting, colour and background colour of text)
(e.g. size, formatting, colour and background colour of text)

Provide volume control when using sounds, background music, 
Provide volume control when using sounds, background music, 
videos with sound etc.
videos with sound etc.

Provide textual descriptions of images, graphs and animations (so-
Provide textual descriptions of images, graphs and animations (so-
called “alt” text) that can be read by screen reader software
called “alt” text) that can be read by screen reader software

Provide sign-language alternatives of all textual content for users that 
Provide sign-language alternatives of all textual content for users that 
only speak sign-language, e.g. signing videos or animations
only speak sign-language, e.g. signing videos or animations

Provide audio description of the visual part 
Provide audio description of the visual part 
of multimedia content such as videos
of multimedia content such as videos

Barriers
Barriers

Layout not adaptable to    
Layout not adaptable to    

Cannot hear sound 
Cannot hear sound 

Provide text alternatives of all relevant audio, 
Provide text alternatives of all relevant audio, 
e.g. sub-titles / captioning for videos
e.g. sub-titles / captioning for videos

Provide content in a way that it can 
Provide content in a way that it can 
be read by screen reader software, 
be read by screen reader software, 
e.g. by using valid HTML code
e.g. by using valid HTML code

Cognitive 
Cognitive 
impairments
impairments

users viewing needs (e.g. 
users viewing needs (e.g. 

font-size, contrast)
font-size, contrast)

Cannot see visual 
Cannot see visual 

content (images / 
content (images / 

multimedia)
multimedia)

Structure large amounts of texts, 
Structure large amounts of texts, 
e.g. by using headings and sub-
e.g. by using headings and sub-
headings or by breaking down 
headings or by breaking down 
into several pages 
into several pages 

Difficult to 
Difficult to 
understand large 
understand large 
amounts of   
amounts of   
unstructured text
unstructured text

Use images, icons or graphs in 
Use images, icons or graphs in 
a sensible manner to illustrate 
a sensible manner to illustrate 
textual content
textual content

Confused 
Confused 

by animations, 
by animations, 
sounds etc.
sounds etc.

Avoid confusing, fast moving, 
Avoid confusing, fast moving, 
flashing animations and 
flashing animations and 
unexpected, loud, 
unexpected, loud, 
out-of-context sounds
out-of-context sounds

Confused by unintuitive / 
Confused by unintuitive / 
badly structured menus
badly structured menus

Confused by complicated 
Confused by complicated 

language, jargon
language, jargon

Low literacy
Low literacy

Provide easy, clearly structured menus, using 
Provide easy, clearly structured menus, using 
labels that are familiar to users
labels that are familiar to users

Viewing needs require 
Viewing needs require 

adaptation of layout 
adaptation of layout 
(small display)
(small display)

at all or at usual 
at all or at usual 

volume
volume

Avoid user alerts that are only based on 
Avoid user alerts that are only based on 
sound and provide a visual alternative
sound and provide a visual alternative

Cannot  read textual 
Cannot  read textual 
content due to illiteracy 
content due to illiteracy 
(some deaf)
(some deaf)

Dexterity 
Dexterity 
impairments
impairments

Difficulties hitting   
Difficulties hitting   
small elements on 
small elements on 
the screen with 
the screen with 
mouse
mouse

Provide elements (like buttons, 
Provide elements (like buttons, 
menu items, form fields)  of 
menu items, form fields)  of 
sufficient size and with sufficient 
sufficient size and with sufficient 
margin to adjacent elements
margin to adjacent elements

Cannot use   
Cannot use   

keyboard instead 
keyboard instead 

of mouse
of mouse

Alternatively, use flexible layouts 
Alternatively, use flexible layouts 
that allow users to control the size 
that allow users to control the size 
and formatting of those elements
and formatting of those elements

Unable to response
Unable to response

in given time limit
in given time limit

Provide full support for keyboard-only 
Provide full support for keyboard-only 
users, e.g. by defining keyboard 
users, e.g. by defining keyboard 
shortcuts
shortcuts

Long loading times 
Long loading times 
due to large 
due to large 

amounts of data
amounts of data

Avoid response mechanisms (like 
Avoid response mechanisms (like 
pressing a button) that impose time 
pressing a button) that impose time 
limits or ensure that time limits 
limits or ensure that time limits 
are not too restricted
are not too restricted

Slow connections, small displays etc.
Slow connections, small displays etc.

Use flexible layouts that can be adapted by users to viewing needs
Use flexible layouts that can be adapted by users to viewing needs

Avoid unnecessarily complicated language and jargon, provide 
Avoid unnecessarily complicated language and jargon, provide 
alternative easier descriptions and explanations of jargon or 
alternative easier descriptions and explanations of jargon or 
abbreviations
abbreviations

Make reasonable efforts to ensure that a website remains 
Make reasonable efforts to ensure that a website remains 
usable when the transmission of images and multimedia content 
usable when the transmission of images and multimedia content 
has been turned off by the user in order to save bandwidth
has been turned off by the user in order to save bandwidth

Figure 3: Some web-related e-accessibility challenges and solutions 

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b) EU policy measures  

The  importance  of  web  accessibility  has  been  recognised  for  many  years  by  the  European 
Institutions and Member States: 

– 

– 

– 

– 

– 

In 2001 the Commission adopted a Communication on web accessibility, encouraging 
Member States to endorse the Web Accessibility Initiative Guidelines41.  
In  two  Resolutions  adopted  in  2002  and  200342,  the  Council  stressed  the  need  to 
increase efforts to speed accessibility to the web and its content.  

The European Parliament suggested in 2002 that all public websites be fully accessible 
to disabled persons by 2003, the European Year of Disabled Persons43.  
In 2005, the Commission Communication on e-accessibility44 again drew attention to 
the importance  of EU-level policies  in  this field and  the  Ministerial  Declaration  on 
eInclusion  at  Riga  in  2006  set  as  one  of  its  priorities  the  promotion  of  inclusive 
eGovernment  by  ensuring  accessibility  of  all  public  websites  by  2010.  However 
despite  increasing  awareness  of  authorities  and  other  schemes,  progress  on  web 
accessibility remains unsatisfactory. It was already clear at the end of 2007 that this 
objective would not be met, as only around 5% of public websites and only 3% of 
commercial websites across the EU were sufficiently accessible.  
The Communication on e-Inclusion in 200745 called upon Member States to agree by 
mid 2008 on a roadmap for accessibility of public websites.  

c) Websites accessibility in Member States  

When  the  MeAC  study  tested  a  sample  of  key  public  and  sectoral/commercial  websites  in 
each Member State, only a very small percentage were found to meet accepted international 
accessibility standards.  

– 

– 

– 

12.5%  and  5.3%  of  government  websites  were  accessible  for  automated  and  manual 
testing respectively46.  

For  sectoral/commercial  websites,  just  3.9%  passed  the  automated  test  and  none 

passed the manual test.  

These  results  mean  that  only  a  small  proportion  of  key  public  websites  (national 
governments,  national  parliament,  and  key  ministries  such  as  social,  employment, 
health and education) meet the accessibility standards and the situation is even worse 
for key sectoral/commercial websites (e.g. railways, TC, newspapers, retail banking). 
In a few countries, the majority of the public websites tested met the standards, but in 
many none of them did. 

Across the Member States the most common instruments used to promote and improve web 
accessibility  are  detailed  technical  guidance,  support  training  schemes,  monitoring  and 

41 
42 
43 
44 
45 
46 

COM (2001)529. 
2002/C 8602 and 2003/C 39/03. 
C5-0074/2002-2002/2032(COS). 
COM2005(425). 
COM (2007) 694 final. 
The  automated  test  uses  a  software  tool  Test  Accessibilidad  Web  (TAW)  of  the  Spanish  Fondacion 
CTIC  (http://www.tawdis.net/taw3/cms/en).  Sites  that  passed  Level  A  from  this  automated  test  were 
then subjected to a human (manual) assessment by web-accessibility experts. 

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assessment  of  websites,  various  awareness  campaigns,  coordination  with  relevant 
stakeholders and research activities both at national and European level. 

The public consultation showed that the majority of the respondents indicated that the above 
mentioned  actions  would  contribute  to  a  high  level  of  availability  of  accessible  web  sites. 
(83.4% generally agreed, whilst 38.5% strongly agreed and only 4.9% disagreed). About one 
in  ten  respondents  (11.8%)  had  no  opinion.  Also,  a  clear  majority  of  respondents  perceived 
the  need  to  encourage  intranet  websites  to  be  accessible.  In  addition,  94.3%  of  respondents 
agreed  with  the  statement  that  Member  States  should  seek  alignment  with  international 
standards.  

3.2.  Web accessibility activities  

3.2.1.  Non legislative activities supporting web accessibility 

a) Research support 

An example of EU R&D input to technology developments is the link between the W3C Web 
Accessibility  and  Ageing  Task  Forces47,  supported  for  data  collection  and  dissemination  by 
the  WAI-Age  project48  funded  under  the  6th  Framework  Programme.  This  action  aims  at 
better  understanding  the  needs  of  the  ageing  community  in  the  context  of  existing  web 
accessibility  guidelines.  To  this  end,  it  provides  a  contribution  from  the  ageing  community 
into  the  work  of  the  W3C  in  revising  and  complementing  educational  materials  to  better 
reflect  the  needs  of  the  elderly  and  to  pursue  standards  coordination  in  order  to  promote 
adoption and implementation of a common set of guidelines.  
A cluster of research projects funded under the 6th Framework Programme also investigated 
the harmonisation of web accessibility measurement, resulting in an assessment methodology 
(UWEM)49,  a  CEN  Workshop  Agreement  on  Specifications  for  a  Web  Accessibility 
Conformity Assessment Scheme and a Web Accessibility Quality Mark50. 

b) Deployment / innovation support 

In  relation  to  deployment  and  innovation  support,  support  can  also  come  from  the  CIP 
programme. However, in the first two years of this programme (2007-2008), web accessibility 
was not singled out for funding. 

c) Web accessibility standardisation  

As  regards  web  content,  the  current  de  facto  standard  is  version  1  of  the  Web  Content 
Accessibility  Guidelines (WCAG 1.0)  from  W3C,  although  this is not a European standard. 
W3C has been working on version 2 of the guidelines (WCAG 2.0) for several years and is 
about to officially adopt it. These guidelines are the result of a long process involving many 

47 

48 
49 

World  Wide  Web  Consortium:  A  vendor-neutral  forum  for  the  creation  of  de-facto  standards  for  the 
web. www.w3.org/WAI/EO/2008/wai-age-tf.html. 
www.w3.org/WAI/WAI-AGE. 
Uniform Web-accessibility Evaluation Methodology (http://www.wabcluster.org/uwem), to be used 
both when reviewing a web site, attributing quality marks or implementing an automatic surveillance 
observatory. Specifications for statistical indicators: 
http://www.eiao.net/publications/Indicator_refinement_FINAL_v1.31.pdf. 
CEN workshop agreement: 

50 
ftp://ftp.cenorm.be/PUBLIC/CWAs/e-Europe/WAC/CWA15554-00-2006-Jun.pdf. 

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specialised  bodies  and,  when  adopted,  it  will  become  the  international  reference  for  web 
accessibility.  

W3C  has  developed  three  sets  of  guidelines  to  ensure  web  accessibility:  Web  content 
accessibility guidelines (WCAG), authoring tools accessibility guidelines (ATAG), and User 
agents’ accessibility guidelines (UAAG)51, addressing website owners, providers of authoring 
tools  and  providers  of  user  agents  (web  browsers  and  related  assistive  technologies) 
respectively.  

At  European  level,  work  continues  on  the  Mandate  376,  which  closely  follows  the  work  of 
W3C/WAI.  

Strong  support  was  given  for  the  coordination  of  web  accessibility  efforts  across  Europe  in 
the public consultation. 

Many Member States have developed national standards or regulations based on these W3C 
WAI guidelines. 

d) Measurement and coordination 

Both  at  national  and  European  levels  substantial  measurement  and  benchmarking  are  being 
carried out. One of the most recent is the MeAC study, which reported at the end of 2007 the 
finding of a severe lack of web accessibility, as mentioned above.52  

e) Awareness and promotion 

In  the  specific  field  of  web  accessibility,  the  Commission  supports  the  Web  Accessibility 
Benchmarking  (WAB)  Cluster  of  projects.53  The  cluster  is  developing  an  EU-harmonised 
assessment methodology for Web accessibility, based on W3C/WAI and to be synchronised 
with the planned migration from WCAG1.0 to WCAG2.0. This should ensure that evaluation 
tools  and  methods  developed  for  global  monitoring  or  for  local  evaluation  are  mutually 
compatible and coherent (and with WAI).  

Awareness  and  promotion  campaigns  are  carried  out  in  many  countries.  At  European  level, 
awareness  and  promotion  campaigns  were  launched  at  Ministerial  conferences  and  related 
exhibitions (Riga 2006, Lisbon 2007 and Vienna 2008), and the 2008 e-Inclusion Award in 
which e-accessibility, including web accessibility, is one of 7 best practice award categories. 
Best practices in web accessibility are promoted through the ePractice portal. 

However,  there  remains  a  lack  of  awareness  and  promotion  of  web  accessibility  issues. 
Results from the public consultation confirm this: a large majority of respondents (over 90%) 
are  in  favour  of  more  schemes  to  train  relevant  bodies,  exchange  best  practice  and  provide 
information and guidance to people with disabilities. 

51 
52 

53 

www.w3c.org/WAI. 
Another  study  was  done  in  2007  by  Cap  Gemini  as  part  of  the  e-Government  benchmark  into 
availability of online public services. In that case the presence of a web accessibility compliance mark 
was measured. National level measurement activities are extensively reported in the web accessibility 
study report. 
http://www.wabcluster.org/. 

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3.2.2.  Legislative approaches 

a) At European level 

There  are  no  specific  web  accessibility  legislative  measures  at  European  level.  However, 
some  of  the  legislation  on  e-accessibility  mentioned  in  section  2.1.3  also  applies  to  web 
accessibility. 

b) At Member States and third country level  

In  Member  States,  accessibility  of  public  websites  has  received  policy  attention  in  recent 
years.  However,  there  is  considerable  variation  in  terms  of  the  type  and  nature  of  policy 
approaches implemented. The study report on web accessibility mentioned in the introduction 
gives  a  detailed  overview  of  the  situation  and  identifies  key  differences  between  Member 
States, e.g. in terms of: 

Type of approach: 

Six Member States have direct legislation on web accessibility (AT, DE, CZ, ES, FI, IT, SK), 
while others have indirect legislation (e.g. equal rights legislation) on web accessibility (F, IE, 
MT,  UK).  Other  Member  States  have  addressed  web  accessibility  through  non-legislative 
approaches of various types. 

Websites covered: 

The majority of Member States focus only on public websites in their direct measures on web 
accessibility. The available evidence indicates that the scope of coverage of public websites 
varies;  some  Member  States  include  all  levels  of  government  and  public  entities,  whereas 
others  only  directly  cover  central  government.  One  country  (DE)  explicitly  covers  the 
intranets of public bodies. In the few cases where commercial websites are directly covered 
(DE, IT, PT), this tends to be done through ‘encouragement’ measures.  

Timeframe for web accessibility: 

About half of the Member States have implemented a specific timeframe within which web 
accessibility is be achieved, with time horizons ranging from 2005 to 2010. In some countries 
(NL, SK, UK) new websites are given an immediate deadline whereas existing websites are 
given some time to adapt. 

Accessibility requirements: 

W3C’s Web Content Accessibility Guidelines (WCAG 1.0) represent a major reference point 
in  almost  all  Member  States  that  have  put  in  place  some  type  of  measure.  A  few  countries 
have developed variants, based on national norms and/or the US section 508 standards (CZ, 
IT, NL, SE). Most countries refer to WCAG 1.0 single A and/or double A requirements; triple 
A requirements are referenced to a lesser extent. The forthcoming WCAG 2.0 guidelines seem 
to have been formally addressed by only one Member State (DE). 

Support for web owners: 

The  evidence  available  suggest  that  the  countries  (AT,  DE,  DK,  UK)  that  have  adopted 
dedicated  measures  to  support  web  owners  in  implementing  accessibility-related  policies 
focus on three key aspects: awareness rising, networking of relevant actors and organisational 
capacity building. 

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Enforcement: 

Enforcement is not very visible in the majority of countries. Where it is the case, it tends to be 
based on persuasion (e.g. through award schemes, “naming and shaming”). Penalties for non-
compliance are only apparent in a few countries (ES, FR, IT, SK). 

Conformity assessment: 

In the majority of countries conformity assessment schemes have not been put in place; only 
in  three  Member  States  have  these  schemes  so  far  been  set  up  as  part  of  a  dedicated 
government  policy  (AT,  NL,  IT).  In  some  countries  voluntary  web  accessibility  labelling 
schemes have emerged, operated by NGOs or commercial parties. 

Monitoring: 

Benchmarking of accessibility of web sites has been identified in less than half of the Member 
States;  where  it  happens,  annual  benchmarking  has  remained  an  exception.  The  various 
monitoring  efforts  pursued  so  far  vary  greatly  in  terms  of  scope  (e.g.  number  and  types  of 
websites sampled) and methods applied (e.g. accessibility criteria applied, self-evaluation vs. 
external evaluation); it is thus difficult to compare outcomes across countries. 

As  regards  third  countries,  it  is  important  to  mention  the  USA:  Section  508  of  the 
Rehabilitation  Act  specifically  provides  that  federal  agency  websites  must  be  accessible  to 
federal employees and the general public. Federal contractors also are bound by this mandate. 
The obvious strength of Section 508 is its clear applicability to federal websites as provided 
by  statute.  Its  weakness  lies  in  the  reliance  on  individuals  with  disabilities  to  bring  about 
enforcement by filing complaints. 

3.3.  Further web accessibility actions 

3.3.1.  Rationale for further action on web accessibility 

There is clear consensus on the importance of accessing the internet, the modest achievements 
to date as regards web accessibility, and the need for further action to improve the situation.  

Since there are no EU legislative provisions on web accessibility, the main responsibility for 
improving  web  accessibility  remains  with  the  Member  States  and  individual  service 
providers.  Nevertheless,  as  explained  in  the  Communication  “Towards  an  Accessible 
Information Society” further action can also be taken at EU level. The overall goal would be, 
by  better  coordinating  Member  States’  action,  to  reinforce,  accelerate  and  extend  existing 
efforts  to  remove  accessibility  barriers  that  prevent  citizens,  government  and  business  in 
Europe from realising the full potential of the web.  

The  key  objective  would  then  be  to  accelerate  web  accessibility  (in  order  to  fulfil  the  Riga 
target of accessibility of 100% of public websites by 2010). A second objective would be to 
overcome  fragmentation  in  web  accessibility  specifications  caused  by  uncoordinated 
approaches in Member States over the years. In this respect the timing is right given the move 
to  new  web  specifications.  Specifically,  two  important  future  developments  in  web 
accessibility are the official adoption by W3C of WCAG 2.0, expected in the near future and 
the establishment of a European standard on web accessibility as an outcome of Mandate 376.  

Preparing the ground for these — in a way that avoids the fragmentation of the past — would 
mean jointly  anticipating compliance  and preparing migration towards the modern technical 
requirements  for  accessible  websites  by  Member  States,  website  owners,  authoring  tools 
providers and providers of user agents. Currently the best reference point for these technical 

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requirements — in absence of a European standard — is WCAG 2.0 as the guidelines are not 
yet approved.54 

While  binding  web-accessibility  legislation  might  be  expected  to  have  a  stronger  and  more 
consistent  impact  across  the  Member  States,  for  practical  purposes  such  legislation  would 
require  the  availability  of  the  relevant  standard.  For  this  reason  the  schemes  in  the 
Communication,  for  which  additional  background  is  presented  below,  focus  on  the 
preparation for a swift implementation of the new standard. 

3.3.2.  Estimated benefits and costs of implementing web accessibility 

There is no definitive picture available of the costs of web accessibility for websites owners. 
Part of the reason for this is that costs vary according to many different factors. However, it is 
generally  accepted  that  costs  are  typically  much  lower  at  the  design  stage  than  the  costs  of 
retrofitting accessibility for existing websites. Costs are likely to increase with increasing size 
and  complexity  of  websites,  particularly  for  retrofitting  existing  websites.  The  evidence 
suggests  that  costs  are  often  overestimated  and  they  have  tended  not  to  be  considered 
excessive  by  the  courts  when  action  is  taken  by  disabled  people  on  grounds  of 
inaccessibility55. 

Despite the likely variability in costs according to the circumstances, the available evidence to 
date suggests that costs of accessibility would not represent an undue burden for web owners 
in most cases.  

Alongside costs, benefits should also be taken into account. The study on ‘the accessibility to 
ICT  products  and  services  for  disabled  and  elderly  people’  (mentioned  in  the  introduction) 
provides  a  detailed  model  of  the  cost-benefits  of  investment  in  web  accessibility  linked  to 
transaction  cost  savings  from  citizens  using  eGovernment  services.  Based  on  the  available 
evidence, the model takes a range of estimates for the additional costs associated with making 
public  websites  accessible  in  the  Member  States  and  examines  how  the  cost-benefit 
implications  vary  with  increasing  ‘reach’  to  the  disabled  and  older  people,  who  would 
otherwise be excluded through lack of accessibility.  

The model makes a number of assumptions:  

(1) 

(2) 

54 
55 

The costs of annual spending on online public web sites are extrapolated from UK data 
from 2004 to 2007 and from the EU-25, correcting for the actual online public services 
availability  of  each  country.  The  empirical  data  available  on  the  additional  costs  for 
making a website accessible are limited. Therefore the model allows these costs to be 
taken as a variable (see the column headings in the table below, with additional costs 
varying from 2% to 30%).  

The  additional costs are the same for all  government websites (which is in fact  very 
unlikely  as  it  is  estimated  that  at  least  40%  of  current  government  websites  may  be 
quite close to being accessible and relatively easily made accessible so that even 20% 
would be a reasonable upper limit to costs at this point in time). 

WCAG 2.0 was published as a W3C Proposed Recommendation on 3 November 2008.  
For  example,  in  Australia  in  the  context  of  a  judgment  in  favour  of  a  complaint  against  the 
inaccessibility  of  the  Sydney  Olympics  website  the  courts  brought  in  expert  witnesses  and  a 
commission determined that it would cost relatively little (and a lot less than was originally estimated) 
to  make  the  site  accessible.  The  site’s  creator  estimated  for  instance  that  fixes  would  cost  around 
US$2.2 million. Experts’ cost estimates were $29 450.00. C. f: Olympic Failure: Tom Worthington: A 
Case for Making the Web Accessible. 

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(3) 

(4) 

(5) 

(6) 

There  is  the  same  level  of  recurring  costs  per  annum.  This  also  is  a  conservative 
assumption  as  in  many  cases  the  costs  of  maintaining  accessibility  should  be  a  lot 
lower than the initial (retrofit) costs, especially if good design principles are adopted at 
an early stage. 

Government cost savings per transaction of €18.22, which is a conservative estimate 
(based on data from the UK).  

On average an online citizen will use online government services (of any type) twice a 
year.  

Consumer benefits are calculated taking average time savings of 69 minutes by using 
online  instead  of  ‘traditional’  services  (data  from  EU-15,  Norway,  Iceland).  Time 
savings are valued on the basis of actual consumer wages in each country. Consumer 
costs of PC and Internet connection are not taken into account (as these are likely not 
specifically incurred for consumers carrying out transactions with government). 

The analysis shows that the overall cost-benefit return becomes increasingly positive as cost 
estimates for accessibility go down and additional reach percentages go up. Most cost/reach 
scenarios  are  positive  for  governments  and  only  the  highest  cost  and  lowest  reach  ones  are 
negative.  

Reach 
amongst 
target 
group 

Economic costs-benefit 
categories 

Additional costs to achieve website accessibility 

2% 

5% 

15% 

30% 

government costs for e-accessibility 

-24,256,800 

-60,641,999 

-181,925,997  

-363,851,994 

government transaction cost savings 

158,223,882 

158,223,882 

158,223,882  

158,223,882 

5% 

net government costs/benefits 

133,967,082 

97,581,883 

-23,702,115  

-205,628,112 

consumer benefits 

total cost/benefit 

153,112,707 

153,112,707 

153,112,707  

153,112,707 

287,079,790 

250,694,590 

129,410,592  

-52,515,405 

government costs for e-accessibility 

-24,256,800 

-60,641,999 

-181,925,997  

-363,851,994 

government transaction cost savings 

316,447,764 

316,447,764 

316,447,764  

316,447,764 

10% 

net government costs/benefits 

292,190,964 

255,805,765 

134,521,767  

-47,404,230 

consumer benefits 

total cost/benefit 

306,225,415 

306,225,415 

306,225,415  

306,225,415 

598,416,379 

562,031,180 

440,747,181  

258,821,184 

government costs for e-accessibility 

-24,256,800 

-60,641,999 

-181,925,997  

-363,851,994 

government transaction cost savings 

632,895,528 

632,895,528 

632,895,528  

632,895,528 

20% 

net government costs/benefits 

608,638,729 

572,253,529 

450,969,531  

269,043,534 

consumer benefits 

total cost/benefit 

612,450,829 

612,450,829 

612,450,829  

612,450,829 

1,221,089,558 

1,184,704,358 

1,063,420,360  

881,494,363 

Table 1 Cost-benefit modelling for accessible eGovernment: net cost-benefit p.a. (in €, EU 25) 

The overall cost-benefit (for governments and users) is only negative in the least favourable 
cost-reach scenario (30% additional costs for achieving web accessibility and 5% increase in 
reach). In the most favourable scenario (2% additional costs for web accessibility and a 20% 
increase in reach) the model suggests total estimated benefit of more than €1.2 billion. 

In addition to the benefits of reaching core groups (people with disabilities and older people 
with  functional  limitations)  there  are  also  the  benefits  of  reaching  and/or  providing  better 
usage  experiences  for  other  groups,  such  as  those  using  low  bandwidth  connections,  using 
mobile phones or other small display devices and the like. Other tangible benefits can also be 

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achieved  because  accessible  design  requires  attention  to  good  design  principles56.  These 
include  increased  search  engine  optimisation,  enhanced  usability  for  all  users  and  technical 
benefits such as lower site maintenance costs, reduced server load, improved interoperability 
and preparation for advanced technologies. These benefits can result in substantial economic 
benefits  in  terms  of  increased  business  reach  and  direct  cost  savings  through  reduced 
personnel costs, amount of server capacity needed and avoiding the need for multiple versions 
of a site for different user devices57. 

3.3.3.  Accelerating in a common way the realisation of modern web accessibility 

A  common  approach  for  web  accessibility  at  European  level  is  supported  by  96%  of 
respondents to the public consultation. Success of a common European approach relies mainly 
on  Member  States,  individual  service  providers  and  the  Commission.  A  common  approach 
should  address  accelerated  and  coherent  (joint)  preparation  for  the  new  international 
guidelines WCAG 2.0 and the outcome of Mandate 376 as well as awareness and promotion. 

There is broad consensus that WCAG 2.0 guidelines are the technical specifications to be met 
for  web  accessibility.  Once  W3C  reaches  agreement  on  the  guidelines,  European 
Standardisation can be completed within the framework of Mandate 376.  

To prepare for a swift incorporation of the new specifications into national rules and actively 
promote their implementation, Member States should take the following steps:  

– 

– 

– 

– 

Update  the  rules  to  take  account  of  the  new  specifications  (or  adopt  rules  where 
accessibility requirements do not yet exist).  

Ensure  the  requirements  are  made  public  and  visible  (e.g.  through  a  single  contact 
point, see below).  

Translate  the  specifications  and  accompanying  documentation  to  ensure  a  proper 
understanding and implementation at national level.  

Follow the same timeline for updating and publication, so that Member States are in 
a position to  compare their  choices for aspects  of  the  WCAG  2.0  specification  and 
Mandate 376 results and seek alignment in order to avoid fragmentation and reduce 
efforts (economies of scale).  

To improve implementation of web accessibility, it is suggested that Member States set up a 
list of the websites from their national authorities that should be accessible by 2010. As soon 
as this list is available, the websites concerned can begin preparations. By comparing the lists 
fragmentation can be addressed. Together with this list Member States would be expected to 
set targets (such as the level of accessibility to reach) and milestones (i.e. deadlines). Again, 
this  is  also  information  that  should  be  made  public.  By  making  their  intranets  accessible 
Member  States  also  are  in  a  better  position  to  comply  with  the  Employment  Equality 
Directive,  which  requires  employers  to  take  reasonable  measures  to  ensure  employment  of 
persons  with  disability  in  the  cases  where  accessible  intranets  would  be  part  of  the 
accommodation required. 

To  better  leverage  awareness  and  information,  Member  States  can  play  an  active  role  by 
supporting  training  schemes  which  are  essential  for  bodies  such  as  websites  designers,  ICT 

56 

57 

Shawn  Lawton  Henry  (2006)  Understanding  web  accessibility.  In:  Thatcher  et  al  (2006)  Web 
Accessibility, Web Standards and Regulatory Compliance. 
Customer Respect Group (2008): Accessibility and Business Value Study. 

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tools  providers,  web  content  providers,  etc.  In  such  training  schemes  direct  involvement  of 
persons with disabilities is desirable to understand their needs and expectations.  

Member States can also encourage non public websites providing services of general interest 
to be made accessible. 93% of respondents to the public consultation agree that the common 
European  approach  should  not  merely  address  public  websites  but  also  other  websites 
providing services of general interest. The aim here is to ensure that people with disabilities 
are  not  excluded  from  essential  services  (see  the  detailed  explanation  of  services  of  general 
interest in the related Communication58).  

In terms of supporting the exchange of practices, a role can be played by the ePractice portal 
as  the  one  stop  shop  to  exchange  advice,  experiences  and  events  on  practices  of  e-
Government,  e-Health  and  e-Inclusion.  ePractice  offers  the  most  complete  information  and 
exchange  opportunities  for  these  areas  in  Europe.  Real  life  cases,  insight  and  lessons  learnt 
are  shared.  It  represents  a  real  bridge  between  these  communities,  as  there  is  a  wealth  of 
interesting lessons to be learnt.  

An  important  task  is  to  improve  the  awareness  and  understanding  of  web  accessibility. 
Problems  of  accessibility  often  stem  from  a  lack  of  proper  information.  Member  States  can 
make  sure  that  persons  with  disabilities  receive  sufficient  and  clear  information  on  web 
accessibility.  This  should  also  include  information  on  how  to  use  assistive  technology  in 
relation to websites.  

For  better  visibility  and  support,  an  accessibility  statement  on  a  website  can  provide  useful 
information  such  as  the  accessibility  policy  of  the  website,  compliance  with  relevant 
specifications  and  support  for  persons  with  disabilities.  It  can  be  presented  in  the  way 
“privacy statements” or other “legal information” is available in many websites today. It can 
of course be linked to a certification and labelling scheme if that exists. The general level of 
agreement in the public consultation in favour of such a statement was 89%.  

Reporting on web accessibility implementation is crucial to assess the situation and progress 
made  and  to  decide  on  further  steps.  In  order  to  reduce  fragmentation  Member  States  can 
work  together  to  develop  a  common  assessment  and  monitoring  methodology.  Assessment 
and reporting should then also concern compliance and costs for web accessibility. Likewise, 
collecting user input is key to comprehensively assess the situation and better understand their 
needs and expectations.  

Lastly, a single national contact point has already been raised as a one stop shop to find web 
accessibility related information and a single entry point for stakeholders. It can simply take 
the form of a website.  
The Commission uses an Information Provider’s Guide59 which is mandatory for webmasters, 
editors,  content  providers  and  others  dealing  with  websites  in  the  Commission.  This  set  of 
standards  and  guidelines  includes  a  chapter  on  e-accessibility  that  currently  makes  direct 
reference to WCAG 1.0 from W3C. Action from the Commission includes updating the Guide 
and strengthening the internal policy towards web accessibility.  

Although  Member  States  have  the  prime  responsibility  of  ensuring  swift  implementation  of 
modern  accessibility  requirements,  this  does  not  prevent  the  Commission  from  proposing 
legislative measures at a later stage where necessary. 

58 
59 

COM(2007) 725. 
http://ec.europa.eu/ipg/index_en.htm  

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