Talk: What You Need to Know about the EU Accessibility Directive

This is a transcript of a talk I did at WordCamp Turku on the 28th of September, 2018. The slides to my talk are on Slideshare. I will update this post with a video when that is available.

“The power of the Web is in its universality.
Access by everyone regardless of disability is an essential aspect.”

Tim Berners-Lee, W3C Director and inventor of the World Wide Web

The web was meant for everyone, and it should continue to be so. The dream of an EU-wide accessibility standard goes back at least to the turn of the millenium, when it was thought that the Web Accessibility Initiative guidelines could have been adopted by the end of 2001. In 2006, a declaration of EU ministers hoped to have all public sector web sites accessible by 2010. That didn’t happen either, but in politics in general and in the EU especially things progress is sometimes slow. Finally, in 2016 the European Web Accessibility Directive came into force. But what is it about?

The Directive

From the preamble of the directive:

“The providers of information and services, such as public sector bodies, rely increasingly on the internet in order to produce, collect and provide a wide range of information and services online which are essential to the public.”

Simply put, more and more public services rely on the Internet, and if those services are not accessible to people with disabilities, we’re actually excluding them from a big part of society.

Unifying national legislation

Many countries in the EU already have regulation concerning accessibility, but they’re all at least slightly different from each other. The EU hopes that, by reducing fragmentation, suppliers will be able to offer their services easier in other European countries, and buyers of websites won’t have to face so high prices.

When is this happening?

  • New public sector websites must be accessible by September 23, 2019
  • Old sites published before September 23, 2018 must be accessible by September 23, 2020
  • Mobile applications must be accessible by 23 June, 2021

Who does the directive apply to?

In Finland, it applies to at least the following

  • Government institutions (ministries etc)
  • Municipal institutions (schools etc)
  • Some parliamentary institutions and the Office of the President
  • Associations that perform a public service
  • Independent public sector organisations such as Kela
  • Universities and universities of applied sciences
  • The Finnish Orthodox Church
  • Corporations providing a service

In Finland, the national legislation was supposed to be ready beginning of September 2018, but it’s been postponed, probably at least until the end of the year.

The legislation is still a draft, but probably it will apply to these too:

  • All organisations governed by public law
  • Services providing strong digital identification, such as online banks
  • Third sector organisations receiving public money for their website
  • Water, energy, traffic and postal services meant for the general public

And by January 2021,

  • Credit providers
  • Banks
  • Companies providing investment services
  • Insurance companies

However, a yet-to-be-finalised European Accessibility Act concerning certain products and services in the EU might also apply to this last list of organisations, so I wouldn’t be suprised if they were removed from this law.


The following do not have to comply with the directive.

  • Small and experimental digital services built in an educational context.
  • Live streamed events (but the video should be made accessible in a reasonable time if published after 23 September 2020)
  • Maps, if the essential information is available elsewhere in an accessible form
  • National broadcasters such as YLE in Finland.
  • National heritage collections
  • Office file formats (MS Office, PDF etc) published before 23 September 2018, unless they are essential for daily administrative processes.
  • Third party content that are not essential to the website and are not funded by a public entity.

Regarding the last item, third party content, it should not prevent using the rest of the site. A bad example of this would be a social media widget that traps keyboard focus by loading more and more content, preventing accessing e.g. the footer of a website.

Disproportionate burden

If making a part of the service fully accessible would cause a disproportionate burden on the organisation, they’re allowed to leave some parts of the web service non-accessible or not fully accessible.

This should take into account the

  • size,
  • resources and
  • nature of the public sector body concerned,
  • the costs and
  • benefits to the organisation in relation to the estimated benefits for persons with disabilities,
  • frequency and duration of use of the specific website or mobile application.

For now this sounds all very vague and will probably need example cases and clear guidelines. In Finland there are certainly many smaller public sector bodies that might not have the resources to make their digital services fully accessible.

Accessibility Statement and feedback mechanism

Sites impacted by the directive need to have an accessibility statement. It should include information on which parts of the website are not fully accessible and why, instructions on how to access the information or service in an accessible way, contact information for sending accessibility-related feedback and a link to the website of the monitoring body for registering an accessibility complaint.

There should be more detailed instructions on the form and content of the statement from the EU by the end of this year.

Both the statement and feedback mechanism themselves need to be accessible!


The monitoring body in Finland will be responsible for

  • Giving general guidance on how to implement accessibility
  • coordinating accessibility standards in Finland and the translations of them into Finnish and Swedish
  • Handle accessibility complaints without delay
  • Talking to various stakeholders

The monitoring body has the right to get the necessary information from the organisation being monitored on how accessibility requirements have been implemented and ensured. They can use external accessibility experts to do that.

The monitoring body can order a fine, if the organisation being evaluated does not comply with the request to provide information or does not follow the accessibility requirements. In Finland the legal term for this is “uhkasakko”.

The monitoring body in Finland is Etelä-Suomen Aluehallintovirasto, and Valtion lupa- ja valvontavirasto (Luova) starting in 2020.

How do we define accessible

The standard referred to in the directive is EN 301 549 v 1.1.2 chapters 9-11, which has the title “Accessibility requirements suitable for public procurement of ICT products and services in Europe”. Essentially this is just a wrapper for the established Web Content Accessibility Guidelines (WCAG) 2.0 level AA.

At the top level, WCAG has four main principles, that web content should be perceivable, operable, understandable and robust. Let’s have a look at the first one as an example.

1. Perceivable says that must be able to perceive the information being presented, i.e. it can’t be invisible to all of their senses.

Below the principles there are guidelines. For example, Guideline 1.4 Distinguishable says “Make it easier for users to see and hear content including separating foreground from background.”.

Below guidelines, there are specific Success Criteria, which are testable statements about the application or web site. These criteria are divided into three levels: A, AA and AAA. To be able to say that a site conforms with WCAG 2.0 AA, it must also conform with all A level criteria. This is an example of one success criterion:

Success Criterion 1.4.3 Contrast (Minimum)

(Level AA)

The visual presentation of text and images of text has a contrast ratio of at least 4.5:1, except for the following:

  • Large Text: Large-scale text and images of large-scale text have a contrast ratio of at least 3:1;

  • Incidental: Text or images of text that are part of an inactive user interface component, that are pure decoration, that are not visible to anyone, or that are part of a picture that contains significant other visual content, have no contrast requirement.

  • Logotypes: Text that is part of a logo or brand name has no contrast requirement.

How do we build accessible sites?

There are great resources on the web to help you build accessible sites, here are a few:

  • For WordPress, a very good place to start is the WordPress Accessibility Handbook, the current version of which has been largely written by Sami Keijonen and Rian Rietveld. It’s going to be restructured a bit, but it’s already an excellent starting point and full of links for more information.
  • The tutorials of the Web Accessibility Initiative are also worth checking out for general purpose examples of accessible web components.
  • When you’re evaluating how accessible a solution is, the W3C Quick Reference can be filtered by what your role is in the team.
  • The Inclusive Components website by Heydon Pickering has lots of very well-written articles on creating accessible components, discussing pros and cons of different approaches. He has also just published an e-book with the same name, and there is a print version in the works.
  • You might want to use a checklist to make sure you haven’t missed anything. For that, there is an excellent list by WebAIM here.

Resources in Finnish


The upcoming Gutenberg editor has some neat tools for helping create accessible content. The built-in colour contrast checker makes sure you don’t use an inaccessible text/background combination, and the editor encourages you to insert alternative text when embedding an image.

Accessibility Plugins

Be careful with these! The last one on this list has many useful accessibility features, but I still believe the best option is to build or have a theme that is accessible to begin with. If you’re not technically knowledgeable enough to evaluate what features your website theme already has, knowing what to enable or disable in the plugin can be difficult, and you might end up making your site a bigger mess than it was.

Embrace the directive and educate everyone

If you want to make accessibility hard and expensive, leave it to the developer to sort out at the end. That’s a guaranteed way to go over budget, and end up with a site which might just about satisfy the WCAG guidelines, but is probably not very inclusive, robust or actually usable especially for people with disabilities. So please don’t do that.

When you involve everyone from the start, salespeople, interaction designers, visual designers, project managers, copyrighters… and above all, evaluate or test your ideas early, you’re less likely to have to rewrite everything or come up with a less-than-optimal fix at the end.

So if you or your agency build websites for clients, embrace the Web Accessibility Directive as a chance to fix and improve your design and development processes. If you represent an organisation who the directive applies to, think of it as an opportunity to ensure the information you put out there will reach a widest possible audience.

For more information on the EU directive, see the Web Accessibility page of the European Commission. For up-to-date information on Finnish legislation, see the Saavutettavuusdirektiivi page of the Finnish treasury department.

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