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European Disability Forum EDF Report: A Compilation of Resources on the E- and Web- Accessibility Internal Market June 2012 “In the development and implementation of legislation and policies to implement the present Convention, and in other decision-making processes concerning issues relating to persons with disabilities, States Parties shall closely consult with and actively involve persons with disabilities, including children with disabilities, through their representative organizations.” Article 4 § 3 of the United Nations Convention on the Rights of Persons with Disabilities 1 EDF REPORT: A COMPILATION OF RESOURCES ON THE WEB-ACCESSIBILITY INTERNAL MARKET - FEBRUARY 2012

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European Disability Forum

EDF Report: A Compilation of Resources on the E- and Web-Accessibility Internal Market

June 2012

“In the development and implementation of legislation and policies to implement the present Convention, and in other decision-making processes concerning issues relating to persons with disabilities, States Parties shall closely consult with and actively involve persons with disabilities, including children with disabilities, through their representative organizations.”

Article 4 § 3 of the United Nations Convention on the Rights of Persons with Disabilities

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List of contents

Abbreviations........................................................................................31. Introduction....................................................................................32. E- and Web-Accessibility for Persons with Disabilities.....................3

2.1. Reports and Studies about E- and Web-Accessibility for Persons with Disabilities........................................................................3

2.1.1. Report on Releasing Constraints: Projecting the Economic Impacts of Increased Accessibility in Ontario (Canada).......................................................3

2.1.2. Accessibility to E-Commerce - A Study of People with Disabilities’ Opportunities to Shop Online (Denmark)...........................................................3

2.1.3. Accessibility of Websites in Denmark.....................................................3

2.1.4. Analysis of How Public Authorities Address Web-Accessibility (Denmark)..........................................................................................................3

2.1.5. Proceedings of the 4th European E-Accessibility Forum focusing on E-Accessibility of Public Services in Europe (France).............................................3

2.1.6. Open Letter for E-Accessibility of Public Services (France).....................3

2.1.7. Report of the French Accessibility Monitoring Centre (France).............3

2.1.8. List of E- and Web-Accessibility Reports by Braillenet (France).............3

2.1.9. IDEOSE, a French Portal on E-Accessibility for Persons with Disabilities (France)..............................................................................................................3

2.1.10. Portal of the Institute on E-Accessibility (France)...................................3

2.1.11. Greek E-Government Web Portal for Persons with Disabilities (Greece)3

2.1.12. Universally Accessible E-Services for Persons with Disabilities by the PanHellenic Association of the Blind (Greece)...................................................3

2.1.13. Monitoring Accessibility of Greek Websites (Greece)............................3

2.1.14. Reporting Inaccessible Public Websites in Italy......................................3

2.1.15. Report on ICT accessibility and social inclusion of people with disabilities and older people in Ireland: The economic and business dimensions (Ireland)..........................................................................................3

2.1.16. Cost Benefit Study of Implementation of Dutch Web Guidelines “Webrichtlijnen “ (The Netherlands)..................................................................3

2.1.17. Report on Accessibility of Social Networks (Spain).................................3

2.1.18. Report on the Accessibility of Public Administration Websites in 2010 in Spain...............................................................................................................3

2.1.19. Report on the State of Play of Accessibility of ICTs (Spain)....................3

2.1.20. Report on Accessibility of Websites of SMEs in Spain............................3

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2.1.21. Reports on Accessibility of Spanish Enterprises (Spain).........................3

2.1.22. Report Presenting Proposals for Future Actions on the Monitoring of E-Accessibility (Sweden)........................................................................................3

2.1.23. Report on Electronic Payment and Banks Accessibility in 2010 (Sweden)............................................................................................................3

2.1.24. Reports on Electronic Payment and Banks (Sweden).............................3

2.1.25. Study on Accessibility of Swiss Websites (Switzerland)..........................3

2.1.26. Report ‘Accessible Information and Communication technologies (ICT): Benefits to Business and Society’.......................................................................3

2.1.27. Assessing the Effects of the Americans With Disabilities on Accessibility of Goods and Services, Including ICTs, for Persons with Disabilities (United State of America (USA))......................................................................................3

2.1.28. List of Web Design References (USA).....................................................3

2.2. Reports and Studies Outside the Web-Accessibility Field but Applicable to the Digital Environment..................................................3

2.2.1. Study ‘Socioeconomic Model of Universal Design for Persons with Disabilities in Transport’ (Professor James Odeck).............................................3

2.2.2. Report on Economic Impact of Digital Exclusion (USA)..........................3

2.2.3. Report ‘Champion for Digital Inclusion, the Economic Case for Digital Inclusion’ (UK)....................................................................................................3

2.3. The Perspective of Disabled People Organisations on Web-Accessibility in Europe...........................................................................3

2.3.1. Web-Accessibility for Deaf Sign Language Users....................................3

2.3.2. Accessibility of Websites of Telecommunication Operators: a Good Practice Example from Ireland...........................................................................3

2.3.3. Involvement of Disabled People Organisations in Checking Accessibility of Websites: the Good Practice Example from Spain.........................................3

2.4. Real Life Story of Persons with Disabilities with Regard to Web-Accessibility...........................................................................................3

2.4.1. Pierre, Belgium.......................................................................................3

2.4.2. Wim, Belgium.........................................................................................3

2.4.3. Sofia, Bulgaria.........................................................................................3

2.4.4. Antonio, Italy..........................................................................................3

2.4.5. Mark, Ireland..........................................................................................3

2.4.6. Joseph, Malta.........................................................................................3

2.4.7. Frank, Netherlands.................................................................................3

2.4.8. Wioletta, Poland.....................................................................................3

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2.4.9. Jenny, Romania......................................................................................3

2.4.10. Hans, Sweden.........................................................................................3

2.4.11. Peter, Sweden........................................................................................3

3. The Perspective of Companies Operating on the Web-Accessibility Market..................................................................................................3

3.1. Introduction...............................................................................33.1.1. Template Survey Sent to Companies Operating on the Web-Accessibility Market...........................................................................................3

3.1.2. General Remarks....................................................................................3

3.2. Amas (Ireland)...........................................................................3

3.3. Atalan (France)..........................................................................3

3.4. ETU AB (Sweden).......................................................................3

3.5. Frontend (Ireland).....................................................................3

3.6. In Use Consulting (Sweden).......................................................3

3.7. Open-S (France).........................................................................3

3.8. Royal National Institute of the Blind Access Consultancy Services (United-Kingdom)....................................................................3

3.9. Technosite (Spain).....................................................................33.9.1. Designing accessible websites:...............................................................3

3.9.2. Certificating websites:............................................................................3

3.9.3. A List of Additional Costs for Web-Accessibility Service Providers to Offer their Service Throughout Europe..............................................................3

4. The Perspective of Owners of Accessible Website for Persons with Disabilities.............................................................................................3

4.1. Introduction...............................................................................34.1.1. Template Survey Sent to Owners of Accessible Websites for Persons with Disabilities..................................................................................................3

4.1.2. General Remarks....................................................................................3

4.2. Hilfsgmeinschaft der Blinden und Sehschwachen Österreichs (Austria).................................................................................................3

4.3. Austrian Federal Chancellery (Austria)......................................3

4.4. Accessibility of the Website of European or International Organisations (Belgium)........................................................................3

4.5. Danish Association of the Blind (Denmark)...............................3

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4.6. Danish Institute for the Blind and Visually Impaired (Denmark)3

4.7. The perspective of a Swedish web site owner with a disability (Sweden)...............................................................................................3

5. Acknowledgement..........................................................................36. APPENDIX.......................................................................................3

6.1. AGE-ANEC-EBU-EDF Document ‘Access Denied! Campaign for Accessible Websites’, June 2011...........................................................3

6.2. AGE-ANEC-EBU-EDF Proposal for a Legal Act on Accessible Websites, June 2011..............................................................................3

6.3. AGE-ANEC-EBU-EDF Leaflet ‘Inaccessible Websites: Time to Act!’, July 2011......................................................................................3

6.4. Contact Person at the EDF Secretariat:.....................................3

EDF Report: A Compilation of Resources on the Web-Accessibility Internal Market, February 2012.

The document is available in English, and on alternative format upon demand.

©European Disability Forum 2012. This document may be quoted and reproduced, provided the source is given.

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Abbreviations

DPOs Disabled People Organisations

EDF European Disability Forum

EU European Union

IS International Sign

IT Information technology

MS Member States

UK United-Kingdom

W3C WAI WCAG World Wide Web Consortium Web-Accessibility Initiative Web-Content Accessibility Guidelines

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1. IntroductionThe European Disability Forum (EDF) is the European umbrella organisation led by persons with disabilities and representing the interests of 80 million disabled people in Europe. EDF’s mission is to ensure persons with disabilities full access to fundamental and human rights through their active involvement in policy development and implementation in Europe. EDF works closely with the institutions of the European Union (EU), the Council of Europe and the United Nations.

In the Digital Agenda for Europe (DAE), one of the flagship initiatives of Europe 2020 Strategy, the European Commission foresees to take action on web-accessibility by the end of 2011: “based on a review of options, make proposals by 2011 that will make sure that public sector websites (and websites providing basic services to citizens) are fully accessible by 2015.” In this framework, EDF releases its Report: A Compilation of Resources on the Web-Accessibility Internal Market. It consists of a gathering of resources giving further perspectives on the internal market for accessibility of websites for persons with disabilities. We would like to let our readers know that this list of resources is by no means exhaustive.

2. E- and Web-Accessibility for Persons with Disabilities

2.1. Reports and Studies about E- and Web-Accessibility for Persons with Disabilities

The reports and studies listed in this section give further insight on the state of play of web-accessibility for persons with disabilities in various EU countries, but also in Canada and the United-States of America (USA). Some of the documents also analyse the socio-economic impact of making websites accessible to persons with disabilities, and the larger audience who can benefit from accessibility features.

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2.1.1. Report on Releasing Constraints: Projecting the Economic Impacts of Increased Accessibility in Ontario (Canada)

In Canada, Martin Prosperity Institute (MPI), Adaptive Technology Resource Centre (ATRC) and Institute for Competitiveness & Prosperity (ICP) have generated a report on “Releasing Constraints: Projecting the Economic Impacts of Increased Accessibility in Ontario”.

The report is available online.

2.1.2. Accessibility to E-Commerce - A Study of People with Disabilities’ Opportunities to Shop Online (Denmark)

In 2010, Equal Opportunities Centre for Disabled Persons in Denmark carried out a study of accessibility of 26 sites, all of which relate to online shopping. These are websites with consumer information about online shopping, price comparison sites and e-shops. The study shows that none of the websites are fully accessible and that many of the pages are poorly accessible. The study also shows that there can be problems for some people with disabilities in relation to make payment online and there may be problems with receiving the goods afterwards.

The report is available in Danish in html and PDF format online.

2.1.3. Accessibility of Websites in Denmark

In September 2007, the Danish Government, Local Government and Regions concluded an agreement on the use of mandatory open standards for software in the public sector. The agreement says that all public authorities, from 1 January 2008, are to use 7 sets of open standards when creating new IT solutions.

One of these standards is the web-content accessibility guidelines (WCAG) 2.0 of the World Wide Web Consortium (W3c). Unfortunately, a comparison of a mapping of public web sites in 2008 and another mapping in 2010 shows that the accessibility of public web sites has not improved since this agreement was made.

Information about the Political Agreement is available in Danish online.

Information about the mappings of accessibility (compliance with WCAG) of websites in 2008 and 2010 is available in Danish online.

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2.1.4. Analysis of How Public Authorities Address Web-Accessibility (Denmark)

The Danish Information Technology and Telecom Agency have conducted an analysis of how the public authorities work with web accessibility.

The analysis shows that web accessibility is not just a question of money. It is also a question of incorporating accessibility features from the very beginning of the development or redesign of websites.

The analysis also shows that the public authorities who have experience with web-accessibility believe that it doesn’t cause extra financial resources to purchase and maintain a good accessible website. However, certain content types (e.g. videos, Web 2-Functions and PDF) create special challenges.

The public authorities who manage to make accessible websites do not consider creating accessible websites to be more costly than websites that do not consider accessibility.

The analysis "Report on the authorities to work with Web Accessibility" has been conducted by Ramboll Management on the basis of a questionnaire and a series of interviews with government authorities and information technology (IT) suppliers.

The analysis shows that:

- Authorities, whose management focuses on web-accessibility, result in good accessibility of their website.

- It is important to be aware of where the responsibility to ensure accessibility is placed in the organisation when a public authority shall ensure good web-accessibility.

- Accurate knowledge of persons with disabilities motivates management and employees to focus on web-accessibility.

- In order to obtain accessible websites, it is crucial that the underlying organization is aware of and understands the relevant guidelines in Denmark i.e. the WCAG 2.0.

The analysis can be found in Danish on the Danish Information Technology and Telecom Agency’s website.

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2.1.5. Proceedings of the 4th European E-Accessibility Forum focusing on E-Accessibility of Public Services in Europe (France)

In 2010, the 4th European E-Accessibility Forum gathered experts from all Europe to discuss the state of play of accessibility of public services. Several presentations can be useful to better understand the web-accessibility -internal- market.

The proceedings are available in English and French online.

2.1.6. Open Letter for E-Accessibility of Public Services (France)

This open letter was collectively written by several actors operating on the web-accessibility market and is supported by many individuals. It notably explains why the French legislation on accessibility is not delivering its promises for better web-accessibility for persons with disabilities.

The letter is available in French on the article 47 website.

2.1.7. Report of the French Accessibility Monitoring Centre (France)

In May 2011, the French Accessibility Monitoring Centre has issued its first report. It notably explains the state of play of (e-) accessibility in France and gives some recommendations about e- and web-accessibility (from page 108 onwards).

The Report is available in French on the Observatory on the French Monitoring Centre on Accessibility website.

2.1.8. List of E- and Web-Accessibility Reports by Braillenet (France)

On its website, Braillenet, a French organization dealing with accessibility of websites, lists existing French reports about e- and web-accessibility for persons with disabilities. It is updated until 2008.

The list is available in French on Braillenet website.

2.1.9. IDEOSE, a French Portal on E-Accessibility for Persons with Disabilities (France)

IDEOSE is a French portal about e- and web-accessibility. It notably has a good section referring to many resources on e- and web-accessibility.

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The portal website is: http://www.ideose.eu/ressources-accessibilite/.

2.1.10. Portal of the Institute on E-Accessibility (France)

The portal of the French Institute on E-Accessibility provides with rationale on why acting to deliver e- and web-accessibility for persons with disabilities.

More information is available on the website of the Institute on E-Accessibility.

2.1.11. Greek E-Government Web Portal for Persons with Disabilities (Greece)

The web applications available via the Portal include:

- The Online Citizen Service Centre, a one-stop-shop service for information retrieval and application submission to public administration bodies;

- Job Finding Service, supporting persons with disabilities in searching on – line for jobs, eliminating the need for their physical presence in the workspace in order to conduct any preliminary negotiations with employers;

- Digital library of assistive technology product and services, addressing individual users as well as public bodies and organizations;

- Voice Portal, as an alternative means to access the content available through the Online Citizen Service Centre with the use of telephone.

More information is available in Greek online.

2.1.12. Universally Accessible E-Services for Persons with Disabilities by the PanHellenic Association of the Blind (Greece)

It is a national funded project that aims to promote the equal participation of persons with disabilities in e-government services, and supports independent living by enabling the provision of personalized and informative fully accessible e-services available through mobile devices as well as traditional desktop personal computers equipped with assistive technology.

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More information is available in Greek on the website.

2.1.13. Monitoring Accessibility of Greek Websites (Greece)

For a detailed account regarding the status of accessibility of public websites in Greece, see Basdekis et.al. (2010) "An overview of web accessibility in Greece: a comparative study 2004–2008".

More information is available in Greek online.

2.1.14. Reporting Inaccessible Public Websites in Italy

In Italy, any citizens can report online about the inaccessibility of public websites.

More information is available in Italian on the dedicated website.

2.1.15. Report on ICT accessibility and social inclusion of people with disabilities and older people in Ireland: The economic and business dimensions (Ireland)

“The report, entitled "ICT accessibility and social inclusion of people with disabilities and older people in Ireland: The economic and business dimensions", was commissioned from the Work Research Centre. It reveals that the rate of access to and usage of the internet among people with disabilities and older people is only half that of the general population. Although this is partly due to socioeconomic factors and attitudes to Information and Communication Technologies (ICTs), accessibility barriers are also shown to play a significant role. The majority of public and commercial websites in Ireland, for example, have serious accessibility and usability defects. These can present insurmountable barriers to many of the 20.5% of Irish adults who have a disability and/or are in the older age group.” (Extract from NCBI Centre for Inclusive Technology website).

More information is available in English online.

2.1.16. Cost Benefit Study of Implementation of Dutch Web Guidelines “Webrichtlijnen “ (The Netherlands)

“In commission of ECP-EPN, the Platform for the Information Society, the University of Twente conducted a study on the potential costs and

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benefits of implementation of the Webrichtlijnen (the Dutch web guidelines) for non-governmental organizations, like businesses, corporations, not-for-profit and charity organizations, and other private parties. The Webrichtlijnen are compulsory for Dutch governmental organisations. Although the impression in the market exists that implementing guidelines have a positive effect on different indicators of cost and benefit, it is not possible to make any financial or economic conclusions, due to the lack of hard evidence of effects of implementation of guidelines.”

More information is available in English online.

2.1.17. Report on Accessibility of Social Networks (Spain)

The report is conducted under the auspices of ONCE Foundation.

The whole report is available in word and PDF in Spanish and the Executive Summary is available in word and PDF format online.

2.1.18. Report on the Accessibility of Public Administration Websites in 2010 in Spain

The report presents the current situation of accessibility of public administration websites in Spain in 2010. (Oficina Permanente Especializada. Consejo de la Discapacidad. Ministerio de Sanidad, Política Social e Igualdad).

The report is available in Spanish online.

2.1.19. Report on the State of Play of Accessibility of ICTs (Spain)

Conducted by CERMI, the Spanish Committee of Representatives of Persons with Disabilities, the report highlights the state of play of e-accessibility (CERMI; Fundacion Vodafone; Spanish. El Estado Actual de la Accesibilidad de las Tecnologías de la Información y la Comunicación (TIC)).

The report is available in Spanish online.

2.1.20. Report on Accessibility of Websites of SMEs in Spain

Conducted by INTECO, the report consists of an analysis of the accessibility of websites of SMEs in Spain (2007).

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The report is available in Spanish in PDF format online.

2.1.21. Reports on Accessibility of Spanish Enterprises (Spain)

Conducted by CERMI, the reports analyses accessibility of websites of some Spanish enterprises (CERMI, Observatorio de Accesibilidad de las Páginas de Internet de las principales empresas españolas (2ª entrega 2010) and Observatorio de Accesibilidad de las Páginas de Internet de las principales empresas españolas).

The reports are available in Spanish on CERMI website online and online.

2.1.22. Report Presenting Proposals for Future Actions on the Monitoring of E-Accessibility (Sweden)

This report makes several proposals on how to monitor and follow-up on e-accessibility for persons with disabilities. It explains that the e-accessibility requirements of persons with disabilities are not as well-known as the web-accessibility ones. It also proposes an evaluation system depending on the areas (e.g. education).

The report is available in Swedish in PDF format online.

2.1.23. Report on Electronic Payment and Banks Accessibility in 2010 (Sweden)

The report discusses the need for personal service to complement electronic services. Some parts of the report also cover testing with persons with different disabilities.

The report is available in Swedish in PDF format online.

2.1.24. Reports on Electronic Payment and Banks (Sweden)

The report explains how older persons, persons with disabilities and persons living in rural areas could use electronic communications. It primarily takes up electronic payment and communication about health care and similar services from local governments.

The report is available in Swedish in PDF format online.

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2.1.25. Study on Accessibility of Swiss Websites (Switzerland)

The Access for All Foundation produced a study on accessibility of Swiss websites in 2011. Around 100 websites of national and regional public institutions and of the private sector have been tested. It is the third study checking accessibility of websites for persons with disabilities.

The study is available in PDF format in French online.

2.1.26. Report ‘Accessible Information and Communication technologies (ICT): Benefits to Business and Society’

The organization OneVoice for Accessible ICT Coalition issued a report entitled Accessible Information and Communication technologies (ICT): Benefits to Business and Society. There are several case studies highlighting the impacts of making ICTs accessible.

The report is available in PDF format online.

2.1.27. Assessing the Effects of the Americans With Disabilities on Accessibility of Goods and Services, Including ICTs, for Persons with Disabilities (United State of America (USA))

Several reports present the impact of the Americans with Disabilities Act on the provisions of accessible goods and services, including ICTs, in the USA:

- Report on Americans With Disabilities Act: Effects of the Law on Access to Goods and Services (1994). A summary in html format and the report in PDF format are available online.

- Report on Americans With Disabilities Act: Challenges Faced by Transit Agencies in Complying With the Act's Requirements (1994). A summary in html format and the report in PDF format are available online.

- Report on Americans With Disabilities Act: Initial Accessibility Good But Important Barriers Remain (1993). A summary in html format and the report in PDF format are available online.

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2.1.28. List of Web Design References (USA)

The University of Minnesota Duluth provides a list of web design references. Notably, there is a section on the benefits of web-accessibility.

The list of web design references is available in English on the University of Minnesota Duluth.

2.2. Reports and Studies Outside the Web-Accessibility Field but Applicable to the Digital Environment

Several reports and studies concern matters outside the web-accessibility field itself. However, these evidences bring rationale and elements that also apply to web-accessibility for persons with disabilities. It would be worth taking them into account while addressing how the operators of the web-accessibility internal market operate with consumers with disabilities.

2.2.1. Study ‘Socioeconomic Model of Universal Design for Persons with Disabilities in Transport’ (Professor James Odeck)

“Economic appraisal of universal design in transport: Experiences from Norway and applicability to ICT

Professor James Odeck specialises in applied transport economics, production economics and performance measurement. His research includes valuation of impacts, benefit-cost analysis, road pricing, and price elasticity in transport, cost estimations of infrastructure projects, efficiency and productivity measurement using econometric methods. He teaches at Molde University College and the Norwegian University of Science and Technology. An abstract of his article explaining this model applied to the transport sector is available online, where the full article can also be bought

Summary: Norway has recently developed an economic assessment framework for Universal Design projects. Universal Design (UD) refers to the design of transport systems in a way that they are accessible to all users, irrespective of the users’ abilities. The framework demonstrates that that UD projects are surprisingly profitable from a socioeconomic point of view because UD, despite that they are aimed at those with disabilities, they are a benefit to all. This presentation deals with the Norwegian framework for economic assessment of UD and argues that it

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represents a potential model for application in the ICT domain. It claims that measures or projects aimed at equal access to ICT are parallel to those of UD and, hence are likely to be profitable from socioeconomic point of view.” (Extract from the website of the 5th European e-accessibility Forum organized by Braillenet).

2.2.2. Report on Economic Impact of Digital Exclusion (USA)

In the USA, the “Digital Impact Group and Econsult Corporation have produced this assessment of the economic impact of digital exclusion”.

The report is available in PDF format online.

2.2.3. Report ‘Champion for Digital Inclusion, the Economic Case for Digital Inclusion’ (UK)

“The report assesses the potential scale of the ‘digital dividend’ to the UK of achieving greater digital inclusion. Our work has assessed the expected economic benefits of reducing digital exclusion in key areas and considered the aggregate potential benefits of reducing digital exclusion depending on how many of the digitally excluded can be brought online.”

The report is available in PDF format online.

2.3. The Perspective of Disabled People Organisations on Web-Accessibility in Europe

2.3.1. Web-Accessibility for Deaf Sign Language Users

Public sector websites and websites providing basic services to citizens should be accessible to any Deaf person from any EU country. This implies that websites shall be translated into the national sign language of the website in order to provide full information to Deaf sign language users.

However, major barriers are still visible at European level, in the internal market: most of the websites are not accessible to Deaf sign language users from other countries where they use their own national sign language. This huge barrier prevents Deaf people to access those services from another country where they are studying, working or even travelling. For example, a Deaf person from France cannot find appropriate information on his or her rights as a worker and the

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procedure to follow to become a resident in the UK because of the lack of information translated into the national sign language and International Sign (IS) on the UK Border Agency website.

Therefore, service providers of accessible websites should be aware of the need to make their websites accessible in the national sign language, as well as in IS. We strongly encourage service providers and public procurers to ensure that any content of the website is translated into the national sign language and IS.

2.3.2. Accessibility of Websites of Telecommunication Operators: a Good Practice Example from Ireland

Two telecommunication operators, Eircom (telephone landline) and Mobile Phone Operators, in Ireland have agreed after consultation with Disability Strategy Group on ICT and Communications Regulator to adopt a ONE CLICK INITIATIVE whereby their websites are more accessible for persons with disabilities to get all issues relating to disabled users on one click link from Home Page. The Irish Disability Act 2005 has set up a Centre of Excellence of Universal Design and part of this is the Department of Communications commitment to continuous improvement of the accessibility of its services with particular priority being given to ICT accessibility. All public bodies obliged to meet access standards, what is still an on-going action.

2.3.3. Involvement of Disabled People Organisations in Checking Accessibility of Websites: the Good Practice Example from Spain

In 2009 and 2010, CERMI, the Spanish Committee of Representatives of Persons with Disabilities, has reported 13 cases of Spanish organisations (both public and private) which websites are not accessible, as well the US-based company Facebook (that do not meet regular accessibility standards). However, up to now no fine has been imposed (all cases are still unresolved).

CERMI is providing templates and guidelines in order to facilitate formal complaints related to the lack of web-accessibility of relevant websites and helping user associations to prepare them easily and making them known. Further information is available online.

Technosite carries out specific reports about the accessibility level of websites in selected sectors (named “Observatorios de Accessibilidad), in collaboration with CERMI. This is a way to monitor the accessibility level

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of very relevant websites or essential public websites. Some examples are available at the following links:

http://www.cermi.es/es-ES/Biblioteca/Paginas/Inicio.aspx? TSMEIdPub=57

http://www.cermi.es/es-ES/Biblioteca/Lists/Publicaciones/ Attachments/176/CERMI-ObservatorioWebEsp-Parte2_100430%20.pdf

2.4. Real Life Story of Persons with Disabilities with Regard to Web-Accessibility

EDF gathered real life stories of persons with disabilities using the web and ICTs to exercise their freedom of movement to travel, study or work in the EU. These stories underline how accessible ICTs and websites are a key enabler in the everyday life of persons with disabilities. However, many ICTs and websites are not accessible to disabled people –yet-, and it leads to deprivation of the exercise of their freedom of movement around Europe.

2.4.1. Pierre, Belgium

“The other day I could not book a flight with my usual airline company just because their date picker for travel dates is not accessible.”

2.4.2. Wim, Belgium

“The manual about activating internet on my phone came in a PDF document. The document was readable but the settings to be entered were shown in a screenshot and not repeated in the text. So the manual became completely useless.”

2.4.3. Sofia, Bulgaria

“When I want to watch the news online, there are no subtitles in the videos or no transcripts available below. I cannot inform myself about day to day events like others do.”

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2.4.4. Antonio, Italy

“Free movement for a blind person in the EU is very complicated: there is very little information available in accessible format. A blind person is dependent on audible information and not visual information. This means that information icons/signals/displays are not accessible. Assistance services are not standardized and are in general difficult to reach. Tactile surface indicators are not standardized as well as traffic lights acoustic signals.”

2.4.5. Mark, Ireland

I was preparing a trip to London and I found that, at least 2 of their websites, providing information on how to travel in London, are really useful. I found the information excellent and could get what I needed from them easily. Both sites are well designed and both have information specifically to assist persons with disabilities. I could also order free travel and tourist information from the Transport for London website in alternative formats and by phone at no charge.

The websites are www.visitlondon.com and www.tfl.gov.uk .

2.4.6. Joseph, Malta

“There is almost no accessible public websites for persons with disabilities in Malta. The only accessible website in Cyprus is the one of the CCOD. CCOD is following and promoting the e-accessibility needs of persons with disabilities.”

2.4.7. Frank, Netherlands

“I need to contact customer service from my rail service about a refund. The only way they will allow so is by calling a phone number. That number is on the website. No ability to send an e-mail for the problem. After a complicated and long searching, I was able to obtain the e-mail address from the service centre. However, they kept demanding I use the phone despite explaining that I am a Deaf person.”

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2.4.8. Wioletta, Poland

“As a hard of hearing person, using hearing aid or cochlear implant I find difficult to access services in Poland. I have dual citizenship and often travel to Poland from UK where I am based. Public transport has no accessible information for people with hearing loss that includes buses and trains. Train stations do not provide up to date visual information thus making it impossible to be up to date with travel planning. Members of staff in public services have no patience to repeat any requests. This stops me from enjoying my travels in Poland and I feel more comfortable travelling in other European countries where information is more accessible for me.”

2.4.9. Jenny, Romania

“My first language is sign language. When we had elections I did not know whom to vote for, because there was hardly any sign language interpretation of the political messages.”

2.4.10. Hans, Sweden

“I am interested in technology and there is a web magazine that I try to follow every day, but it is so difficult to read because of flashes and commercials interrupting the text so I get lost.”

2.4.11. Peter, Sweden

“The government has started to have open online seminars on things that interest me but there are no subtitles so I cannot participate or even access what is being said.”

3. The Perspective of Companies Operating on the Web-Accessibility Market

3.1. Introduction

While drafting this Report, EDF and its member organisations contacted several companies operating on the web-accessibility market in order to understand better their perspective and especially their views on the cross-border aspects of the web-accessibility market. EDF and its

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members used a standardized survey, which consisted of a set of 5 questions. Organisations answering it were also welcome to give us their feedback on the topic freely. This survey was conducted on an ad-hoc basis; it collects cases of companies only and is by no mean exhaustive or fully representative.

3.1.1. Template Survey Sent to Companies Operating on the Web-Accessibility Market

The questionnaire sent to companies was as follows:

If your company operates in the business of Website development:

1. Have you tried or did you plan to offer your services (bid for a public contract) in an EU country different than yours? If no: any particular reason related to technical specifications in the call for tenders?

2. Do you offer the implementation of Web accessibility? If yes: according to which standard/guidelines?

3. If you have tried to offer or have offered services for the development of accessible websites in an EU country different than yours, have you faced any problem because the web accessibility requirements in the call for tenders were different from those in your country? If yes, please explain.

4. Do you consider that the current situation of having different specifications in the EU countries create barriers to your business?

5. Do you consider that an EU standard (same specification across the EU) would facilitate growth of this market segment (development of accessible websites?

3.1.2. General Remarks

The survey was answered by 8 companies based in various European countries (Ireland, France, Sweden and UK). Some general remarks can be drawn from the feedback received:

- Most companies did not answer bids or sell their services in another European country yet, but they plan doing so in a near future. However, a website can be accessed from anywhere, so disabled Internet users can get confused navigating from one European website to another.

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- All companies apply the W3c WAI WCAG 2.0 to build accessible websites. Whenever existing, they also use tools developed by national legislators or public authorities (France, Sweden and the UK).

- While planning their development outside their national borders, all companies are in favour of a single set of rules applying throughout Europe. Being in compliance with several sets of legislation and standards is an obstacle for them: it creates administrative burdens and it implies additional human and financial costs.

To summarise, complying with the same legislation and European standard throughout the EU countries would open up business opportunities for the companies operating in the web-accessibility market.

3.2. Amas (Ireland)

1. Have you tried or did you plan to offer your services (bid for a public contract) in an EU country different than yours? If no: any particular reason related to technical specifications in the call for tenders?

<Answer> We haven't bid for public contracts in other EU countries.

2. Do you offer the implementation of Web accessibility? If yes: according to which standard/guidelines?

<Answer> Primarily WCAG 2.0.

3. If you have tried to offer or have offered services for the development of accessible websites in an EU country different than yours, have you faced any problem because the web accessibility requirements in the call for tenders were different from those in your country? If yes, please explain.

<No answer>

4. Do you think that the current situation of having different specifications in different EU countries creates barriers to your business?

<Answer> Not to ours, as we are primarily an internet strategy company, but for companies primarily focused on accessibility, differing national specifications would be a substantial barrier.

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5. Do you consider that an EU standard (same specification across the EU) would facilitate growth of this market segment (development of accessible websites?

<Answer> Yes, standardisation (provided that the common specifications are not unduly complex) would help the market for accessible website development to grow and would help purchasers get better value.

3.3. Atalan (France)

1. Have you tried or did you plan to offer your services (bid for a public contract) in an EU country different than yours? If no: any particular reason related to technical specifications in the call for tenders?

<Answer> Yes, first, we plan to offer, with help of partners, our services in few EU countries or neighbouring countries like Belgium or Switzerland.

We also plan to get closer to accessibility specialists in several other EU countries to make studies and research on e-accessibility.

2. Do you offer the implementation of Web accessibility? If yes: according to which standard/guidelines?

<Answer> Yes. WCAG 2.0 or French guidelines like AccessiWeb and RGAA (Référentiel Général d'Accessibilité pour les Administrations).

3. If you have tried to offer or have offered services for the development of accessible websites in an EU country different than yours, have you faced any problem because the web accessibility requirements in the call for tenders were different from those in your country? If yes, please explain.

<Answer> Not yet.

4. Do you consider that the current situation of having different specifications in the EU countries create barriers to your business?

<Answer> Yes, definitely.

5. Do you consider that an EU standard (same specification across the EU) would facilitate growth of this market segment (development of accessible websites?

<Answer> Yes, it would be easier to evaluate the level of accessibility in different countries and to work on a common basis.

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3.4. ETU AB (Sweden)

1. Have you tried or did you plan to offer your services (bid for a public contract) in an EU country different than yours? If no: any particular reason related to technical specifications in the call for tenders?

<Answer> We do not have any intention to offer our services in other countries. But we have had customers that published websites in more than one country.

2. Do you offer the implementation of Web accessibility?

<Answer> Yes. We give advice to our customers to deliver accessible websites. But we do not develop websites for them.

If yes: according to which standard/guidelines?

<Answer> WCAG 2.0.

3. If you have tried to offer or have offered services for the development of accessible websites in an EU country different than yours, have you faced any problem because the web accessibility requirements in the call for tenders were different from those in your country? If yes, please explain.

<No answer>

4. Do you consider that the current situation of having different specifications in the EU countries create barriers to your business?

<Answer> Not really.

5. Do you consider that an EU standard (same specification across the EU) would facilitate growth of this market segment (development of accessible websites?

<Answer> We believe that a common EU standard would be good, in particular for companies that develop authoring tools to produce web sites or e-commerce sites. They can get a wider customer base. Other web-based applications can be used and sold in more countries. It would also be beneficial for companies having websites in several countries in different languages.

3.5. Frontend (Ireland)

<Answer> "Our only EU cross border experience is in complying with both UK DDA and our legislation/policy here in Ireland. However the current voluntary guidelines (WCAG 2) for the most part exceed the legal/policy

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requirement in both jurisdictions so that in practice the measures taken to comply/conform are identical. The result is that so long as WCAG 2 conformance remains sufficient there's no major impact to sales/procurement or delivery of online services."

3.6. In Use Consulting (Sweden)

1. Have you tried or did you plan to offer your services (bid for a public contract) in an EU country different than yours? If no: any particular reason related to technical specifications in the call for tenders?

<Answer> No, we mainly have Swedish clients. Our few international clients buy more strategy and design competence from us, than accessibility. So no particular reasons related to technical specifications there.

2. Do you offer the implementation of Web accessibility? If yes: according to which standard/guidelines?

<Answer> Yes. We refer to Swedish National Web guidelines for public sector (former 24-timmarswebben) and WCAG 2.0. That is what our clients ask for.

3. If you have tried to offer or have offered services for the development of accessible websites in an EU country different than yours, have you faced any problem because the web accessibility requirements in the call for tenders were different from those in your country? If yes, please explain.

<Answer> No.

4. Do you consider that the current situation of having different specifications in the EU countries create barriers to your business?

<Answer> No, not at the moment. See answers above.

5. Do you consider that an EU standard (same specification across the EU) would facilitate growth of this market segment (development of accessible websites?

<Answer> Yes, I think that could help. But it is of great importance that it is comprehensive, concrete and easy to use both as requirements and as guidelines for designers, developers and editors.

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3.7. Open-S (France)

1. Have you tried or did you plan to offer your services (bid for a public contract) in an EU country different than yours? If no: any particular reason related to technical specifications in the call for tenders?

<Answer> Yes, in Brussels (for a European Commission contractor).

2. Do you offer the implementation of Web accessibility? If yes: according to which standard/guidelines?

<Answer> Yes, we obviously follow the WCAG 2.0, and more specifically the two French guidelines (AccessiWeb, RGAA- Référentiel Général d'Accessibilité pour les Administrations).

3. If you have tried to offer or have offered services for the development of accessible websites in an EU country different than yours, have you faced any problem because the web accessibility requirements in the call for tenders were different from those in your country? If yes, please explain.

<Answer> No.

4. Do you consider that the current situation of having different specifications in the EU countries create barriers to your business?

<Answer> Yes that may happen. A harmonization work was conducted by the time of the WCAG 1, it is called UWEM.

A year ago, the Braillenet association (France) has launched a similar project for WCAG 2, called the WCAG-CAC project (CAC standing for Conformity Assessment Coherence). The project aims at verifying that a given webpage/website recognized accessible in Italy, is also accepted as accessible in Germany (and so on, all over EU countries).

The project includes members from (no particular order) Spain, Italy, Belgium, UK and France. We (Open-S) are part of the French team and are also the technical provider for accessibility materials and tools in this project.

5. Do you consider that an EU standard (same specification across the EU) would facilitate growth of this market segment (development of accessible websites?

<Answer> Of course, as long as:

1) It follows the WCAG;

2) It relies on existing work already done;

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3) It copes with the lack of penalty (nowadays, French law includes an obligation, but no penalty exists if web-accessibility is not respected!).

3.8. Royal National Institute of the Blind Access Consultancy Services (United-Kingdom)

Royal National Institute of the Blind (RNIB) Access Consultancy Services is a pan-disability, not for profit access consultancy. We aim to help create an inclusive society by improved access for disabled people to the environments and services they use. 1. Have you tried or did you plan to offer your services (bid for a public contract) in an EU country different than yours? If no: any particular reason related to technical specifications in the call for tenders?

<Answer> We did participate to a bid in conjunction with the Italian-Belgium Chamber of Commerce but we do not normally actively seek European contracts as we concentrate on the UK market.

2. Do you offer the implementation of Web accessibility? If yes: according to which standard/guidelines?

<Answer> We offer audits and trainings and use both WCAG 2.0 and a set of guideline called Surf Right, based on WCAG 2.0 Double-A but with a different organisation of the principle and some additions.

3. If you have tried to offer or have offered services for the development of accessible websites in an EU country different than yours, have you faced any problem because the web accessibility requirements in the call for tenders were different from those in your country? If yes, please explain.

<Answer> The above mentioned tender was a one-off joint tender and we only provided our quote to the organisation leading the bid.

4. Do you consider that the current situation of having different specifications in the EU countries create barriers to your business?

<Answer> Non applicable. As mentioned above, RNIB Access Consultancy Services are focused on the UK market.

5. Do you consider that an EU standard (same specification across the EU) would facilitate growth of this market segment (development of accessible websites?

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<Answer> Definitely - clear and uniform rules would help. Our understanding is that most EU countries base their guidelines on WCAG 2.0. We would refer to WCAG 2.0 if we had to bid for a European contract.

3.9. Technosite (Spain)

When providing services on web-accessibility throughout Europe, organisations offering services related to web accessibility in the EU encounter barriers to operate in other Member States (MS), and lose business opportunities as a consequence of the different web-accessibility legislations to comply both when designing and developing websites, as well as when certifying the accessibility level of a certain site.

3.9.1. Designing accessible websites:

Developing accessible websites for a client located in other MS is an issue for organisations in the sector.

First of all, accessibility is not already mainstreamed in the market, and when giving quotes to clients it is important to explain what web accessibility is and why it is important for organisations and clients.

Secondly, when planning a website for a client, developers must know the standards and law applicable in the country where the client is located. As shown in the MeAc2 Study (Smart 2008-0066, led by Technosite, and available at http://www.eaccessibility-monitoring.eu/; see data below from 2010), legislations are quite different in the sample of countries analysed. Whereas some countries enforce WCAG 2.0 (the de facto standard applied internationally), others refer to its previous version (WCAG 1.0) or have their own norm (such as in Spain, where websites must comply with UNE norm, based on WCAG 1.0); in addition to this, there are different levels of compliance for each of these aforementioned norms (for example, WCAG 2.0 has three levels of compliance: A, AA, and AAA).

Thirdly, in each country the standardization and legal framework covers different sectors, which adds complexity and makes even more difficult to know what kind of organisations are obliged by law or legal obligations. In certain countries, only governmental organizations websites must be accessible by law, whereas in other countries

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companies offering goods and services of public interest must be also accessible (e.g. financial services, education, transport, etc.), in addition to the public ones. Therefore, it is difficult for businesses (clients) to know in which countries their website must be accessible, and according to what rules. In order to illustrate this situation, the Report on implementation and interpretation of WCAG 2.0 (that is part of the Monitoring E-Accessibility Study) gives further explanations on the different legislations in place in 4 EU Member States. The study can be found in Word format and in English on the study website.

As a consequence of the fragmented EU legislation and standards, web-accessibility developers (which are mostly small- and medium-sized enterprises NGOs or freelancers) tend to have clients locally (in their own country). However, there are clients that operate globally, which means that they have a website per country where they sell their goods and services. It is a problem, both for clients and suppliers (web developers) to have a website per country complying with every country´s legislation or even worse, to have only a website to comply with several legislations at the same time.

It can be concluded that a common EU standard on web-accessibility would reduce complexity of the business activity, lower costs and would facilitate the internationalization of companies within the web-accessibility field. We acknowledge that under Phase 2 of the standardization mandate 376 a European Standard on the accessibility of products and services in public procurement is being developed and it will contain specific references to web-accessibility. Nevertheless, this will be a standard that can be applied in a voluntary basis, but not enforced by EU law.

3.9.2. Certificating websites:

Another service often offered is the certification of the accessibility level of a website. Certification is intended to guarantee that, in a certain period of time, the website maintains a certain level of accessibility. The purpose of certifying is that a third party tests and also gives trust about the level of accessibility achieved by a given website. This quality mark is beneficial for companies, as their customers can trust the website for being accessible to all users regardless of their abilities. It is worth to recall that web-accessibility degrades over time, and in spite of designing websites accessible from its very beginning, if it is not maintained, it decreases.

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Nevertheless, the lack of a common methodology at EU level on how to evaluate websites, and the legislation patchwork about accessibility of websites makes it very difficult to certify websites across Member States.

In order to create awareness about the importance of certifying, quality marks or accessibility labels can be an asset. Due to this fact and the lack of stable policy context, 3 organisations in the private sector (Braillenet, Anysurfer and Technosite) promoted a common certifying label named EURACERT, aimed at being mutually recognized in the three countries where these companies are located (France, Belgium and Spain). This label is based on WCAG 1.0 and is a pioneer initiative in order to ensure transnational certification; however, for the moment this initiative is available only in these 3 countries, as expanding it is difficult due to the lack of support from public bodies and because there are different interpretation of web accessibility criteria across Europe.

3.9.3. A List of Additional Costs for Web-Accessibility Service Providers to Offer their Service Throughout Europe

Quantifying economic losses and non-seized business opportunities is really difficult. Among the costs to be taken into account, we can mention the following:

- Translation costs, as national guidelines on web accessibility are not always written in EU official languages;

- Costs related to understand and learn how to apply each web accessibility standard in a national context;

- Costs related to replicate websites to make them compliant with national standards or to make a website one-size-fits-all norms;

- Cost to look for those companies that are obliged by law to have their websites accessible, in order to try to sell them web accessibility related services. The set of organisation that are potentially obliged by law varies from country to country;

- Cost to look for which certification schemes are in place in each MS, and if they are compulsory or not.

Organisations providing consultancy services, such as Technosite, within the web-accessibility field are highly affected by this lack of common legislation on web accessibility. For example, our sales managers have difficulties when looking for international clients/tenders as they have to spend extra working days reading and learning how to apply different

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national legislation and these extra-cost are charged to the client. Therefore, our quotes to clients may be higher than a local competitor quote, which reduces possibilities to be awarded.

4. The Perspective of Owners of Accessible Website for Persons with Disabilities

4.1. Introduction

In the framework of drafting this Report, EDF and its member organisations contacted several owners of an accessible website in order to better understand why they decided to make their websites accessible. EDF and its members used a standardized survey, which consisted of a set of questions. Organisations answering it were also welcome to give us their feedback on the topic freely. This survey was conducted on an ad-hoc basis, collects cases of owners of accessible websites only and is by no mean exhaustive or fully representative.

4.1.1. Template Survey Sent to Owners of Accessible Websites for Persons with Disabilities

The survey sent to companies was the following one:

If your organisation/company has a website:

1. How was it developed? In-house (own staff)? By an external service enterprise? If yes, from your own country?

Who maintains it? In-house? By an external service enterprise? If yes, from your own country?

2. If your website is accessible, does it meet any of the following accessibility criteria?

Accessibility Guidelines and level of compliance

WCAG 1.0

A

AA

AAA

WCAG 2.0 A

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AA

AAA

Other (please specify name and level of compliance):

3. If your website has been developed by an external enterprise, have you raised or did it raise the issue of accessibility?

If yes: were there different offers: one for a non-accessible website and other(s) for an accessible site?

a. If yes: how much was the additional cost/s (% difference).

b. If yes, and for the case of accessible websites: were there different offers according to the standard and/or level of compliance?

4. How do you certify your accessibility level? By whom?

4.1.2. General Remarks

EDF received 6 answers: 2 are from organisations of persons with disabilities based in Austria and Denmark, 2 from public institutions in Austria and Denmark again. In addition, a Belgium organization raised the difficulties encountered by European organizations that have to cope with heterogeneous web-accessibility levels in the different EU Member States, despite web-accessibility and the W3c WAI WCAG 2.0 being the same everywhere. Finally, a Swedish business owner, who happens to be a person with a disability, also gives the perspective of providing services accessibly.

From the answers provided to EDF, some general remarks can be drawn:

- When designing a website, an organisation generally use both in-house professional and an external service provider to create an accessible websites.

- The organisations also use a mix of competences when checking the accessibility of their website with the W3c WAI WCAG.

- The W3c WAI WCAG are the benchmark used to assess accessibility of the website. Organisations using WCAG 1.0 are now moving to WCAG 2.0.

To summarize, organisations having an accessible website create and assess its accessibility using a mix of in-house professionals and external

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service providers. They also mostly use the W3c WAI WCAG, now moving to the second version.

4.2. Hilfsgmeinschaft der Blinden und Sehschwachen Österreichs (Austria)

If your organisation/company has a website: http://www.hilfsgemeinschaft.at

1. How was it developed?

<Answer> In-house with external programmer, Typo3 customized.

In-house (own staff)?

<Answer> Partly, typo script programming outsourced.

By an external service enterprise?

<Answer> Programming/typo script.

If yes, from your own country?

<Answer> Yes.

Who maintains it? In-house? By an external service enterprise? If yes, from your own country?

<Answer> In-house.

2. If your website is accessible, does it meet any of the following accessibility criteria?

<Answer>

Accessibility Guidelines and level of compliance

WCAG 1.0A

AA x

AAA

WCAG 2.0A

not yet checked

AA

AAA

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Other (please specify name and level of compliance):

3. If your website has been developed by an external enterprise, have you raised or did it raise the issue of accessibility?

<Answer> We raised the issue, because it is absolutely necessary for us to have an accessible website for blind and visually impaired people.

If yes: were there different offers: one for a non-accessible website and other(s) for an accessible site?

a. If yes: how much was the additional cost/s (% difference).

<Answer> No different offers.

b. If yes, and for the case of accessible websites: were there different offers according to the standard and/or level of compliance?

4. How do you certify your accessibility level?

<Answer> No, no acknowledged certification in Austria.

By whom?

<No answer>

4.3. Austrian Federal Chancellery (Austria)

If your organisation/company has a website:

1. How was it developed? In-house (own staff)? By an external service enterprise? If yes, from your own country?

<Answer> By an external service enterprise from my own country.

Who maintains it? In-house? By an external service enterprise? If yes, from your own country?

<Answer> In-house and by an external service enterprise from my own country for some extensions for the content management system.

2. If your website is accessible, does it meet any of the following accessibility criteria?

<Answer>

Accessibility Guidelines and level of compliance

WCAG 1.0 A

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AA

AAA

WCAG 2.0

A

AA mostly

AAA

Other (please specify name and level of compliance):

see http://www.bundeskanzleramt.at/site/7482/Default.aspx

3. If your website has been developed by an external enterprise, have you raised or did it raise the issue of accessibility?

If yes: were there different offers: one for a non-accessible website and other(s) for an accessible site?

a. If yes: how much was the additional cost/s (% difference).

b. If yes, and for the case of accessible websites: were there different offers according to the standard and/or level of compliance?

<No answer>

4. How do you certify your accessibility level? By whom?

<Answer> No certification but testing and evaluation over the years by ourselves and with partners. For instance, in 2008, the accessibility and usability evaluation was done by KI-I.

See http://www.digitales.oesterreich.gv.at/site/5884/default.aspx#a2

4.4. Accessibility of the Website of European or International Organisations (Belgium)

Organisations that are active in all European countries can be confused when they want to have their website certified for accessibility. In different countries these organisations see different certification schemes and they wonder which one to choose. In fact all these national certification schemes want the same thing: more accessible website according to the W3c WCAG standards. So in theory this European organisation can order the certification from any of those certification providers and obtain the same thing.

Why is it that the national certification schemes are not exactly the same? This might be because of a legal initiative in one specific country

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but basically it is all about communication. WCAG standards are hard to promote as they are many certification organisations that feel the need to rephrase/restructure the WCAG 2.0. In order to be visible they invent labels and other "brand names" for something that is in essence the same: WCAG certification.

This definitely helps on national level but creates confusion for international and European organisations.

A trial to harmonise certification is undertaken by Euracert. Another initiative is the WCAG 2.0 Evaluation Methodology Task Force.

4.5. Danish Association of the Blind (Denmark)

If your organisation/company has a website:

1. How was it developed? In-house (own staff)? By an external service enterprise? If yes, from your own country?

<Answer> Externally, and it was a Danish company.

Who maintains it? In-house? By an external service enterprise? If yes, from your own country?

<Answer> In-house.

2 If your website is accessible, does it meet any of the following accessibility criteria?

<Answer>

Accessibility Guidelines and level of compliance

WCAG 1.0

A

AA X

AAA

WCAG 2.0

A

AA X

AAA

Other (please specify name and level of compliance):

3. If your website has been developed by an external enterprise, have you raised or did it raise the issue of accessibility?

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<Answer> Yes, first priority, and Danish Association for the Blind chose to pay the designer some money to adjust the CMS, which now helps when creating websites that have to be accessible.

If yes: were there different offers: one for a non-accessible website and other(s) for an accessible site?

A. If yes: how much was the additional cost/s (% difference).

<Answer> No.

B. If yes, and for the case of accessible websites: were there different offers according to the standard and/or level of compliance?

4. How do you certify your accessibility level? By whom?

<Answer> It is not certified as there is no such thing in Denmark. A group of our members with different skills have tested our side, among them persons with advanced knowledge about web accessibility.

4.6. Danish Institute for the Blind and Visually Impaired (Denmark)

If your organisation/company has a website:

1. How was it developed? In-house (own staff)? By an external service enterprise? If yes, from your own country?

<Answer> By an external service enterprise from Denmark.

Who maintains it? In-house? By an external service enterprise? If yes, from your own country?

<Answer> In-house.

2. If your website is accessible, does it meet any of the following accessibility criteria?

<Answer>

Accessibility Guidelines and level of compliance

WCAG 1.0

A X

AA

AAA

WCAG 2.0 A X

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AAit will meet this criteria in the future

AAA

Other (please specify name and level of compliance):

3. If your website has been developed by an external enterprise, have you raised or did it raise the issue of accessibility?

If yes: were there different offers: one for a non-accessible website and other(s) for an accessible site?

<Answer> There were there different offers: one for a non-accessible website and other(s) for an accessible site? We raised the question of accessibility, and the offer became more expensive.

a. If yes: how much was the additional cost/s (% difference).

<Answer> 25 %.

b. If yes, and for the case of accessible websites: were there different offers according to the standard and/or level of compliance?

<Answer> No, but we only asked for one standard.

4. How do you certify your accessibility level? By whom?

<Answer> Ourselves - we have experts on web and accessibility in our staff.

4.7. The perspective of a Swedish web site owner with a disability (Sweden)

The web site owner presents accessibility barriers and suggestions to solve them both as a user of e-commerce web sites and as an owner of a small company wanting to use e-commerce opportunities. The lack of back office accessibility is a barrier for people with disabilities who want to enjoy equal commercial opportunities in the single market. The perspective is available online.

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5. AcknowledgementThis Report has been prepared in consultation with the EDF ICT Email Expert Group. EDF would like to thank its members for their participation in the drafting of this Report.

EDF would also like to thank the companies operating on the web-accessibility market, as well as the owners of accessible websites for persons with disabilities, that accepted to answer the EDF survey and thus actively contributed to this Report.

6. APPENDIX

6.1. AGE-ANEC-EBU-EDF Document ‘Access Denied! Campaign for Accessible Websites’, June 2011

The document is available in word on EDF website.

6.2. AGE-ANEC-EBU-EDF Proposal for a Legal Act on Accessible Websites, June 2011

The document is available in word on EDF website.

6.3. AGE-ANEC-EBU-EDF Leaflet ‘Inaccessible Websites: Time to Act!’, July 2011

The document is available in word and PDF format on EDF website.

6.4. Contact Person at the EDF Secretariat:

Nadège Riche, EDF Policy Officer

Tel: +32/0 2 282 46 05, Email: [email protected]

More information about EDF is available on www.edf-feph.org.

Should you have any problems in accessing the document, please contact the EDF Secretariat (T: +32/0 2 282 46 00).

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