Annex 2: Web accessibility policies and standards

Introduction

An accessibility policy is the set of rules and regulations that indicate what decision-makers within an organization must do to make sure that accessibility is considered and implemented across the organization’s structure. The policy provides guidance to employees and governs the way in which the importance of accessibility is communicated. An accessibility policy not only provides the foundations on which to build any accessibility programmes or initiatives, but it also ensures that long-term, strategic accessibility efforts have continuity, and designates roles and responsibilities across the organization. An accessibility policy sets out the formal rules put in place by an organization to achieve its accessibility goals and outlines how an organization should operate and interact with its employees and customers. The aim of the principles and guidelines set forth in an accessibility policy is to ensure that an organization’s internal and external-facing digital assets (websites in particular) comply with the provisions set out by the corresponding national accessibility law and accessibility standards. A web accessibility policy is designed to guide all internal decisions, strategies and processes pertaining to digital accessibility within an organization.

Most private-sector organizations around the world still do not have a strong and consistent digital accessibility policy, which hinders general progress in improving the extension and implementation of accessibility. While many public sector entities in certain countries and regions (such as Australia, Canada, the European Union and the United States) do have digital accessibility policies that mandate the use of specific accessibility standards and regulations, in many cases the enforcement mechanisms are not strong enough. As a result, the implementation of accessibility in public-facing websites and services, such as e-government portals or IT procured for internal or external use, remains low.

Causes of absent or weak enforcement of digital accessibility policies:
Absence of organizational leadership and culture
Absence of commitment by organizational leadership
Poor incorporation of policy into key processes
Absence of, or low, technical knowledge and awareness

While the CRPD contains defined obligations in relation to desired outcomes by application area, it does not provide specific technical guidance. It is therefore incumbent upon policy-makers, regulators, civil society and industry to identify and define solutions tailored to their individual country’s needs, international standards and global economies of scale in order to lower costs and promote interoperability. Depending on each country’s legal and institutional framework, different aspects of ICT policy and regulation may be the responsibility of different bodies and stakeholders, which will need a range of tools, including laws, policies, regulations, standards, self-regulatory/co-regulatory codes and guidelines, on which they can draw as a comprehensive framework for addressing ICT accessibility.

Steps for developing an accessibility policy

Assess current policies and identify any gaps. Organizations – especially public sector organizations – are encouraged to consult persons with disabilities when developing accessibility policies and plans in order to obtain their inputs as to what the main barriers that affect them are and how to remove them and, consequently, ensure that accessibility policies and plans are correctly geared towards addressing real needs. Ways to do this include engaging employees, customers or volunteers and running brainstorming sessions to identify programmes, services, products and situations that are known or suspected to generate barriers to people with disabilities.
Organize and write the policy; for example, “[Name of organization] will provide, on request, information in an accessible format or with communication support to persons with disabilities, in a manner that takes into account their disability.”
Publish the policy.
Review and update the policy. Public sector organizations are encouraged to publish annual status reports (in accessible formats) to inform the general public about what has been accomplished.
The Model ICT Accessibility Policy Report

The Model ICT Accessibility Policy Report developed by ITU in collaboration with G3ict provides a framework to guide countries in developing policies. Drawing on legislation, regulations, standards and guidelines, the report addresses various facets of the ICT sector with the aim of assisting policy-makers, regulators and other stakeholders (including non-governmental organizations, organizations of persons with disabilities, and members of parliament) in building policies on public ICT access, mobile communications, television/video programming, web accessibility and public procurement. The report set out good practices for policy development and implementation across a range of ICT sub-sectors (public communications, mobile communications, television/video programming, the Internet and public procurement) on the basis of the following principles:
Mainstreaming ICT accessibility through inclusive language, definitions and provisions in policies, laws and regulations;
Identifying key steps to promote ICT accessibility;
Raising awareness among key stakeholders;
Building consensus and promoting inclusive policy-making through national debate;
Promoting public-private partnerships;
Setting clear targets and conducting periodic reporting to monitor implementation;
Promoting training, capacity-building and educational programmes on disability awareness.
ITU has also developed a freely available toolkit and self-assessment for ICT accessibility implementation, which provides fundamental knowledge on the topic to facilitate and incentivize global implementation and inclusion. The self-assessment aspect is based on the CRPD and ICT-related requirements. A video guide is available with captions in Arabic, Chinese, English, French, Russian and Spanish.

What to include in a web accessibility policy

The W3C Web Accessibility Initiative provides guidance on defining and developing a policy for creating, managing and delivering accessible websites and an example of a comprehensive organizational policy.

The key components to include in a web accessibility policy are:

  • a summary statement(s) that explicitly justifies the policy, describes the expected outcomes and sets out what the key steps are, how they should be completed and when they should be taken;
  • the date on which the policy comes into effect;
  • the scope of the policy, detailing which web applications fall under the policy and whether there are any exceptions;
  • the technical standard to which the organization’s web assets should conform. The most commonly used standards are:
    1. WCAG 2.1;
    2. the Authoring Tool Accessibility Guidelines;
    3. the User Agent Accessibility Guidelines;
    4. EN 301 549;
    5. Section 508 of the Rehabilitation Act of 1973 (United States);
  • a provision for procurement, stating that accessibility should be included in all requests for proposals and contracts to purchase web-based products and services;
  • the consequences if units or individuals choose non-conformance, including a detailed description of what happens if the policy is not followed;
  • a description of the mechanism for ongoing review, including who is responsible.19

A web accessibility policy must not be confused with an accessibility statement, which is a public declaration of the organization’s commitment to digital or web accessibility.

European Union policies

In the European Union, the Web Accessibility Directive mandates that all websites and mobile applications of public sector bodies must meet standard EN 301 549, which is aligned to WCAG 2.1. All European Union member States should already have transposed the Directive into their national laws by 23 September 2018. From September 2020, all websites must be accessible, and all mobile applications must be accessible from June 2021.20

Figure 1 – Timeline of the publication of the Web Accessibility Directive

Source: ITU, “ICT accessibility assessment for Europe region ”, 2021.

With most job-seeking activities being performed online, website accessibility should be a given. Unfortunately, the opposite is the norm, as most websites are still highly inaccessible. Research indicates that, despite global calls and the adoption of requirements such as the Web Accessibility Directive, the accessibility gap is widening as the global digital transformation process accelerates. When career websites, and, more specifically, online job application forms, contain accessibility barriers, jobseekers with a disability face challenges in finding or applying for jobs, and employers looking for qualified candidates miss out on valuable talent.

19 United States, National Center on Disability and Access to Education, “Writing a solid web accessibility policy: Cornell gets it right”.
20 ITU, “ICT accessibility assessment for Europe region ”, 2021.