The Ministry of Interior is set to lead by example, but it is already failing in its foundations

In the last article we dealt with the summary report of the eGovernment department of the Ministry of the Interior for the EU on the state of the accessibility of websites in the public sector. The text of the article can be found here: https://www.actumdigital.com/insights/web-accessibility-czech-republic.

Today, we will switch from the general evaluation of web accessibility in the state administration to a look at specific pages. We will start at the website of the Ministry of the Interior of the Czech Republic, in the sense of Act No. 99/2019 Coll., on the accessibility of websites and mobile applications. This means that it is obliged to have its website in accordance with the standard EN 301 549 V2.1.2, which is based on the international standard WCAG 2.1. 

And not only that. The Ministry of the Interior is responsible for compliance supervision of websites with the standard for other state and public administration entities. The ministry team is responsible for regular monitoring and reporting. In addition, this ministry published the Methodological Instruction with Requirements, which is intended for other obligated public administration entities in the Czech Republic. Therefore, we expect the website to be in full compliance with the standard (and thus with the law) and will in principle be a model for the rest of the public sector. 

We took a brief look at the website preferentially. We emphasize in advance that we did not perform a full-conducted audit according to the internationally recognized WCAG 2.1 methodology. We focused only on some criteria of success and their compliance with level A, or higher-level AA. 

Web Content Accessibility Guidelines, or WCAG, is considered to be the benchmark for website accessibility. Created by the World Wide Web Consortium (W3C), following WCAG guidelines is the best and the easiest way of making your website usable for all of your customers.  

Accessibility Statement

A mandatory published Accessibility Statement is easy for a site visitor to find, as the link is listed in the footer of all pages viewed. At https://www.mvcr.cz/clanek/prohlaseni-o-pristupnosti.aspx, you can find the text required by law, i.e., references to laws, date of issue of the statement and contacts. We were most interested in the section "Inaccessible Content" stating which of the criteria of the standard EN 301 549 V2.1.2 the site does not meet. 

The ministry lists only two criteria that do not comply: 

• Some links do not contain an identification of their purpose in the form of a label (Rule 2.4.9 Purpose of the link (only from the text of the link))
• Some images do not contain alternative text (Rule 1.1. Text alternatives) 

At the same time, however, the statement pleases with this promise: "Compliance with the law is currently underway, provided that the conditions are met by 2021 at the latest."

What did we find?

The following criteria in the lowest A level of compliance are not met and even not mentioned in the Accessibility Statement: 

1.2.2: Captions (Prerecorded) – fail

• most of the videos do not have captions (open or close)

E.g., majority of videos in this section: https://www.mvcr.cz/videozpravodajstvi.aspx 

2.4.1: Bypass Blocks – fail

• bypass control element is available, but it does not work as it should

Instead of moving the user's focus to the content and the possibility of skipping repetitive navigation, the element from any page always redirects the user back to the introductory page

3.1.1: Language of Page – fail

• The English version does not reflect the English language in html (lang attribute) used by the web page.

This common fail affects assistive technologies, typically screen readers.  

In AA level criteria we have found immediately these shortcomings: 

1.4.5: Images of Text – fail

• images of text are used, they cannot be visually customized (font, size color, background) even in the alternative text version

1.4.10: Reflow – fail 

• website is not responsive

If the content is enlarged to 400%, the user is required to scroll vertically and horizontally to reveal all the content, even in alternative text version webpage layout. 

3.1.2: Language of Parts - fail

• The human language in some passages in the content is not programmatically determined (lang attribute). 

This makes it possible for user agents and assistive technologies to present content according to the presentation and pronunciation rules for that language. (e.g. https://www.mvcr.cz/migration/article/other-languages.aspx)

Fails in Accessibility Statement 

• According to our findings, a description of other inaccessible parts is missing.
• Contrary to the Methodological Instruction, the reason why the site is not in full compliance with the law is not stated.
• The statement page is only available in Czech. Even when navigating from another language version. 

Verdict

As a WCAG websites accessibility auditing company, we could not issue a verdict other than "DOES NOT MEET the requirements of WCAG 2.1. Level A". 

We focused on those criteria that, in our opinion, can be eliminated with less effort, can significantly affect the user experience of people with some specific needs, and are obvious to an experienced auditor immediately without the use of other tools.

Monitoring

The accessibility statement states, "The method of self-assessment performed by the Ministry of the Interior was used to prepare this statement." We do not know the details of this method. But we believe that the standard, if it is to be truly functional, should be adhered to in its entirety. In our case, this means that when auditing our clients' websites, we only adhere to the given methodology, in our case, WCAG at the chosen level. This also applies to the subsequent evaluation method.

Therefore, if the Ministry of the Interior's website is evaluated as satisfactory by the Ministry's internal team, then we have doubts about the overall credibility of the "Report of the Czech Republic on the Accessibility of Public Sector Websites and Mobile Applications Monitoring”. We will certainly deal with other aspects of public entities and their evaluation according to WCAG.

Summary

Despite the fact that these are websites of the public accessibility web accessibility authority in the Czech Republic, these websites do not meet the required standard at the basic level. Shortcomings can even be found in the Accessibility Statement, which does not list all the criteria with shortcomings and the reason for not meeting them.

The striking fact is that the Accessibility Statement has not been updated since September 14th, 2020 (i.e. from the time when the Ministry of the Interior was already bound by law to meet all conditions). The sentence "Compliance with the law is currently being worked on with the assumption that the conditions will be met during the year 2021 at the latest," could be understand therefore also as, “We promise a Moon.“

Our aim is to remove the barriers that people with special needs, such as disabilities and impairments may experience. However, adhering to these guidelines is always beneficial for all users. At the same time, we consider public administration to be a place where web accessibility should be a matter of course. And not just because it's required by law.

Older articles about internet accessibility in public sector: The State of Web Accessibility in the Czech Republic Public Sector

Sources:

• web of The Ministry of the Interior: www.mvcr.cz 
• Accessibility Statement: https://www.mvcr.cz/clanek/prohlaseni-o-pristupnosti.aspx
• More about accessibility from The Ministry of the Interior: https://www.mvcr.cz/clanek/pristupnost-internetovych-stranek-a-mobilnich-aplikaci.aspx
• Report of the Czech Republic on the Accessibility of Public Sector Websites and Mobile Applications Monitoring Only in Czech): https://www.dia.gov.cz/wp-content/uploads/2023/03/Zprava_CR_o_vysledku_monitorovani_pristupnosti_za_2020-2021_-_20211222.pdf
• WCAG: https://www.w3.org/WAI/standards-guidelines/wcag/
• W3C consortium: https://www.w3.org