The State of Web Accessibility in the Czech Republic Public Sector
At ACTUM Digital, we regularly monitor the accessibility status of websites of both foreign and domestic companies and state entities. That is why we eagerly awaited the report which the Ministry of the Interior of Czech Republic published on December 22nd, 2021, entitled "Report of the Czech Republic on the results of monitoring the accessibility of websites and mobile applications of public sector entities for the monitoring period 2020-2021." (link to the report in Czech) The report evaluates a selected sample of state administration and self-government websites. In the Czech Republic, this report is currently the only source of information on the state of accessibility of public sector websites.
So, what are the findings of this report?
Who should be concerned?
Pursuant to the provisions and Act No. 99/2019 Coll., on the accessibility of websites and mobile applications, (in simple terms) all public sector entities have been obliged since September 23rd, 2020, to maintain their websites in accordance with EN 301 549 V2.1.2 standard, which is based on the international standard WCAG 2.1. The aim is to make the public sector accessible to everyone, including citizens with handicaps, disabilities, or impairments affecting the possibility of accessing information on the Internet. However, this global "web accessibility" trend, often seen under a numeronyme “a11y,” brings benefits to absolutely all users. If the guidelines of the WCAG standard are followed, the website is more user-friendly thanks to four basic principles: Perceivable - Operable - Understandable - Robust.
In the United States, all private companies are required to comply with these rules. This year alone, there were 4,055 lawsuits in the United States filed for non-compliance. In the EU, web accessibility will become mandatory for all (not only for public sector) as early as 2025.
The report prepared by the eGovernment department of the Ministry of the Interior evaluated 286 websites using the simplified method, 24 websites using the thorough method, and 17 mobile applications.
The results and measurement data look like this:
|Websites||Simplified methodology||Detailed methodology|
|Most common faults||
68 % - 1.4.3 Contrast (Minimum)
43 % - 1.3.1 Info and Relationships
42 % - 2.4.4 Link Purpose (In Context)
58 % -1.4.3 Contrast (Minimum)
54 % - 2.4.4 Link Purpose (In Context)
46 % - 1.1.1 Non-text Content
|Accessibility statement discrepancy||198||16|
Failures found in the audited entities, especially in the obligations:
- publish and update the website accessibility statement in accordance with the law,
- make the website perceptible - in particular, to ensure compliance with success criterions 1.4.3 Contrast (Minimum), and 1.3.1 Info and Relationships,
- make the website operable - in particular, to ensure compliance with the success criterion 2.4.4 Link Purpose (In Context).
What can we read from that?
- Authorities and institutions that are obliged to keep websites compliant with standard EN 301 549 break the law.
- Most entities do not even have a correctly prepared and published Accessibility Statement. This means, for example, that the user does not have a chance to find out which parts of the website already meet the standard, which do not, and why.
Even more important is what we cannot read from the report:
- Which websites / mandatory entities have been monitored.
- What result was found for each monitored website.
- Detailed description of compliance with the WCAG 2.1. guidelines for each criterion of the tested sites.
- The exact methodology for testing the individual success criteria according to EN 301 549 / WCAG 2.1 is not known.
The result of the measurement is therefore actually only an indication of the percentage of the three most common errors. However, such information is completely insufficient for accessibility professionals and the public, even though it meets the requirements of Directive (EU) 2016/2102 of the European Parliament and of the Council.
The report also brings other interesting findings:
- The report states that "none of the automated tools can fully verify compliance with accessibility criteria at this time".
- This means that the simplified method of testing 286 websites has literally zero evidence.
- This finding is not unexpected. According to various research and our experience, automated tools are able to detect only about 25% of failures, which must be validated manually. The survey methodology itself thus shows serious shortcomings, which make it impossible to obtain relevant outputs.
- Although the report should be completely transparent, the results are presented only to the entities that were in the scope of the monitoring. The public is not informed.
- Such an approach does not seem right to us. The public sector should be completely barrier-free and transparent at the same time, even beyond the current legislation. It is not only the matter of approach to citizens, but also a good example for the private sector in terms of approach to customers, especially to those with specific needs.
So, how to make it better?
We believe that it is not enough just to place a filled in template of the Accessibility Statement on the website and thus "fulfill" the obligation. Even monitoring and testing with automated tools does not ensure sufficient compliance with the law. Each obligated entity's website should be evaluated in a proper accessibility audit by an independent auditor in accordance with the currently applicable WCAG 2.1 methodology. This audit provides a sufficient basis not only for the Accessibility Statement but will also serve as a basis for remediation of the website. Further, the site should be regularly monitored to ensure that it is still compliant over time, given the number of dynamic changes that websites typically go through.
The Accessibility Report of the Ministry of the Interior will evaluate the condition of the websites every year, again on a set sample. We believe that the public will be better informed next year and that the above-mentioned shortcomings will be remedied. We believe that barrierless internet is an essential part of human rights today. Who else should offer accessibility to all without exception at this moment, but the state administration and self-government? And we are not talking about the fact that public sector institutions should not break the law.
In the next articles that we are preparing for you, we will deal in detail with the websites of some entities that are a mandatory subject by law. We will pay particular attention to the compliance of the Accessibility Statement compared to reality and will point out shortcomings. At the same time, we will show concrete examples of unresolved website accessibility fails, especially those that we believe can be eliminated with minimal effort.