Accessibility Statements V3

V3 - May 2020 Update of my Accessibility Statements and other guidance research is now live. This research shows accessibility statements and other accessibility guidance on a range of websites across the UK. Accessibility statements are a required document under the Public Sector Bodies (Websites and Mobile Applications) Accessibility Regulations 2018 (PSBAR) in which all new websites must have one from launch and all websites created before 23rd September 2018, must have a statement after 23rd September 2020.

You can also look back at V1 - September 2019 and V2 - October 2019.

As mentioned before, I planned to make updates to this research to provide more up to date information as we move through the first UK monitoring period, and reach the 23rd September 2020 deadline.

There has also been some fantastic development regarding the research as it has now been discussed by the European Commission Web Accessibility Directive Experts Group (EU WADEX) back in December 2019 in which it was given as the only example of proactive monitoring of statements available across the EU at the time.


What’s new in V3

The V3 May 2020 update contains the same great information previously seen however I have expanded the reach of the research and have continued refining the methods of grading to make it even more clear where improvements need to be made.

The latest research now covers an expanded list of organisations which has grown to include:

  • Rail Companies
  • Bus Companies
  • Some utilities companies
  • Supermarkets
  • Disability Assessment Centres
  • Also the side projects of Denmark and Luxembourg!


Why have we chosen to include these companies when many of them are private entities not public sector?

Within the regulations there is a line that clarifies it can cover non-government organisations if they provide “essential services to the public” or "specifically address the needs of, or are meant for, persons with disabilities". Now while the Cabinet Office has made it clear that PSBAR will never apply to non-public sector organisations, I wanted to take a broader look at these definitions including The UN definition of essential services which does include utility providers.

This is a helpful definition, however I do not feel that it aligns with the outcome of accessibility for end users very well. Some companies (such as food provision) that are listed as essential live in a competitive market, so if you have a problem with their accessibility you can always go somewhere else. While other services you don’t necessarily have a choice in are not included. For example train companies or water providers.

This definition of services essential to the public has become even more of a vital debate during the current pandemic as the nation now more than ever relies on the accessibility of online services for things such as food.

Despite the fact that many of these organisations I have listed do not need to comply with PSBAR, I think that given how current circumstances have highlighted the need for "essential" services to be accessible, we should be looking to PSBAR as a standard of good practice and encourage other organisations to improve their accessibility anyway.

My proposed grouping for organisations that should consider meeting accessibility requirements and the regulations example as a form of good practice (even if they are not legally required to do so) is as follows;

Organisations should align to the PSBAR regardless of scope if they;

  1. Hold an area monopoly for their function (for example water companies or train lines), or;
  2. A user has no choice but to interact with the organisation for any other reason, or;
  3. The organisation is defined as providing essential services (for example supermarkets, or any other service the Government deemed necessary to remain open for the public good during the enforced 2020 quarantine), or;
  4. The organisation is defined as providing services specifically address the needs of, or are meant for, persons with disabilities (for example all disability assessment centres even if they are private businesses).

Thus, with my definition in place I have decided to look at the accessibility guidance of;

  • Rail companies because each company has an area monopoly and users cannot get a competitor's train if they don’t like the service.
  • Bus companies for the same reason regarding area monopolies, the bus routes are run on contract so there is no alternative. For many people with disabilities trains and buses are their only viable forms of transport if they cannot drive, so I feel both should be included.
  • Water companies because they have area monopolies and users cannot in many cases choose an alternate provider.
  • The National Grid because it is listed as an essential service by the UN.
  • Supermarkets because their online shopping services are a vital method for many isolated individuals to remain fed during the quarantine. I feel that given the current restrictions on movement and increase in people using online delivery, many users no longer have the choice of going to a competitor because sooner availability of a delivery slot by a less accessible service may mean the difference between being fed or not for some users.
  • Disability assessment centres because they provide services that are specifically to address the needs of persons with disabilities (even if they are private businesses).

In contrast I am not going to look at Electricity and Gas providers despite these being listed as “essential” by the UN definition, because there is no reason that a user cannot switch these services.


A note on compliance

Since the last update, the Government Digital Service (GDS) have specified additional ‘legally required’ parts of an accessibility statement which now must be followed. You can see this in full in their sample accessibility statement.

What a statement must now deliver is:

  • Contact method for reporting accessibility issues
  • Information on the Enforcement Procedure
  • Specific sentence detailing the level of compliance (full, partial, not)
  • Known issues and reasonable adjustments or other actions being taken to resolve the issues. This must be in the specific heading structure detailed below and you must include these headings:
    • Non accessible content (h2)
      • Non-compliance with the accessibility regulations (h3)
      • Disproportionate burden (h3)
      • Content that’s not within the scope of the accessibility regulations (h3)
  • Specific sentence detailing when the statement was prepared.

Following this update, I have decided to continue to monitor compliance based on the description of accessibility statement requirements in the main regulations document. However for all organisations that I have marked as compliant, I have added comments that detail what information they need to include to become fully compliant with all requirements including those set by GDS based on the adopted EU model statement. This means that many statements I list as compliant may not meet GDS’s expectations and may be flagged in their monitoring.


Grading Method

Over the previous 2 versions the variety of ‘Grades’ an organisation might fall into has been increased to better reflect the range of guidance made available.

I would like at this point to clarify something about the research. Many of the organisations that have been included are not yet required to publish a compliant accessibility statement as the final deadline for existing websites under the regulations is September 23rd 2020. So they will be judged on whatever Accessibility guidance they do have published.

With that said, I think any organisation that has not yet published a statement within the currently elapsed 20 months since the regulations went live for their ‘main’ website and arguably top priority communication channel, is significantly behind where they need to be to be delivering accessibility effectively and meeting the 2020 deadline for their entire digital estate.

V3 sees additions made to the grading and more clarification. The new grades are as follows and I promise that I will not be adding any more.

Compliant Statement

This grade represents statements that deliver the compliance requirements of the accessibility statement.

To meet this grade an accessibility statement must:

  • Identify known issues
  • Identify workarounds or actions being taken to fix issues
  • Provide a contact method
  • Direct to the enforcement procedure
  • Include required wording for statement of compliance

Good Attempt

This grade represents organisations that may not have delivered on all the points of compliance under the regulations but deliver on useful support to end users.

To meet this grade an organisation will:

  • Deliver on two or more of the points listed to meet compliance
  • Provide website specific guidance, guidance on tools on the website, or other support available such as BSL or alternate format services

Partial Attempt

This grade represents organisations that provide ‘some’ accessibility guidance.

To meet this grade an organisation will:

  • Deliver on one or more of the points listed to meet compliance
  • Have a mixture of elements characterising good and poor attempts. For example providing some website specific guidance but also referencing outdated legal information
  • Provided generic accessibility support information

Poor Attempt

This grade represents organisations that provide ‘poor’ accessibility guidance.

To meet this grade an organisation will:

  • Deliver one or no points listed to meet compliance (standard is no points, with occasions where the poor guidance or complete lack of all other content outweighs the inclusion of a contact method). For example if a page was a single line with a contact email
  • Provide outdated standards information. For example specifically mentioning WCAG 1 or testing by nonexistent companies
  • Provide outdated or incorrect legal information. For example referencing the Disability Discrimination Act 1995 while being an organisation that operates specifically in any geographical area besides Northern Ireland
  • Provides outdated and generic support information. For example mentioning testing completed using the Netscape browser which ceased to exist in 2008
  • Have not included the page directly navigable from the home page so it has to be searched for
  • Have a page but include either;
    • No information whatsoever, or
    • A couple of sentences saying for example; the website was built accessibly and if there are any issues it is a user issue, or a problem with their browser

No Statement

This grade represents organisations that have not published an accessibility statement in any format.

Accessibility Statements ‘Stock Market’

I think it is important to show the changes in saturation of compliance statements across each group. So from now on I will be including a ‘stock market’ style rise and fall section of accessibility statements in each group, which will show the number of compliant statements. (Hopefully only rises).

Local Government: 20.3% (+9.4%)

Universities: 30.8% (+7.9%)

Police Forces: 41.7% (+10.4%)

Fire & Rescue Services: 11.3% (+5.7%)

Colleges: 2.9 (+1.9%)

NHS Organisations: 5.93% (+1.8%)

Disability Assessment Centres: 6.6%

Utilities Companies: 0%

Regulators: 8.8%

Other: 2.7%

Bar chart showing compliance increases. Information provided in text above.

Findings

You can download the Version 3 May 2020 dataset to look at the information gathered for yourself.

I have also created an online map that has been embedded below for those who may wish to view the information with its geographical component.

Overall Results

Overall Results

The below lists show statistics for the overall results of the study. The first list shows the number of organisations in each category.

  • Compliant Statements: 202
  • Good Attempt: 88
  • Partial Statements: 247
  • Poor Attempt: 703
  • No Statements: 584
  • Total: 1824

The second list shows the percentage breakdown for each section.

  • Compliant Statements: 11.1%
  • Good Attempts: 4.8%
  • Partial Statements 13.5%
  • Poor Attempts: 38.5%
  • No Statements: 32%

Overall we are seeing a positive trend toward compliance with 92 more compliant statements present since October 2019.

Local Government

The below lists show statistics for the Local Government results of the study. The first list shows the number of Local Government organisations in each category.

  • Compliant Statements: 75
  • Good Attempt: 25
  • Partial Statements: 69
  • Poor Attempt: 157
  • No Statements: 43
  • Total: 369

The second list shows the percentage breakdown for each section.

  • Compliant Statements: 20.3%
  • Good Attempts: 6.8%
  • Partial Statements 18.7%
  • Poor Attempts: 42.5%
  • No Statements: 11.7%

Universities

The below lists show statistics for the Universities results of the study. The first list shows the number of Universities in each category.

  • Compliant Statements: 41
  • Good Attempt: 17
  • Partial Statements: 13
  • Poor Attempt: 52
  • No Statements: 10
  • Total: 133

The second list shows the percentage breakdown for each section.

  • Compliant Statements: 30.8%
  • Good Attempts: 12.8%
  • Partial Statements 9.8%
  • Poor Attempts: 39.1%
  • No Statements: 7.5%

Police Forces

The below lists show statistics for the Police Forces results of the study. The first list shows the number of Police Forces in each category.

  • Compliant Statements: 20
  • Good Attempt: 0
  • Partial Statements: 3
  • Poor Attempt: 15
  • No Statements: 10
  • Total: 48

The second list shows the percentage breakdown for each section.

  • Compliant Statements: 41.7%
  • Good Attempts: 0%
  • Partial Statements 6.3%
  • Poor Attempts: 31.3%
  • No Statements: 20.8%

Fire & Rescue Services

The below lists show statistics for the Fire & Rescue Services results of the study. The first list shows the number of Fire & Rescue Services in each category.

  • Compliant Statements: 6
  • Good Attempt: 2
  • Partial Statements: 9
  • Poor Attempt: 24
  • No Statements: 12
  • Total: 53

The second list shows the percentage breakdown for each section.

  • Compliant Statements: 11.3%
  • Good Attempts: 3.8%
  • Partial Statements 17%
  • Poor Attempts: 45.3%
  • No Statements: 22.6%

Colleges

The below lists show statistics for the Colleges results of the study. The first list shows the number of Colleges in each category.

  • Compliant Statements: 11
  • Good Attempt: 5
  • Partial Statements: 55
  • Poor Attempt: 136
  • No Statements: 177
  • Total: 384

The second list shows the percentage breakdown for each section.

  • Compliant Statements: 2.9%
  • Good Attempts: 1.3%
  • Partial Statements 14.3%
  • Poor Attempts: 35.4%
  • No Statements: 46.1%

NHS Organisations

The below lists show statistics for the NHS organisations results of the study. The first list shows the number of NHS organisations in each category.

  • Compliant Statements: 26
  • Good Attempt: 11
  • Partial Statements: 67
  • Poor Attempt: 224
  • No Statements: 110
  • Total: 438

The second list shows the percentage breakdown for each section.

  • Compliant Statements: 5.9%
  • Good Attempts: 2.5%
  • Partial Statements 15.3%
  • Poor Attempts: 51.1%
  • No Statements: 25.1%

Disability Assessment Centres

The below lists show statistics for the Disability Assessment Centres results of the study. The first list shows the number of Disability Assessment Centres in each category.

  • Compliant Statements: 17
  • Good Attempt: 22
  • Partial Statements: 10
  • Poor Attempt: 39
  • No Statements: 169
  • Total: 257

The second list shows the percentage breakdown for each section.

  • Compliant Statements: 6.6%
  • Good Attempts: 8.6%
  • Partial Statements 3.9%
  • Poor Attempts: 15.2%
  • No Statements: 65.8%

Utilities Companies

The below lists show statistics for the Utilities Companies results of the study. The first list shows the number of Utilities Companies in each category.

  • Compliant Statements: 0
  • Good Attempt: 1
  • Partial Statements: 4
  • Poor Attempt: 11
  • No Statements: 10
  • Total: 26

The second list shows the percentage breakdown for each section.

  • Compliant Statements: 0%
  • Good Attempts: 3.8%
  • Partial Statements 15.4%
  • Poor Attempts: 42.3%
  • No Statements: 38.4%

Industry Regulators

The below lists show statistics for the Industry Regulators results of the study. The first list shows the number of Industry Regulators in each category.

  • Compliant Statements: 7
  • Good Attempt: 2
  • Partial Statements: 12
  • Poor Attempt: 24
  • No Statements: 34
  • Total: 79

The second list shows the percentage breakdown for each section.

  • Compliant Statements: 8.9%
  • Good Attempts: 2.5%
  • Partial Statements 15.2%
  • Poor Attempts: 30.4%
  • No Statements: 43%

Other Results

I have also looked at Bus Companies, Train Companies and Supermarkets. Each of these sets on their own are too small so have been combined into an ‘other’ category. The below lists show statistics for these other results of the study. The first list shows the number of other organisations in each category.

  • Compliant Statements: 1
  • Good Attempt: 3
  • Partial Statements: 5
  • Poor Attempt: 20
  • No Statements: 8
  • Total: 37

The second list shows the percentage breakdown for each section.

  • Compliant Statements: 2.7%
  • Good Attempts: 8.1%
  • Partial Statements 13.5%
  • Poor Attempts: 54.1%
  • No Statements: 21.6%

Observations

Good

  • Police, Local Government and Universities are all still seeing a good increase in the number of compliant statements.
  • Many of the statements I have marked as compliant already meet the full GDS requirements, but everyone should check just to be safe.

Bad

  • There is still a significant amount of organisations claiming disproportionate burden which through my other research can be seen to often lack supporting evidence. I know of more than 100 claims now and have marked live claims in the notes within the dataset.
  • Disability assessment centres not only have a lack of accessibility information about their websites, but also many also lack any readily available information about privacy or cookie policies, GDPR and subject access requests etc.

Common Pitfalls

  • Saying you will specifically not publish a statement.
  • Mentions of Netscape, AOL or IE5 guidance all of which are ancient browsers and demonstrate the information has not been updated in a long time.
  • Mentions of WCAG 1.0 which as a standard was superseded in 2008. the WCAG 1.0 requirements are very different to the latest 2.1 requirements. This again demonstrates that information has not been updated in a long time.
  • Mentions of the Disability Discrimination Act (DDA) 1995 by organisations across England. The DDA was superseded by the Equality Act 2010 everywhere apart from Northern Ireland.


Up Next

As I add more and more organisations to the list this becomes a more and more substantive task with each iteration. I will produce more updates to monitor the compliance jump over September 2020 but we will then just have to see if I do this again.

I am interested in how compliance looks across Europe and as such will be doing more accessibility statements research for other countries in the future.


European Research

I have been discussing for some time a project to catalogue accessibility statements across Europe. To start my look at Europe, I began looking at the methodology by which government is categorised across countries (NUTS Nomenclature of Territorial Units for Statistics). Then I decided to start with a couple of country as a test. For no reason in particular I chose Denmark and Luxembourg.

If people are interested in this expansion of the list to other countries and can help me by directing to lists of government organisations etc. I would like to hear from you.

Denmark

You can download the Denmark dataset to look at the information gathered for yourself.

I have also created an online map that has been embedded below and you can find the information in the main map above for those who may wish to view the information with its geographical component.

Luxembourg

You can download the Luxembourg dataset to look at the information gathered for yourself.

I have also created an online map that has been embedded below and you can find the information in the main map above for those who may wish to view the information with its geographical component.

I am particularly concerned about my look at the Luxembourg municipalities (communes) as it appears that none have any significant information on website accessibility. Now this could be down to me looking for it in the wrong places, or there are other organisations in Luxembourg that I should be looking at so any information people have on the subject would be much appreciated.

Spain

You can download the Spain dataset to look at the information gathered for yourself.

I have also created an online map that has been embedded below and you can find the information in the main map above for those who may wish to view the information with its geographical component.

Sources

For this research I used a number of sources to develop the dataset. For each of the groups I had to find organisational lists. The ones I used are:


Get in touch

I hope that people find this research and my thoughts on statements and possible scope options for the regulations of use. If you want to talk about this research or want help with ensuring your compliance with the Public Sector Bodies (Websites and Mobile Application) Accessibility regulations 2018 please contact us.


Disclaimer

This research is not perfect and was completed as a personal endeavour that I gladly share publicly in the hope that it can prove useful to improving accessibility across the UK Public Sector.

In this research I have included a number of bodies that are not in scope of the Public Sector Bodies (Websites and Mobile Applications) Accessibility Regulations 2018 under the current interpretation. In this research I am at no point speculating that any of these organisations are not performing their legally required duty under they Equality Act 2010 or any other legislation.

Transport organisations (bus and train companies), supermarkets, utilities companies, and many of the disability assessment centres are private organisations. Whether some come in scope of the regulations because of the 'essential' description or for their focus on providing services specifically for people with disabilities, has not yet been confirmed by the Government Digital Service and as such my suggestion for the interpretation of those clauses is just a proposed idea.

This research is for general information only and is not legal advice. All Able Ltd will not accept liability for any loss, damage or inconvenience arising as a consequence of any use of, or the inability to use any information contained within this research.