How to make your public sector website or mobile app more inclusive and meet accessibility standards
Making a website or mobile app accessible means making sure it can be used by as many people as possible.
This includes those with:
- impaired vision
- motor difficulties
- cognitive impairments or learning disabilities
- deafness or impaired hearing
Accessibility means more than putting things online. It means making your content and design clear and simple enough so that most people can use it without needing to adapt it, while supporting those who do.
For example, someone with impaired vision might use a screen reader (software that lets a user navigate a website and ‘read out’ the content), braille display or screen magnifier. Or someone with motor difficulties might use a special mouse, speech recognition software or on-screen keyboard emulator.
In the UK, 1 in 5 people have a disability.
Why it’s important
People may not have a choice when using a public sector website or app, so it’s important they work for everyone. The people who need them the most are often the people who find them hardest to use.
Accessible websites are better for everyone. For example, they are faster and easier to use, and appear higher in search engines.
You may also be breaking the law if your public sector website or app doesn’t meet accessibility standards.
Most public sector websites do not currently meet accessibility standards. For example, a recent study found that 4 in 10 local councils’ homepages failed basic tests for accessibility.
Common accessibility problems include websites that can’t be navigated using a keyboard, inaccessible PDF forms that can’t be read out on screen readers, and poor colour contrast that makes text difficult to read, especially for partially sighted people.
What you need to do
New regulations came into force for public sector bodies on 23 September 2018.
They say you must make your website or mobile app more accessible by making it ‘perceivable, operable, understandable and robust’.
You can do this by meeting the accessibility standards.
You must also:
- publish an accessibility statement - this must include details of content that doesn’t meet accessibility standards
- if someone requests it, provide an accessible alternative within a reasonable time for content that doesn’t meet the standards
Public sector bodies include central government, local government, and some charities and other non-government organisations.
There are particular types of bodies and content that are exempt from the new regulations.
You can get help if you’re not sure if your organisation is a public sector body.
The new legal requirements build on your existing obligations to disabled people under the Equality Act 2010 (or the Disability Discrimination Act 1995 in Northern Ireland). These say that all UK service providers must make ‘reasonable adjustments’ for disabled people .
Meeting accessibility standards can help show that you’re making reasonable adjustments for disabled users of your website or app.
You also need to provide information in another format if someone requests it, where it’s reasonable to do so.
Your website or app will meet the new public sector requirement to be more accessible if it complies with the international WCAG 2.1 AA accessibility standard.
In some situations you may not need to fully meet this standard for all of your website or app.
This can be the case if making the changes to your website or app would cause what the new legal requirements call a ‘disproportionate burden’.
The government will be monitoring public sector websites and apps to check they follow these rules and aren’t breaking the new legal requirements.
The deadline for meeting the standard and the steps you need to take depend on whether you have:
- a new website (published on or after 23 September 2018)
- an existing website
- a mobile app
What counts as disproportionate burden
If you want to argue that something is a disproportionate burden, you will need to carry out an assessment. When you’re doing the assessment, you can only consider factors that are relevant. These include:
- the benefits to users with disabilities of meeting the standards
- the cost of meeting the standards
- how it’s used by disabled people - how often and for how long
- your organisation’s size and resources
You can’t take into account irrelevant things like lack of time or knowledge, or because you haven’t given it priority.
New websites must usually be fully accessible and meet the WCAG 2.1 AA standard.
It’s very unlikely that you could make a valid argument that doing this is a disproportionate burden. This is because most modern websites, and the software for managing them, meet the accessibility standards.
Your new website must meet the standards by 23 September 2019.
Accessibility standards apply in the same way for apps, but the deadline for meeting them is 23 June 2021.
We recommend that you make sure your new website or app meets the standards by:
- making sure the team or agency responsible for your website or app understands WCAG 2.1
- making sure the content is accessible
- doing some basic accessibility tests before you sign off your new website or app
Existing websites must meet the accessibility standards from 23 September 2020.
You may not have to meet the standard for your whole website if doing so would be a disproportionate burden.
We recommend that you act now so that you:
- make sure new content you publish is accessible - so you don’t have to go back and fix it
- make a plan to meet the standards by the deadline (and identify anything that’s disproportionate to fix)
If you’re not sure what would be disproportionate in your situation, talk to your legal adviser.
You’re legally responsible for your website meeting accessibility standards, even if you’ve outsourced your website to a supplier.
Making a plan to meet accessibility standards
You‘ll need to identify which parts of your website need fixing before you can work out what to prioritise.
Identify what you need to fix
Start by finding out which parts of your website meet accessibility standards and which parts don’t.
As well as telling you what you’ll need to fix, you’ll need this for your accessibility statement.
To work out what is and isn’t accessible, you’ll need to work with the people involved in running your website, including:
- the team or agency that’s responsible for maintaining the website code
- people involved with creating content
- any other suppliers who provide forms, tools or transactions
You’ll then need to work out how you’ll identify accessibility problems. One way is to check your website using automated and manual accessibility tests. These tests will uncover many issues with code, design and content.
But if you’re a larger organisation, for example, you may need to pay for a full accessibility audit for a more in-depth review. These can cost between £3,000 and £7,000 depending on the size and scope of your website.
Think about the criteria for ‘disproportionate burden’ when working out which methods to use.
Work out what to prioritise
Once you’ve identified your website’s accessibility problems, you’ll need to work out what to prioritise.
Keep in mind the criteria for ‘disproportionate burden’. For example, it’s probably of more benefit to your users if your essential services meet than old PDF newsletters.
And relatively cheap changes are less likely to be disproportionate. For example, a simple code change that improves your website’s colour contrast will cost much less than making your website responsive (automatically change size to fit the user’s device).
Remember that if something is a disproportionate burden, you’ll still need to make reasonable adjustments for people with disabilities - for example, by providing the information they need in another format that’s accessible to them.
Talk to your legal adviser if you’re not sure what to do.
Make a roadmap
Once you’ve worked out your priorities, you can make a high level plan or roadmap to show how you’ll meet accessibility standards.
Aim to fix the highest priority things first, and think about how you’ll know when each problem has been fixed.
You will need to publish an accessibility statement from:
- 23 September 2019 for new websites created from 23 September 2018
- 23 September 2020 for existing websites
- 23 June 2021 for mobile apps
For websites, publish the statement as an html page, linked to from a prominent place like the website footer. For mobile apps, make the statement available in an accessible format where users can download the app.
The accessibility statement must say:
- which parts of your service do not meet accessibility standards and why
- how people with access needs can get alternatives to content that’s not accessible
- how to contact you to report accessibility problems - and a link (to be confirmed) to the government website that they can use if they’re not happy with your response
The new legal requirements say you must respond within a reasonable amount of time if someone requests information in an accessible format.
We will link to a model accessibility statement by December 2018.
Making content accessible
Make sure new content that you publish fully meets accessibility standards. If it doesn’t, you’ll have to go back and fix it.
For existing content, work out what you need to prioritise and fix as part of your accessibility plan.
Tell the people who create content on your website that they have a responsibility to make the content accessible.
- making sure PDFs or other documents they create are accessible
- making sure images are accessible
- following conventions for creating accessible content (for example, write descriptive links instead of using ‘click here’)
It’s unlikely that making new content accessible would be considered a valid disproportionate burden.
Some types of content, website and organisations are exempt from the new public sector regulations.
But even if something is exempt, all UK service providers have a legal obligation to make reasonable adjustments under the Equality Act 2010 (or Disability Discrimination Act 1995 in Northern Ireland).
Meeting accessibility standards is a way of showing that you’ve made reasonable adjustments for disabled people. You also need to provide information in another format if someone requests it, where reasonable to do so.
Some types of organisation are exempt:
- non government organisations like charities (unless they provide services that are essential to the public or aimed at disabled people)
- schools or nurseries - except for the content the public need to use their services
- public sector broadcasters and their subsidiaries
Exempt types of content
You usually need to make documents like PDFs and Microsoft Office files accessible if they’re primarily intended for use on the web.
There’s an exemption if they’re both:
- published before 23 September 2018
- not essential for services that your organisation provides
There are also exemptions from making content accessible if it’s:
- pre-recorded audio and video published before 23 September 2020
- live audio and video
- maps - if the map helps users find a service you offer, you must provide directions another way
- part of a heritage collection - for example, scanned manuscripts
- third party content that’s under someone else’s control if you didn’t pay for it or develop yourself - for example, social media ‘like’ buttons
Intranets, extranets and archives
There’s an exemption for:
- content on intranets and extranets published before 23 September 2019 (unless you make a major revision after that date)
- archived websites if they’re not needed for services your organisation provides
Procuring an accessible website or app
Some public sector organisations have outsourced some or all of their websites to suppliers that make it very expensive to make even simple changes. If this is the case, it may be a disproportionate burden to make part of your website fully accessible.
Where possible, we recommend that you should renegotiate your contract or change supplier. You should:
- follow government guidance on procuring technology - awarding contracts that aren’t too long and using open standards, for example, makes it easier to take advantage of technical advances that can improve accessibility
- where possible, use web technologies rather than native mobile apps - because it’s easier to update web technologies
- make meeting WCAG 2.1 AA standard part of the request for quotation (RFQ)
- consider building regular accessibility reviews into the contract
- include accessibility as part of the contract evaluation
The European Commission has published guidance in its Accessible ICT Procurement Toolkit.
Get support, training or advice
Depending on where you work, you may be able to get support from:
- the local government digital network - you can ask questions on their accessibility Slack channel
- the central government accessibility community
The Government Digital Service is researching what guidance and support that public sector organisations need to meet accessibility standards. If you’re interested in taking part in this research, contact firstname.lastname@example.org.
If you’re not sure the rules apply to you
Check with your legal adviser if you’re not sure whether the new accessibility rules apply to you.
The rules are known as the The Public Sector Bodies (Websites and Mobile Applications) (No. 2) Accessibility Regulations 2018. This regulation implements the EU directive on the accessibility of the websites and mobile applications of public sector bodies into UK law.
For example, if you don’t know whether your organisation is a public sector body, or whether some of your content is exempt.
Even if you’re not covered by the new rules for websites and apps, all UK service providers have a legal obligation to make reasonable adjustments under the Equality Act 2010 or the Disability Discrimination Act 1995 (in Northern Ireland).