Public sector bodies must prepare and regularly update a detailed, comprehensive and clear Accessibility Statement on the compliance of their websites and mobile applications with the European Union (Accessibility of Websites and Mobile Applications of Public Sector Bodies) Regulations 2020. (2020 Regulations). The 2020 Regulations transpose the “Directive (EU) 2016/2102 of the European Parliament and of the Council of 26 October 2016 on the accessibility of the websites and mobile applications of public sector bodies”.
Writing an Accessibility Statement for your website or mobile application (app)
The Accessibility Statement must be displayed in a prominent position on all pages on a website and from within the mobile application.
The 2020 Regulations require that the Accessibility Statement is provided in an accessible format and is based on the Model Accessibility Template in Commission Implementing Decision (EU) 2018/1523.
The purpose of the Accessibility Statement is to describe the website or mobile app’s compliance with the accessibility requirements and to provide helpful information to anyone who may need it. This information includes:
- a statement of compliance of the website or mobile app with the 2020 Regulations
- a description of the inaccessible parts of the website or mobile app,
- advice on how a person can ask for assistance, provide feedback or make a complaint in relation to the accessibility of the website or mobile app.
- in an accessible format;
- prepared using the model accessibility statement, outlined below
- in the case of a website, be published on the website concerned
- in the case of a mobile app, be published on the website of the public sector body that developed the mobile app or alongside other information available when downloading the application
What the Accessibility Statement must contain
Under the 2020 Regulations, the Accessibility Statement for a website or mobile app must be:
The Accessibility Statement must provide an explanation about those parts of the website or mobile application that are not accessible, the reasons for that inaccessibility and, where appropriate, the accessible alternatives provided.
Feedback, redress and complaints mechanism
The Accessibility Statement must contain a description of, and a link to, a feedback mechanism.
The feedback mechanism must enable any person to notify the public sector body of any failure any of its website or mobile app to comply with the accessibility requirements set out in the 2020 Regulations.
The feedback mechanism must also enable any person to request information and assistance in relation to those parts of the content that is inaccessible.
The Accessibility Statement must also link to the relevant redress and complaints provisions under either the Equal Status Act 2000 (No. 8 of 2000) and the Disability Act 2005 (No. 14 of 2005) or both.
Advice on making a complaint under the Disability Act is available on the website of the Office of the Ombudsman.
Advice on making a complaint under the Equal Status Act is available on the website of the Workplace Relations Commission.
Public sector bodies must give an adequate response to a notification or request within a reasonable period of time.
Preparing the Accessibility Statement
The public sector body must ensure that it provides accurate information on its compliance with the 2020 Regulations. The statement of compliance should be based on one of the following:
- a self-assessment done by the public sector body;
- an assessment carried out by a third party.
Structure of the Accessibility Statement
The accessibility Statement must be prepared using the following structure, as per the Model Accessibility Statement.
Insert the appropriate text in the square brackets.
[Name of public sector body] is committed to making its [website(s)] [and] [mobile application(s)] accessible, in accordance with European Union (Accessibility of Websites and Mobile Applications of Public Sector Bodies) Regulations 2020.
Insert the name of your organisation in the square brackets.
Add or remove text for website or mobile applications as appropriate
This accessibility statement applies to […].
Insert the scope of the accessibility statement, e.g. website(s)/mobile application(s) to which the statement applies.
Choose one of the three options below
1. [This] [These] [website(s)] [mobile application(s)] [is] [are] fully compliant with the Web Content Accessibility Guidelines 2.1 level AA.
Use this if your website mobile app is fully compliant with all level AA Success Criteria from the Web Content Accessibility Guidelines 2.1
2. [This] [These] [website(s)] [mobile application(s)] [is] [are] partially compliant with the Web Content Accessibility Guidelines 2.1 level AA , due to [the non-compliance(s)] [and/or] [the exemptions] listed below.
Use this if your website or mobile app does not meet all level AA Success Criteria from the Web Content Accessibility Guidelines 2.1. You can provide a list of the content and features that are not accessible or are exempt later in the accessibility Statement.
[This] [These] [website(s)] [mobile application(s)] [is] [are] not compliant with the Web Content Accessibility Guidelines 2.1 level AA. The [non-compliance(s)] [and/or] [the exemptions] are listed below.
Use this if your website or mobile app does not meet any level AA Success Criteria from the Web Content Accessibility Guidelines 2.1.
This should be included in all Accessibility Statements unless the public body is confident it reaches conformance rating AA with WCAG 2.1.
Choose the appropriate reason below from:
B) Disproportionate Burden;
C) Out of scope.
The content listed below is non-accessible for the following reason(s):
Choose the appropriate reason
A) Non-compliance with the European Union (Accessibility of Websites and Mobile Applications of Public Sector Bodies) Regulations 2020.
Describe in non-technical terms, as far as possible, how and why the content is not accessible, including reference to the
applicable requirements in the relevant standards and/or technical specifications that are not met; e.g.:
‘The login form is not fully usable by a keyboard’
B) Disproportionate burden
The 2020 Regulations require that a public sector body claiming disproportionate burden for making the content accessible in accordance with the accessibility requirements “shall carry out an assessment of the extent to which compliance with those accessibility requirements would impose on it such a burden.” This assessment shall include:
“(a) the size, resources and nature of the public sector body concerned;
(b) the estimated costs and benefits for the public sector body concerned in relation to the estimated benefits for persons with disabilities, taking into account the frequency and duration of use of the websites or mobile applications concerned.”
Where possible and appropriate, accessible alternatives must be provided.
C) The content is not within the scope of the applicable legislation
List the non-accessible section contents or functions of the website or mobile app which are out of scope of the applicable legislation. Indicate accessible alternatives where appropriate.
Preparation of this accessibility statement
This statement was prepared on [date].
Insert date of the first preparation, or a subsequent update, of the accessibility statement following an evaluation of the websites/mobile applications to which it applies. It is recommended that an evaluation is carried out and the statement updated following a substantial revision of the website/mobile application.
The statement was prepared by [method to prepare the statement]
Indicate the method used to prepare the statement. This could be a self-assessment conducted by the public sector body or an assessment carried out by a third party. See the Centre for Excellence in Universal Design’s guidance on Web accessibility auditing
The statement was last reviewed on [insert date of latest review].
It is recommended that the claims made in the accessibility statement are reviewed as regards their accuracy on a regular basis, and at least once per year. If such a review has taken place without a full evaluation of the website/mobile app, whether or not such a review has led to any changes in the accessibility statement, please indicate the date of the last such review.
Feedback and contact information
The Accessibility Statement must provide contact details to allow a member of the public to:
- Notify the public body of any accessibility failures they encounter
- Request information about or assistance with accessing any content or functionality that is inaccessible
[Provide a description of, and a link to, the feedback mechanism to be used to notify the public sector body of any compliance failures and to request information and content excluded from the scope of the 2020 Regulations.]
This could be a feedback form, email address, telephone number or other contact details. Ensure that the choice of feedback channels enable the widest range of people possible to communicate with the public sector body.
[Provide the contact information of the relevant entity, unit, or person responsible for accessibility and for processing requests sent through the feedback mechanism.]
This could include the Access Office as designated under Section 26 “Access to services” of the Disability Act 2005, the person/unit in charge of maintaining the website, or the communications unit.
The 2020 Regulations state that enforcement procedure is to be “used in the case of unsatisfactory responses to any notification or request sent in accordance with Article 7(4)(c) of the 2020 Regulations
Section 38 of the Disability Act says a person, or a specified person may make a complaint in writing to the head of a public body if that body is not following the law as outlined in sections 25, 26, 27, 28 or 29 of the Act.
[Provide contact information of the relevant enforcement body].
Optional Content for the Statement
Your Accessibility Statement may also contain the following additional information:
- An explanation of the commitment to digital accessibility
- Endorsement of the statement (administrative or political)
- Date of publication of the website and/or mobile application
- Date of last update of the website and or mobile application after substantial revision
- Link to evaluation report (good to have if indicated as fully compliant)
- Phone assistance for persons with disabilities and AT users
- Any other content deemed appropriate