Accessibility and public sector websites

September 23, 2019 by No Comments | Category Digital Public Services, Digital Scotland

Kevin White, Head of Accessibility with the Scottish Government’s Office of the Chief Designer, explains what the legislation means if you’re a public body and what you can do to meet the requirements.

What is accessibility?

Accessibility describes a quality of a thing, whether a website, building or cooker. An accessible product or service is one that is designed and made with the needs of disabled people in mind. It’s important to make sure things are accessible to avoid creating barriers for people with health conditions or impairments.

Accessibility regulations

The Public Sector Bodies (Websites and Mobile Applications) (No. 2) Accessibility Regulations 2018 came into force September 2018. This challenges us to make sure the digital parts of the services we design and build for the people of Scotland are done so with accessibility at their core.

In reality this duty has existed since the Disability Discrimination Act in 1995 and then the Equality Act in 2010. The difference is that the new act is much more descriptive on what we should be doing and by when.

What the new act means

The 2018 legislation asks anyone responsible for delivering public services via a website or an app to:

  • evaluate the accessibility of websites and apps
  • fix identified accessibility issues
  • publish an accessibility statement

The deadlines vary based on whether it is a new or existing site, or an app:

  • for new websites: 23 September 2019
  • for existing websites: 23 September 2020
  • for mobile applications: 23 June 2021

In this case, ‘new’ means published on or after 23 September 2018.

Internal websites and apps are included within these regulations. However, the regulations do not apply if the website or app was published before 23 September 2019 until there is a ‘substantial revision’. There are a number of other exemptions outlined in Part 1 Regulation 4 Section 2 of the regulations. For example, Office file formats, such as PDFs and Word documents, published before 23 September 2018 are exempt.

The regulations state that websites and mobile apps should be built to the Web Content Accessibility Guidelines version 2.1 (WCAG) Level A and AA success criteria. That’s what most of us were already using as guidance.

It’s less clear for mobile apps. This is discussed in the slides So, you want to create an accessible app?, which include a list of helpful resources.

Reviewing the accessibility of your websites and apps

Evaluating against the standards is an involved and specialist task. There are organisations that will conduct an audit for you – this is recommended.

You can also check a number of things yourself with a little technical knowledge. The Web Accessibility Initiative provide a guide on some Easy Checks that you can use as a first review. This isn’t a full audit but it will provide you with an idea of the problems that might exist.

Making a plan for improvements

Fixing anything you find can be challenging, but knowing where the issues are is a good start. While issues won’t be fixed overnight, having a plan in place for improvements is important.

You may be able to address some issues if work is underway. If there is no work planned, issues can be captured as requirements for future revisions.

Creating an accessibility statement

Most websites provide an accessibility statement which cover off the important things, mainly how to contact someone if there is an accessibility issue or barrier. The legislation requires a few more things to be added.

Your accessibility statement should:

  • be accessible – make sure users can find and understand it
  • be published on your website or available when downloading an app
  • state whether the website or app meets, partially meets, or does not meet the standards
  • explain what is not accessible
  • describe what accessible alternatives are available
  • provide a method of reporting issues
  • explain how to complain

Some of this information needs to be in a particular format and form of words. The UK Government Digital Service has created a sample accessibility statement which can be used as a template or to better understand what you should cover.

There is also a good example of a live accessibility statement on

The Office of the Chief Designer will be conducting some research to understand how accessibility statements can be written to meet the regulations, as well as the needs of users.

What you can do

Here are some things you can do as a starting point that will help you meet the regulations and improve the services we deliver to the people of Scotland:

  • evaluate your website based on the Easy Checks
  • commission an accessibility audit
  • write and publish your accessibility statement based on what you know – this could be difficult as there are likely to be issues but it’s important to acknowledge them
  • include accessibility in any procurement you are doing
  • join accessibility communities
  • share your experiences and challenges so we can all learn from each other

Get in touch with to find out more.

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