Users still looking for solutions

Complaints about accessibility are rarely resolved

Friday, February 24, 2023

Some users with disabilities take the opportunity to alert the SIP or the Ombusdman about the digital accessibility problems they experience on a daily basis. They are rarely offered an appropriate solution in the short term.

In 2022, the SIP (Information and Press Service) received nine complaints from users who were prevented from browsing or consulting websites or mobile apps.

Illustration showing a woman using a voting machine that can be used by the blind and partially sighted
Photo: iStock / Getty Images / inside-studio

These complaints included:

  • Four related to apps
  • Three related to websites
  • One concerning access to a PDF file
  • One concerning access to a CAPTCHA module

Three of the services in question are in the transport sector, one in health and one in education. Four others are not listed.

Only two short-term solutions were offered to these citizens - although, in one of the two cases, the request did not fall within the framework of the law: it concerned a PDF that was not accessible, but published before September 2018. Of the seven complaints that were not resolved in the short term, one responsible body never replied and another claimed that the burden was disproportionate.

Over the period 2020-2021, the SIP handled 18 complaints. Six short-term solutions were proposed. Two organisations had never responded, and four had argued that the burden was disproportionate. Two proposed solutions were not accessible either. Finally, one request was not acted upon because it did not fall within the legal framework.

Graph 7. Complaints received and short-term solutions proposed (see description below).

Description of graph 7

This bar chart shows the total number of complaints received by the Information and Press Service related to digital accessibility issues, i.e. 18 in 2020 - 2021 and nine in 2022. Six and then two short-term solutions have been proposed respectively.

A better integration of user's needs for 2023 is an objective which is… accessible

How do I make a complaint to the SIP?

Any citizen can contact the SIP to make a complaint about the accessibility of a public sector website or mobile application. To do so, simply fill in the form on the SIP website or send an email to accessibilite@sip.public.lu. Before making a complaint, it is advisable to contact the organisation concerned directly. The contact details can be found in the accessibility statement for each site or mobile application.

One accessibility statement in four does not exist

There are more than 700 websites and apps in Luxembourg belonging to public sector bodies. At present, 180 have an accessibility statement, which has been notified to the SIP. As a result, three quarters of public sector sites do not display this statement, despite the fact that it is compulsory. This figure can be put into perspective somewhat, as the SIP may not be aware of the existence of certain statements.

However, this accessibility statement is anything but anecdotal. It is precisely this statement that details the complaints procedure. Whether you are blind, partially sighted, physically disabled, etc., it also helps you to understand how compliant the site is, what content is not accessible and what burdens are considered to be disproportionate.

"Disproportionate burden": less of an argument

The accessibility statement gives the person responsible for the site or app the option of excluding from the scope a certain number of elements whose correction, redesign or rewriting is deemed too costly in relation to the estimated benefit for users(more information on the disproportionate burden). Examples include the subtitling of videos, or older editorial content that is deemed too time-consuming to rework given the resources available.

At the top of the list are PDF and Office documents, followed by navigation elements and, to complete the podium, authentication procedures. It is common for several elements to appear in the same statement.

Graph 8. The five main reasons given for disproportionate burden, as a percentage (see description below).

Description of graph 8

This bar chart shows, in percentage terms, the main reasons for disproportionate burden given in accessibility statements. PDF or Office documents are the most cited element in this case.

The trend from 2020-2021 to 2022 also shows that proportionately less use is made of the disproportionate burden argument. At the end of 2021, 79 out of 118 claims, or two out of three, contained at least one mention of disproportionate burden. At the end of 2022, these figures were 86 out of 180, or less than half. In concrete terms, last year, out of 62 new statements, only seven mentioned a disproportionate burden. Several factors may explain this encouraging figure: a less complex nature of mobile sites and apps, an update of previous statements from which the "disproportionate burden" aspect had been removed, and finally mobile sites and apps whose design incorporates the objective of full compliance from the outset.