2024, the headwinds of accessibility

Wednesday, January 15, 2025

Each year, between 15 and 17 sites undergo an in-depth monitoring. The average compliance rate for these sites was 44% in 2021, rising by four points the following year, then by six points in 2023, and finally by seven points last year, to reach 61%. The trend is therefore positive.

A site is considered non-compliant if it obtains a score of less than 50%, partially compliant if the score is between 50% and 100%, and fully compliant only at 100%.

In 2021, four out of ten sites had reached or exceeded the 50% compliance threshold, while less than half had done so by 2023... and almost two-thirds (63%) last year.

A site audit consists of giving good and bad points (136 compliant or non-compliant criteria) for around fifteen pages. If a criterion is non-compliant on one page, it will automatically be non-compliant on all.

Description of graph 1

This bar chart shows sixteen public sites targeted for in-depth monitorings in 2024 in decreasing order of compliance with RAWeb criteria, from the Digital Accessibility Portal (100%) to the cc-ctsa.lu site (35%).

Below the 50% mark, a site is not considered accessible. That is 6 out of 16 sites audited.

100% compliant, it's possible

The SIP itself wished to submit the Digital Accessibility Portal to an audit, and has worked towards achieving the compliance required by law (i.e. a score of 100%). Experience has shown that this objective is far from unattainable.

Over the last three years, we have calculated the most recurrent non-compliance issues. Here are the critical points most frequently cited in monitoring reports:

1. Script incompatible with assistive technologies

   This is a major problem: consider, for example, a menu bar that is inaccessible because it cannot be navigated by assistive technologies, such as screen readers, which vocalise the structure and content of a site to enable blind people in particular to consult it.

2. Poor structuring of the page or within the page

   • Tags used only for layout purposes
   • Unstructured list
   • Inappropriate headings structure
   • Unstructured web page

   An unstructured page, or a page with poorly structured elements, means that people with disabilities can miss out on some of the information. The most obvious example is the unstructured list: who hasn't used dashes instead of the canonical bulleted list? And yet the latter is very practical for the visually impaired: the screen reader can announce the existence of a structured list with the number of items it contains and shortcuts can be used to navigate quickly between lists or within the same list.

   Even more annoying is the inappropriate headings structure. On screen, it's easy to understand the hierarchy of headings thanks to different font sizes, for example. However, this hierarchy is not always respected in the code. A screen reader does not know how to interpret what is displayed, so it will render the HTML tags, in particular the heading tags (<h1> to <h6>). They must therefore be consistent with what can be seen on the page: this is not always the case, and can disrupt the browsing experience.

   More generally, the web page itself should be made up of different blocks (header, main area, navigation area, search area, footer). If this composition is not reflected in the code, users of assistive technologies can quickly get lost.

   Less problematic is the case of tags used only for layout purposes, which can lead users to wonder. For example, to put text in bold, it may be tempting to use a heading tag, or to use a quote tag to highlight text, although in either case it may not be a heading or a quote.

3. Insufficient contrast

   • Insufficient interface component contrast
   • Insufficient text contrast
   • Focus not visible enough

   To cater for certain types of visual disabilities, care must be taken to always maintain a minimum contrast for texts and interactive components (buttons, links, form fields, etc.). Since 2021, public authorities have been working in this direction, so that this issue is no longer in pole position for non-compliance. Related to these issues, the visibility of the focus is essential for those who navigate using a keyboard: the site must be able to make the focus of the interactive element sufficiently visible.

4. Missing language changes

   Luxembourg is the place par excellence where languages mingle, on café terraces or on web pages. But... try to understand someone speaking to you in Portuguese with Chinese pronunciation rules: a voice synthesiser user experiences the same adventure when the HTML code of the page asks the voice synthesiser to read a paragraph written in French in English. It's difficult to understand. We invite you to reread our wrap up on the lang attribute.

5. No accessible version of office documents

   Inaccessible PDFs are still a major problem today: PDFs scanned in image mode or untagged... all examples that make documents inaccessible. Today, on the most visited public sites in Luxembourg, the majority of these PDFs are inaccessible, as our study in the spring of 2023 revealed. Finally, it should be noted that, in the accessibility statements, which in particular list non-compliance issues and derogations for disproportionate burden - the volume of work is considered to be such that a derogation is invoked - PDF documents top the list of these derogations.

Communes catch up... a little

These audits are accompanied each year by around a hundred so-called simplified audits, which offer an additional perspective. Here too, the average scores have improved, from 55% in 2021 to 61% last year. However, they show another interesting breakdown: by administrative level, state sites confirm their clear advance ahead of local authorities sites - or local authorities associations - and the others - public establishments, etc.

Description of graph 2

This column chart shows the average compliance scores of state, municipal and other public entities sites over the first 2020-2021 campaign and the following three (2022-2024).

Everyone picked up a few points: six for the State and local authorities, and one for other public sector bodies. That said, the rate of change was more flattering for the municipalities, which rose from 42% to 48% (14%), than for the State, which rose from 60% to 66% (10%).

The Top 10 most common errors include, in addition to those already mentioned, issues relating to forms: fields without labels (the voice synthesiser will not know whether to announce a first name, a date of birth, etc.) or forms without relevant error management (in the case of mandatory fields, misspelled e-mail addresses, etc.).

Apps do little to promote accessibility

While the good results for websites are to be welcomed, the picture is partly clouded by the relative under-performance of mobile applications. The average score for apps audited in 2022 was 49%, one point above the average for websites audited that same year. Unfortunately, this score has fallen to 43% and then 37% in 2024. For the first time last year, none of the apps audited achieved partial compliance.

This is not specifically a question of platform: although the apps audited are slightly more accessible on Android than on iOS (44% compared with 41%), the difference is too small and the sample too restricted to draw any conclusions.

One thing is certain, however: the lack of commitment on the part of developers to creating accessible apps is already reflected in the absence of accessibility statements, which provide vital information about the non-compliance of the site or app. While almost half of Luxembourg's public Websites have such a declaration, only 13% of public apps currently have one.

Administration too often without a solution

Finally, we would like to remind you of the right of every citizen to ask the public administration for an accessible version of online information that is not accessible. Twenty complaints were received between 2022 and 2024. Only in eight of these cases was it possible to find a solution to a specific problem in the short term, either by actually correcting the problem on the site or by providing an alternative functionality that would guarantee an equivalent level of service. Inaccessible PDF documents are the main reason for complaints.

Description of graph 3

This bar chart shows the main reasons for complaints from users of public sites and apps, from 2022 to 2024.

Despite these last two areas for improvement, throughout 2024, the Information and Press Service was able to observe a real involvement and desire for genuine investment of all the administrations within which it carried out an awareness-raising mission.

The year 2025 will see the rise of a new public body dedicated to accessibility: OSAPS (Office de surveillance de l'accessibilité des produits et services). From June onwards, not only the private sector, but also certain public sector bodies, particularly in the field of mobility, will have to offer accessible products and services. This time, this Office will have the power to impose financial penalties.

This article is a summary of a report on the state of accessibility of public sector websites and mobile applications in Luxembourg, produced every three years for the European Commission. This is the second report of its kind written by the Information and Press Service. You will find a description of the monitoring methods used, the full results (audits, user complaints, derogations, etc.) and detailed analyses of the data collected over the period 2022 - 2024.