UK University Websites Need to be Accessible
On 23 September 2018 new Web Accessibility Regulations came into force for UK university and other public sector websites and mobile applications.
The regulations mean UK universities need to make their public-facing websites (and mobile apps) accessible in line with a statutory timetable. Sites going live after 23 September 2018 have one year to comply, pre-23 September 2018 sites have two years. Mobile applications need to comply from 23 June 2021.
In parallel with making their websites accessible, universities will have to prepare accessibility statements explaining how their sites comply with the Web Accessibility Regulations.
The Equality and Human Rights Commission (EHRC) will enforce the regulations and the Government Digital Service (GDS) will verify accessibility statements. The GDS will also audit a sample of public sector websites, as part of an ongoing monitoring function.
UK universities must comply with the regulations save for one proviso, described below.
Building on Current Disability and Equality Laws
The UK has equality and disability discrimination laws already requiring public sector entities to make information and services accessible. The new regulations strengthen existing legislation by adding specific accessibility compliance obligations and a verification process.
The Web Accessibility Regulations transpose an EU public sector website and mobile device directive into UK law. Dr. Albert Sanchez-Graells, at the University of Bristol Law School, explains why this directive applies to UK higher education institutions in his post: UK Universities must soon comply with the EU Web Accessibility Directive.
While the regulations require university websites to be accessible, they do so with the rider that this requirement not impose a disproportionate burden and they offer ‘opt-outs’ for specific content types. The regulations describe how to determine proportionality and provide a list of exempt content.
University Website Design and Development Implications
As website accessibility is consistent with higher education’s public service aims, universities may wish to be seen as leaders in adopting these regulations. As a result, university web teams and legal departments will need to understand and interpret how to implement the regulations and do so quickly, in view of the deadline dates. As with all regulatory changes, the devil will lie in the details.
In deciding on their desired website accessibility outcomes institutions will be able to develop implementation policies. Good policy will aid in assessing a site’s current accessibility status and determining any effort needed to bring it up to the required standard.
Sizing up the accessibility implementation task
Section 4 of the regulations says “these Regulations apply to a website or mobile application of a public sector body”, but many universities have dozens or hundreds of sites and microsites: each one potentially having its own content creator or owner. Perhaps the ECHR will view any site using a university’s main domain name as a university website or perhaps it will take a more restrictive view? And, we don’t know how sites that don’t use the main university domain name will be handled.
While some universities have hundreds of sites and microsites and hundreds of thousands or even millions of web pages, in aggregate, not all sites or pages are created equal. Web analytics show us that small numbers of pages account for a high percentage of traffic and many pages see few or no visitors. The former should be the focus of initial assessments and can be identified using Google Analytics or similar data.
Carrying out these assessments can be problematic when comprehensive website lists are not available or there is no reliable information about recent site updates.
Accessibility testing affected sites and pages
Automated accessibility testing software can check web pages for WCAG 2.1 level AA guideline compliance, the implied standard under the regulations. However, automated accessibility testing generates large volumes of data, including false positives. Thus, it may be more fruitful to view automated test results as quality indicators rather than absolute accessibility measures.
Regardless of how they are viewed, automated testing results will need analysis and interpretation and reliable interpretation needs staff trained in accessibility. Some of those staff will be web developers, who will need to understand how to make accessible web pages, others will be content editors who will need to understand how to publish accessible content.
Our research shows that keeping website content accessible is tough. The evidence suggests that content editors spread across campus find it hard to consistently maintain content accessibility: see our post Keeping Higher Education Websites Accessible is Hard to Do. For example, neither the Web Accessibility Regulations nor the explanatory notes have been published as accessible PDF documents.
Inclusive design for long-term accessibility
Exercises to understand the number of sites and individual pages needing changes will feed into one-off remediation projects. The accessibility implementation timetable set out in the regulations and assessments of disproportionate burden will determine the pace and scope of this work.
While fixing current accessibility issues is important, delivering good long-term website accessibility will come from inclusive design thinking, content creation workflow changes, quality assurance tools and using content management system features.
To be successfully implemented, each of these elements for more readily delivering accessibility requires shifting from current thinking so that accessibility becomes part of standardised processes supported by workflows and systems.
The All-Party Parliamentary Group for Assistive Technology has published a very useful report on how these regulations will affect Virtual Learning environments: Accessible VLEs - making the most of the new regulations. And, JISC has established a LISTSERV group specifically addressing the new regulations: DIGITALACCESSIBILITYREGULATIONS
There is much work to be done and the countdown timer is running.