RE: Website with known set of issues

That list is from the EU legislation, which you can see at https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX%3A32019L0882. It’s not paginated, so it’s difficult to find anything, but the scope is defined in Chapter 1 Article 2. In the English version of the PDF version, it’s on page 14.

The online appointment booking tools you mention are out of scope. It sounds like the Germans are implementing a much broader interpretation – so much for harmonisation across the EU to simplify and encourage cross-border trade. The protectionist French can be expected to go a lot further, but I expect the Mediterranean and Eastern European countries will do the minimum possible.

Steve

From: Marc Haunschild (Accessibility Consulting) <marc.haunschild@t-online.de>
Sent: Wednesday, May 22, 2024 2:48 PM
To: Steve Green <steve.green@testpartners.co.uk>
Cc: Marc Haunschild (Accessibility Consulting) <marc.haunschild@t-online.de>; WAI Interest Group discussion list <w3c-wai-ig@w3.org>
Subject: Re: Website with known set of issues

Hi Steve,

im not really sure if you’re right I have to admit as I’m familiar with the German implementation of the EAA.

The EAA is the baseline that national law has to respect, but the member states can exceed this minimal requirements. So maybe it’s a German thing but here from June 2025 it’s about Services in electronic commerce with consumers (e.g. e-commerce, online appointment booking tools).

If an Entertainment website offers a service like playing the songs you bought, it has to be accessible.

Also Austria for example has in the section of their national law which says what has to become accessible a single word: websites

So on the one hand you may be right, that the EAA actually doesn’t demand all of this, but many (most?) eu members have stricter laws than that.

Also the WCAG is just one (big) part of the European Norm that services has to comply to.

But yes, there are many holes in this law, exceptions but looking back on what happened step by step in the last 20 years I’m quite sure this is not the end of the road…

It will get better.

Mit freundlichen Grüßen,


Marc Haunschild
https://accessibility.consulting/ - a web designed for ALL!


Am 22.05.2024 um 09:55 schrieb Steve Green <steve.green@testpartners.co.uk<mailto:steve.green@testpartners.co.uk>>:

The EAA specifies the electronic products and services to which it applies. Leaving aside the physical products, it applies to communication services, audiovisual media services, transport service information and ticketing services, consumer banking services (but not business banking, apparently), e-books, e-commerce services and emergency services.

It doesn’t apply to anything else, so it wouldn’t apply to the W3C website, and it wouldn’t apply to my company’s website, or indeed any of our competitors other than the few that sell online. It doesn’t apply to B2C information or entertainment websites. It appears not to apply to some B2C interactive services such as job boards.

There are exemptions for online maps and mapping services, some third-party content and archives, also for documents and audiovisual content published before 28 June 2025.

I agree that the 2018 public sector regulations have made a massive difference, and that next year’s law will make a big difference in the specified sectors, but the law does not apply to a vast number of websites, so I don’t expect those to improve.

In fact, the public sector regulations haven’t even caused an improvement in the quality of work done by most developers. Our experience has been that they still churn out inaccessible websites like before, and only fix those covered by the regulations. Websites outside the regulations are as inaccessible as before.

Steve


From: Marc Haunschild (Accessibility Consulting) <marc.haunschild@t-online.de<mailto:marc.haunschild@t-online.de>>
Sent: Tuesday, May 21, 2024 10:38 PM
To: Steve Green <steve.green@testpartners.co.uk<mailto:steve.green@testpartners.co.uk>>
Cc: bryan rasmussen <rasmussen.bryan@gmail.com<mailto:rasmussen.bryan@gmail.com>>; Karen Lewellen <klewellen@shellworld.net<mailto:klewellen@shellworld.net>>; WAI Interest Group discussion list <w3c-wai-ig@w3.org<mailto:w3c-wai-ig@w3.org>>
Subject: Re: Website with known set of issues

Why the EAA should only apply to a small portion of websites?

All online B2C services will have to be accessible.

Also there is a transparent development of the next step.

The underlying European norm 301 549 will be updated a year later.

Given that we had about a dozens of changes in laws (at least in Germany, some already in the EU) during the last 20 years - each stricter than the one before - I don’t see the end of the road yet.

Fines are around 100.000 euro and can be given multiple times and it’s also possible that competitors sue each other. Of course everything is new and a lot will depend on the decisions made by judges, but actually we see a huge raise of interest and awareness.

Also in the public sector, where a huge update came in 2018/2021. I think that’s a decent progress.

Mit freundlichen Grüßen,



Marc Haunschild
https://accessibility.consulting/ - a web designed for ALL!



Am 21.05.2024 um 20:40 schrieb Steve Green <steve.green@testpartners.co.uk<mailto:steve.green@testpartners.co.uk>>:

To all intents and purposes, WCAG 2.x conformance is effectively zero. A tiny number of websites are fully conformant – I doubt if there are more than a few hundred. Perhaps 1% are moderately conformant, perhaps having half a dozen non-conformances per page. The other 99% have made no attempt at conformance.

We test a couple of hundred websites a year across a wide range of sectors. When we first see them, they typically have 10 to 20 non-conformances per page. Very, very few clients fix everything we report – perhaps 1 or 2 a year. Most stop fixing things when they get down to 5 to 10 non-conformances per page. And these are the people who care enough about accessibility to get their websites tested professionally. And it’s taken 25 years of advocacy and law-making to get there.

I don’t expect much to change in the coming years. Next year’s European Accessibility Act will only apply to a small proportion of private sector websites, and I am not aware of any significant legislation after that.

With regard to WCAG 2.x and 3.x, my (possibly incorrect) understanding is that 3.x will not supersede 2.x, but they will run in parallel. 3.x will differ substantially in many ways and won’t simply extend 2.x.

Steve


From: bryan rasmussen <rasmussen.bryan@gmail.com<mailto:rasmussen.bryan@gmail.com>>
Sent: Tuesday, May 21, 2024 6:45 PM
To: Karen Lewellen <klewellen@shellworld.net<mailto:klewellen@shellworld.net>>
Cc: WAI Interest Group discussion list <w3c-wai-ig@w3.org<mailto:w3c-wai-ig@w3.org>>
Subject: Re: Website with known set of issues

I think in this case we might suppose it is more like how OS development used to work, that is to say you did not start developing for where the hardware was at the time you started but where it would be when you shipped.

With WCAG versions we can sort of see how widespread things can be expected to reasonably be based on legal standards, so we might assume reasonably widespread compliance with WCAG 2.0 in 2025-2026, might as well start pushing now - just my feeling.

On Tue, May 21, 2024 at 7:11 PM Karen Lewellen <klewellen@shellworld.net<mailto:klewellen@shellworld.net>> wrote:
actually, Steve's comment raises a question.
I recall last week a post about early reviews of WCAG 3.

May I ask what evaluation method the w3c uses to confirm that enough
compliance  with current wcAG criteria exists before starting a updated
set?
Speaking personally, should not a uniform baseline for end users exists
before  companies and organizations find themselves faced with changes?
Just wondering,

Karen


On Tue, 21 May 2024, Steve Green wrote:

> Note that that GDS page was created early in 2018, so it predates both WCAG 2.1 and 2.2. Another 18 level A and AA success criteria have been added since then.
>
> Steve Green
> Managing Director
> Test Partners Ltd
>
>
> From: Kevin White <kevin@dewoollery.co.uk<mailto:kevin@dewoollery.co.uk>>
> Sent: Tuesday, May 21, 2024 5:16 PM
> To: Phill Jenkins <pjenkins@us.ibm.com<mailto:pjenkins@us.ibm.com>>
> Cc: WAI Interest Group discussion list <w3c-wai-ig@w3.org<mailto:w3c-wai-ig@w3.org>>; Shawn Henry <shawn@w3.org<mailto:shawn@w3.org>>
> Subject: Re: Website with known set of issues
>
> Hi Phill,
>
> Not sure if it would meet your needs but GDS did testing of accessibility tools on a standard set of failures<https://alphagov.github.io/accessibility-tool-audit/test-cases.html> that they presented in a single page. The association with success criteria is clear but not explicitly linked.
>
> Thanks
>
> Kevin
>
> P.s. Would love to update Before/After demo!
>
>
> On 21 May 2024, at 16:40, Phill Jenkins <pjenkins@us.ibm.com<mailto:pjenkins@us.ibm.com><mailto:pjenkins@us.ibm.com<mailto:pjenkins@us.ibm.com>>> wrote:
>
> Is there a website (or set) with a known set of issues mapped to all the WCAG 2.2 Success Criteria?
>
> In other words, “this set of pages demonstrates failures for all the WCAG Success Criteria”.
>
> There is that decades old Before After demo website<https://www.w3.org/WAI/demos/bad/Overview.html> created by W3C that was an initial attempt to do something like that. However, it is woefully out of date.
> I’ve head that there may be some web pages maintained by a university or organization for spot testing or spot demos, but a curated list would be very helpful for the community.
>
> _______
> Regards,
>
> Phill Jenkins
> IBM Accessibility, IBM Design
> Equal Access toolkit and accessibility checker at ibm.com/able/<http://ibm.com/able/><https://www.ibm.com/able/>
> “Without accessibility, there is no diversity, equity, or inclusion for disabled people”
>
>