What the accessibility statement has to say

Article 15.1 of Royal Decree 1112/2018 asks for a «detailed, comprehensive and clear» statement on how the website complies with the decree. At a minimum (article 15.2) it must explain which parts are not accessible and why, with any alternatives, and link to the feedback mechanism and the complaints procedure.

The text follows the model in Commission Implementing Decision (EU) 2018/1523, which public sector bodies in every Member State have to use (article 1 of the Decision). The model’s instructions say to edit or delete the text in italics and remove all the notes before publishing. The mandatory part has these blocks.

  • Scope. Which websites or apps the statement covers.
  • Compliance status. Fully, partially or not compliant. Only one.
  • Non-accessible content, by reason. Non-compliance, disproportionate burden or outside the scope of the law, with the alternatives.
  • Preparation. Date, method (self-assessment or assessment by a third party) and the date of the last review.
  • Feedback and contact details. How to report a problem and who handles it.
  • Enforcement procedure. Where to turn if the answer is unsatisfactory.

Where it has to be linked and how to publish it

The statement is published on the website itself and must be reachable from every page through a link called «Accesibilidad», or its equivalent in the language of the page (article 15.1). The usual place is the footer, next to the legal notice.

The EU model’s instructions add that it has to be easy to find, for example from a header or a static footer, and that it must be in an accessible format. If the council has a mobile app, the statement goes on the council’s website next to the download link, or with the information in the app store (article 15.1).

Our council website has no statement. Where do we start?

Start with an accessibility review, even a self-assessment, because the statement has to say what it is based on. Then fill in the EU model. Scope, compliance status, non-accessible content, contact details and appeals procedure. Link it from the footer of every page and review it within a year.

How often to review it and the deadlines the decree sets

The statement must be updated at least once a year, or every time an accessibility review is carried out (article 15.1). Reviews are a separate duty. Article 17 requires them at the design stage, before launch and periodically afterwards, especially when content or technology changes.

Each review must combine automated checks with expert manual review, and the result must be recorded in an accessibility review report (article 17.3), so an automated tool on its own is not enough. For websites, the first review had to be done within two years of entry into force on 20 September 2018, that is, before 20 September 2020 (article 17.6).

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How complaints and requests are handled

Article 10 requires a feedback mechanism with two channels. One to report non-compliance or access difficulties, and another to file complaints and request excluded information. The first channel works by email or a form plus a phone line or an office (article 11). For complaints, the decree sets registration under Law 39/2015 and an answer within twenty working days (article 12).

The answer has to name the unit issuing it, the decision, the deadline for fixing the problem and where to appeal (article 12.5). If there is no agreement or no answer arrives, the person can appeal to the accessibility unit, which has two months to reply (article 13). The statement must link to the appeals procedure (article 15.2) and say which unit handles it.

One caveat. According to the BOE’s note on the consolidated text, Constitutional Court ruling 100/2019 found that the twenty working days, registration under Law 39/2015 and paragraphs 2 to 6 of article 13, including the two months, encroach on regional powers and are not basic legislation. For a Catalan council those deadlines are therefore a reference, not a national obligation. What binds is whatever Catalan rules set, if any.

Can we say the website is partially compliant?

Yes, it is one of the three options in the model. You choose it when most of the requirements of the technical standard are met but with some exceptions, and you have to say which. If most are not met, the option is «not compliant». «Fully compliant» only when every requirement is met without exception.

Who is responsible inside the council

Every obliged body has to designate an accessibility unit, the Unidad responsable de accesibilidad. Local authorities designate it according to their own organisation (article 16.1). As an example, in a small council in the Gironès it may be the clerk’s office with the IT technician. In a comarcal council, the service that runs the website.

This unit coordinates the feedback mechanism, answers appeals and coordinates periodic reviews (article 16.3). Its designation is notified to the monitoring body (article 16.4), which according to the Web Accessibility Observatory is now the Ministry for Digital Transformation and the Civil Service.

If the website runs on a shared platform, what is your part

If the website runs on another administration’s platform, such as the municipal website platform the Diputació de Girona provides through its Oficina de Suport a l’Administració Electrònica, the template may already carry the «Accessibility» link. That does not settle it. The obligation sits with the body responsible for the website (article 15.1), even when a supplier builds it.

Check that the text names your council, that the preparation and last-review dates are real, that the contact and the responsible unit are yours and that the registry link works. If the electronic office (seu electrònica) sits on another domain, make sure the statement’s scope covers it.

A checklist for the council’s technician

You can go through the statement in an afternoon with this list. The Web Accessibility Observatory offers public administration staff, through its Comunidad Accesibilidad, an online diagnosis service with an automated check of the website and the statement. Keep the result with its date for the annual update.

  • An «Accessibility» link on every page, including the electronic office.
  • It follows the Decision 2018/1523 model and picks a single compliance status.
  • It explains non-accessible content by reason, with the alternatives.
  • Preparation date, assessment method and a last-review date under a year old.
  • It links to the feedback mechanism, names the accessibility unit and links to the registry for appeals.
  • An internal routine to answer complaints (the decree sets twenty working days) and a stored review report.
  • An accessible HTML page. Images and scanned PDFs do not count.
Hand ticking the boxes of a checklist in a notebook with a pen
Going through the statement point by point and saving the result with the date makes the yearly update easier.Photograph by Jakub Żerdzicki / Unsplash

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