Practical steps to meeting accessibility regulations

Accessibility statements

An important part of meeting the regulations is publishing an accessibility statement. You may need more than one. Most organisations start with a statement that covers their public facing website. Some might publish a series of separate statements that cover more web content and systems, while others will nest these within an overarching statement.

Have a look at some existing statements that are organised in different ways, like these:

• University of Sunderland accessibility statement
• University of Kent accessibility statement
• University of Glasgow accessibility statement

It’s important that the statement is easy to find. A link to an accessibility statement is usually placed in the footer of a website.

It is essential to get your statement right. If the Central Digital and Data Office selects your website for monitoring, or there is a complaint about your digital estate, auditors will first look at your statement. Your accessibility statement(s) should cover your:

• Website
• Virtual learning environment (VLE)
• Third party systems and content you have paid for
• Mobile apps created for or by you, and available to the public

The Central digital and Data Office provides a template for your statement and a sample statement. There are legally compliant ways of describing how accessible your website is, so use the wording provided. Remember to list the numbers and characteristics of the WCAG 2.2 AA success criteria you are currently unable to meet.

Your statement needs to be regularly updated and will change over time. It’s a fluid document where you can let people know about outstanding problems, fixes and future plans. Use it to identify resources you’ll need in the coming year. It’s good practice to publish a roadmap showing your plans to fix issues.

Testing for accessibility

Before you can write your statement, you must identify problems with your digital estate. You need to decide whether you will do it yourself, get someone in, or do a bit of both. The approach you choose will depend on:

• Resources - a professional audit carries a financial cost, do you have the funds to do it and to fund more tests when your content changes?
• Skills - do staff have the skills, or the opportunity to learn, how to audit their own content?
• Time - are staff given time to prioritise testing and professional development in this area?

Jisc member organisations tell us they use a mix of external auditing, going it alone, and a combined approach. If staff know how to test for accessibility themselves, this builds a sustainable approach that will see you into the future as your content and systems inevitably change.

Whichever route you choose, it’s a good idea to have a clear-out of old content that is rarely used. The less you need to work with, the easier your job will be. This will also help you to meet sustainability goals.

If you decide to use an external auditor

The GOV.UK service manual contains a guide to getting an accessibility audit. This contains tips for writing a brief and what to expect.

Identify a representative sample of content you want to be checked. Include frequent user journeys through your sites and a range of pages that include different features.

Questions to ask

Is the consultant or company able to direct you to solutions in their report, or will you need to contract them further to assist with this?

A blended approach where the consultant or company works with your staff to build skills and help them to fix problems independently will embed sustainability.

Who else have they completed reports for and do they come recommended? Some organisations post their full accessibility reports on their websites, which means you can see what to expect.

Will the consultant write your accessibility statement as part of the job?

Doing it yourself

You don’t need to check every page. Select a representative sample that shows the variation in content and functionality of your website. By finding problems in a sample, you should be able to fix issues across the whole website.

Check the content against WCAG 2.2 AA standards. You can use a few automated tests to identify some initial things to look at, but these alone will not uncover all the issues.

WAVE (web accessibility evaluation tool from WebAim) is a suite of evaluation tools that can identify many accessibility errors, but also facilitates human evaluation of web content.

Axe is another popular accessibility checker for developers. It’s a good idea to use more than one automated test as different tools will pick up different things.

Web2Access uses free tools to check your site and can export results into a draft accessibility statement. It cannot access all types of web content, but is a helpful free resource.

There are also paid-for solutions to support testing online content, such as Siteimprove and Silktide.

Test your site with assistive technology (AT). The Accessibility in Government blog provides tips on how to get hold of free AT for testing and includes links to cheat sheets for using common assistive technologies like screenreaders.

Staff development

Testing and making plans to fix problems or build accessibility into new project might lead you to identify a need to develop staff skills.

You’ll find news about training and events in Jisc's accessibility community group.

Here are some free courses and resources to investigate. More advanced technical training is also available from a range of suppliers.

• IAAP is the international accreditation body for accessibility professionals
• Microsoft provides lots of tutorials
• W3C has created a suite of free self-study resources and a MOOC for EdX

Prioritising and planning for improvement

Start with fixing problems that will have the greatest impact. Look for the most serious accessibility errors and those that are easiest to fix. Prioritise your most frequent user journeys and essential systems. It’s generally more sustainable to focus your efforts on new content. Note that some content is exempt from the regulations.

Getting management buy-in and ensuring staff take ownership of areas to be tested and fixed is key.

It’s useful to identify a quick win – something you can achieve in a short timeframe that will build momentum and motivation. It could be something like ensuring any Wordpress blogs staff use are in accessibility-ready themes, or create accessible, branded Word and PowerPoint templates for staff to use.

If you suspect that some remediation may be cost-prohibitive, you could have a case to make a claim of disproportionate burden. If you decide not to fix something due to disproportionate burden, you will need to be able to evidence how and why you came to that decision and it needs to be done on the basis of cost.

Dealing with third-party content and systems

You will need to provide accessibility information for all the third party content and systems you have paid for, that staff and students access through a browser. Ask vendors to provide this. You can also look for information on searchBOX. If you have customised third party products, or are unsure how current the accessibility information provided is, we would recommend testing it yourself.

If suppliers do not provide a statement, you may need to write one for the product you paid for. Request that your procurement team embeds a need for accessibility statements and accessible content in procurement guidance. Sometimes suppliers will provide you with a voluntary product accessibility template (VPAT). This is worded differently to UK accessibility statements, but should provide the detail required.

Images and video

Describing images

Image description depends on context. What is an image conveying? If it is purely decorative, label it as such. If it contains useful information, you need to provide a text description. If the image is complex, consult the lecturer to ensure you have got the meaning correctly. Helpful resources include:

• Accessibility community group - hosted on Microsoft Teams and includes channels for diagrams/images and STEM contain examples
• Highcharts blog on how to write accessible descriptions for interactive charts
• Moz.com advice with examples
• Poet image description tool

Dealing with video

Pre-recorded video published online on or after 23 September 2020 comes within scope of the accessibility regulations. Accessibility guidelines define accessible video as having:

• Subtitles/captions
• A transcript
• Audio description
• A media player that enables users to control using keyboard commands
• No flashing images or background distractions

The impact of the BSL (Scotland) Act 2015 means many colleges and universities in Scotland will also provide video content of important information in British Sign Language.

There are a few ways to create subtitles and the right one for you will depend on your learning platform and staff resource.

Given the range of approaches and complexity often involved in quality assuring captions and transcriptions in education, we have created a dedicated captioning guide.

VLE design, functionality and gatekeeping

There are two aspects to virtual learning environment (VLE) accessibility: the platform itself and the content uploaded to it. The first is similar to guidelines for web accessibility and you can use the government sample accessibility statement as a template for your VLE accessibility statement.

As many members of staff and students can upload content, the quality can be hard to monitor. How will you ensure only accessible and good quality content is uploaded?

Some options:

• Provide mandatory, accessibly designed templates
• Provide checklists for staff to use before uploading
• Share simple guides like SCULPT to remind lecturers of key accessibility elements
• Embed accessibility into staff and student training – it’s about good digital skills
• Recognise good practice and offer to work collaboratively with departments
• Involve students to know what you’re doing works for them
• Provide support with specialist tasks like subtitling and image description
• You could form working groups to help shape guidance for subject specific content

Accessible documents

Accessible documents and resources are simply correctly constructed documents. They look good, display consistently across platforms and devices, and offer students flexibility - eg, they can use assistive technology to access the content, or simply increase the font size without the formatting going all over the place.

Frequently used formats like Word, Excel and PowerPoint all have built-in accessibility checkers.

Word documents

Use headings and styles to structure the document. Structure hierarchically: heading 1 for the title/main heading, heading 2 for subheadings and so on.

Use a sans serif font like Arial and avoid text smaller than point 12 (regulations don’t specify font size, but this is generally good practice).

Align text to left. Do not justify as this creates uneven gaps between words which as well as looking bad, become huge and disorientating when text is magnified. On the topic of spacing, you do not need a double space after a full stop, this is a hangover from manual typewriting, not an accessibility practice.

Ensure colour has good contrast eg light on dark. Do not rely on colour to convey meaning.

Use plain English. When providing instructions, use active language, not passive, eg, “contact learning support…” rather than “students are advised to make contact with learning support…” Avoid metaphors and culturally specific references in information. Be clear, say what you mean.

Use meaningful hyperlinks so that when read by a screen reader, the link makes sense, eg, use “learn about meaningful hyperlinks” - linking the whole action being described - rather than “Click here to learn about meaningful hyperlinks”. 

Provide alternative text for images (we’ll consider this specifically later in the guide).

Use the Word accessibility checker to proof your document.

As it is such a widely used format, WebAIM offers an in-depth course on Word accessibility.

PowerPoint

Ensure there is good colour contrast between text and background.

Many of the features of accessible Word documents are relevant here too, eg, alignment, alt text, font style, meaningful hyperlinks.

Avoid cluttering a slide with too much text – you can use the Notes field to expand on detail.

Aim to use as large a font size as possible, ideally size 24 and avoid using all caps in text.

Use the PowerPoint Accessibility Checker to proof your slides and check the items on each slide are in the correct reading order.

pdf

Ensuring pdfs are accessible requires a bit more effort and knowledge. Adobe Acrobat has an accessibility checker and Adobe also provides guidance on creating accessible pdfs.

The regulations state that pdfs published before 23 September 2018 do not have to be fixed, unless they contain essential information. Remember that you’re still legally required to make reasonable adjustments for disabled people when they’re needed though, for example by providing the information a disabled student needs in another, more accessible format.