The governments in the European Union, United Kingdom and United States have a requirement to regularly publish data on digital accessibility of their departments and agencies. This public reporting has unleashed a great deal of accessibility innovation in Europe. The US Department of Justice (DOJ) just recently published their summary findings from their agencies, after failing to for a decade. It is clear now how much time they have lost.  

Canadian government departments do not need to publish data on the accessibility of their digital services. 

This year, we should start to see department specific reports against the accessibility action plans of that department. Unfortunately, this is way too general. It is unclear if these will be public. The lack of specificity makes it impossible to provide a government-wide report on digital accessibility for the Government of Canada. We will not be able to know if the government as a whole is making progress. 

Most government websites do not even meet WCAG 2.0 AA, let alone the current best practices. More importantly, government services continue to present barriers to Canadians. 

For many working in government, this will be new information. The assumption for most federal employees is that the government is already meeting the WCAG 2.0 AA requirements. There was a clear decision of the 2012 Supreme Court in the Donna Jodhan Case which reinforced that having an inaccessible site is a violation of Charter rights. At that point all government websites were mandated by the courts to ensure that they meet WCAG 2.0 AA. 

The Accessible Canada Act was intended to be a brave step in improving services for disabled Canadians. The act targets the Government of Canada and about 20,000 federally regulated organizations. There is space within the act to regulate those organizations, but the act was signed in 2019 and Canada seems to be falling further behind. 

Progress on digital inclusion in the Canadian Government has just not kept up with the changes in technology, or advances made by other governments. Fortunately, there are best practices in digital inclusion that can be applied from other governments globally, including the UK and the EU. Canada clearly needs to jumpstart its accessibility maturity, to ensure that it is addressing the inclusion challenges of 2023 with approaches that are appropriate for today. 

1) Clearly state that PDFs must be avoided

The most cost-effective and inclusive approach to document accessibility was provided by the UK government. They highlighted not only that PDFs are a problem to assistive technology users, which they are, but also that they present a significant problem for anyone using a smartphone. Unlike HTML, PDFs generally do not reflow to fit the size of the screen. 

PDFs are an ongoing problem with accessibility. It is commonly known that most PDFs present barriers to access for people with disabilities. PDFs were never built to be accessible. Efforts to add accessibility into the format are only partially successful. They exclude low vision users as well as anyone trying to read a document on their cell phone.  They are an outdated format that excludes many Canadians.

It is still too easy to publish PDFs, and too difficult to make them accessible. This is especially true with PDF Forms. Sadly, for people without accessibility expertise, it is still nearly impossible to distinguish between accessible and inaccessible PDFs. 

The Treasury Board should clearly state that government content should be published in HTML, and that PDFs should be avoided. Write clear guidance indicating how to write accessible documents and warning people about the challenges that are inherent with PDFs. Provide accessible templates for agency document policies to help enforce this. 

Automate Basic PDF Validation

If government agencies insist on using PDFs, there needs to be automated validation built in to block the PDFs that obviously fail to meet accessibility standards. Canada should build on open source tools like Luxembourg’s simplA11y PDFCrawler, which can collect PDFs and evaluate them for basic accessibility issues. While Luxembourg is a very small country, this approach could be expanded so that it could serve much larger government agencies to automate the process of identifying inaccessible documents. 

Many of the approaches here could also be incorporated into CMS like Drupal or WordPress. It is possible to evaluate if documents have basic semantic markup within the PDF and block files from being uploaded that have images without a text alternative or proper tagging. This would catch many of the PDFs that are uploaded to government sites. 

There also should just be more friction in the process of uploading PDFs, so that departments shift their behaviours. Publishing tools can be configured to actively discourage users from uploading PDFs, and explaining how they can use other formats like EPUB. Creating HTML or EPUB documents is often much easier when authors are starting with their original publishing tool (often MS Word). 

2) Standardize government-wide accessibility monitoring

Because of the Web Accessibility Directive, both European Union countries and the UK are doing government-wide accessibility monitoring. For countries following this EU Directive, they must provide a public report of digital accessibility every three years. 2022 was the first year these monitoring reports were made available and many also have English translations. 

Each member state of the EU chooses its own path to accomplish this, but they have made efforts to make results that are comparable. The European Commission has funded the W3C’s Accessibility Conformance Testing (ACT) to see that there are different open source accessibility engines that can be used, but that have comparable results.  Ireland and the Netherlands both have introduced a dashboard that allows departments to make meaningful comparisons. 

In Canada, it should be mandatory that the full reports from government departments are public to allow for independent evaluations and comparisons. The reports should include both automated testing, manual testing, and feedback from users with disabilities. 

Create a dashboard that highlights errors

Open source tools now allow for basic government-wide accessibility testing. Government agencies can find real barriers and avoid false positives, by using site-wide accessibility monitoring services. Many are currently using proprietary tools which take a page by page approach. Some departments are using these tools to support their accessibility efforts. When looking at a government-wide solution a proprietary solution would be too expensive and limited in scope. 

A centralized accessibility scanning service, funded by the federal government, leveraging open source tools, would centralize the cost and remove budgetary barriers for individual departments. 

It would also provide a common platform for basic metrics, which would provide useful comparisons that are nearly impossible today. Inconsistent evaluation practices of different agencies makes central reporting far less meaningful. Self reporting by agencies provides far too much room for bias. 

By leveraging common open source tools like Deque’s axe, it is possible to create a meaningful dashboard which highlights a common set of accessibility barriers across all government departments. The Netherlands has an excellent example of what a public dashboard should look like.  Departments should be on a government-wide leaderboard that highlights their web accessibility errors. This would allow executives to easily understand how their team’s work compares with others. It should also allow the ability to view progress over time. This can be automated so that data is gathered government-wide and reported on a monthly or weekly basis.

CivicActions is working with open source approaches that allow for government-wide scanning using a central open source approach. Our goal is to produce an open source leaderboard, as we have described. 

3) Support authors to create accessible content

One of the best ways to improve accessibility for websites is to provide better support for authors. Most content on government websites is not written by accessibility experts. Authors need support in producing accessible content. The W3C’s WAI produced the Authoring Tools Accessibility Guidelines (ATAG) 2.0 to help provide guidelines for how authors can get the support they need. 

ATAG is broken into two parts. Part A highlights the need for the back-end interface to be as accessible as the front-end. The authors and administrators of government websites may have disabilities, much like the rest of the population. This is sometimes considered in procurement.

Part B promises the biggest opportunity to address accessibility barriers. Authors should be supported in writing accessible content. Having patterns be accessible by default makes it harder for authors to create inaccessible content. 

There is also a huge opportunity to help use automated tools to show authors how to create more inclusive content. We know this works for spellcheck and grammar check—why isn’t this enabled by default by authoring tools for accessibility? It has been encouraging to see the advancement of authoring tools like Editoria11y and Sa11y which have built tools to help with this. 

The European Commission supported the We4Authors Cluster project, which supported accessibility best practices for authoring interfaces. The We4Authors project sought to determine what CMSs were used within the EU.  The goal was to encourage the software designers to identify and implement best practices for authoring interfaces which would make accessibility easier. This may be the only cross-CMS author focused accessibility study that has been funded by a government. 

Of the EU government sites surveyed with the We4Authors project, the majority used Drupal. CivicActions participated on behalf of the Drupal community in this EU funded project. Some of the recommendations were already introduced in Drupal 8, while others are still being incorporated. 

4) Create meaningful feedback loops through accessibility statements

In Canada it isn’t uncommon to see government sites say that they are trying to meet WCAG 2.0 AA requirements, or even WCAG 2.1 or EN 301 549. But this statement alone is insufficient. The UK government has provided an amazing example of impactful accessibility statements. 

The UK is using their accessibility statements to assess issues like:

  • What are the known barriers? 
  • Are there workarounds which are known? 
  • What tools and techniques have been used to address accessibility? 
  • Are there easy ways for people to report problems? 

Departments could go further to:

  • Track this feedback
  • Ensure that barriers can be submitted anonymously
  • If people provide contact information, provide follow-up to ensure their issue is being addressed
  • Link to existing accessibility policies
  • Provide links to descriptions of accessibility accommodations in physical offices

The government of the Netherlands produces accessibility statements like the UK, but they have gone a step further. They are monitoring these statements across all their government sites. They are also evaluating not just the presence or absence of these statements, but if the statements need work to be fully compliant. In the Netherlands, government departments that do not have compliant statements need to state when they expect to have compliant accessibility. This pushes departments to identify and commit to a timeframe, rather than simply settling with not being fully compliant.

People with disabilities deserve access to government services. Most are not interested in becoming engaged in filing a complaint with the Accessibility Commissioner. Sites need to facilitate getting feedback from users with disabilities to those who can most quickly address those barriers.  The guidance on this to organizations is overly general, and will be inconsistently implemented without clear direction. 

5) Keep accessibility evergreen

Europe has made a commitment to keep up with the evolutions of best practices of digital accessibility. Digital technologies are rapidly accelerating because of the internet. To support the needs of users, it is critical that governments agree to follow the latest recommendations from the World Wide Web Consortium (W3C)’s Web Accessibility Initiative (WAI). There are some government departments still looking for digital interfaces to meet WCAG 2.0 AA, which was a best practice in 2008—15 years ago.

The EU is evaluating the WCAG release recommendations and their accessibility standards, EN 301 549, is updated regularly. The standards bodies that create this EU Standard evaluate best practices and release updated versions to support digital inclusion.

There is no reason not to build to the latest WCAG recommendation. It is the codified best practice for building digital accessibility into good customer experience. This can be incorporated into existing contracts and even into public accessibility statements. 

Invest in standards organizations

It took 4 years to provide an official translation of WCAG 2.1 into French. If the Government of Canada wanted to see that Francophones were included, they would begin translating the draft recommendations prior to the finalization by the W3C. An interim set of recommendations could be used while the W3C is finalizing the official French release. This could be an effective role for the new Accessibility Standards Canada. 

The EU is investing in maintaining the EN 301 549 standards, which are maintained by three separate EU standards organizations. Accessible Standards Canada, could be engaging with new releases of the EN 301 549 and ensuring that these can be effectively integrated into Canadian legislation. Like WCAG regulations, these will also need to be translated into French. 

The EU also supports several initiatives from the W3C WAI. The W3C really is the central organization that manages global accessibility for the web.  The Government of Canada could financially support WAI initiatives. It could also support involvement of Canadians to develop WAI initiatives. Doing this would be an effective way to support the basic infrastructure for our modern digital life. Digital government depends on open standards, which can be implemented consistently worldwide. 

6) Procurement

Government procurement should be improving government accessibility. There has not been a great deal of innovation in Europe around accessible procurement. Most European countries have looked at the early leadership from the USA on Section 508 and the Voluntary Product Accessibility Template and decided that this was not a model that was effective for them. European countries are struggling to find better ways to engage with their vendors, but there is no clear leadership. 


The Netherlands and the W3C have done a lot of innovation with the creation of the WCAG Evaluation Methodology (WCAG-EM). This process and the associated WCAG-EM Tool help website evaluators strategically evaluate the accessibility of websites. Contracts can be set up to evaluate a website when it is launched, and then every year after that. Because the WCAG-EM Tool produces machine-readable reports, it is easy to see a comparison between different departments and over time. 

The CivicActions team saw an opportunity to modernize procurement by leveraging the open source solutions provided by the WCAG-EM Tool. Working for the USA Government’s General Services Administration (GSA) we built OpenACR to support a transition to a modern machine-readable approach to leverage global best practices. We saw that there was a need to rethink how Accessibility Conformance Reporting was done that allowed agencies to use the data to inform decision-making about a vendor’s accessibility claims. With a machine-readable approach, it will finally be possible to have an enterprise-wide view. 

There is a lot that can be done to revise the procurement process. In the USA, we have seen PEAT Works and Disability:IN produce some amazing recommendations for best practices. Procurement and contracting officers have a critical role in structuring accessible procurement. Early engagement with vendors and consistent application across government departments is key for effective adoption. 

Next steps 

There is a lot to be learned from global government agencies. Accessibility is a serious problem which requires a holistic approach. The EU and the UK have provided a great deal of leadership around accessibility in the last few years. Because this has been developed and implemented in Europe already, it will be easier for adoption to occur in Canada. We do not need to establish a new precedent or reinvent the wheel—we can improve on models that European countries are already using to improve accessibility.  By refining and contextualizing these ideas, we can easily transform Canadian digital government so that inclusivity is baked into our government’s websites.