Regulatory context
Government and public sector websites are covered by two major EU regulations. The Web Accessibility Directive (WAD, Directive 2016/2102) has been in force since 2018 and requires all public sector websites and mobile apps to meet EN 301 549 (WCAG 2.1 Level AA). The EAA (Directive 2019/882) adds requirements for any services governments provide that fall within EAA scope - e-commerce, banking, transport ticketing, and more. Public sector bodies must also publish accessibility statements, provide feedback mechanisms for users to report barriers, and undergo regular monitoring by national authorities. EN 301 549 is the harmonised standard for both directives. Many member states have transposed these directives with additional national requirements that exceed the EU minimum.
Common issues Lumi finds in government & public sector websites
Complex form and application processes
Government forms for tax returns, benefit applications, licence renewals, and permit requests are frequently long and complex. Multi-step processes with conditional logic, document uploads, and reference number lookups need proper form labelling, error handling, and progress indication for screen reader users.
Document and PDF accessibility
Government bodies publish vast quantities of PDFs - reports, guidance documents, consultation papers, forms, and legal texts. The majority of government PDFs lack proper tag structure, reading order, alt text, and language attributes. Under the WAD, all published documents must be accessible.
Authentication and identity verification
National identity systems (eIDAS, national eID schemes) and government login portals frequently have accessibility barriers in authentication flows. Multi-factor authentication, document scanning for identity verification, and CAPTCHA all create obstacles for users with disabilities.
Data tables and statistical publications
Government statistical data, open data portals, and public registers use complex data tables that frequently lack proper header markup, scope attributes, and captions. Large datasets presented as tables become impenetrable without proper semantic structure.
Video and multimedia content
Government communications increasingly use video - ministerial statements, public consultations, service explainers, and emergency broadcasts. Videos require captions, audio description, and transcripts. Many government video platforms lack these alternatives entirely.
Accessibility statement and feedback mechanism
The WAD requires every public sector website to publish an accessibility statement and provide a mechanism for users to report barriers. Many government sites have incomplete statements, outdated audit results, or feedback mechanisms that are themselves inaccessible.
Government & Public Sector-specific challenges
Government and public sector organisations face the most stringent accessibility requirements in the EU because citizens have no choice but to use these services. Unlike commercial services, users cannot switch to a competitor. This creates a higher obligation to ensure universal access. Government websites are often large (thousands of pages), maintained by multiple departments with varying levels of accessibility expertise, and built on legacy content management systems. Procurement processes mean third-party suppliers must also deliver accessible products. National monitoring bodies conduct regular audits, and results are publicly reported to the European Commission.
Compliance timeline
The WAD has been enforceable since September 2018 for new public sector websites, September 2019 for existing websites, and June 2021 for mobile apps. Government bodies should already be compliant. The EAA adds requirements from June 2025 for any government-provided services in EAA scope. National monitoring bodies conduct periodic audits, with results reported to the European Commission. Non-compliant public sector sites face enforcement action under national transpositions of the WAD.
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Frequently asked questions
What accessibility law applies to government websites in the EU?
The Web Accessibility Directive (Directive 2016/2102) is the primary legislation for public sector websites and apps. It requires conformance with EN 301 549 (WCAG 2.1 Level AA), an accessibility statement on every site, and a feedback mechanism for reporting barriers. The EAA adds further requirements for government services that fall within its scope.
Do government PDFs need to be accessible?
Yes. Under the WAD, all documents published on public sector websites must be accessible. This includes PDFs, Word documents, spreadsheets, and presentations. They need proper tag structure, reading order, alt text, and language attributes. Only documents published before September 2018 are exempt, unless they are needed for active administrative processes.
What is the difference between the WAD and the EAA for government?
The WAD specifically targets public sector websites and mobile apps, requiring EN 301 549 conformance, accessibility statements, and monitoring. The EAA targets products and services sold to consumers across sectors. Government bodies are subject to the WAD for their websites and apps, and additionally to the EAA for any consumer-facing services they provide that fall within EAA scope.
Are government mobile apps covered?
Yes. The WAD explicitly covers public sector mobile applications, which have been required to comply since June 2021. EN 301 549 includes specific requirements for mobile apps beyond web content, covering touch interaction, gestures, and platform accessibility API support.
Related resources
Last reviewed: April 2026. Content is reviewed quarterly for accuracy.