The EU Web Accessibility Directive
In 2016, the European Parliament and Council adopted Directive 2016/2102 on the accessibility of the websites and mobile applications of public sector bodies. The directive requires that public bodies’ digital solutions must meet WCAG 2.1 AA and enable all citizens — including people with disabilities — to access public information and services digitally.
The directive also introduced the requirement for public bodies to publish an accessibility statement describing the extent to which their digital solutions meet the requirements, along with a contact option for citizens who encounter accessibility barriers.
Implementation in Danish Law
In Denmark, the EU directive has been implemented through Act No. 692 of 8 June 2018 on the accessibility of public sector bodies’ websites and mobile applications. The law requires all public bodies — at state, regional, and municipal level — to ensure their websites and mobile apps meet the harmonised European standard EN 301 549, which references WCAG 2.1 AA.
The Danish Agency for Digital Government is the national supervisory authority and is responsible for monitoring compliance. The Agency conducts ongoing supervision and publishes reports on accessibility status in the public sector.
What is Concretely Required of Public Authorities?
In practice, the legislation places the following requirements on public authorities:
- Websites and mobile apps must meet WCAG 2.1 AA for all new and existing pages.
- An accessibility statement must be available on the website and updated regularly.
- Citizens must have a contact option for reporting accessibility barriers.
- A reasonable response time must be provided for accessibility enquiries (within 4 weeks).
- The statement must specify which parts of the website are exempt — e.g. map applications or older PDF archives.
PDFs and Accessibility in the Public Sector
One of the largest accessibility problems in the public sector is PDF documents. Many authorities distribute forms, guidance, and reports exclusively as PDFs — and by no means all of these PDFs meet the necessary accessibility requirements.
Guidance indicates that PDF files which are the only alternative for information must either meet the PDF/UA standard or be accompanied by an accessible HTML version. This is a resource-intensive task for many authorities that may have archives containing thousands of documents.
Browser-based solutions like PDFAccess offer a practical alternative here: with a few clicks, existing PDF documents can be converted to WCAG 2.1 AA-compatible HTML — without server upload and without purchasing expensive software.
Accessibility and Users with Disabilities
In Denmark, approximately 17% of the population live with some form of disability — equivalent to nearly one million Danes. In addition, many older citizens have difficulty using digital solutions and benefit from accessible design.
For these citizens, digital accessibility is not a nice-to-have, but a prerequisite for participating in society on equal terms. Accessible web content and accessible PDF documents are a crucial step towards digital inclusion.
Resources and Practical Guidance
There are several good resources for public authorities wishing to work systematically on web accessibility:
- The Danish Agency for Digital Government (digst.dk): National guidance, accessibility templates, and supervisory reports.
- W3C Web Accessibility Initiative (w3.org/WAI): Official documentation, techniques, and test procedures for WCAG.
- WAVE Web Accessibility Evaluation Tool (wave.webaim.org): Free browser-based accessibility testing.
- axe DevTools: Browser extension for automated accessibility scanning.
- PDFAccess (pdfaccess.net): Free conversion of PDF documents to WCAG 2.1 AA-compatible HTML.