Digital Democracy for All?
Web Accessibility in Ireland, 2002

Dr. Barry McMullin
Research Institute for Networks and
Communications Engineering (RINCE)
Dublin City University

4 November 2002
[Document also available in PDF Format.]


Preface: Users With Disabilities Need Not Apply

Irish people with disabilities, who make up ten per cent of our population, experience varying degrees of difficulty in accesssing the most significant comunications medium in the history of technology--the World Wide Web. For many of us, unless we have direct personal experience, these 400,000 people are invisible. Yet they should be seen as an asset as well as a responsibility for the entire community. Because of the present and growing importance of web accessibility for all citizens, particularly those with disabilities, AIB Bank commissioned a study by Dr. Barry McMullin of the Research Institute for Networks and Communications Engineering (RINCE) at Dublin City University. This brochure summarises the excellent and important work contained in that study, entitled Web Accessibility in Ireland; the full text of the study is available online McMullin (2002b).

To highlight just one of the many illuminating points made in the study: if all the bodies and people involved in commissioning, publishing and designing web sites were to make these sites more accessible for people with disabilities, they also would make them much more accessible for people without disabilities--thus enhancing their appeal and use.

If anybody asks me what the Internet means to me, I will tell him without hesitation: To me (a quadriplegic) the Internet occupies the most important part in my life. It is my feet that can take me to any part of the world; it is my hands which help me to accomplish my work; it is my best friend--it gives my life meaning.
- Dr. ZhangXu (Zhangxu & Aldis, 2001)


The technology of the Internet holds tremendous promise to significantly improve access to information, goods, and services for many people with disabilities. Properly engineering web sites can interoperate with dedicated assistive technologies to flexibly address a wide range of disabilities. Almost overnight, it has become possible for a person who is blind to read papers, magazines and books, without assistance, and on the same day they are published; for a person with restricted mobility to shop for groceries, and pay her bills without even leaving home; for a deaf student to attend a "virtual" lecture, with sub-titling and text transcripts (W3C, 2001a).

The key is in the design of web sites so that they facilitate--rather than obstruct--access by groups of people with disabilities. This is not rocket science: the basic requirements have been internationally codified since 1999 in the Web Content Accessibility Guidelines (WCAG) 1.0 published by the World Wide Web Consortium (W3C, 1999), and more recently endorsed by the European Commission (2001) and the Irish National Disability Authority (2002).

These guidelines define a series of checkpoints which, if satisfied by a web site, will ensure that it has a high likelihood of being accessible to the widest possible variety of users. This is good for the community of people with disabilities--but it is also very good for the general community of web users. It is well established that universal design frequently results in products and services that are more usable for all. And in the world of the web, where another site is only ever a key-click or a button-press away, improved usability must be a key priority for all web site operators. It is the proverbial win-win situation.

Though this is the promise, the reality depends, of course, on the extent to which the guidelines are actually observed in practice.

WCAG defines three conformance level: WCAG-A is a minimum standard which a site must meet to be considered accessible for any significant disability groups; WCAG-AA is a "professional practice" standard, which all sites should meet to be accessible to a broad range of disability groups; finally WCAG-AAA is a "gold standard" of maximum accessibility which some sites may choose to aim for--for example, sites with a particular remit to serve communities of people with disabilities.

Over the last two years, with the support of AIB PLC, a project has been underway at the Research Institute for Networks and Communications Engineering (RINCE) at DCU to investigate the conformance of the Irish web to the WCAG guidelines. Following the development of technical support tools, a detailed accessibility study of over 159 separate web sites operated by Irish organisations, spanning a wide range of activities, information, and services, was conducted in the Summer of 2002.

These sites were tested for a selected set of 25 separate characteristics, or potential defects, which are correlated with the WCAG guidelines. This set is not exhaustive: it cannot determine that any site positively meets the guidelines; but failure on any of these tests definitively demonstrates failure against the guidelines.

Complete technical details of the methodology and outcomes of the study are available in (McMullin, 2002b): the current summary report distills the key results, summarises the most pervasive defects encountered--and, most importantly, the recommendations for action that follow.

Key Results

Of the sample sites studied:

Pervasive Defects

Of the 25 specific accessibility barriers studied, the most pervasive (at WCAG-A and WCAG-AA standards) were as follows:

Of course, many sites exhibited a combination of these defects, and others.

The list above should be interpreted carefully. It identifies a number of accessibility barriers which this study has identified as pervasively present across the Irish Web; however, the list is by no means exhaustive. For technical reasons, many other potential accessibility barriers were not even considered in the current study: it is likely that at least some of these would be as pervasive as some or all of the factors identified above. In other words, bleak as the above picture is, it is almost certainly an understatement of the difficulties faced by users with disabilities in accessing the Irish Web.

This list may be a useful starting point for web site operators in considering the accessibility of their own individual sites: but it is, of course, no substitute for:

Recommendations for Action

Public Awareness

A web accessibility awareness campaign, targeted specifically at relevant policy and decision makers in both public and private sectors, should be an immediate priority. This should focus explicitly on the incorporation of accessibility requirements into all specifications, tender documents, etc., for web services.

The most pervasive accessibility barriers identified in this study currently appear to be primarily products of ignorance rather than design. Senior decision makers, responsible for commissioning web sites and services, presumably do not set out to discriminate against users with disabilities. However, it seems that, in too many cases, they are still unaware of the requirements (and opportunities!) of making web sites and services universally accessible.

There is some evidence that this situation is improving. The Information Society Commission has been active in promoting public debate on this and related issues (Irish Information Society Commission, 2000). The NDA has recently published over-arching IT Accessibility Guidelines (incorporating WCAG), and is actively promoting their adoption (Irish National Disability Authority, 2002). A number of Irish web design consultancies now highlight accessible design. The recent requirements statement for the Public Services Broker, issued by the Irish Government Agency REACH, explicitly includes accessibility requirements (REACH, 2002).

Nonetheless, the results of the current study indicate that these efforts are certainly not yet fully effective, and it is recommended that advocacy efforts be intensified.

New Tools and Technologies

Organisations developing software and tools for web site development should ensure that these conform to relevant standards and guidelines for producing accessible contents and services. Organisations sourcing or evaluating new web development tools should make conformance to accessibility guidelines an essential qualifying condition.

It is increasingly the case that web content and services are developed using a variety of more or less sophisticated authoring tools, packages etc. The accessibility of the developed content and services then depends significantly on the extent to which those tools have been designed to support this. The W3C has again been to the forefront in promoting good practice in this area, for example in specific guidelines for authoring tools and applications (W3C, 2000,2001b). Unfortunately it seems that many tools still do not incorporate such techniques adequately.

Leading by Example

A detailed timetable should be immediately published for all Government Department Web sites to achieve WCAG-AA compliance. Reports on progress against this timetable should be issued regularly. A co-ordinated project to achieve compliance across the wider public sector should be centrally initiated and monitored. Private sector organisations should initiate similar comprehensive commitments to an accessible Irish web.

In the context of the E-Europe Action Plan, Ireland declared a target that all Government Department Web sites should have achieved WCAG-AA compliance by the end of 2001 (European Commission, 2001). This is a very laudable goal, and substantial resources are evidently being directed to it. However, it was apparent from the current study that this had certainly not been achieved by the target date; in fact, defects were detected on all such departmental sites included in the sample. In any case, this initiative should surely not stop at Government Departments, but should extend to all publicly supported agencies and institutions. Similar initiatives can, and should, by taken by private sector companies, representative organisations and professional bodies.

Education and Training

Training materials, courses, etc., relevant to universal design should be developed and promoted by the widest possible variety of organisations involved in education and training. Professional bodies should require that Universal Design be incorporated in the curriculum of all relevant educational programmes.

It is apparent that specific, pervasive, web design flaws identified in this study could be drastically reduced or eliminated if the issues were adequately understood by relevant personnel. There is a particular need to provide appropriate training for technical and design professionals. Some progress is being made in this front at the European Level, particularly through the E-Europe Action Plan (European Commission, 2000), which includes a commitment to the development of a European curriculum in "design for all" for designers and engineers. However, effective engagement with such European initiatives relies on support from national agencies in individual member states.


Legislation should set explicit, comprehensive, and legally enforceable standards for accessibility of all web products and services to users with disabilities.

There is evidence from other jurisdictions (notably the US, UK, Germany and Australia) that strong legislation to protect the rights of citizens with disabilities (in all areas of life) is a regrettable, but nonetheless essential, element in achieving comprehensive engagement with accessible design. The current Irish legal situation regarding web accessibility is, at best, unclear. Some protection may be available through the Equal Status Act (An tOireachtas, 2000), through there is no case law yet to test this. The criteria and remedies available under that act are, in any case, strictly limited. The Disability Bill (An tOireachtas, 2001) proposed some more explicit (but still strictly limited) measures. However that bill was, of course, withdrawn following considerable opposition from disability groups. It is to be hoped that a revised bill, inter alia specifically addressing accessibility of information goods and services, in both public and private sectors, will now be published as a matter of urgency by the new government.

Further Research

Research and development of technologies to support social inclusion in the information society should be actively encouraged, and materially supported, by both public and private sector agencies and organisations.

The current study provides only a crude baseline assessment of the accessibility of the Irish web. The detailed report (McMullin, 2002b) discusses both the strengths and limitations of its particular methodology; and lays out a programme of further work to extend, clarify, and refine our ability to monitor the evolving state of Irish web accessibility--as an essential tool for informed policy formation. There is also an ongoing need for research and development of new web technologies to support both service providers and users with disabilities. The previous Disability Bill (An tOireachtas, 2001) proposed the establishment of a national Centre for Excellence in Universal Design to promote and support research in all aspects of Universal Design, on a continuing basis: this proposal should be elaborated in the drafting of any new bill. By this means, or otherwise, there should also be strong engagement by Ireland in international fora (such as W3C) concerned with accessibility of information society technologies.


This study should be a "wake-up call"--for government, for public agencies, for private companies, organisations and individuals. It signals that, despite Ireland's justifiable pride in its economic and technological development, despite very laudable goals in documents such as the E-Europe Action Plan (European Commission, 2001,2000), the current commitment to accessibility of the Irish web for users with disabilities is, at best, aspirational--and, at worst, cynically inadequate.

This is doubly unfortunate. It is not just that web technology is not being applied--as it could be--to positively improve opportunities and capabilities for users with disabilities; but on the contrary, as web services become more pervasive and essential, to the extent that they remain inaccessible this will actually impose progressively more disadvantage and exclusion on groups with disabilities in our society.

It is hoped that the results of this study will serve to highlight these issues, and to further encourage the many agencies and organisations who are already actively promoting and supporting voluntary improvements in web accessibility in Ireland. Ultimately however, there must surely also be a role for compulsion--legislation and regulation--to fully guarantee and vindicate the rights of all citizens to equal treatment in a digital democracy.


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` Equal Status Act, 2000', Government Publications Office.
(Accessed: 31 July 2002)
An tOireachtas (2001),
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(Accessed: 31 July 2002)
Engelfriet, A. (1997a),
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(Accessed: 2 August 2002)
Engelfriet, A. (1997b),
` What's Wrong With Frames?', Web Design Group.
(Accessed: 2 August 2002)
European Commission (2000),
` eEurope 2002: Action Plan'.
(Accessed: 17 October 2002)
European Commission (2001),
` eEurope 2002: Accessibility of Public Web Sites and their Content: Communication from the Commission to the Council, the European Parliament, the Economic and Social Committee, and the Committee of Regions', Commission of the European Communities.
Microsoft Word Format.
(Accessed: 17 October 2002)
Flavell, A. J. (2002),
` Use of ALT Texts in IMGs'.
(Accessed: 20 April 2002)
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(Accessed: 23 October 2002)
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(Accessed: 17 October 2002)
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(Accessed: 17 October 2002)
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(Accessed: 17 October 2002)
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PDF Format (2.3MByte).
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(Accessed: 22 June 2002)
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(Accessed: 20 April 2002)
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(Working Draft).
(Accessed: 20 April 2002)
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(Accessed: 1 August 2002)
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(Accessed: 17 October 2002)
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(Accessed: 26 September 2002)


The work described here could not have come about without generous financial support provided by AIB PLC. I am especially indebted to John Kelly, Head of Business Banking at AIB. He demonstrated an enduring faith and commitment to the the project, and the ultimate value that it could have in setting the agenda for Ireland's emerging information society.

Detailed research and development for the project was carried out by my two research students, Esmond Walshe and Carmen Marincu.

The work was carried out in the Research Institute for Networks and Communications Engineering (RINCE), established at DCU under the HEA Programme for Research in Third Level Institutions (PRTLI).

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