Accessibility instructions for product owners

These instructions are intended for product owners and other persons who are responsible for a digital service covered by the Digital Services Act. The purpose of the instructions is to help meet the requirements of the Digital Services Act.

More links to the University of Helsinki’s accessibility instructions and orientation material concerning the self-assessment of accessibility can be found in Flamma.

    Accessibility requirements in digital services

    The Act on the Provision of Digital Services (Only in Finnish), or more familiarly the Digital Services Act, obligates the authorities and, therefore, the University of Helsinki. 

    The Digital Services Act contains three key requirements that a digital service covered by the Act must meet:

    1. The service and its contents must meet the accessibility requirements, i.e. 49 of the A and AA level criteria of the international Web Content Accessibility Guidelines (WCAG) 2.1.
    2. The accessibility of the service and its contents must be assessed and the status of accessibility and its possible shortcomings must be presented in the accessibility statement.
    3. The service must include an electronic feedback channel for submitting accessibility feedback. Feedback must be responded to within fourteen (14) days.

    The University's values include sense of community, which means, among other things, equality and non-discrimination between University staff and students. On the other hand, the Non-Discrimination Act obligates the employer, even though user interfaces intended only for employees are not covered by the Act. 

    The Ministry of Education and Culture has ordered higher education institutions to draw up an accessibility plan. The Rector approved the accessibility plan of the University of Helsinki in March 2023. One of the areas of the plan is digital accessibility. The related priority measures for 2023–2024 are the accessibility audit of the systems and the preparation of an accessibility statement.

    Accessibility of digital services is required by the legislation, but it is also estimated that up to 1–2 million Finns directly benefit from accessibility. Improved accessibility benefits all users as well as enables the use of services for certain groups of users.

    Web Content Accessibility Guidelines (WCAG) 

    • Collection of accessibility guidelines whose A and AA level criteria must be complied with according to the Digital Services Act.
    • The current version of the WCAG guidelines required by the Digital Services Act is 2.1. The requirements of the Act may change with new versions.
    • The guidelines illustrate the content and structure of network services and provide means to ensure accessibility.


    Fulfilling the requirements of the Digital Services Act

    According to the Digital Services Act, the service must have an accessibility statement. In order to create an accessibility statement, an accessibility assessment must first be carried out to determine the accessibility status of the service. The assessment can be carried out as a self-assessment, or it can be commissioned by an external supplier. The accessibility assessment checks the accessibility of the service against the A and AA levels of the WCAG 2.1 guidelines.

    Accessibility self-assessment

    Scoping of the assessment
    The scope of the content to be assessed should be as comprehensive a sample of the service as possible. For example, different subpages, typical usage situations and paths as well as key components and elements should be assessed. It is often not possible to assess the entire site.

    Accessibility testing

    Automatic testing

    • Browser extensions, e.g. WAVE and Accessibility Insights
    • Find most of the technical accessibility issues, but are unable to assess context-dependent content.
    • Form a test package with manual testing.

    Manual testing

    • Includes screen readers and use of the keyboard.
    • Go through the service with a keyboard only, without a screen reader, and with a screen reader. All functionalities must be accessible through both methods.
    • Verify the results of automatic testing and review all aspects that cannot be tested through automatic testing, such as the clarity and relevance of the content.
    • Different checklist tools can be used for testing.


    Assessment by an external expert

    The accessibility audit (accessibility assessment with improvement proposals) can be commissioned by an external supplier. The University of Helsinki has a framework agreement for digital services, which also includes work related to accessibility, such as accessibility audits.

    More information on purchasing an audit can be found in Flamma.

    Fixing accessibility issues

    From the point of view of the legislation, all accessibility issues are equal and all users must be treated equally. Any accessibility issues must be fixed.

    However, the most serious issues can be prioritised when scheduling the fixing of issues, such as:

    • a problem that completely prevents the use (e.g. login is not possible)
    • a problem in frequently used functions or elements.

    Preparing the accessibility statement and maintenance

    An accessibility statement is a file that contains the following mandatory information:

    • accessibility status
    • inaccessible content
    • date and method of preparation of the statement
    • feedback mechanism and contact details for processing feedback
    • implementation method

    You can use the Regional State Administrative Agency's statement tool to compile the statement. The statement produced by the tool complies with the EU Directive on the model accessibility statement. The tool contains detailed filling instructions.

    The statement must be legible, clear and understandable. Record the issues at a general level, a breakdown per page is not necessary if the issues occur throughout the site. The most important thing is to state in concrete terms what is not working.

    English and Swedish translations of the statement must be available. The translation versions can be ordered through the translation services.

    The statement should be updated at least once a year. Accessibility feedback must be responded to within fourteen (14) days, including during holidays.


    Accessibility in purchases

    Purchase of a ready-made system

    It must be required in the invitation to tender that the system meets the current legal requirements for accessibility. 

    The final contract must include the following accessibility conditions: 

    • The Supplier is responsible for ensuring that the system meets the aforementioned accessibility requirements.
    • The Customer has the right to carry out a separate audit on accessibility and determine who performs it.
    • The Supplier is obligated to fix the detected accessibility issues at its own expense, the deadline for fixing should also be defined.

    The aforementioned conditions should already be included in the contract template attached to the invitation to tender documents. The following example sentences can be used system-specifically to define the conditions:

    As part of the delivery of the Service, the Supplier is responsible for ensuring that the Service meets the national Act on the Provision of Digital Services and WCGA 2.1 specifications “Accessibility measurements”. The Customer has the right to perform a separate audit regarding the accessibility requirement.

    The Customer has the right to perform an audit regarding the fulfillment of the Accessibility measurements criteria regulated and defined in this contract, national legislation and/or the WCAG 2.1 guideline. The audit is performed by an external service provider specified by the Customer. The Customer is responsible for the costs of this audit. 

    For the sake of clarity, let it be stated that the costs resulting from the implementation of errors, omissions or additions found in this audit are the responsibility of the Supplier.

    According to the University of Helsinki's policy, a possible accessibility statement prepared by the supplier cannot be directly used, but the state of accessibility must be assessed by the University of Helsinki.

    Purchase of application development resources

    The invitation to tender concerning purchase of resources must specify that application developers have accessibility competence so that the system to be developed meets the requirements of the law. Make sure that the responsibilities of accessibility competence are clearly described in the invitation to tender. If the responsibilities of accessibility competence are not described in the invitation to tender, the supplier's default is that the product owner is responsible for accessibility in its entirety. In the invitation to tender, you can ask the supplier to take the main responsibility for the accessibility of the service or application.

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