Accessible ICT Documentation for Europe?

(Note: This article originally appeared in the Spring 2008 edition of Communicator, the quarterly journal of ISTC – Institute of Scientific and Technical Communicators. Accessible Techcomm is grateful for the permission to reprint the article here.)

Richard Hodgkinson reports on new developments for European ICT documentation accessibility.

Regular readers of these pages will recall my reports on the US Government ("Section 508") requirements for the accessibility of Information and Communication Technology (ICT) documentation (Autumn 2003) and software documentation accessibility (Summer 2007). Whilst those requirements are not mandatory for the documentation of ICT products sold within Europe, the situation is beginning to change.

An estimated 90 million people in the European Union (or 20% of the population) are elderly or have some form of disability. With improved healthcare we are living longer and the numbers of elderly people are increasing. Across Europe, public procurement has long been recognised as the key means of improving the accessibility of ICT products (hardware and software) and services (e.g. web sites) for the elderly and disabled. In the USA, meeting the "Section 508" requirements has resulted in the same accessible products being available to all private and business users, not just government organisations.

EC Mandate 376

In 2005 the European Commission published Mandate 376 (Standardisation mandate to CEN/CENELEC and ETSI in support of European accessibility requirements for public procurement of products and services in the ICT domain).

M/376 requests that the standards organizations work to harmonize throughout Europe those accessibility requirements that may be applied, regardless of the value of the purchase to public procurement of ICT products and services and thereby to achieve interoperability.

The ultimate aim is to establish a set of mandatory requirements to be used by all government organizations (including local government) across the European Union when purchasing ICT equipment, software and services.

The mandate is being carried out in two phases:

Phase 1

This phase will include the creation of an inventory of European and international accessibility requirements, and an assessment of testing and conformance schemes for ICT products and services. The work is being shared between ETSI (European Telecommunications Standards Institute) and CEN/CENELEC (European Committee for Standardisation), and in September 2007 two teams were established for this purpose…ETSI HF STF 333 and CEN/BT WG 185.

The two teams are working closely, and regular drafts have been produced. Next summer the Design for All and Assistive Technology Standards Co-ordination Group (DATSCG) will host a public workshop to present the work. Publication of the final report is planned for early 2009. The work of both teams is open to public view and comment on their respective web sites (see below).


ETSI Human Factors Specialist Task Force 333 is currently researching existing public procurement requirements and practices, national legislation and accessibility standards across Europe, the USA, Canada, Japan and Australia (see Specialist Task Force 333: European Accessibility Requirements for Public Procurement of Products and Services in the ICT Domain (EC Standardization Mandate M 376, Phase 1) ). The latest version of the ETSI report was recently published and is available from the above link. Initial findings indicate that whilst many countries have already established requirements for government web site accessibility that are conformant with the World Wide Web Consortium guidelines (see ) minimal requirements exist for ICT equipment and software.


CEN/BT WG 185 is currently investigating conformance schemes for accessibility (see Certification or conformance: making a successful commitment to WCAG 2.0 )  Updated

Phase 2

When the work of Phase 1 is complete and the recommendations have been accepted, work will commence on Phase 2 to develop new requirements and standards to support the introduction of EU legislation for the public procurement of accessible ICT products and services.

What does this mean?

Early in the next decade we should expect to see the introduction of EC Directives and national legislation that will make it mandatory for EU government organizations to purchase only accessible ICT products, services and supporting documentation. Non-accessible products and services are unlikely to be able to enter the bidding process for those contracts.

What about ISO documentation standards?

With the background of the US situation and knowledge and experience gained, ISO/IEC JTC 1/SC 7/WG 2 (Software and systems documentation) has already commenced work on a suite of documentation standards that will incorporate accessibility requirements and guidance as appropriate to specific audiences. When published these standards can be referenced in purchasing requirements, they are:

  • ISO/IEC 26511 – Requirements for managers of user documentation,
  • ISO/IEC 26512 – Requirements for acquirers and suppliers of user documentation,
  • ISO/IEC 26513 – Requirements for testers and assessors of user documentation,
  • ISO/IEC 26514 – Requirements for designers and developers of user documentation.

Richard Hodgkinson FISTC has participated in the development of ISO standards addressing icons, symbols, software documentation and software accessibility since 1990. He is also a team member on ETSI HF STF 333. E: Richard_Hodgkinson at

International Disability: United States

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