Web Accessibility Requirements Under EU Directive 2016/2102/EU

April 7, 2017 BY ELISA LEWIS
Updated: March 2, 2021


With the accelerated growth of online information, web and mobile services are available for everything from online banking to meal delivery. As online media continues on this trajectory of growth, web accessibility is more important than ever before, and continues to become increasingly so.

Implementing minor adjustments that increase accessibility is beneficial to all people, not just those with disabilities. Several cases where accessible content benefits everyone include being able to listen to a book when lighting conditions are bad, reading captions when sound is inaudible, and gaining a larger audience for brands and businesses.

What Is a Directive?

A directive is a legislative act of the European Union (EU) that sets a broad objective which must be obtained by member states. In some cases, directives can be used to set minimum EU standards to be applied, while subsequently allowing member states leeway to implement more stringent national measures.

While a directive sets the policy to be reached, it does not determine the means of securing the outcome. Member states are responsible for passing their own legislation to determine how they will go about meeting the objective of the directive within the given time period.

EU Directive 2016/2102 and What it Covers

On October 26, 2016, EU Directive 2016/2102 was approved with the goal to increase web and mobile accessibility. In order to accomplish this, EU Directive 2016/2102 set forth standards for member nations of the European Union regarding the accessibility of websites and mobile applications of public sector bodies.

EU Directive 2016/2102 applies to websites and mobile applications under the control of bodies governed by public law – including State, regional, and local authorities. All associations formed by these authorities are required to follow the standards of this directive as well.

The directive provides standards to make websites and mobile apps more accessible. Although the means of achieving the desired outcome are not formally dictated, the means of successfully meeting the standards can be determined from the regulations themselves.

For example, the directive doesn’t say that alternative text for images or closed captions are required. However, it can be inferred that in order for the content to be accessible to a blind individual, you would need alternative text for an image so that it could be read by a screen reader. Likewise, in order for your content to be accessible to a Deaf or hard of hearing person, captions and transcripts would be an appropriate tool to implement.

Regular monitoring and reporting of public sector websites and mobile apps by member countries are required and must be relayed to the Commission, as well as made public.

What Is Not Covered in EU Directive 2016/2102?

Due to limitations of technology or the need for sector-specific legislation, there are sometimes exceptions for whom and what are required to follow these regulations. In this case, the exemptions are not required to be made accessible. Although not a comprehensive list, the following items give an idea of the major exclusions:

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  • Archived Content:
    This includes information that is no longer needed for active administrative processes, and is not updated or edited. However, anything updated or edited after September 22, 2019 will have to be created accessible.
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  • Third-Party and User-Generated Content:

    This refers to content that is “neither funded nor developed by, nor under the control of, the public sector body.” For example, several things that would fall under this category are email programs, blogs, user-contributed content, news aggregators, and advertisements.

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  • Office File Formats:
    Microsoft Office file formats, including those embedded in websites and Goggle Docs, which were published earlier than September 22, 2018 are excluded from this directive, excluding content that is needed for active administrative duties.
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  • Time-Based Media:
    Time-based media includes video files that contain an audio track, such as a short film or a press conference. Live streaming time-based media is excluded from the directive, in addition to pre-recorded time-based media published before September 22, 2020.
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  • Online Maps:
    Mapping services, including online maps, are excluded from this directive. However, the directive makes a unique distinction between maps intended for navigation purposes, which are required to be accessible, and maps simply intended for geographical depiction, which are exempt from this requirement.
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  • Public Broadcaster Sites and Applications:
    Public service broadcasters include government funded TV, radio, and media outlets, which are meant to fulfill a public service.


Next Steps

Directives can be adopted, or placed into power, by a variety of legislative procedures depending on the subject matter of the directive. When adopted, directives give member states a timetable for the implementation of the directive’s planned outcome.

The European Commission will adopt implementing acts of EU Directive 2016/2102 by the end of 2018 in order to ensure the implementation of necessary changes required by the directive.


When it comes to accessibility, there’s no time like the present! Find out more, and get started captioning today.

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