A municipality’s website is often the only door to a service: booking an appointment for a new identity card, paying for a parking permit, checking when the library is open. If that door does not work with a keyboard, a screen reader (software that reads the screen aloud) or a large zoom, some residents cannot get in at all. That is why the EU has had a specific law for public sector websites since 2016, years before the European Accessibility Act for businesses. This article explains what it asks, how Belgium, the Netherlands, France and Germany apply it, and gives a practical plan for a small public body.
One European rule for every public body, large or small
The rule is the Web Accessibility Directive, officially Directive (EU) 2016/2102. It applies to "public sector bodies": the state, regional and local authorities, and bodies governed by public law, which often includes social welfare centres and public libraries. The deadlines have long passed. New websites had to comply from 23 September 2019, all other websites from 23 September 2020, and mobile apps from 23 June 2021.
One point surprises many small organisations: there is no size exemption. The European Accessibility Act exempts micro-enterprises from its rules for services. The Web Accessibility Directive does not. A village of 3,000 people has the same obligations as a capital city.
There is one safety valve, the disproportionate burden. A public body may decide that making a specific part accessible would cost far more than it would help, given its size, resources and how often people use that part. It must explain this in its accessibility statement and, where possible, offer an alternative. The Dutch government’s guidance is blunt about it: a lack of priority, time or knowledge is not a valid reason.
The directive itself leaves out a few types of sites. The websites of public service broadcasters are excluded, and so are those of non-profit organisations that do not provide essential services or services for people with disabilities. Member states may also exclude the websites of schools, kindergartens and nurseries, except for content about essential online administrative tasks, such as enrolment. Check whether your country or region used that option before you assume a school site is exempt.
What the rules ask for
The obligations come down to four things.
- Meet the European standard. The directive asks that sites are perceivable, operable, understandable and robust. In practice, this means meeting the standard EN 301 549, which for web pages builds on WCAG 2.1 level AA. WCAG are the Web Content Accessibility Guidelines of the W3C, the body behind web standards; levels A and AA together contain 50 criteria. A new version of the standard, EN 301 549 V4.1.1, was published in September 2026 and moves to WCAG 2.2, but at the time of writing it has not yet been formally cited in the Official Journal of the EU. Aiming for WCAG 2.2 AA does no harm.
- Publish an accessibility statement. Each website and app needs a statement based on the European model. It says how far the site meets the standard, which parts are not accessible and why, and which alternatives exist.
- Offer a way to report problems. The statement must include a feedback mechanism, such as a form or an email address, so anyone can report a barrier or ask for inaccessible content in another format. The body must answer within a reasonable time. The statement must also link to the enforcement procedure: where people can turn when the answer is unsatisfactory.
- Accept monitoring. Every member state has a monitoring body that checks a sample of public websites and apps and reports to the European Commission.
Content that falls outside the rules
Some content is excluded, which matters especially for libraries, archives and museums:
- office files such as PDFs and Word documents published before 23 September 2018, unless people need them for an active administrative process, like applying for a permit
- pre-recorded video and audio published before 23 September 2020, and live video and audio
- online maps, as long as essential information, such as an address or route, is also available in an accessible way
- content from third parties that the body neither funds, develops nor controls
- reproductions of items in heritage collections that cannot be made fully accessible, such as a scan of an old manuscript
- archives that are not needed for active processes and have not been updated since 23 September 2019
Not on this list: last year’s PDF form, a recording of last month’s council meeting, or the booking tool your supplier built. Those all count.
Belgium: one directive, seven sets of rules
Belgium transposed the directive at every level of government. The federal law of 19 July 2018 covers federal bodies, and each region and community has its own decree or ordinance. Flemish local governments, OCMWs included, fall under the Bestuursdecreet of 7 December 2018, as the Flemish government explains. Brussels municipalities fall under an ordinance of 4 October 2018, and Wallonia, the Fédération Wallonie-Bruxelles, the French Community Commission and the German-speaking Community have their own texts.
The Federal Public Service Policy and Support, known as BOSA, was designated by the Royal Decree of 5 September 2019 as the body that monitors the directive and coordinates the six Belgian monitoring bodies. Its report for 2022 to 2024 gives a clear picture:
- 1,936 audits in total, of which 1,763 simplified audits: mostly automatic, with two manual checks.
- In the simplified audits, 28% of sites were partially compliant and the rest not compliant. A simplified audit cannot award more than "partially compliant".
- In the 133 in-depth website audits, done by experts, 56% were partially compliant.
- The most frequent problems were page structure (found on 86% of sites), insufficient contrast (85%), buttons and fields that assistive software cannot identify (84%), no way to skip repeated blocks such as menus (70%) and images without a text alternative (69%).
BOSA also offers free tools: the BOSA Accessibility Check, a button for your browser’s bookmarks bar that checks the page you are on, and an assistant to write your statement. Flemish local governments can order in-depth audits through an interfederal framework contract instead of running their own tender.
The Netherlands: statuses A to E
In the Netherlands, the rules started in 2018 with the Tijdelijk besluit digitale toegankelijkheid overheid and, since July 2023, sit in the Besluit digitale toegankelijkheid overheid under the Wet digitale overheid. The Dutch approach stands out for its transparency. Every public body publishes its statements through a central register at toegankelijkheidsverklaring.nl, and each statement gets a status:
- A: a full, recent evaluation shows the site meets all 50 requirements.
- B: a full evaluation exists, not all requirements are met yet, and the statement describes the measures being taken.
- C: no evaluation yet, but one is planned within six months, or the site will be closed.
- D: there is a statement, but no evaluation and no plan.
- E: no statement at all.
Only A, B and C meet the law, and C only for six months. Evaluations must follow WCAG-EM, the W3C’s method for evaluating a whole website, and stay valid for three years. Statements with status A or B must be updated at least once a year.
In early October 2026, the public Dashboard DigiToegankelijk listed 9,099 government websites and apps: 861 with status A, 4,419 with B, 565 with C, 2,360 with D and 894 with E. So about 42% had no valid full evaluation or no statement at all.
France and Germany in brief
In France, the obligation comes from article 47 of the loi of 11 February 2005 on equal rights for people with disabilities. Public bodies apply the RGAA, the French method for testing against the European standard, currently version 4.1.2, with a version 5 announced for the end of 2026. The home page must say "Accessibilité : totalement conforme", "partiellement conforme" or "non conforme", and a dedicated accessibility page holds the statement, a multi-year plan of up to three years and the action plan for the current year. Large companies with a turnover of 250 million euros or more fall under the same article. The official RGAA site lists who is covered.
In Germany, federal bodies follow the BITV 2.0, the federal regulation on accessible information technology. The statement must be reachable from every page and updated every year and after major changes. A German peculiarity: the home page must explain its main content, navigation and statement in German Sign Language and in Leichte Sprache (Easy Language). The 16 federal states have their own laws for their administrations and municipalities, usually built on the same standard.
A practical plan for a small public body
This plan works for a municipality, a CPAS or OCMW, a library or a school. Put a name and a date next to each step.
- Make an inventory. List every website, subsite, app, online form and booking or payment tool, including the ones suppliers run for you, and note who owns each one. Forgotten subsites are a common gap.
- Check what you have. Start with the pages people need most: the home page, contact, opening hours, forms, appointment booking and payment. Run an automatic check on each one, then do the 10-minute keyboard test. Automatic checks find a part of the problems, roughly a third to a half, so the manual test matters.
- Fix what blocks people first. A form that cannot be sent with a keyboard is more urgent than a slightly pale footer. Ask your supplier to fix shared templates first: one fix in the form template repairs every form at once.
- Get a full evaluation when you need one. A statement that claims full or partial compliance should rest on a real evaluation of all criteria, by your own trained staff or by an outside expert. In the Netherlands, status A or B requires one. Plan it after the obvious problems are fixed, so you do not pay an expert to find missing image descriptions.
- Publish or update your statement. Link to it from the footer of every page. List what is not accessible yet, give a working email address or form for feedback, say how fast you answer, and link to your country’s enforcement procedure. Our guide to the accessibility statement explains each part in plain language.
- Keep monitoring. Websites change every week. Check your key pages again after each update, review the statement at least once a year, and actually answer the feedback you receive.
- Train your editors. Most new problems come from everyday content: images without a description, headings chosen for their size, links that say "click here", scanned PDFs. A short session and a one-page checklist go a long way. Where you can, publish a web page instead of a PDF.
- Put accessibility in your contracts. When you buy a website, app or online tool, require compliance with EN 301 549 and WCAG 2.1 AA, or better 2.2 AA. Ask for an evaluation report at delivery, accessible templates for your editors, and free repairs of accessibility defects during the warranty period. The Flemish government publishes model clauses you can adapt.
Where an automatic checker helps, and where it stops
An automatic check suits steps 2, 3 and 6 of the plan: it shows the common problems quickly and confirms whether a fix worked. It does not replace the full evaluation your statement relies on, and no tool can declare a site compliant. People still judge whether an image description is right, whether a form makes sense and whether everything works with a keyboard and a screen reader. Our article on automatic checks and human audits explains where that line lies.
Check your most important page today
Check a page for free with ibin and start with the page residents use most, often the home page or the appointment form. The report lists the problems in plain language, ordered by what to fix first. Sign in to check up to 200 pages of one site for free, ask for a weekly check to see what got fixed and what is new, and use the repair guides and the statement guide to take the next steps.
See how your own site does
Check a page for free, without an account. You get a plain list of what to fix first, with pictures of where each problem is.
