How the government will monitor public sector digital accessibility compliance

On the day before this week's Public Sector Bodies Accessibility Regulations (PSBAR) deadline (23 September 2020), AbilityNet's Amy Low provided on a free AbilityNet webinar aimed at the Public Sector, an update on the PSBAR, and how the Government Digital Service (GDS) will be monitoring compliance.

On the webinar, we asked attendees 'How much do you understand about how the Government Digital Service (GDS) will be monitoring compliance?  

  • Answer 1: I understand it fully - 5%
  • Answer 2: I know a little - 48%
  • Answer 3: I am not clear - please enlighten me - 34%
  • Answer 4: Nothing at all - fill me in - 13%

Poll results screenshot asking question How much do you understand about how the Government Digital Service (GDS) will be monitoring compliance?   Answer 1: I understand it fully  Answer 2: I know a little  Answer 3: I am not clear - please enlighten me  Answer 4: Nothing at all - fill me in - results in article text

To help explain the next steps, Amy shared GDS guidance published on 20th August 2020, about how it is selecting samples, what it will be testing and reviewing and how feedback and reporting will be undertaken.

How does compliance testing work? 

The first monitoring period is already underway and covers between January 2020 to December 2021.

The aim is to monitor a sample of all organisation and website types and sizes, including those with exemptions, to learn about any differences needed in the monitoring process.

Sampling is taken from two lists:

  • public sector organisations
  • domain names registered on public sector top-level domains, such as, and

The sample must be:

  • diverse
  • representative
  • geographically-balanced
  • inclusive of a broad range of public services

Sampling within each organisation type or domain list is random. If a certain organisation type, size, location or purpose is dominating the sample it will be reviewed and rebalanced to ensure wider coverage. GDS has also advised that there may be some sectors who update their websites less often and will not be in scope of the regulations until after 23 September 2020. GDS will rebalance the sample in 2021 to ensure coverage of those sectors.

Testing types

Two kinds of test will be undertaken:

  1. ‘Simplified’ – mainly automated
  2. ‘In-depth’ - manual assessment

The first phase of testing includes:

  • 1395 simplified tests
  • 80 detailed audits
  • 24 mobile application audits
  • GDS will also be checking accessibility statements for compliance

Testing covers accessibility of a site against Web Content Accessibility guidelines 2.1 AA standard

Simplified testing will test a site's homepage plus a sample of other pages across the site (number depends on size of site), and will be testing using the Axe automated tool. Methodologies will remain under review as technologies advance. Manual tests will also test areas such as keyboard controls and zoom function. 

If simplified testing finds major issues, the site is likely to be referred for a detailed audit, which will test against the full range of success criteria up to level AA using assistive technologies, automated and manual testing methods. Prioritisation of sites to be tested will consider the social impact, for example the size of population or level of complaints received.

Image of two people working on computers in office

Reporting compliance issues

Public sector institutions tested will receive a report and given a reasonable time to fix issues identified. If issues remain after a certain timeframe, the report will be passed to Equality and Human Rights Commission (EHRC) or Equality Commission for Northern Ireland (ECNI).

In addition, GDS will publish its findings on a regular basis, and on behalf of cabinet office will be publishing a list of websites with non-compliant accessibility statements. 

Compliance monitoring answers from the webinar

Attendees of the HE/Public Sector webinar held on Tuesday 22 September were able to submit their questions for the speakers during the webinar, and below are a selection of the questions asked relating to GDS monitoring.

Q: Will we know if we have been 'sampled' and tested?

Everyone that is tested will receive a report from GDS sharing the findings (as long as there's contact information that works).

Q: How often will the Cabinet Office publish the list for non-compliant statements? Have they said?

They haven’t indicated any frequency so far. Having asked GDS, they indicated it's likely to be twice a year or quarterly.

Q: How will the government monitor sites that are not public? Presumably they need to request access (e.g. to intranets, virtual learning environments (VLE) behind institutional portals?

Yes, the risk for non public sites is going to be higher on the basis of student led complaints which could then lead to a detailed audit on the specified site. Whilst the risk of having something picked up by the monitoring body is therefore low, the VLE and intranet are arguably more critical to the student experience and more likely to create barriers that could impact on student success so really important to ensure these are prioritised to improve their accessibility.

Q: Will all issues identified in tests/evaluations require fixing?

The regulations require that you are compliant at WCAG AA standard and therefore it is quite possible that GDS could request that all issues found at levels A and AA are fixed. Give the size and complexity of many university sites the time allocated (stated as reasonable) should be commensurate with the effort required to achieve the standard.

GDS has responded to the question with the following: "The simplified tests only pull out issues that we think have major effects on the accessibility of sites. Yes, sites should fix to WCAG 2.1 AA as strictly as possible. We currently give sites 12 weeks to fix issues and get back to us. We're working with EHRC and ECNI to determine what they are likely to consider acceptable, and we give a recommendation to them when we hand the cases over after the 12 week period for them to determine."

Watch the public sector-focused accessibility webinar playback below or download the transcript.

Further resources:

Webinar playback: HE/Public Sector update: Excelling in digital accessibility at Open University - includes GDS monitoring information section

Blog: Accessibility statements webinar: your questions answered

Blog: 10 actions for universities to ensure safe access for disabled students during Covid-19

Blog: What are the digital accessibility gaps in further education?