In accordance with the harmonized technical standard UNI CEI EN 301549:2021 and WCAG 2.1
The purpose of this report is to provide support for the accessibility analysis of the “Skilla” Website in order to allow its use by the widest possible number of users, without discrimination, including users with disabilities, users with suboptimal abilities, and users in suboptimal environments, as well as to enable the administration to proceed with a subsequent technical evaluation activity for the completion of the declaration of conformity.
The document is organized into chapters describing the verification methodology used (Chapter 2), the summary list of the macro-criticalities identified (Chapter 3), and conclusions with suggestions (Chapter 4), followed in the appendix by the references of the subjects who carried out the audit, the reference standards, and general information (Appendix A).
Accessibility overview is a simplified sample analysis method, carried out according to the points of the European harmonized technical standard UNI CEI EN 301549:2021, which incorporates the WCAG 2.1 success criteria regarding the web.
Operationally, the analysis was carried out by accessibility experts who, by accessing the website, identified a sample of features that presented violations of the success criteria associated with the four core principles of accessibility (perceptibility, operability, understandability, and robustness)—principles that must be respected to ensure full accessibility, without discrimination, to all types of users, including those with disabilities.
The macro-criticalities identified are reported below (Chapter 3), followed by conclusions regarding the general state of accessibility of the “Skilla” Website (Chapter 4). For an analytical detail of the issues encountered, please refer to the technical data sheet.
During the activity, content and features were verified on a structural sample basis, at least to the depth allowed by the credentials in use and those present in relation to the pre-loaded content.
NOTE. This type of analysis is not a technical verification. A technical accessibility verification (as defined by UNI CEI EN 301549:2021 and WCAG 2.1) is not a user experience analysis but a precise analysis of technical requirements necessary to define an accessible system, useful for planning specific remediation activities.
The guidelines and success criteria—which are the references for web content accessibility audits within WCAG 2.1—are organized around the following four principles, which establish the necessary foundation to allow the greatest possible number of people to access and use Web content.
Anyone wishing to use the Web must have content that is:
If any of these principles are not met, users with disabilities will be unable to use the web content being audited.
Under each of the principles, there are guidelines (13) and Level A (Level “A”) and Level Double-A (Level “AA”) success criteria (50), which are mandatory according to the technical standard UNI CEI EN 301549:2021 and help address these principles for people with disabilities.
Level A is assigned to first-level importance criteria, while Level Double-A (AA) is assigned to second-level importance criteria. However, for a site to be considered accessible, it must satisfy all Level A and Level Double-A (AA) success criteria. The subsequent level (present in the WCAG), Level Triple-A (AAA), is instead optional.
The purpose of this success criterion is to make information conveyed by non-text content accessible through the use of a text alternative. Text alternatives are a primary way to make information accessible because they can be rendered through any sensory modality (e.g., visual, auditory, or tactile) to meet the user’s needs. Providing text alternatives allows information to be displayed in various ways by various user agents. For example, a person who is unable to see an image can have the text alternative read aloud using speech synthesis. A person who is unable to hear an audio file can display the text alternative so that they can read it. In the future, text alternatives will also allow information to be more easily translated into sign language or a simpler form of the same language.
On the “Skilla” Website, there are several types of violations for this success criterion:
The purpose of this success criterion is to provide people who are blind or visually impaired with access to visual information in a synchronized multimedia presentation. This success criterion describes two approaches, either of which can be used.
One approach is to provide an audio description of the video content. The audio description augments the audio portion of the presentation with necessary information when the video portion is unavailable. During existing pauses in dialogue, the audio description provides information about actions, characters, scene changes, and on-screen text that are important and are not described or spoken in the main soundtrack.
The second approach involves providing all information in the synchronized media (both visual and auditory) in text form. An alternative for time-based media provides a running description of everything that happens in the synchronized multimedia content. The alternative for time-based media reads like a script or a book. Unlike audio description, the description of the video portion is not limited only to pauses in existing dialogue. Full descriptions of all visual information are provided, including visual context, actions and expressions of actors, and any other visual material. Furthermore, non-vocal sounds (laughter, off-screen voices, etc.) are described, and transcripts of all dialogues are included. The sequence of the description and dialogue transcripts is the same as the sequence in the synchronized media itself. Consequently, the alternative for time-based media can provide a much more complete representation of the synchronized multimedia content than audio description alone.
If there is any interaction as part of the synchronized multimedia presentation (for example, “press now to answer the question”), the alternative for time-based media should provide hyperlinks or whatever is necessary to provide the same functionality.
On the “Skilla” Website, there is a YouTube video in the “About Us” section containing visual informative content (text) with background music, making it impossible for blind users to perceive the information.
The purpose of this success criterion is to ensure that information and relationships implied by visual or auditory formatting are preserved when the presentation format changes. For example, the presentation format changes when content is read by a screen reader or when a user style sheet is substituted for the author-provided style sheet.
On the “Skilla” Website, tables are used with header elements (TH) without a scope indication. This issue can make it difficult for assistive content-simplification technologies to represent the content. Furthermore, in almost all pages, there is an incorrect heading order, with jumps from H3 to H5 and, in some cases, empty headings.
The purpose of this success criterion is to ensure that all users can access information conveyed by color differences—that is, the use of color where each color has an assigned meaning. If information is conveyed through color differences in an image or text, the color may not be understood by users with specific disabilities. In this case, providing the information conveyed by color through another visual means ensures that users who cannot see color can still perceive the information.
On the “Skilla” Website, active (selected) menu items have no semantics to allow a screen reader to perceive them as such.
The purpose of this success criterion is to provide sufficient contrast between text and its background so that it can be read by people with moderately low vision (who do not use contrast-enhancing assistive technology). For people without color deficiencies, hue and saturation have little or no effect on legibility as assessed by reading performance (Knoblauch et al., 1991). Color deficiencies can affect luminance contrast to some extent. Therefore, contrast is calculated in such a way that color is not a key factor, so that people who have a color vision deficit also have adequate contrast between text and background. Decorative text and text that conveys no information are excluded.
Larger text with wider character strokes is easier to read with lower contrast. The contrast requirement for larger text is therefore lower. This allows for a wider range of color choices for large text, which is useful for page design, particularly headings. 18-point regular or 14-point bold text is judged large enough to require a lower contrast ratio. Because there are so many different fonts, general measures are used, and a note regarding fancy or thin fonts is included.
On the “Skilla” Website, on internal pages, gray text on a white background is used (e.g., “About Us” page) with an insufficient contrast ratio. The same problem occurs in the placeholders of form input fields.
The purpose of this success criterion is to ensure that visually rendered text, including text-based controls (text characters that have been displayed so they can be viewed), can be successfully resized so that it can be read directly by people with mild visual disabilities, without requiring the use of assistive technologies such as a screen magnifier. Users may benefit from resizing all web page content, but text is most critical.
The content meets the success criterion if it can be resized up to 200%, i.e., up to twice the width and height. Layout constraints may cause text to overlap with other content when resized; or only one word of a sentence may fit on each line, causing the sentence to be displayed as a vertical column of text that is difficult to read.
On the “Skilla” Website, on internal pages with 200% magnification, there is content overlapping between the header and the body of the text.
The purpose of this success criterion is to ensure that, wherever possible, content can be operated through a keyboard or a keyboard interface (so that an alternative keyboard can be used). When content can be operated through a keyboard or an alternative keyboard, it is usable by people who are blind (who cannot use devices such as mice that require eye-hand coordination) as well as by people who must use alternative keyboards or input devices that act as keyboard emulators. Keyboard emulators include speech input software, on-screen keyboards, scanning software, and a variety of assistive technologies and alternative keyboards. Individuals with low vision may also have trouble locating a pointer and find using the software much easier (or only possible) if they can control it from the keyboard.
On the “Skilla” Website, there are several issues of this type that make the website unusable, thus making it impossible for users with motor disabilities and blind users to engage with it. For example, on some sliders, it is not possible to scroll using keyboard commands, but only with a mouse click.
The purpose of this success criterion is to avoid distracting users during their interaction with a Web page.
In the definition of the success criterion, “Moving, blinking, and scrolling” refers to when visible content conveys a sense of movement. Common examples include moving images, synchronized multimedia presentations, animations, real-time games, and scrolling stock tickers. “Auto-updating” refers to content that updates or disappears based on a preset time interval. Common time-based content includes audio, automatically updated weather information, news, stock price updates, and auto-advancing slideshows and messages. The requirements for moving, blinking, and scrolling content and for auto-updating content are the same except that:
Content that moves or updates automatically can be a barrier for anyone who has trouble reading stationary text quickly and for anyone who has trouble tracking moving objects. It can also cause problems for screen readers.
Moving content can also be a severe distraction for some people. Certain user groups, particularly those with attention deficit disorders, find blinking content distracting, making it difficult for them to focus on other parts of the Web page. Five seconds was chosen because it is long enough to get a user’s attention, but not so long that they cannot wait out the distraction if necessary to use the page.
On the “Skilla” Website, the slider does not allow the rotation to be paused either via keyboard commands or via mouse hover.
The purpose of this success criterion is to allow people who navigate sequentially through content more direct access to the primary content of the Web page. Web pages and applications often have content that appears on other pages or screens. Examples of repeated blocks of content include but are not limited to navigation links, header graphics, and advertising frames. Small repeated sections such as individual words, phrases, or single links are not considered blocks for the purposes of this provision.
On the “Skilla” Website, this bypass content functionality is not available, forcing users to navigate through all menu items to access the main content.
The purpose of this success criterion is to help users understand the purpose of each link so they can decide whether they wish to follow it or not. Whenever possible, link text should be provided that identifies the purpose of the link without the need for additional context. Assistive technology has the ability to provide users with a list of links present on the Web page. Link text that is as meaningful as possible will help users who wish to choose from this list of links. Meaningful link text also helps those who wish to tab from link to link. Meaningful links help users choose which links to follow without requiring complicated strategies to understand the page. The text associated with the link is intended to describe the purpose of the link.
On the “Skilla” Website, there are several links pointing to the same destination (e.g., “Find out more”) as well as links that open new windows (with the target=”_blank” attribute) without informing the user, thus causing general disorientation for users of assistive technologies (e.g., blind users, those with motor disabilities) as well as users with cognitive difficulties.
The purpose of this success criterion is to help a person know which element has the keyboard focus. It must be possible for a person to know which element among multiple elements has the keyboard focus.
On the “Skilla” Website, most of the content during navigation lacks a visible focus indicator, making navigation difficult if not impossible for users with motor disabilities.
The purpose of this success criterion is to ensure that content developers provide information in the Web page that user agents need to correctly present text and other linguistic content. Both assistive technologies and conventional user agents can render text more accurately when the language of the Web page is identified. Screen readers can load the correct pronunciation rules, visual browsers can correctly display characters and scripts, and media players can correctly show captions. Consequently, users with disabilities will be able to better understand the content.
On the “Skilla” Website, the page language definition is not correctly indicated for any of the languages used on the site.
The purpose of this success criterion is to ensure that content authors present instructions or labels that identify controls in a form so that users know what input data is expected. Instructions or labels may also specify data formats for fields, especially if they fall outside usual formats or if there are specific rules for correct input. Content authors may also choose to make such instructions available to users only when the individual control is active, especially when instructions are long and detailed.
The purpose of this success criterion is not to clutter the page with unnecessary information, but to provide important guidance and instructions for the benefit of people with disabilities. Too much information or instruction can be as harmful as too little. The goal is to ensure that enough information is provided to allow the user to complete the task without excessive confusion or navigation.
On the “Skilla” Website, input fields only have placeholders and do not have labels linked through specific elements (label).
The purpose of this success criterion is to ensure that assistive technologies can gather information, activate (or set), and stay updated on the status of user interface controls in the content.
When standard controls from accessible technologies are used, this process is straightforward. If user interface elements are used according to specifications, the conditions of this provision will be met. If, however, custom controls are created or interface elements are programmed (in code or script) to have a role and/or function different from usual, additional steps must be taken to ensure the controls provide important information to assistive technologies and allow themselves to be controlled by assistive technologies.
A particularly important state of a user interface control is whether it is active or not. The activation state of a control can be determined programmatically, and notifications about activation changes are sent to user agents and assistive technology. Other examples of user interface control states include whether a checkbox or radio button has been selected, or whether a collapsible tree or list node is expanded or collapsed.
On the “Skilla” Website, there are several issues related to accessible names and roles:
Upon completion of the evaluation, the “Skilla” Website is currently partially compliant with the accessibility requirements provided by the harmonized technical standard UNI CEI EN 301549:2021 regarding the web, with 14 (fourteen) violations linked to the failure to satisfy success criteria out of the 50 required to consider a product compliant.
Although no immediately blocking criticalities were found, the audit highlighted widespread issues that compromise usability and the optimal enjoyment of content for various categories of users.
Issues are found in key interface components, such as the pop-up menu, which can cause significant disorientation and constitute major obstacles in user navigation.
Fabrizio Caccavello
Roberto Scano
The topic of accessibility of ICT products, promoted by the European Union through directives to member countries, has become a central theme in the procurement of technological products.
The delivery of products and services through ICT technologies impacts the entire population, interacting with both the public and private sectors. Purchasing non-accessible ICT solutions, which may discriminate against certain categories of people with disabilities, can create a situation of discrimination punishable under national regulations.
In Italy, a regulation has been in force since 2004 requiring the purchase of accessible ICT products for public administrations. Recently updated following the transposition of the European Directive 2016/2102, the accessibility requirements provided by the application guidelines of Law no. 4/2004 have become “essential” rather than a “preferential title.” This means that a public administration MUST purchase accessible products (otherwise, it must be adequately justified). As part of improving services provided by private entities, a specific rule was included in the so-called “Rilancio” decree-law that extends the accessibility obligation even to private companies with a turnover exceeding 500 million euros, with possible sanctions up to 5% of the turnover.
On June 7th, the European Commission published the European Directive 2019/882 “European Directive on the accessibility requirements for products and services”, better known as the European Accessibility Act (EAA). This is a regulation that guarantees accessibility in various commercial contexts and will closely affect publishing in European countries. Furthermore, it should be noted that under this directive regarding accessibility obligations, products placed on the European market after June 28, 2025, must fully comply with accessibility requirements.
However, it should be remembered that Law no. 67/2006, concerning the discrimination of people with disabilities, has been in force since 2006 and is applicable in both the public and private sectors. This means that, in the digital sphere, a product that does not guarantee accessibility is discriminatory, and a person with a disability can appeal to an ordinary judge for the removal of the problem and eventual compensation. The same applies if an employee with a disability cannot access information and services provided by the company, falling in this case under discrimination in the workplace (Legislative Decree 216/2003).
European technical standardization activity has produced references for both technology developers and procurement officers. The harmonized technical standard UNI CEI EN 301549:2021, in fact, allows for the implementation and evaluation of any ICT technology against functional requirements (by disability type) and technical requirements.
Regarding the Web, the harmonized technical standard UNI CEI EN 301549:2021 references the Web Content Accessibility Guidelines (WCAG) 2.1, which define technical specifications to make Web content more accessible to people with disabilities. Accessibility concerns a wide variety of disabilities, including visual, auditory, physical, vocal, cognitive, language, learning, and neurological ones. While these guidelines consider many issues, they cannot satisfy the needs of people with all types, degrees, and combinations of disabilities. These guidelines also make Web content more usable by older people with changing abilities due to aging and often improve overall usability for all users.
WCAG 2.1 is built upon WCAG 2.0, which in turn is built upon WCAG 1.0, and they are designed to apply broadly to different Web technologies both now and in the future, as well as to be testable through a combination of automated testing and human evaluation.
