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What is digital accessibility?
Digital accessibility means that your website can be used by everyone, including people with disabilities.
In Luxembourg, it is not only a matter of inclusion, but also a legal obligation for many companies, associations and other organisations.
Overview of the legal framework
For public bodies
The European Directive on web accessibility has been transposed into Luxembourg law. Since 2020, it has required the State, local authorities and numerous State-funded organisations and non-profit associations to make their websites and mobile applications accessible.
For private companies
The European Accessibility Act was transposed into Luxembourg law in 2023 and requires private companies that meet certain criteria to make their products and services accessible. These obligations include a wide range of digital content such as websites and documents published on the internet.
Standards and guidelines
All websites concerned must comply with the criteria of the European standard based on the international WCAG 2.1 standards. The RAWeb (Web Accessibility Assessment Framework) is the Luxembourg framework for assessing the accessibility of web pages.
Understanding digital accessibility
In the following sections, I discuss an idea that is often misunderstood: a website does not need to be tailored to every individual need. I also give practical examples of how to use an accessible website.
An approach based on standards rather than on specific cases
It is important to understand that the goal is not to add a multitude of so-called “accessibility” features, nor to adapt a website to every specific need. What matters is compliance with accessibility standards, particularly WCAG, so that the website works properly with all types of assistive technologies, all ways of viewing them, and on all devices.
People who need enhanced accessibility generally use their own tools – called assistive technologies – which they are already familiar with. Such as screen readers, magnification software, or keyboard navigation. By following standards, you ensure that your digital content can be accessed through assistive technologies.
Concrete examples of how to use an accessible website
A blind person cannot see that headings are displayed in a larger font than the rest of the text, nor can they see the URL that appears when hovering over a link with a mouse.
They do not use a mouse and instead navigate using a screen reader, which renders the page content in speech or braille. For this to work effectively, the website must be developed in an accessible way: headings must be properly tagged, links must have descriptive text, and form fields must be correctly labelled so that the user knows what to enter.
Keyboard navigation is another fundamental feature. An accessible website allows users to navigate all interactive elements – menus, links, buttons, form fields – using only the keyboard, in a consistent and predictable order.
Accessibility also applies to display. When a visually impaired user zooms in on a page to 400%, the content must remain legible and usable, without disappearing beyond the edges of the screen or requiring excessive horizontal scrolling.
Finally, the overall logic of the structure and navigation is essential. Clear page organisation, consistent menus and explicit headings enable all users, with or without assistive technology, to find their way around easily and access the information they are looking for without unnecessary effort.
Digital accessibility laws and obligations
Digital accessibility has become a legal requirement in Luxembourg, and it affects far more organisations than is often thought. Whether you are a public authority, a local council, a non-profit organisation serving the public interest, or a private company offering certain services, you may be affected.
1. The public sector
Act of 28 May 2019 on the accessibility of websites and mobile applications of public sector bodies.
Who is affected?
- The Luxembourg State (ministries, administrations)
- Municipalities (communes)
- Public law bodies
For example, many non-profit organisations fall under the definition of public law bodies if they are mainly financed by public funds and carry out a mission in the general interest.
If you are unsure, you can check your status with Akzent or with the Information and Press Service (Digital accessibility portal).
The main obligations are as follows:
- WCAG 2.1 Level AA compliance for all websites, mobile applications, and office documents published online
- An accessibility statement published on each website and application
- A feedback mechanism allowing users to report accessibility issues
- A response to reported issues within 30 days
2. Accessibility of products and services
The law from 2023 about the accessibility of products and services transposes the European Accessibility Act (2019/882), It aims to ensure that products and services can be used by everyone, particularly people with specific needs. It applies to commercial relationships between businesses and consumers.
Main products and services concerned
- E-commerce (online shopping, booking)
- Online banking services
- Passenger transport (websites, transportation apps, tickets, timetables)
- Electronic communications (messaging, contact forms, newsletters)
- Audiovisual media services
- E-books and e-reader devices and apps
Scope of the obligation
For websites and mobile applications, the accessibility requirement applies to digital interfaces used to provide the services listed above.
This includes ordering and payment processes, booking systems, customer areas, commercial contact forms, as well as all navigation elements required to access these features (menus, search functions, and service-related information pages).
Example: a newsletter subscription form (which constitutes a contractual exchange) must be accessible, as must the navigation path leading to it.
Exemptions
Micro-enterprises are exempt with regard to services (but not products).
Definition: a company with fewer than 10 employees and an annual turnover or annual balance sheet total not exceeding €2 million.
Control and sanctions
The OSAPS (Office for the Surveillance of Accessibility of Products and Services) is responsible for monitoring compliance and may impose sanctions in the event of non-compliance.
For web designers and agencies, this means not only optimising individual pages, but considering the entire user journey through to the completion of a transaction.
In practice, determining the exact scope of the content concerned can be complex. As websites often use a single theme (both visually and technically) across all pages, it is generally simpler and more efficient to make the entire website accessible.
My web design services
- I develop accessible websites.
- I analyse accessibility and correct existing websites.
I make websites usable by everyone, in compliance with Luxembourg accessibility requirements.