It is not only websites that must be made accessible, It is all of the content on those websites, or content in any other digital format that also needs to be accessible to people with access needs.

You may work with 3rd party content creators to deliver bespoke assets for you to use in different ways across your digital estate and digital communication channels. When getting 3rd party creators to produce content, it is vital that accessibility is included into the requirements to stop you “buying in problems”.

Public Sector Bodies have a responsibility under the Public Sector Bodies (Websites and Mobile Applications) (No.2) Accessibility Regulations 2018 (PSBAR), and the Public Sector Equality Duty, and all organisations have a responsibility under the Equality Act 2010 to ensure that the digital content they own is accessible. We have an equal duty to not discriminate against members of the public or our staff because of disability. We do this by making sure digital content meet the required standards, with clear evidence to support compliance with our legal responsibilities.

There are many complexities when it comes to UK public sector accessibility regulation responsibilities and 3rd parties. We have more information on these complexities in our 3rd party content responsibilities guide.

This resource is a living set of guidance. If you have feedback or want to suggest how we can improve this guide, please contact us using the route in the footer of this website. This guide was put together by accessibility professionals and consultation from Creative Triangle, a design company with an interest in making accessible content for their customers.

We hope that the template will be of use to others, but as with any procurement exercise, these clauses may be adjusted to your organisation needs, and we suggest that you still seek your own advice before use.

The idea of this guide is for you to be able to use the following example requirements in tender and procurement processes for digital content, documents and other design services. We encourage you to copy or adapt these resources into your own content procurement / commissioning processes.

Step 1 – Definitions

Use the definitions to help you identify which category the content you plan to purchase fits in to, and therefore which requirements to include.

You can also share these with suppliers in your additional documentation or as a reference sheet to help suppliers identify what of their offering is covered in your expectations.

Step 2 - Requirements

The problem with writing a guide for content requirements is that there are so many different types of content each with their own accessibility requirements.

Use the requirements section to include both the general DA requirements and format requirements relevant to the type of content you want to buy into your tender documents.

For example, if you are looking to pay a creative agency to create a promotional PDF document for you with
significant branding included, this would be covered by the Documents and Text requirements. But if you were looking for a creative agency to create that same branding as a set of assets to be used in several situations, that would be covered by the Images and Branding section.

Step 3 – Evaluating responses

Use the guidance on evaluating supplier responses to make an informed decision on which supplier is going to deliver you the most accessible content.

Reflect on the relevant regulations and standards, if the supplier has shared examples, or can show understanding of the requirements listed, and try and avoid dubious claims of AI tools that solve accessibility problems.

Step 4 - Contracts

The final step after you have confirmed your preferred supplier is to include meeting your chosen accessibility requirements into the contract for the work. This is one of the only ways we can hold suppliers to their responsibilities to provide legally compliant products as you requested.

Digital “content” can mean many things and the definition covers several different formats and situations in which we may share information with users.

The format types we are broadly referring to:

• Documents of any format. This includes Word, PowerPoint, Excel, PDF, ePub, open file formats and any other “document” formats not listed here.
• Images and visuals of any format. This includes JPEG, PNG, SVG, WEBM, and any other “image” formats not listed here.
• Videos, audio, animations, and multimedia content.
• Mixed formats including those above which may or may not be delivered as HTML or print media.

The content situations we are broadly referring to though this is a non-exhaustive list, and any content created that is to be shared through any of digital channels should be accessible:

• Long documents – reports, research documents, books, journals, articles, slide decks and presentations
• Promotional or ‘glossy’ documents – prospectuses, brochures, leaflets
• Branding, promotional assets, and social media assets – logos, colour schemes, design and layout schemes, banners, stock images
• Video, animation, and multimedia content – promotional videos, interview, talking heads, physical estates videos set to music, drone footage, 360 virtual tours, gifs, animated banners or carousels, background animations, podcasts, soundbites and other audio snippets, including associated alternatives such as captions, transcripts, audio descriptions and British Sign Language (BSL).
• Templates – for documents, slide decks, images, branding and video assets
• Text content or ‘copy’ – articles, blogs, social media posts, ad campaigns, testimonials, case studies, and research.

DA - Compliance

Describe how the supplier will ensure that any content shall meet compliance with the content relevant success criteria in the latest published version of WCAG (Web Content Accessibility Guidelines) (currently 2.2) and detailed in EN 301 549, in line with regulation requirements and international best practice.

DA - Tooling

Describe how the supplier creates digital content and the tools used.

For example does the supplier create PDF documents within Adobe InDesign before exporting and how does the supplier ensure an accessible final document that passes all Adobe PDF accessibility checks.

DA – Delivering accessible formats

Answers based specifically on appropriate practices for all applicable formats the content / assets may be used in.

For example, if buying assets for use in web animation, social media, and video background, supplier would evidence how that content would be made accessible for multiple use cases.

Documents and text

The below information describes the formats, content types, accessibility expectations, and appropriate evidence for documents and text content.

Format

Documents of any format. This includes Word, PowerPoint, Excel, PDF, ePub, open file formats and any other “document” formats not listed here.

Content types

• Long documents – reports, research documents, books, journals, articles, slide decks and presentations.
• Promotional or glossy documents – prospectuses, brochures, leaflets.
• Text content or “copy” – articles, blogs, social media posts, ad campaigns, testimonials, case studies, and research.

Expectations

Comply with the WCAG relevant success criteria of EN 301 549

• Good structure

  • Tagging and appropriate reading order (PDFs)
  • Lists – Correct use of programmatic lists
  • Links – With human readable descriptive text and not use colour to differentiate from surrounding text
  • Headings – Hierarchical heading structure using programmatic headings
  • Tables – Used for tabular data not layout purposes
  • Bookmarks (longer PDFs) – Structure created from headings
  • Doc title and language

• Alternatives

  • Image alt text – Descriptive and context relevant.

    • Complex images adhere to Complex image guidance.
    • Images of people adhere to MTA guidance on describing people.
    • Artifact decorative images where used purely for decorative purposes.

  • Graphs – Adhere to complex image guidance, do not use colour alone to differentiate information, clear labelling required, and meet contrast requirements.

• Colours

  • Contrast – Text and graphical elements meet contrast requirements, check with WebAIM contrast checker
  • Colour blind – Colour alone is not used to differentiate information, text labelling alongside any use of RAG statuses.

Evidence

• Demonstrate capability to deliver appropriate content
• Supplier to provide examples of comparable previous work
• What methods or tools does the supplier use to check and confirm accessibility compliance?
• Will the content pass accessibility reporting within their final format? Eg. Word or Adobe automatic checker?
• Will the content meet higher standards? PAC / PDF UA?
• Does the supplier have the IAAP Accessible Document Specialist certification

Images and Branding

The below information describes the formats, content types, accessibility expectations, and appropriate evidence for images and branding content.

Format

Images and visuals of any format. This includes JPEG, PNG, SVG, WEBM, and any other “image” formats not listed here.

Content types

Branding, promotional assets, and social media assets – logos, colour schemes, design and layout schemes, banners, stock images.

Expectations

• Appropriate resolutions and cross platform compatible formats. For example avoidance of HEIC files.

• Comply with the WCAG relevant success criteria of EN 301 549

  • Image alt text – Descriptive and context relevant.

    • Complex images adhere to Complex image guidance.
    • Images of people adhere to MTA guidance on describing people.

  • Graphs – Adhere to complex image guidance, do not use colour alone to differentiate information, clear
    labelling required, and meet contrast requirements.

  • Colours

    • Contrast – Text and graphical elements meet contrast requirements, check with WebAIM contrast checker
    • Colour blind – Colour alone is not used to differentiate information, text labelling alongside any use of RAG statuses.

Evidence

Demonstrate capability to deliver appropriate content

• Supplier to provide examples of comparable previous work
• What methods or tools does the supplier use to check and confirm accessibility compliance?

Video, audio, and multimedia (Time-based media)

The below information describes the formats, content types, accessibility expectations, and appropriate evidence for video content.

Format

Videos, audio, animations, and multimedia content.

Content types

Video, animation, and multimedia content – promotional videos, interview, talking heads, physical estates videos set to music, drone footage, 360 virtual tours, gifs, animated banners or carousels, background animations, podcasts, soundbites and other audio snippets, including associated alternatives such as captions, transcripts, audio descriptions and British Sign Language (BSL).

Expectations

• Comply with the WCAG relevant success criteria of EN 301 549

  • Captions – Closed captions preferred and manually reviewed to ensure accuracy. Automated captions are not accepted.

  • Transcripts – Additional text-only alternative that includes caption text as well as further information to describe any activity on screen.

  • Audio-descriptions, or appropriate narration – May be worked into single video, or offered as an audio-described second video

  • Text, slides or graphics within a video

    • Contrast - Text and graphical elements meet contrast requirements, check with WebAIM contrast checker
    • Colour blind – Colour alone is not used to differentiate information, text labelling alongside any use of RAG statuses.
    • Graphics - Do not use colour alone to differentiate information, clear labelling required.

  • Avoid flashing content – three flashes within a second or below red flash threshold. Preference to avoid anything that could be considered flashing content.

• BSL interpretation – in cases where this is requested, suggest if / how this can be supported.

• Use of media player, iframe or embed option that allows for adjustable playback controls, keyboard navigation and support for captions / media alternatives.

Evidence

Demonstrate capability to deliver appropriate content

• Supplier to provide examples of comparable previous work
• What methods or tools does the supplier use to check and confirm accessibility compliance?

Good practice considerations

Accessibility is the baseline for expected practices but there are other ways in which we can further improve the usability or disability related experience of our content. The below additional suggested areas are things you may want to include as good practice that goes beyond accessibility as a minimum.

DA – Plain English

Content reflects Plain English good practices for written content in alignment with the MTA guidance on Plain English or on the Plain English Campaign website.

Can be tested using the Hemingway editor to check that suggested content meets appropriate reading level.

DA – Easy Read

Where Easy Read specialist content is required, the supplier should demonstrate their understanding of the specialist format and evidence that they can produce easy read content, or that they work with an appropriate third party to deliver Easy Read specialist formats.

DA – Digital vs for Print

Where content may be intended for a mix of digital and print purposes, both versions should adhere to the expectations for digital accessibility as described in the format specific sections. This is to avoid the creation of inaccessible documents for print originally, that then make their way onto digital.

For print specific accessibility complications with links and QR codes there are the following expectations:

• Ensure reasonable steps to avoid QR codes that can be ‘hijacked’ or may be placed on walls / kiosks etc. that can be stickered over with replacement / malicious QR codes. There are also QR code alternatives such as NaviLens which may offer a more reliable experience.
• Where links cannot be used in physical / print media, use Vanity URLs that shorten the visible text that a user must type but still shows the location eg. makethingsaccessible.com/guides. Do not use bitly or other link shortening services that can be ‘hijacked’ and do not clearly show their destination.

DA – STEMM Content

With specialist STEMM content in any format, there can be additional complications with presenting complex STEMM subject information in accessible formats. Supplier to provide additional information in line with the STEMM Accessibility Baseline on how they will ensure the accessibility of specialist STEMM content above and beyond standard documents accessibility expectations. For example, how they would make maths equations accessible.

Reflect on the relevant regulations and standards, if the supplier has shared examples, or can show understanding of the requirements listed, and try and avoid dubious claims of AI tools that solve accessibility problems.

Relevant regulations and standards

When receiving responses from suppliers, they may reference different standards depending on where they are based and what content formats you are procuring. It is good to understand the following relevant regulations and standards for accessibility:

• PSBAR – Public Sector Bodies (Websites and Mobile Applications) (No.2) Accessibility Regulations 2018 (PSBAR) which requires evidence of compliance with WCAG 2.2.       
  EU Web Accessibility Directive – The EU equivalent of PSBAR. Differs between EU members states but all require evidence of compliance with WCAG (under the banner of the EN 301 549 harmonised standard) and an accessibility statement.
• EU Accessibility Act 2019 – Will require evidence of compliance with WCAG 2.1 or better and other standards for physical accessibility for electrical hardware as well.
• Section 508 – The American standards which require evidence of WCAG compliance for 2.0 or better.
• WCAG – The Web Content Accessibility Guidelines. The underlying technical standards that all others refer back to.
• PDF/UA – Enhanced standard for PDFs so that users with disabilities can use the same PDF files and get the same level of value.

Review supplier information

When suppliers have responded to the requirements, you should:

• Check examples shared for accessibility against the expectations listed.
• Note where they have mentioned standards that they adhere to, or where they do not mention any standards.
• Note any mention of accessibility training or how they maintain standards for accessibility good practice.
• Note where they mention tools and check what those tools are if you do not recognise them.
• Note if them mention overlays, AI or the use of any additional products that ‘fix’ their content for them. ‘Fix it’ products do not work and must be avoided. More information in the MTA Overlays and other fix-it products guide.
• Check the MTA guidance on reviewing procurement responses for accessibility, particularly any red flags in the ‘No information or other negative responses’ section.

The final step after you have confirmed your preferred supplier is to include meeting your chosen accessibility requirements into the contract for the work. This is one of the only ways we can hold suppliers to their responsibilities to provide legally compliant products as you requested.

We are working on example contracts clauses that can help hold suppliers to delivering accessible content and these will be published soon.