PSBAR Monitoring and Enforcement Process

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How the monitoring works

The Public Sector Bodies (Websites and Mobile Applications) (No.2) Accessibility Regulations 2018 (PSBAR) are managed by three levels of monitoring and enforcement.

Read the Memorandum of Understanding which explains what each monitoring and enforcement organisation must do.

Level 1 – Support

The first stage of most user complaints under PSBAR should come through the national support route. This support / complaint route is provided by the Equality Advisory and Support Service (EASS).

EASS should provide guidance material to users who wish to complain about inaccessible public sector websites. This guidance covers things like:

Level 2 – Monitoring

The Monitoring body is often seen by many as the “owners” of PSBAR, being responsible for the original roll out of the regulations and monitoring the UKs progress towards compliance which includes reporting progress on the international stage.

The role of monitoring falls to the Cabinet Office, with the actual work being conducted by a specialist Digital Accessibility Monitoring Team. The monitoring team’s position within the government department has changed over the years, sometimes being referred to as GDS (The Government Digital Service), or the CDDO (Central Digital & Data Office). Currently they are known as GDS.

GDS monitors how the public sector are doing at complying with the regulations. To do this they test many hundreds of public sector websites every year against regulations requirements and send letters to organisations with lists of issues to be fixed.

Regularly GDS then have to announce figures for their monitoring results on behalf of the UK. This is fed back into the European Commission so we can see how we are doing compared to other countries.

Read the GDS monitoring figures for 2020-2021

Level 3 - Enforcement

Enforcement is the final stage reserved for when a resolution cannot be reached regarding a user complaint, or a lack of action by a public sector body in response to government monitoring.

Enforcement is carried out by different agencies depending on where you are in the UK.

For England, Scotland and Wales, enforcement is carried out by the Equality and Human Rights Commission (EHRC).

In Northern Ireland enforcement is carried out by the Equalities Commission for Northern Ireland.

Where a public sector body has failed to engage with GDS and/or failed to fix the majority of non-compliance issues, the EHRC will consider whether it is proportionate to take enforcement action. It does this in accordance with its litigation and enforcement policy.

Reasons for being monitored

If you have received contact from GDS as part of the monitoring process, you will be told what has been monitored and why, whether that be because of a complaint or as part of a standard monitoring sample.

Let’s look at the three most common examples of what leads to a public sector body organisation being monitored.

Example 1: User complaint

One of the most common ways for an organisation to get on “the list” for monitoring is for a user to make a complaint about a website or service that public sector body organisation is responsible for. So how does a complaint turn into monitoring and enforcement?

In this example we will look at a user who has been trying to find an accessible prospectus for a university they would like to attend. The user has failed to find the accessible content and feels that they are being discriminated against, or the organisation is not meeting its legal duties.

Step 1: The user has decided to make a complaint through the EASS, directed there by the university’s accessibility statement.

Step 2: The EASS will take 2 actions. The EASS will respond to the user encouraging them to contact the university and ask for an accessible alternative to the prospectus if they have not done so already. The EASS will also forward the complaint to GDS (The Monitoring Body) in all cases.

Step 3: Whether the initial complaint is resolves or not, GDS is now aware of a complaint against that organisation and will prioritise them for monitoring.

Example 2: Basic monitoring

If an organisation has not received a complaint by a user, the other common way for organisations to receive monitoring is just as part of GDS’ ongoing selection of website for sampling.

Most organisations that are selected by GDS to be part of a monitoring sample will receive the basic monitoring which consists of a selection of automated and regulation checks. The full process for this is described below in the ‘How are GDS testing my website?’ section.

Once GDS has completed their testing, organisations will receive a letter telling them what they have to do next. More information on this available below in the ‘What do I need to do?’ section.

Example 3: Advanced monitoring

On rarer occasions, organisations may receive contact from GDS to conduct advanced monitoring. This will involve far more comprehensive testing of a website or digital platform and GDS will work with you to define things like scope of testing, gain access to systems as necessary and generally talk you through what is expected.

How are GDS testing my website?

Basic monitoring

GDS have published information about how they sample and choose pages for simplified testing.

GDS test pages using a combination of automated accessibility tools and manual tests. GDS currently use an automated tool called Axe. You can replicate the errors GDS find by downloading Axe as a free browser extension. For these tests, GDS are only looking for severe or critical Axe errors.

Automated testing does not find all accessibility issues. GDS also do manual tests including:

These manual tests find issues such as keyboard functionality, visibility of keyboard focus and reflow which are some of the most common barriers to users with accessibility needs and are not likely to be picked up in automated tests.

Tests are completed using different settings in the Google Chrome browser on Mac OSX with a 13 inch screen.

GDS expect your organisation to fully audit the website to find any other accessibility issues.

With the introduction of WCAG 2.2, GDS published an update to the regulations in October 2022. GDS explained in their government article that there will be a grace period after WCAG 2.2 comes into effect, after which GDS will be requiring organisations to evidence compliance against WCAG 2.2. GDS have explained that there will be a 12 month grace period from the date of WCAG 2.2 release.

What do I need to do?

Just received the letter

When you receive the monitoring letter from GDS, they will tell you:

Timelines and Actions

Once you have received an audit GDS ask that you:

GDS will get in touch with you at the end of 12 weeks to request an update on your progress. The 12 weeks starts from the date you are sent the accessibility report unless communicated otherwise.

After 12 weeks GDS will ask for:

GDS will then retest your website to check that any accessibility issues listed in the report have been fixed.

If GDS find outstanding issues from the report, they will ask you for timelines to fix them. Any issues that have not been fixed should be included in your accessibility statement. This will help users understand where they might find potential barriers when using your website and ways they can request other formats where necessary.

After the 12 weeks, information regarding your website will be passed to the EHRC or ECNI. They will decide whether further action needs to be taken.

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