1112/2018 R.D.
Since the Observatory of Web Accessibility have prepared the following documents that aim at clarifying the precepts of RD 1112/2018, how to implement them and the deadlines within which this must be done:
- Summary of the RD 1112/2018 for interested persons . Prepared from the perspective of users of the web sites and mobile applications of the public sector that will be the winners of the implementation of this royal decree.
- Summary of the RD 1112/2018 for Entities Bound . Prepared from the perspective of the various public entities (and private) that needs to implement the requirements of the RD 1112/2018.
With the adoption of the Royal Decree 1112/2018, of 7 september on accessibility of websites and applications for mobile devices in the public sector, which reflected the directive (EU) 2016/2102, requires that all websites web and mobile applications of public administration or dependants of This accessible according to standard harmonized system of the european commission published in august 2021 (implementation decision 2021/1339).
Since 12 february 2002, the standard on spanish public administrations on their websites and mobile applications is IN 301549 v3.2.1 (2021-03) in Spain, which corresponds to the UNE-EN 301549:2022.
A proposal the text that could be included in the recruitment would be as follows:
The adjudicatario "shall take into account established by the RD 1112/2018, of 7 september on accessibility of websites and applications for mobile devices in the public sector and therefore apply the rules
EN 301549 V3.2.1 (2021-03) Accessibility requirements for ICT products and services
standard which is to be harmonised in the implementation decision (EU) 2021/1339 of 11 august 2021. In Spain this provision corresponds to the UNE-EN 301549:2022
".
After analysing the issue was legally concludes that there would be necessary to make accessible authentic copies for the following arguments:
- The document that is subject to the copied real is a document that provides the individual citizen or concerned; it is not a separate issue, develop or belong to the administration itself (but a document “ external ” or that becomes part of their official status files). It is possible to interpret, therefore, that can apply the exclusion provided for in article 3.4 (e) of the royal decree 1112/2018, of 7 september, which provides, they are excluded from its scope of the contents of third parties that are not funded or developed by the subject required or control .
- We must not forget that the original paper document subject authentic copied provides, at the individual concerned. It is true that current rules stipulate that the documents “ can be downloaded ” and work Electronic headquarters of the public Sector must be accessible but is no less true that this is laid down in safeguarding the stakeholders of the proceedings (which are those who can access the Electronic Headquarters and download the documents); therefore, if the individual concerned brings to the proceedings a document that is not accessible (role), it is clear that any losses suffered by the fact to access the document in a format equivalent, in terms of accessibility (copy rnpn), which He himself had provided the file.
- The legislation establishes specific requirements and demands an authentic copy; conduct a further process of “ accesibilización ” would duplicate the documents in the file to comply with legislation (because, in addition to the resulting electronic digitalisation should have a new document or electronic archiving “ accessible ”). Apart from the additional costs (both in the procedure for obtaining an authentic copy as eventual file - that we need greater capacity in the systems of the Government's Strategy-), this may lead to problems of evidence in administrative and/or judicial proceedings (especially in the case of any discrepancy between the official might be in the file).
- Finally, article 7 of the royal decree 1112/2018, of 7 september, states that derogate from compliance with accessibility requirements when it involves a disproportionate burden to the entity. While each Administration should make its proper justification, it is objectively reasonable that cannot be bound to the public Sector to carry out a process of scanning accompanied by a process of “ accesibilización ” given the cost implications in time, funds and commitment of management skills, becoming disproportionate as foreseen by the royal decree.
To know what accessibility requirements apply to PDF documents, or otherwise, we must see (10 Documents not "" of the web IN 301549 v.3.2.1 (2021-03)
.
The report of the revision of Accessibility (IRA) web site and mobile applications, in fact sheet "R10. Documents not", contains web accessibility requirements should be evaluated for web documents.
