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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:

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, forcing all the pages web and mobile applications of public administration or dependants of This accessible according to standard to the european commission has published at the end of 2018.

From 21 december 2018, the standard on spanish public administrations in their web sites is the 301 549 v2.1.2 (2018-08) (equivalent to WCAG 2.1). In the case of mobile applications apply from 23 june 2021.

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 of" UNE-EN 301 549. Accessibility requirements for ICT products and services ". This rule, it is the official version to the EN 301 549 V2.1.2 (2018-08) Accessibility requirements for ICT products and services standard which is to be harmonised in the implementation decision (EU) 2018/2048 of 20 december 2018, and which is equivalent to meet all requirements of A level and of the AA WCAG 2.1. "




After analysing the issue was legally concludes that there would be necessary to make accessible authentic copies for the following arguments:

  1. 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 .
  2. 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.
  3. 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).
  4. 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.

In order to know which criteria in accordance applied to PDF documents, or otherwise, we must see (10 Documents not "" of the web rule UNE-EN 301549:2019 (Opens in new window) .

Subparagraph 2 (b), one may conclude that there are five criteria of conformity of the WCAG 2.1 that no you must check, because not web documents (both PDF documents and other documents), we are:

  • 2.4.1 Avoid blocks
  • 2.4.5 Multiple routes
  • 3.2.3 Coherent navigation
  • 3.2.4 Consistent Identification
  • 4.1.3 Status messages

If you are filling the report of the revision of accessibility (IRA), in such approaches and PDF documents (or any other type), you should take directly "N/A" (Does Not Apply). In the other criteria, i.e. the 45 remaining criteria, you must perform a manual review of each criterion which can take any value: "Passes", "" Fails or "N/A".

Below you will find a correspondence table between the WCAG 2.1 and paragraph 10 "" web documents of the standard UNE-EN 301549:2019:

WCAG 2.1 UNE-EN 301549:2019 (paragraph 10 "" web documents)
1.1.1 Textual content Textual content
1.2.1 Only audio and video only (recorded) Only audio and video only (recorded)
1.2.2 Subtitles (recorded) Subtitles (recorded)
1.2.3 Audiodescripción or Alternative Means (recorded) Audiodescripción or alternative multimedia content (recorded)
1.2.4 Subtitles (live) Subtitles (live)
1.2.5 Audiodescripción (recorded) Audiodescripción (recorded)
1.3.1 Information and outreach Information and outreach
1.3.2 Significant Sequence Significant Sequence
1.3.3 Sensory characteristics Sensory characteristics
1.3.4 Guidance Guidance
1.3.5 Identify the purpose of field Identification of the purpose of the entry
1.4.1 Color usage Color usage
1.4.2 Audio Control Audio Control
1.4.3 Contrast (minimum) Contrast (minimum)
1.4.4 Re-Dimension of the text Change of text size
1.4.5 Images of text Text Images
1.4.10 Reflow Realignment of the text
1.4.11 Contrast in non-text elements Contrast textual not
1.4.12 Spacing in the text The text Spacing
1.4.13 Content in over or focus Content with the mouse pointer pointed or that has focus
2.1.1 Keyboard Keyboard
2.1.2 Without traps for the keyboard focus Without traps for the keyboard focus
2.1.4 Shortcut keys with characters Keyboard Shortcuts
2.2.1 Adjustable Time Adjustable Time
2.2.2 Pause, stop, hide Pause, stop, hide
2.3.1 Threshold of three flashes or less Threshold of three flashes or less
2.4.1 Avoid blocks -------
2.4.2 Entitled pages Entitled of document
2.4.3 Order of focus Focus Order
2.4.4 Purpose of links (japan) Purpose of links (japan)
2.4.5 Multiple routes -------
2.4.6 Headers and tags Headers and tags
2.4.7 Focus visible Focus visible
2.5.1 Pointer Gestures Gestures with the mouse pointer
2.5.2 Cancellation pointer Cancellation of pointer
2.5.3 In the name Tag Inclusion of the label in the name
2.5.4 Activation through movement. Activation through movement
3.1.1 Language of the page Language of the page
3.1.2 Language of the parties Language of the parties
3.2.1 To receive the focus Upon receiving the focus
3.2.2 To receive posts When receiving entries
3.2.3 Coherent navigation -------
3.2.4 Consistent Identification -------
3.3.1 Errors Errors
3.3.2 Labels or instructions Labels or instructions
3.3.3 Suggestions to errors Suggestions to errors
3.3.4 Prevention of errors (legal, financial, data) Prevention of errors (legal, financial, data)
4.1.1 Processing Processing
4.1.2 Name, role, value Name, role, value
4.1.3 Status messages -------