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Re: Map exemptions from Public Sector Bodies Accessibility Regulations - trying to get clarity on what is exempt and what not

for

From: Steve Green
Date: Aug 4, 2023 9:06AM

Hi Jim, you've actually got it back to front.

Firstly, note that the 2018 regulations have been subject to a post-Brexit 2022 amendment at https://www.legislation.gov.uk/uksi/2022/1097/made. The amended regulations are essentially the same, but there are two key differences:

1. They explicitly refer to WCAG, whereas the original regulations referred to EU standards. This meant that EN 301 549 applied, which contains a few requirements that are not in WCAG 2.1 (not that anyone ever took any notice of this).

2. Conformance with new versions of WCAG will automatically become mandatory. This was not the case with the original regulations - my understanding is that updated versions of EN 301 549 would apply, but it would not automatically be updated to match the latest version of WCAG.

To your question, as is so often the case, explanatory information provided by various sources is misleading or wrong. In this case, the regulations are so simple that no further explanation is necessary. Simply rearranging the awkwardly written clause 4.-(2)(d), we get two statements:

1. For maps intended for navigational use, essential information must be provided in an accessible digital manner.

2. These Regulations do not apply to other online maps and mapping services.

It really is that simple. Unfortunately, some people have latched onto the phrase "essential information" and are saying that all essential information in maps must be provided in an accessible manner. That is not true.

Note that some organisations may require mapping services to achieve a higher level of accessibility, but that is an internal decision not mandated by law. For instance, we are working on a hideously complicated interactive map for estimating air pollution levels arising from proposed building developments. This is exempt from the regulations, but the government department involved would only fund the project if it is designed to achieve a high level of accessibility. GDS insist we aim for more than WCAG conformance, so we are doing user testing with disabled participants over the next couple of months (which of course the regulations do not require).

Steve Green
Managing Director
Test Partners Ltd