Web accessibility in the public sector is not a matter of good practice: it is a legal obligation with a technical standard, a public statement, a unit responsible for it and monitoring by Spain’s Web Accessibility Observatory (Observatorio de Accesibilidad Web). Royal Decree 1112/2018 (Real Decreto 1112/2018) imposes it on every public sector website and mobile app, and in practice the point where it is breached most often is the one that matters most to citizens: the e-office (sede electrónica, a public body’s official site for online procedures), its forms and the documents people download from it. This guide explains what the legislation requires, how compliance is demonstrated, what usually goes wrong in e-offices and case management systems, and what the public body must require of its supplier so that accessibility does not depend on a review after the event.

What Royal Decree 1112/2018 requires

Royal Decree 1112/2018 of 7 September transposes Directive (EU) 2016/2102 and obliges public authorities, public sector bodies and other entities to make their websites and mobile applications perceivable, operable, understandable and robust. The scope is broad: textual and non-textual information, downloadable documents and forms, pre-recorded media, forms of two-way interaction and the identification, authentication, signature and payment processes, whatever the technology. The obligations have applied to websites since 23 September 2020 and to mobile applications since 23 June 2021.

The applicable technical standard is UNE-EN 301 549 (the Spanish edition of EN 301 549), the harmonised European standard on accessibility requirements for ICT products and services, which for web content incorporates the Web Content Accessibility Guidelines (WCAG) 2.1 at level AA. Complying with the royal decree means, in practice, meeting those criteria on every page, form and document.

Beyond the content itself, the royal decree imposes management obligations:

An accessibility statement on every website and app, following the model in Implementing Decision (EU) 2018/1523: level of conformance, content that is not accessible and why, the date of the last review, and the contact and complaints channels.
A feedback mechanism so that anyone can report failures, request information in an accessible format or make a complaint, with deadlines for a reply.
A unit responsible for accessibility in every entity, which coordinates the work, deals with the feedback received and draws up the reports.
Periodic accessibility reviews and the submission of information to the Web Accessibility Observatory, which carries out the monitoring and publishes the results, and to the European Commission through the national report.

Why the e-office is the critical point

The corporate home page is usually well looked after; the problems arise where citizens have to do something:

E-office forms with unlabelled fields, errors that are not described, session timeouts with no warning and validation that is conveyed by colour alone.
Identification and signature: steps involving certificates, pop-up windows and components that cannot be used with a keyboard or a screen reader, even though the royal decree expressly covers them.
Downloadable documents: decisions, notices and template forms as PDFs with no structure or real text, or scanned as images, which are inaccessible by definition.
Notifications and the citizen folder (carpeta ciudadana, the citizen’s personal area): data tables without headers, icons with no text alternative, statuses conveyed by colour alone.
Content generated by the case management system: if the system produces documents and screens, it also determines their accessibility, or the lack of it. We explain this in what a custom case management system must comply with.
Mobile apps published without review, which escape the checks that are carried out on the website.

The result is an accessibility statement that promises level AA and a service that a blind person or someone with a motor impairment cannot get through. In the event of a complaint or a review by the Observatory, the responsibility lies with the public body, not with the supplier.

How to check where you stand today

Automated review with analysis tools, useful for detecting the 30 or 40 per cent of problems that are the most mechanical: contrast, text alternatives for images, heading structure, form labels.
Manual review using the WCAG conformance evaluation methodology on a sample of pages and on complete processes: keyboard navigation, screen reader, magnification, forms from start to finish.
Testing with users who have a range of disabilities, on the most frequently used procedures.
Document review: a sample of the PDFs published and of those generated by the case-processing systems.
A review report setting out the criteria not met, their severity, the page or component affected and the proposed fix, which feeds into the accessibility statement and the remediation plan.

What to require of the supplier in the tender specifications

Accessibility is achieved at the design stage and lost with every update. That is why the tender specifications have to make it a requirement both for delivery and for maintenance:

Conformance with UNE-EN 301 549 and WCAG 2.1 level AA in all public-facing interfaces, and in internal ones where they are used by public employees, with an express reference to Royal Decree 1112/2018.
Accessibility of complete processes, not of isolated pages: identification, signature, payment, submission of applications and viewing of notifications, tested from end to end with a keyboard and a screen reader.
Accessible documents: every PDF, form or template the system generates must have structure, real text, tags and a reading order; plus a built-in checking tool for whatever staff upload.
An accessibility review report with every major release, produced using the WCAG methodology, and with any failures corrected before acceptance.
Support for the accessibility statement: the supplier provides the technical information the public body needs to draft it and keep it up to date.
Documented accessible components and patterns, so that future development does not break what has been achieved.
Training for content editors and for the unit responsible for accessibility.
Penalties for level A or AA failures not corrected by the deadline, and an obligation to correct those identified by the Observatory or through citizens’ complaints.

And a reasonable technical capacity criterion: projects delivered with verified accessibility, not just a promise to deliver it. The guide on how to prepare technical specifications with ENS requirements provides a basis for combining these clauses with the security ones.

Accessibility, the ENS and interoperability: three requirements that go together

A public sector system has to be accessible, under Royal Decree 1112/2018; secure, under the National Security Framework (Esquema Nacional de Seguridad, ENS) and Royal Decree 311/2022 (Real Decreto 311/2022); and interoperable, under Law 39/2015 (Ley 39/2015) and the National Interoperability Framework (Esquema Nacional de Interoperabilidad, ENI). All three have to be dealt with at the design stage and suffer if they are left until the end. That is why it makes sense to procure them together and require them of the same supplier, as we explain in what the ENS is and why your supplier must have it and in our comparison of large integrators and mid-sized companies.

How CEDESA approaches it

CEDESA’s case-processing platforms and digital services – developed for the provincial councils (Diputaciones) of Badajoz, Toledo and Ourense and for local councils such as Guadalajara and Puerto del Rosario – build accessibility in as a design requirement: accessible interface components, forms and documents generated with structure, processes tested with a keyboard and a screen reader, and review reports with every release. You can see how we work on our software for the public sector page.

Frequently asked questions about web accessibility in the public sector

What level of accessibility does Royal Decree 1112/2018 require?

The level set by the harmonised standard UNE-EN 301 549, which for web content incorporates WCAG 2.1 at level AA. The obligation has applied to public sector websites since 23 September 2020 and to mobile applications since 23 June 2021, and it covers downloadable documents, forms and the identification, signature and payment processes.

What is the accessibility statement?

A public document, following the model in Implementing Decision (EU) 2018/1523, which every public sector website and app must publish: level of conformance, content that is not accessible and why, the date of the last review, the feedback mechanism and the complaints procedure. It must be updated with every review.

Do PDFs on the e-office have to be accessible?

Yes. The royal decree expressly covers downloadable documents. A PDF scanned as an image, or one without a heading structure, real text and tags, is not accessible, and this is one of the most common failures in e-offices.

Who is answerable if the e-office is not accessible?

The public body that owns the site: to the Web Accessibility Observatory, to citizens who complain and, where applicable, to the courts. That is why the tender specifications must pass on to the supplier the obligation to deliver and maintain accessibility, with review reports and penalties.

How is the accessibility of an e-office checked?

With an automated review of the mechanical problems, a manual review using the WCAG methodology on a sample of pages and on complete processes with a keyboard and a screen reader, testing with users, and a review of the documents published and generated. The result is a report setting out the criteria not met, their severity and the fixes.

Conclusion

Web accessibility in the public sector is won or lost in the e-office: in the forms, in identification and signing, and in the documents citizens need in order to complete a procedure. Royal Decree 1112/2018 sets the standard, the statement and the monitoring; what decides the outcome is making accessibility a design, delivery and maintenance requirement for the supplier. If your organisation is about to overhaul its e-office or its case management system, tell us about your project via our contact page.