Reading Disability and Document Access, a Possible Approach

Publications Ofﬁce of the European Union Reading disability and document access, a possible approach

FINAL STUDY REPORT

Pilot Project 09 04 77 25 The European Commission is not liable for any consequence stemming from the reuse of this publication. Luxembourg: Publications Ofce of the European Union, 2020 © European Union, 2020 The reuse policy of European Commission documents is implemented based on Commission Decision 2011/833/EU of 12 December 2011 on the reuse of Commission documents (OJ L 330, 14.12.2011, p. 39).

Except otherwise noted, the reuse of this document is authorised under a Creative Commons Attribution 4.0 International (CC-BY 4.0) licence (https://creativecommons.org/licenses/by/4.0/). This means that reuse is allowed provided appropriate credit is given and any changes are indicated. For any use or reproduction of elements that are not owned by the European Union, permission may need to be sought directly from the respective rightholders. Print ISBN 978-92-78-42289-9 doi:10.2830/500074 OA-03-20-569-EN-C PDF ISBN 978-92-78-42286-8 doi:10.2830/061822 OA-03-20-569-EN-N Reading disability and document access, a possible approach

FINAL STUDY REPORT

Pilot Project 09 04 77 25

Publications Offce of the European Union This page has been intentionally left blank. Publications Office of the European Union – Reading disability and document access, a possible approach

Contents

FINAL REPORT ...... 5

1. INTRODUCTION ...... 5

2. SECTION I: USER GROUPS ...... 9 2.1. Associations overview ...... 9 2.1.1. Identified user groups ...... 11 2.1.2. Effects on reading ability and user needs ...... 13 2.1.3. Identified gaps in document accessibility ...... 14 2.1.4. Possible solutions and suggested tools ...... 14 2.1.5. Expectations and outcomes regarding the RDDA project ...... 19 2.2. Summary and analysis of user groups, gaps, and solutions identified by associations ...... 20

2.2.1. Proposed user group segmentation ...... 20 2.2.2. Key findings ...... 21

3. SECTION II: RESOURCES AND EU INSTITUTIONS ...... 24 3.1. Institutions overview ...... 24 3.1.1. Identified gaps in document accessibility ...... 27 3.1.2. Current practices and available tools ...... 33 3.1.3. Expectations regarding the RDDA project ...... 35 3.2. Summary and analysis of the documentation, end-users, priorities and practices of institutions ...... 35

3.2.1. Key findings ...... 35

4. SECTION III: ASSESSMENT OF THE TOOLS ...... 39 4.1. Tools overview ...... 42 4.1.1. State-of-the-art solutions ...... 43 4.1.2. Analysis ...... 43 4.1.2.1. Number of solutions per type of users ...... 43 4.1.2.2. Number of solutions per type of solutions ...... 44 4.1.2.3. Price and distribution of the solutions ...... 49 4.1.2.4. Number of solutions per type of provider ...... 50 4.2. Selection criteria ...... 51 4.3. Shortlisted tools ...... 52 4.3.1. OP Guidelines by OP ...... 53 4.3.2. Accessible features from Drupal CMS by Drupal association ...... 56 Publications Office of the European Union – Reading disability and document access, a possible approach

4.3.3. DXP Cloud by Liferay ...... 58 4.3.4. OP Templates by OP ...... 60 4.3.5. Accessibility solution by Siteimprove ...... 61 4.3.6. AbleDocs ...... 64 4.3.7. Accessibil-IT ...... 65 4.3.8. Acrobat DC by Adobe ...... 67 4.3.9. Equidox by Onix ...... 68 4.3.10. WordToEpub by DAISY ...... 70 4.3.11. FACIL’iti ...... 71 4.4. Summary of solutions ...... 73 4.4.1. Key findings ...... 73

5. SECTION IV: MAPPING ...... 74 5.1. Links between the type of solutions and the content ...... 74 5.2. Links between the type of solutions and the end-user groups ...... 75 5.3. Links between the shortlisted solutions and the content ...... 76 5.4. Links between the shortlisted solutions and the end-user groups ...... 76 5.5. Summary of the mapping ...... 77 5.5.1. Key findings ...... 77

6. SECTION V: GUIDELINES AND ROADMAP ...... 78 6.1. Introduction to the proposed roadmap...... 78 6.2. Evaluation phase ...... 81 6.2.1. Content analysis ...... 81 6.2.2. Subset creation ...... 82 6.2.3. Subset evaluation ...... 83 6.3. Prioritisation phase ...... 84 6.3.1. Generation of potential solutions ...... 85 6.3.1.1. C1 – Estimated financial cost ...... 86 6.3.1.2. G1 – Number of issues solved ...... 86 6.3.1.3. G2 – Number of issues prevented ...... 86 6.3.1.4. G3 – Sum of the visits of each impacted content ...... 87 6.3.1.5. G4 – Feedback from associations ...... 87 6.3.2. Prioritisation of the solutions ...... 87 6.4. Implementation phase ...... 88 6.4.1. OP Templates and OP Guidelines ...... 90 Publications Office of the European Union – Reading disability and document access, a possible approach

6.4.2. Typical implementation of CMS with accessibility features ...... 90 6.4.3. Siteimprove accessibility solution ...... 91 6.4.4. Typical implementation of existing PDF remediation ...... 91 6.4.5. Acrobat DC by Adobe ...... 91 6.4.6. Equidox by Onix ...... 91 6.4.7. WordToEpub by DAISY ...... 92 6.4.8. FACIL’iti ...... 92 6.5. Synergy phase ...... 92 6.5.1. Level 0: sharing entity ...... 93 6.5.2. Level 1: controlling entity ...... 93 6.6. Guidelines ...... 94 6.6.1. Directive ...... 95 6.6.2. Standards ...... 95 6.6.3. Guidelines ...... 96

7. CONCLUSIONS ...... 97

8. LIST OF ACRONYMS ...... 102

9. ANNEX ...... 104 9.1. Questionnaire for associations ...... 104 9.2. Questionnaire for institutions ...... 106 9.3. List of associations dealing with dyslexia in Europe ...... 107 9.4. List of solutions ...... 109 9.5. Questionnaire for solution providers ...... 110 Reading disability and document access, a possible approach

Final report

1. Introduction The European Parliament (EP) has mandated the Publications Office to carry out the “Reading disability and document access, a possible approach” pilot project. As pointed out in the introductory note of Mr Daniele Viotti, former Italian MEP, reading disability1 is one of the most common neurological conditions that affect European citizens. Public institutions must be accessible and transparent for everyone, including for the most vulnerable people. Despite the significant efforts made in recent years by EU institutions to improve the accessibility of their documents by establishing more user- friendly publications and public websites, access to relevant EU documents/publications is still problematic for people with reading disabilities.

In light of the provisions of “Directive (EU) 2016/2102 of the European Parliament and of the Council on the accessibility of the websites and mobile applications of public sector bodies”2, it is important to develop and make available appropriate instruments to ensure that people with reading disabilities have equal access to the documents/publications and websites of EU institutions.

One of the goals of the Publications Office (OP) Strategic Objective (SO4) “Linked EU information, increased interoperability and federated search” is to enhance the accessibility of existing documents published by the different institutions. Consequently, ensuring that people with reading disabilities can access documents/publications and websites falls within the scope of this Strategic Objective (SO). Therefore, the implementation of this pilot project was entrusted to the OP.C.1 – OP Portal unit which is in charge of SO4.

The project is complementary with the accessibility projects for users with visual impairments managed by the B2/B3 units of the OP. There is no overlap, only synergies.

The 18-month project consists of two phases:

1 A reading disability can be considered as a condition for which an individual experiences difficulty in reading. Reading disabilities include, for example, dyslexia (learning disorder affecting reading) and alexia (loss of ability to read). For the purposes of the study, the analysis has focused mainly on dyslexia.

2 https://eur-lex.europa.eu/eli/dir/2016/2102/oj

Page 5 of 112 1) A comprehensive survey assessing the targeted audience, the targeted documents/publications and websites, and the relevant tools for enhancing accessibility for users with reading disabilities, mainly dyslexia. 2) Proof of concept by enhancing the accessibility of selected publications and websites.

Deloitte assisted OP in the implementation of phase 1 of the project, in particular as regards conducting the survey.

The aim of the pilot project is multifold:

• Define and assess the needs of target user groups. • Research best practices and existing technologies, including the most recent developments in the area of artificial intelligence. • Provide guidelines and best practices for producers of information and facilitate accessibility and searchability of “reading disorder-friendly” documents/publications and websites for end-users. • Provide better access to a selection of official documents/publications and websites for people with reading disabilities by converting them to a suitable form, as defined by the outcomes of the study. • Estimate the effort and time needed by EU institutions, bodies, and agencies to modify (or replace) existing documents/publications, websites and document production workflows to achieve the targeted level of accessibility.

The aim of the proposed “Reading disability and document access, a possible approach” pilot project is to make the documents/publications and websites of the Commission and EU institutions more accessible for people with reading disabilities. It describes state-of-the-art best practices as a basis for recommending how to create a “reading disorder-friendly” environment for the publications and websites of EU institutions.

It focuses on existing documents/publications (for example PDF and ePub) and websites (which are mainly in HTML format) published by the European institutions.

First, the project seeks to define the targeted user groups (different levels and nature of disability) and to select a subset of documents/publications and websites of various European institutions in order to assess their accessibility.

Then it identifies the technologies, tools, formats, layout, fonts (e.g., openDyslexia) and best practices that can be applied in an automatic or semi-automatic way to existing publications and websites. It is considered as complementary with the work already carried out by the B2/B3 units of OP for users with visual impairments.

The Publications Office proposes the project outcomes and recommendations that the institutions could implement with regard to their documents/publications and websites. Phase 1: A comprehensive study This aim of this report is to present in a consolidated manner the outcome of phase 1 of the RDDA project. The objectives of phase 1 of the project are described in detail in the following paragraphs.

The first part of the study identifies the targeted user groups, explaining the problems and needs of each audience.

The second part of the study assesses the level of accessibility of the documents/publications and websites of the Publications Office, European Commission

Page 6 of 112 and other European institutions for the target groups. It identifies a subset of documents/publications and websites that should be made available, with the first priority being to create a “reading disorder-friendly” environment for the European institutions. The relevant best practices, technologies, tools, and IT Software that could enhance accessibility are described for each type of document/publication and website.

The third part contains an exhaustive assessment of current technologies, tools, formats, layout, fonts (e.g., openDyslexia), best practices, and IT software that could be used to make existing documents/publications (for example PDF and ePub) and existing websites (which are mainly in HTML format) more accessible. It describes the state-of-the-art accessibility solutions for users with reading disabilities, and provides full information on each tool: where to source it, cost, type of document to which it applies, fully automatic or semi-automatic implementable, and targeted audience.

The project team contacted European institutions, user associations, and civil society bodies to gather the most comprehensive information possible to conduct the study.

Finally, it proposes a roadmap for creating a “reading disorder-friendly” environment for EU institutions. It links the assessment of tools, publications/websites and targeted user groups in a comprehensive description of how to make the European institutions more accessible. It also proposes a work plan identifying “low-hanging fruits” to be exploited and a roadmap with milestones.

The study will be communicated to the selected European institutions that own the websites assessed in the study, to enable them to decide how to best leverage the contents. The outcomes of the study could be made public so as to enable organisations in Europe to benefit from it.

The work carried out in phase 1 defines the scope of work for phase 2. In concrete terms, one of the deliverables of phase 1 was to define concrete technical specifications, guidelines and a roadmap for identifying the documents/publications and websites that could be converted and made available to the target group.

Content and structure of the final report

Based on the objectives of phase 1 of the project, the final report is structured as follows:

• Section I: User groups o First of all, this section provides an overview of the approach for identifying the associations to be contacted and interviewed; it then summarises the key findings regarding user groups and possible solutions and tools to facilitate reading accessibility. • Section II: Resources and EU institutions o This section describes the approach followed for identifying the EU institutions to be contacted and interviewed; the section then addresses document accessibility gaps as well as current practices for improving document accessibility. • Section III: Assessment of the tools o This section describes several tools identified for improving document accessibility; for each such tool the section provides relevant information, such as the provider, the technology used, and the needs of the targeted users.

Page 7 of 112 • Section IV: Mapping o The mapping provides a clear picture of the links between user groups, documents and available tools. • Section V: Guidelines and roadmap o This section lists guideline documents for authors and users, and includes a possible roadmap for EU institutions to become more “reading disorder- friendly” in the coming years, • Conclusion o This section summarises the key findings of the study.

Page 8 of 112 2. Section I: User groups Task 02 of the study, User groups, consisted in identifying associations and conducting interviews with their representatives having the specific knowledge and expertise to provide key input for the study. Based on the interviews with association representatives, the ultimate goal of Task 02 is to provide an overview of:

• The identified user groups. • Current gaps in resource accessibility. • Tools that could benefit identified user groups.

Section I of the report is structured as follows:

• Associations overview: this section explains the approach followed for identifying the interviewed associations and provides an analysis of the data collected via the interviews regarding: o Identified user groups. o Effects on reading ability and user needs. o Identified gaps in document accessibility. o Possible solutions and suggested tools. o Expectations and outcomes regarding the RDDA project. • Summary and analysis of the user groups identified by associations, gaps, and solutions: this section describes: o Similarities and unique attributes identified. o Lessons learned applicable to the study.

2.1. Associations overview The associations that might provide relevant input and data for the study were identified by Deloitte and OP during the first month of the study, i.e. between June and July 2019. In order to identify the associations to be interviewed, the definition of reading disability was taken into account with a view to targeting associations with specific knowledge and experience in this field.

First, the European Dyslexia Association (EDA) was identified as an umbrella association that could not only provide key information on the study’s themes, but also propose additional associations to be contacted and interviewed. EDA, in fact, pointed out that the European Disability Forum (EDF) would be a relevant organisation to contact and interview in order to gather relevant data.

The following list of candidate associations for interview was validated by OP: • The European Dyslexia Association (EDA). • The European Disability Forum (EDF). • The Bulgarian Dyslexia Association. An association based in Bulgaria was identified as a relevant interlocutor due to the fact that a different alphabet (Cyrillic) is used.

The identified associations were contacted via email in order to present the study’s objectives and to invite an association representative to be interviewed by Deloitte. A document containing the interview questions was attached to the email to enable the association representatives to prepare their answers prior to the interview. The detailed questionnaire for associations is included as an annex to the report (section 9.1).

Page 9 of 112 Interviews were conducted between August and November 2019. In addition, the project team participated to the autumn 2019 seminar on 27-29 September at Linnaeus University in Växjö, Sweden. On the first day of the seminar, the European Dyslexia Association (EDA) Board conducted the opening ceremony. A message from the President of the European Parliament, Mr. David Sassoli, giving his support and commitment to the dyslexia cause was presented during the seminar’s opening ceremony.

Thereafter, representatives of several associations as well as academics participating in the seminar provided interesting input for the study. The RDDA study was presented during the seminar to all participants. In particular, OP and Deloitte presented and discussed the RDDA study with seven associations (six national associations and EDA).

The table below provides an overview of the interviewed associations, including the interview date as well as a description of the associations and their respective mission. The table also shows the associations that participated to the autumn 2019 seminar and provided useful input for the study.

TABLE 1: IDENTIFIED ASSOCIATIONS Association Description Interview date • EDA is a European non-governmental umbrella organisation for dyslexia associations in Europe; it was founded and established in 1987 in Brussels. • The mission of EDA is to be the platform and voice of European the people with dyslexia and so called “Specific Dyslexia Learning Difficulties” in Europe, and to facilitate the 20/08/2019 Association exchange of information and good practice through (EDA) international networking and lobbying.3 • The EDA Academic committee was created in 2017 for the purpose of sharing knowledge, influencing EU policy making and meeting young people with dyslexia around Europe. • EDF is an umbrella organisation of people with disabilities and a platform that brings together European representative organisations of persons with disabilities Disability Forum from across Europe. 02/10/2019 (EDF) • EDF is run by people with disabilities and their families. • EDF’s mission is to achieve equal opportunities for all men, women and children with disabilities.4 Written The Bulgarian • The association was interviewed to obtain input answers Dyslexia regarding accessibility guidelines with respect to the received on Association Cyrillic alphabet. 25/11/2019 Österreichischer • The association participated in the autumn 2019 27/09/2019 Bundesverband seminar.

3 European Dyslexia Association website, “About us”, https://eda-info.eu/about-the- eda/index.html [accessed on 23/10/2019]

4 European Disability Forum website, “Our work”, www.edf-feph.org/our-work [accessed on 23/10/2019]

Page 10 of 112 TABLE 1: IDENTIFIED ASSOCIATIONS Legasthenie

Dyslexforbundet • The association participated in the autumn 2019 27/09/2019 (Sweden) seminar. L-Università ta' • The association participated in the autumn 2019 27/09/2019 Malta seminar. British Dyslexia • The association participated in the autumn 2019 27/09/2019 Association seminar. Dyslexia • The association participated in the autumn 2019 Association 27/09/2019 Ireland seminar. Associacio • The association participated in the autumn 2019 Catalana de 27/09/2019 dyslexia seminar.

The following subsections (from 2.1.1 to 2.1.5) describe the views of associations.

2.1.1. Identified user groups A reading disability can be considered as a condition whereby an individual experiences difficulty in reading. A reading disability is specifically defined as “a difficulty in learning to read despite normal IQ and opportunity to learn with competent instruction, in absence of general health problems, emotional disturbances or sensory defects”5. Reading disabilities include, for example, dyslexia and alexia. For the purposes of the study, the analysis will focus mainly on dyslexia considering that:

• OP launched the project with the idea of conducting research focused mainly on dyslexia. • Other projects have been implemented or are ongoing in relation to other types of disabilities (visual impairment).

Thus, dyslexia is only one of the different typologies of reading disabilities. References in this report refer mainly to dyslexia. It is important however to be aware that reading disability is a broader term.

Dyslexia can be defined as a learning disorder affecting reading. Overall, it is estimated that about 15% of the population is dyslexic6. Men and women are equally likely to have dyslexia, which moreover occurs in people with different backgrounds and in speakers of every language and country.

5 The Free Dictionary, definition of reading disability, https://medical-dictionary.thefreedictionary.com/reading+disability [accessed on 10/01/2020]

6 The Reading Well, “Dyslexia statistics and myth busting, inspirational, fun facts”, https://www.dyslexia-reading-well.com/dyslexia-statistics.html [accessed on 29/10/2019]

Page 11 of 112 FIGURE 1: DEFINITION OF DYSLEXIA

According to the World Health Organisation’s international classification of diseases v11 (WHO-ICD-11) :

Dyslexia

6A03.0: Developmental Developmental Acquired MB4B.0: Dyslexia and alexia learning disorder with impairment in reading • The loss of a previous ability to read fluently and to • Difficulties in learning accurately comprehend written academic skills related to material reading accuracy, fluency, • Inconsistency with an comprehension individual’s general level of •Surface dyslexia •Semantic dyslexia •Neglect dyslexia • Performance in reading below intellectual functioning what would be expected for • Acquired after the •Phonological dyslexia •Pure dyslexia •Vowel dyslexia chronological age and level of developmental period, such as intellectual functioning due to a stroke or other brain •Deep dyslexia •Hemianopic dyslexia •Attentional dyslexia injury

According to the World Health Organisation’s international classification of diseases, dyslexia can be either developmental or acquired. Developmental dyslexia is defined as a developmental learning disorder with impairment in reading leading to:

• Difficulties in learning academic skills related to reading, accuracy, fluency, comprehension. • Performance in reading below what would be expected for chronological age and level of intellectual functioning.

Acquired dyslexia and alexia are experienced after the developmental period due, for example, to a stroke or other brain injury. They may lead to:

• The loss of a previous ability to read fluently and to accurately comprehend written material. • Inconsistency with an individual’s general level of intellectual functioning.

When trying to identify distinct user groups or to distinguish between diverse reading disabilities, two different methodologies can be followed, notably:

• A medical/academic classification based on symptoms. • A classification based on user needs.

EDA and EDF have the same preferred approach for identifying user groups, namely classification based on user needs, beginning with an examination of the tools that might benefit users.

It is also important to highlight that the definition of dyslexia may differ from one country to the next, and that dyslexia is treated differently between EU countries, not only in terms of recognition, but also from a legislative point of view. The associations recommended that we should avoid focusing on the different definitions and instead follow the user needs-based approach.

Finally, the linguistic aspect also gives rise to some differences. The two alphabets within the scope of the study (Latin and Cyrillic) differ in terms of transparency since

Page 12 of 112 each alphabet has syllables that produce different sounds compared with what might seem intuitive (e.g., words with a different meaning have a similar sound: east – him – hymn)7.

For the purposes of the study, the approach based on user needs was taken into account by the project team, as this approach ensures better mapping of user groups, documents, and tools (as part of section IV of the report), and is in line with the approach suggested by the interviewed associations.

The user difficulties mentioned by associations can be listed as follows:

• Difficulty with reading. • Difficulty with comprehension. • Difficulty with spelling. • Difficulty with phonological processing. • Difficulty with working memory. • Difficulty with speed of retrieval for information from long-term memory. • Difficulty with stress, frustration, and anxiety management. • Low self-esteem. • Visual impairment. • Blindness.

The Bulgarian Dyslexia Association also mentioned that the time needed can be a key requirement when overcoming reading disabilities: users should not have the feeling of being under time pressure.

2.1.2. Effects on reading ability and user needs As indicated by EDA, dyslexia can affect individuals in different ways, for example, regarding phonological processing, working memory, and the speed of retrieval of information from long-term memory. These reading disorders may result in individuals with dyslexia experiencing high stress, anxiety, and low self-esteem.

In specific, when reading, several elements are not handled well by individuals with dyslexia:

• Fonts. • Long sentences. • Dense texts. • Long paragraphs. • Complex wording, such as the use of double negatives. • Black fonts over white background. • Foreign languages. • Non-transparent languages.

7 The associations pointed out that users speaking non-official languages (e.g. Catalan, Basque, Galician) also have the same needs as other users and should, therefore, be considered for the purposes of the study.

Page 13 of 112 Besides individuals with dyslexia, it is considered that other user groups could benefit from increased accessibility of resources, for example blind people, persons with visual impairments, and the ageing population. Thus, by helping people with reading disabilities, new solutions and tools may also benefit other user groups with specific learning disabilities (cognitive, illiteracy), as well as individuals with visual impairments and intellectual disability.

2.1.3. Identified gaps in document accessibility Document accessibility can be defined as the ability of a user to know that a document exists, to identify the document, as well as to navigate within the document and read it.

The interviewed associations were asked for their views on how EU institutions can improve document accessibility. In particular, they were asked to identify any gaps regarding document accessibility on the websites of EU institutions.

The associations indicated that, as they understand the situation, the European Commission has its own policy regarding document accessibility. However, this is not always followed by EU institutions. In this regard, the gaps identified by associations can be described as follows:

• Web content accessibility guidelines exist, but are not generally followed, implying that documents are difficult to access by users. • Some institutions only use PDF documents, which, sometimes, are not accurately designed or do not support Optical Character Recognition (OCR), thus preventing most of the end-user tools from working. • PDF documents can also prevent users from personalising display and layout. • There is a lack of accessible CAPTCHA (Completely Automated Public Turing Tests to Tell Computers and Humans Apart) alternatives. People with reading disabilities have difficulty reading CAPTCHA because embedded characters are distorted and close to each other.

The associations also pointed out that one of the priorities of EU institutions should be to improve the accessibility of the European Parliament’s homepage.

In addition to the feedback provided by associations concerning the accessibility of the documents of EU institutions, the associations also indicated that participants in the Erasmus Mundus programme also experience significant accessibility issues. Students with reading disabilities experience several difficulties when registering for the programme, when finding an accommodation and when moving to another city. The Erasmus Mundus agencies located in different countries are not tied to European institutions and even if this was the case, it is not possible to force agencies to improve document accessibility.

2.1.4. Possible solutions and suggested tools The following paragraphs describe solutions and tools that improve document accessibility and were pointed out by the associations during interviews. For the sake of clarity, the input of the associations is summarised according to the following categories: • Fonts. • Format. • Speech. • Image. • Evaluation.

Page 14 of 112 • Guidelines and standards. • Paper-based. • Future solutions and tools. The abovementioned categories will be referred to throughout the study and are described in detail in section III of the report, Assessment of the tools. Before describing the solutions and tools, it is important to note the general point of view of the associations regarding the relevance of available solutions and tools. First, when discussing solutions and tools, both EDA and EDF highlighted the fact that the focus should be on the accessibility of resources, that is the environment, rather than the on the tool itself. If the environment is not adapted, the use of tools cannot be effective, even if they are available to users and address one or more user needs. A “universally designed environment” is the very first step towards the easy implementation of tools.

FIGURE 2: ILLUSTRATION OF THE DIFFERENCE BETWEEN TOOLS AND ENVIRONMENT

In this regard, the following analogy illustrates the difference between the tools and the environment. A wheelchair user has access to a flat surface and to a portable threshold ramp. However, the fact of having a wheelchair (the tool) does not allow the user to have access to a specific area if the surface (environment) is not adapted (e.g., surface only accessible by stairs), as illustrated in FIGURE 2. In the context of this study, the environment can be understood as a specific document format (such as EPUB, HTML and PDF), while the tool is a means of enabling the user to better read and understand a document.

Secondly, the associations pointed out that rather than identifying one specific tool for each user need, it is preferable to develop a set of tools people can select and use based on their preferences.

Currently, existing solutions and tools can be divided into the following categories:

• Reorganisation tools (rework text). • Simplification tools (able to simplify a text). • Assistance in understanding the text structure.

When considering the available tools, it is crucial to highlight that:

• Users have their own preferences regarding the tool(s) to use. • Users use different features of the same tool depending on their own preferences.

Page 15 of 112 • The use of a specific tool depends on the user’s needs that are covered by the tool itself, as well as on the pricing (freeware, shareware), and on the device/OS compatibility.

Fonts

The associations were asked to indicate the most suitable fonts for people with disabilities: no font emerged as the most suitable. This finding was corroborated by the research8 presented by Eileen Healy, PhD student, during the autumn seminar in Växjö. The key points that emerge from the research carried out by Ms Healy on the use of fonts and typeface can be summarised as follows:

• The use of a specific font from an early age leads individuals with dyslexia to have a preference for certain fonts. Therefore, no font can be considered as the best or optimal. • Gaps between words and lines are more important than the font used with regard to improved readability. • Captcha can be seen as a gap that has not as yet been adequately addressed. • The use of alt tags and appropriate URLs is important for people using screen readers. • A bright white background is not user-friendly for individuals with dyslexia. • Sans serif fonts are preferred, while Times New Roman does not improve reading.

The British Dyslexia Association also indicates in its “Dyslexia style guide 2018” that sans serif fonts, such as Arial (Arial) and Comic Sans (Comic Sans), should be preferred since letters appear less crowded9. Alternatives include Verdana (Verdana), Tahoma (Tahoma), Century Gothic (Century Gothic), Trebuchet (Trebuchet), Calibri (Calibri), Open Sans (Open Sans)10.

EDA indicated that a list of 5 to 10 preferred fonts could be provided to the project team.

Turning to spacing characters, no specific answer was provided in this regard by the associations which indicated that this aspect depends on the preferences of individual users.

Users would benefit from customisable font-related tools. Currently, these tools are considered as effective solutions for some users. However, users have their own preferences that could be accommodated through a customisable tool.

8 Eileen Healy, “Text Design for Dyslexia – Is there a write way?”, https://eda- info.eu/files/events/autumn-seminars/2019/Text%20design%20for%20Dyslexia.pdf, [accessed on 28.02.2020]

9 British Dyslexia Association, “Dyslexia style guide 2018: Creating dyslexia friendly content”, https://cdn.bdadyslexia.org.uk/documents/Advice/style- guide/Dyslexia_Style_Guide_2018-final-1.pdf?mtime=20190409173949, [accessed on 31/10/2019]

10 Idem.

Page 16 of 112 The associations also mentioned the tool Facil’iti, which improves the user’s browsing experience. This tool is described in detail in section III, Assessment of the tools.

Format

The EPUB, HTML, and PDF formats are regarded as being among the most readable formats, since they can be read on almost any device. In terms of accessibility, the EPUB format was proposed as a good alternative to PDF.

EPUB is one of the most popular eBook formats defined by the International Digital Publishing Forum (IDPF) and based on XHTML and XML; Adobe Digital Editions uses EPUB formatting11.

HTML stands for Hypertext Mark-up Language and can be defined as the language used by all internet websites that any browser can read12.

PDF: stands for Portable Document Format and is the most widely used file type created by Adobe and defined in the ISO standard – ISO32000. ISO 14289 – PDF/UA or PDF/Universal Accessibility is the International Standard for accessible PDF technology. Most eBook readers support PDF, but the challenge relating to the PDF format, versus the EPUB format, is to display a 14" diagonal page on a 6" diagonal screen13.

The possibility to dynamically convert documents would also be an interesting solution for users. Conversion software already exists14. Calibre, for example, can be used to reformat PDF documents so that they are better displayed on eBook readers; it is also free and open source. Epubsoft ebook converter allows users to easily convert EPUB, PDF, AZW, MOBI eBooks to other formats. To Epub enables users to convert PDF and other types of documents into different eBook formats including EPUB.

More detailed information regarding available formats is provided in section III, Assessment of the tools.

For historical documents, created via SCAN, some OCR features should be natively accessible; otherwise no action is possible on these documents. The key issue relating to the accessibility of old documents is indexing, which is the very first step required to re- generate readable content (even if this implies losing layout). Thereafter, any indexing should natively be followed by the generation of a simplified_layout_full_content document.

Speech

11 The eBook Reader.com, “Most common eBook formats”, https://www.the-ebook- reader.com/ebook-formats.html [accessed on 29/10/2019]

12 Idem.

13 Idem.

14 The Top Ten, “Top 10 eBook converters”, https://www.thetoptens.com/ebook- converters/ , [accessed on 29/10/2019]

Page 17 of 112 During the autumn seminar in Växjö, researchers pointed out that assistive technology can support users concerning test assimilation and communication. In this regard, two applications by ClaroSoftware embed text-to-speech and speech-to-text features. Researchers have found that these applications have a positive effect on students, by increasing their capabilities and independence when reading and assimilating information.

Image

Research presented during the autumn seminar in Växjö provided divergent feedback about text-to-image. The latter is considered as a new technology for one researcher, whilst another other explained that text-to-image is already used in Denmark to improve reading for young students.

Evaluation

Tools to automatically check the compliance of websites and documents with standards such as WCAG or PDF/UA exist. However, such tools cannot be used to check the content for accessibility features (e.g., alt text description can be automatically detected, but the meaning of the description cannot be automatically verified). It is complicated to check websites as these are dynamic and change over time; full automation is not possible, but it can provide an overall view on the level of compliance. In addition, a limited number of tools enable the user to check the overall compliance of a website, including both its static and dynamic parts.

Examples of tools performing accessibility checks are:

• A11Y Colour Contrast Accessibility Validator: it displays the colour contrast issues of a web page based on WCAG guidelines. • Web Accessibility Checker: it performs accessibility checks on any ASP.NET web application. • WCAG Compliance Auditor: it checks websites as well as groups of websites, against WCAG criteria.

Guidelines and standards

According to the associations, creating guidelines for designers, authors and publishers may eventually increase accessibility since most of the tools can be used to create content in accordance with existing accessibility standards (e.g. WCAG standard and EN 301 549)15.

Paper-based

The tools mentioned by the associations include Lexilight, a lamp that facilitates reading on paper for individuals with dyslexia. This tool is described in detail in annex 9.4 List of solutions.

Future solutions and tools

15 Examples of existing guidelines are provided in section V, Guidelines and roadmap.

Page 18 of 112 When asked about possible solutions and tools that might be introduced in the future, the associations indicated that it is important to trust major providers (private and public) rather than reinventing the wheel. Microsoft Office 365 already has several relevant features at the current time. Additional information in this regard is provided in section III, Assessment of the tools.

In addition, it was stressed that solutions and tools should be:

• Adaptable (e.g., font customisation). • Non-discriminatory (offering the same service as to other users). • Upgradable (improving the features available over time). • Free for end-users and ideally for website and portal editors as well16.

2.1.5. Expectations and outcomes regarding the RDDA project During the interviews, the project team also investigated the expectations of the associations regarding the RDDA study. Based on the feedback from the associations, the study should focus in particular on suggested tools, guidelines, user testing, and exclusion.

1. The associations suggested that the study should assess the use and availability of different tools using a forward-looking approach. 2. The study should also perhaps provide guidelines for authors: it would be interesting to have the equivalent of “web accessibility guidelines” for documents. 3. It would also be interesting to focus on topics relating to the exclusion of user groups (e.g., the consequences of the exclusion of user groups).

The associations suggested that an awareness-raising campaign in the “News” section of the European Parliament’s website might have a major impact and would be extremely symbolic considering that the audience accessing the website is vast.

The point was made during the seminar at Växjö University that the “RDDA” title does not have a positive connotation and that a more positive message could be delivered, for example by adding a subtitle referring to all citizens. Every citizen is, in fact, concerned by these topics. Moreover, the issue of document access concerns all citizens.

EDA mentioned during the seminar at Växjö University that it would be available and willing to contact Members of the European Parliament (MEPs) to facilitate and leverage the conclusions.

16 The associations pointed out that most of the tools offer a free version to users.

Page 19 of 112 2.2. Summary and analysis of user groups, gaps, and solutions identified by associations

2.2.1. Proposed user group segmentation This section summarises the proposed user group segmentation based on desk research, as well as on information collected during the interviews with associations. Prior to listing the identified user groups that will be referred to throughout the report, it is important to underscore that:

• The RDDA study addresses both reading disability and document accessibility. • When considering reading disability, which is a broad term, the study mainly refers to dyslexia in accordance with the OP guidance.

In addition, as indicated in section 2.1.2, the approach used to define the user group segmentation is based on user needs.

According to the associations, user groups have the same priorities as the general public. The user difficulties mentioned by the associations can be broken down as follows:

The definition of user groups is crucial for the study since this is the basis of the mapping between user groups, documents, and tools, which is covered in section IV of the report, Mapping. Based on the interviews carried out with the associations, user groups can be classified as follows:

• Tailored text: bigger fonts, different fonts, word spacing, line spacing, colour contrast, colour backgrounds, and syllables highlight. • Audio needs: listen to the text, navigate the text with sections. • Search needs: speak to the text, navigate the text with sections17. • Image comprehension needs: description of an image. • Additional time needed: more time needed to complete a document/online form.

Individuals can be classified in one or more user groups.

17 Search needs specifically refer to the needs of users to easily navigate a webpage or a document by moving from one section to another.

Page 20 of 112 2.2.2. Key findings This section reports the key findings concerning user groups, based on desk research and the interviews with associations.

KF1) Effects on reading ability and user needs

Reading disability and dyslexia can affect individuals in different ways, from difficulty with reading to low self-esteem.

The aspects of a document that may lead to reading difficulties are:

• Fonts. • Long sentences. • Dense texts. • Long paragraphs. • Complex wording, such as the use of double negatives. • Foreign languages. • Non-transparent languages.

These aspects have been considered throughout the study, for example in the assessment of existing tools and for the mapping exercise.

Also, an important conclusion regarding document accessibility is that increased accessibility would not only benefit individuals with reading disabilities, but also other user groups, for example persons with visual impairments, blindness and the ageing population. Simultaneously, existing tools facilitating document accessibility for people with visual impairments and blindness could benefit users with a reading disability.

Additionally, users in general could benefit from solutions. For example, text-to-speech solutions are widely used by students, journalists, and lawyers etc. for long documents in order to make the reading process faster and easier.

KF2) Identified gaps in document accessibility

During the interviews, the associations had the opportunity to provide their views on document accessibility gaps with respect to EU institutions websites. The gaps identified by the associations are as follows:

• Web content accessibility guidelines exist but are not generally followed, implying that documents are difficult to access by users. • Some institutions only use PDF documents, which, sometimes, are not accurately designed or do not support OCR, thus preventing most of the end-user tools from working. • PDF documents can also prevent users from personalising the display and the layout. • There is a lack of accessible visual CAPTCHA alternatives.

KF3) Possible solutions and suggested tools

The associations pointed out that the environment is crucial when considering the accessibility of resources. If the environment is not adapted, tools cannot be effectively used even if they are available to users and would address the needs of one or more users. Finally, the creation of accessible content can only be achieved by starting and thinking about accessibility from the design stage of a website or document up to the publication of the content.

When considering the available tools, the associations explained that:

Page 21 of 112 • Users have their own preferences regarding the tool(s) to use. • Users use different features of the same tool depending on their own preferences. • The use of a specific tool depends on the user’s needs that are covered by the tool itself, as well as on the pricing (freeware, shareware) and on the device/OS compatibility. The associations provided their feedback regarding solutions and tools. Considering fonts first, no font emerged as the most suitable. This finding was corroborated by the research presented by Eileen Healy, PhD student, during the autumn seminar in Växjö. Sans serif fonts should be preferred, while Times New Roman, a serif font, does not facilitate reading.

Users would benefit from customisable font-related tools.

Turning to formats, it was noted that the EPUB, HTML, and PDF formats are among the most readable ones and can be read on almost any device. Users benefits from tools that enable them to dynamically convert documents. Conversion software already exists18. The associations also indicated that document accessibility could be improved by the creation of guidelines for designers, authors, and publishers. However, tools already exist to create content in accordance with accessibility standards (e.g., WCAG standard and EN 301 549)19.

The associations explained that it is important to trust major providers when considering the possibility to develop and make available future solutions and tools, which should be: • Adaptable (e.g., font customisation). • Non-discriminatory (offering the same service as to other users). • Upgradable (improving the functions available over time). • Free for end-users and ideally for website and portal editors as well20.

Finally, the associations suggested developing a set of tools that people can select and use based on their preferences, rather than identifying one specific tool per symptom.

KF4) Universal and inclusive design

In the approach of implementing accessibility, there are, among others, universal and inclusive designs.

“The Same, But Different: Breaking Down Accessibility, Universality, and Inclusion in Design”21 article written by Matt May and posted on 4.2.2018 on Adobe Blog describes the

18 The Top Ten, “Top 10 eBook converters”, https://www.thetoptens.com/ebook- converters/ , [accessed on 29/10/2019]

19 Examples of existing guidelines are provided in section V, Guidelines and roadmap.

20 The associations pointed out that most of the tools offer a free version to users.

Page 22 of 112 nuances between universal and inclusive design. Universal design is defined as follows in The principles of universal design22 1997:

The design of products and environments to be usable by all people, to the greatest extent possible, without the need for adaptation or specialized design.

Inclusive design does not have a generally agreed-upon definition. The definition that has been identified by Matt May as the most suitable is as follows and comes from the Inclusive Design Research Centre23 at OCAD U in Toronto:

We have defined Inclusive Design as: design that considers the full range of human diversity with respect to ability, language, culture, gender, age and other forms of human difference.

The associations favour the universal design approach for everyone.

21 Matt May, “The Same, But Different: Breaking Down Accessibility, Universality, and Inclusion in Design”, https://theblog.adobe.com/different-breaking-accessibility- universality-inclusion-design/, [accessed on 03.02.2020]

22 Bettye Rose Connell, Mike Jones, Ron Mace, Jim Mueller, Abir Mullick, Elaine Ostroff, Jon Sanford, Ed Steinfeld, Molly Story, and Gregg Vanderheiden, “THE PRINCIPLES OF UNIVERSAL DESIGN” https://projects.ncsu.edu/ncsu/design/cud/about_ud/udprinciplestext.htm, [accessed on 03.02.2020]

23 inclusive design research centre, OCAD University, “What is Inclusive Design”, https://idrc.ocadu.ca/about-the-idrc/49-resources/online-resources/articles-and- papers/443-whatisinclusivedesign, [accessed on 03.02.2020]

Page 23 of 112 3. Section II: Resources and EU institutions The aim of this section is to present in a consolidated manner data and information collected via interviews with EU institutions. In addition, the section specifically focuses on the different types of resources (e.g., portals, websites, and documents) that are used by the institutions and that would need to be adapted.

Section II of the report is structured as follows:

• Institutions overview: this section provides the complete list of interviewed institutions and reports the information collected during the interviews with respect to: o Identified gaps in document accessibility. o Current practices and available tools. o Expectations regarding the RDDA project. • Summary and analysis of the documentation of institutions, end-users, priorities and practices: this section presents a summary of the key lessons learned via the interviews with institutions; key takeaways have been leveraged for the definition of the guidelines and roadmap, section V of the report, as well as for the drafting of the study’s conclusions.

3.1. Institutions overview Before outlining the output of the interviews with the institutions, we report the rationale behind the identification of the institutions to be interviewed. The latter have been identified by taking into account: • The involvement of the institutions in and support for projects and initiatives related to reading disability and document accessibility. • The role of the institutions in reviewing and publishing official publications. • The role of the institutions in designing, implementing, and managing websites. • The institutions publishing several official documents on the OP website. We have also taken into account the views of the associations regarding the institutions to be contacted. The contact person to represent each institution was identified in collaboration with OP. As a result, the following institutions were interviewed: • Publications Office of the EU. • European Economic and Social Committee. • Council of the EU. • European Commission, DG COMM. • European Commission, DG EAC. • European Parliament, DG COMM. • European Parliament, DG ITEC. • European Parliament, DG TRAD.

The approach used to conduct the interviews with the institutions was similar to the one described in section 2.1 relating to the organisation of interviews with the associations. As a first step, the representative of each identified institution was contacted via an email which included a definition of the objectives and the scope of the interview. The interview questionnaire was sent by email prior to the interviews, thus providing the representatives of the institutions to have a detailed overview of the topics to be addressed. The detailed questionnaire for the institutions is included as an annex to the report (section 9.2).

Page 24 of 112 The interviews with the institutions were carried out between October and November 2019. Overall, 11 interviews were conducted. The table below shows the list of interviewed institutions and describes their role regarding either reading disability or document accessibility or both.

TABLE 2: IDENTIFIED INSTITUTIONS Interview Institution Role date Publications Office of the EU • Manages the Portal of the Publications Office (Directorate C, OP Portal from which users can download legal and 21/10/2019 Platform and Digital non-legal publications. Collaborative Tools (C1)) • Manages production of cross-media Publications Office of the EU publications for EU Institutions, prepares (Directorate B, Multimedia contractual requirements, and provides and Publications Unit (B2), editorial advice and accessibility guidelines 08/11/2019 Content and Demand for EU Institutions. Reviews documents Management (B3), Quality received from EU institutions and customises Control (B4)) them before publishing (e.g. layout, structure, format, linguistic aspect). European Commission, DG • Reviews the quality of published documents EAC (Directorate A, and content in terms of visual identity, Stakeholder Engagement structure and metadata, and accessibility; 11/11/2019 and Programme Impact documents and content refer to the (A.3)) educational and cultural sphere. European Commission, DG • Produces and disseminates publications and COMM (Directorate A, online content for the general public, Editorial Service and including children, teenagers, and their 11/11/2019 Targeted Outreach Unit teachers, in all 24 EU languages and in (A2)) HTML, PDF, ePub, and print formats. Council of the EU • Manages the platform of the Council of the EU, uploads content, creates the content and (Directorate C, Digital 14/11/2019 Communication Unit C1) improves user experience, performs quality assurance. European Commission, DG • Is in charge of the EC communication and COMM (Directorate B, Europa covers web governance and web guidance. 14/11/2019 Web Communication Unit • Provides rules and guidance for webmasters B3) within the EC. • Manages the Europarl website together with European Parliament, DG other DGs of the European Parliament (e.g. COMM, (Directorate for DG ITEC), focuses on the conception of the 18/11/2019 Campaigns, Webmaster Unit, website and sometimes on the Implementation Service) implementation, and provides guidelines for webmasters. European Economic and • Distributes documents and publications via Social Committee multiple websites specifically addressing the 18/11/2019 general public. European Parliament, DG • Evaluates translation tools and aims to make 19/11/2019 TRAD translation software more accessible. Publications Office of the EU • Analyses user needs and aims at improving 21/11/2019 (EUR-Lex) user experience. European Parliament, DG ITEC (Directorate for Development and Support, • Manages the Europarl website together with Evolution and Maintenance other DGs of the European Parliament (e.g. 27/11/2019 Unit, Evolution of DG COMM). Communication Services)

Page 25 of 112 The EU institutions publish different types of documents, ranging from general publications to legal publications and articles. Other types include documents, infographics and visualisations, videos, and audio content – all of which are published on the websites of EU institutions.

The interviewed institutions usually publish documents in the 24 official languages of the EU. Some documents are multi-language, meaning that a single document is published in two or more languages (e.g., half in English and half in French). Documents are also produced using the Greek and Cyrillic alphabets, and some documents are published in Chinese, Japanese, and Arabic. More detailed information regarding the role of the interviewed institutions is summarised in the following paragraphs.

OP does not generally create the content of published documents. Rather, authors from different EU institutions send the content to OP in different formats (e.g. WORD, PDF, PDF/X). Documents are provided to OP already translated into the 24 official languages. Before publishing, OP can:

• Create or review the layout. • Structure the document. • Convert the document into the requested formats. • Improve the linguistic aspect, but without modifying the content or providing a translation.

Within the European Commission, DG COMM, publishes its own documents as well as those received from other authors, such as political publications. Documents are reviewed by OP to verify metadata as well as to add and/or translate tags. DG COMM is the author of the following publications and websites, among others: • The European Union – What it is and what it does24. • Europe in 12 lessons25. • ABC of EU law26. • The “Spotlight on” series of infosheets. • Europe – Better together!27 • Let’s explore Europe!28

24 European Commission, “The European Commission What it is and what it does”, https://op.europa.eu/webpub/com/eu-what-it-is/en/, [accessed on 27.04.2020]

25 European Commission, “Europe in 12 lessons”, https://op.europa.eu/en/publication- detail/-/publication/a5ba73c6-3c6a-11e8-b5fe-01aa75ed71a1, [accessed on 27.04.2020]

26 European Commission, “The ABC of EU law”, https://op.europa.eu/en/publication- detail/-/publication/5d4f8cde-de25-11e7-a506-01aa75ed71a1, [accessed on 27.04.2020]

27 European Commission, “Europe Better together”, https://op.europa.eu/webpub/com/europe-better-together/en/, [accessed on 27.04.2020]

Page 26 of 112 • EU&ME29. • Learning Corner website30. • The history of the European Union website.31 • The EU in slides website32.

The European Economic and Social Committee has multiple websites and sub- websites. One of them is interinstitutional with circular economy content (European Commission, DG GROW). Within this institution, the IT team is in charge of the document management tool and processes documents from the European Economic and Social Committee as well as the Committee of the Regions (CoR).

The European Parliament has around 100 websites: some of the European Parliament’s websites are run by the institution (e.g. Europarl.europa.eu website), while other websites are run by external providers. Traditionally, Europarl is a large domain with multiple sites that are managed by multiple CMS. There are around five CMS that are managed by different units and DGs.

The Council of the EU applies a single site policy, which has replaced the 18 websites that previously existed and allows full visual alignment. Besides the main website, the Council of the EU has two separate media: • The news room with videos and photos. • Live streaming. The satellite applications are databases of documents and an email subscription system.

3.1.1. Identified gaps in document accessibility This subsection provides an overview of the identified gaps in document accessibility at the level of EU institutions, by reporting the information collected with regard to:

• Current accessibility checks and identified gaps. • Actions and priorities for the future. • Priorities in terms of document accessibility. • Typical users.

28 European Commission, “Let’s explore Europe!”, https://op.europa.eu/en/publication- detail/-/publication/5a9f6713-495e-4f97-b995-9a359f5f7132, [accessed on 27.04.2020]

29 European Commission, “EU&ME”, https://op.europa.eu/webpub/com/eu-and-me/en/, [accessed on 27.04.2020]

30 European Commission, “Learning corner”, https://europa.eu/learning- corner/home_en, [accessed on 27.04.2020]

31 European Commission, “The history of the European Union”, https://europa.eu/european-union/about-eu/history_en, [accessed on 27.04.2020]

32 European Commission, “The EU in slides”, https://europa.eu/learning-corner/the-eu- in-slides_en, [accessed on 27.04.2020]

Page 27 of 112 Current accessibility checks and identified gaps

This subsection describes the different approaches currently used by EU institutions to make their websites and documents accessible, as well as to regularly check the level of accessibility of the websites and documents. The different approaches followed by the institutions can be summarised for the sake of simplicity:

• Development and distribution of guidelines. • Performance of internal testing. • Organisation of staff training and workshops. • Audit. • Implementation of corrective actions.

Considering first the development and distribution of guidelines, these are provided by several of the interviewed institutions such as OP, the EC, and the Council of the EU. The guidelines developed by OP for authors should be followed by all the DGs of the EC and the other institutions. Within the EC, DG EAC has created a digital version of the Erasmus+ programme guide33 in a user-friendly and accessible format available in 23 languages. The EP, DG ITEC, indicated that a working group will be created with DG COMM. Authors and webmasters will participate in the working group to understand the importance of improving the level of accessibility of technical and editorial documents. The Council of the EU has an editorial style guide for digital communicators, which provides accessibility guidelines referring, for example, to the heading structure, sections, and visuals.

Gaps have been identified specifically in relation to the implementation of guidelines. As mentioned by OP and by the EC, guidelines are not correctly followed due to a lack of:

• Sufficient time dedicated to the production process including proofreading. • Information regarding the availability and distribution of guidelines. • Knowledge regarding alternative text and image description.

As guidelines are non-mandatory by definition, there is a need for different instruments (such as rules) to ensure adherence to the desired process and outcomes.

Another noteworthy gap identified is that the accessibility guidelines focus extensively on websites rather than on documents. This means that knowledge of the existence of guidelines for document accessibility is limited despite the fact that OP produces guidelines for authors, which are shared with other institutions, such as the European Commission.

The European Commission, DG EAC, indicated that it would also be useful to request external consultants to follow accessibility guidelines and standards when delivering documents to EU institutions.

33 European Commission, “How to read the Programme Guide”, https://ec.europa.eu/programmes/erasmus-plus/programme-guide/introduction/how-to- read-programme-guide_en, [accessed on 21.02.2020]

Page 28 of 112 Gaps concerning document accessibility at the level of the institutions have also been identified through the feedback provided by users with reading disabilities and reported by institutions during the interviews. User complaints mainly concern:

• Documents: o Non-accessible PDF documents. o Non-editable tables included in documents. o Images with no related description. • Forms: o Non-accessible forms for blind people requiring the support of an assistant. • Captcha: o Non-accessible captcha.

Internal testing is also common among the interviewed institutions. To provide a few examples, OP regularly performs document testing, specifically regarding the needs of people with visual impairments and leveraging a built-in Voiceover tool and NVDA tool for Windows. Within the European Commission, DG COMM involves external users in testing panels that test its products for (1) 5 to 18 year-old students and their teachers, and (2) the general public. Both testing panels hold a meeting every year and collaborate through an online workspace. The Council of the EU used Site Improve software that performs automatic checks, tests around 40% of WCAG standards and puts forward recommendations for improving website accessibility.

In addition, the Council of the EU tests website accessibility using a speech reader, magnifier, and navigation with keyboard. The EP has a quality assurance team. Testing accessibility is included in the quality assurance by:

• Using tools such as screen readers. • Besides the automatic tests, manual accessibility tests are performed including tests with users with disabilities.

When considering the organisation of training, OP, the European Commission, and the European Economic and Social Committee mentioned that they either provide accessibility training and workshops or encourage staff to participate in similar training programmes provided by another institution. OP organises accessibility workshops and training sessions. In addition, OP published internally a series of videos and documentation regarding the most suitable fonts, formats, alternative text, concepts, plain languages, and screen readers to promote accessibility. Within the European Commission, a dedicated team working on accessible publications provides training, publishes e-learning sessions and raises awareness regarding the tools that can be used to create accessible content. The European Economic and Social Committee encourages authors to follow accessibility training programmes run by the Commission.

Finally, some institutions also request an external audit regarding accessibility matters. This audit generally leads to recommendations for institutions on how to improve the level of accessibility of their documents and websites, as well as an implementation plan with a specific deadline. For example, in November 2018, the European Economic and Social Committee mandated Access42 to carry out an accessibility audit. The audit evaluated WCAG 2.0 and 2.1 level AA of the European Economic and Social Committee website. The review resulted in a corrective plan for webmasters, internal and external contributors. Subsequently, every webmaster and contributor had to participate in a mandatory one-day training session to understand how to apply the correction plan. All of the recommendations have been implemented up to September 2019. Moreover, the European Economic and Social Committee has signed

Page 29 of 112 a four-year framework agreement to review, maintain and improve website accessibility based on the evolution of standards.

The Council of the EU conducted two accessibility audits in 2015 and 2018 run by external auditors and covering a vast range of disabilities. These audits covered only the website's content. They were carried out with manual check-points with user tests, and also with automatic testing including WCAG level AA. The last audit in2018 resulted in 50 recommendations concerning different areas, such as front end, editorial, visual content, and user experience. The audit led to an action plan based on three main steps:

• Implementing audit recommendations (with a self-imposed deadline Q3 2019 for the implementation of the high-priority recommendations). • Creating standard procedures to ensure accessibility compliance across teams creating content (guidelines). • Raising awareness about accessibility through events, presentations and articles on the intranet.

The evaluation and audit focus mainly on the level of accessibility of websites rather than that of documents. Document accessibility is, in fact, only partially assessed.

Actions and priorities for the future

During the interviews, the institutions were asked to outline their future plans for improving website and document accessibility. Overall, the institutions intend to improve the level of accessibility of their websites and documents by focusing on:

• The correct implementation of existing guidelines and the development of new guidelines. • Conducting testing and accessibility studies. • The use of alternative formats. • The use of new tools. • An overhaul of websites.

Some illustrative examples are provided below.

The institutions plan to continue following guidelines and WCAG standards and to implement HTML5. They also intend to continue promoting the correct use of guidelines in order to improve the level of document accessibility.

In addition, the Council of the EU is recruiting a person who will be responsible for coordinating the activities of the Publication Hub. The purpose is to define the next steps in the area of accessibility thanks to the contribution of a dedicated resource. Testing and accessibility studies are now envisaged by various institutions. The European Commission, for example, plans to outsource accessibility testing. Within OP, EUR-Lex has received recommendations based on an accessibility study on the website. The structure of the output was as follows: description of the problem in relation to the accessibility standard, and future recommendations to resolve the problem and ensure compliance with the standard.

The institutions provided the following information as regards their plans to improve document accessibility:

• The EESC aims to create accessible templates for WORD documents and to create all documents in an open format such as XML. • The Council of the EU is currently discussing the possibility of using a single version of a specific document providing only one accessible and user-friendly version with integrated alternative texts for images and transcripts for videos.

Page 30 of 112 • DG EAC is considering an easy-to-read format for static information on its website.

At this stage, it seems that no consensus exists at interinstitutional level regarding the choice between publishing documents in a single universal design version or in multiple versions (universal design and easy-to-read versions).

OP suggested creating a label of accessible publications and outsourcing the certification process in order to assess in a harmonised manner the level of document accessibility. OP also mentioned the possibility of introducing a mandatory level of accessibility metadata in order to provide this information to the reader and to promote accessibility among authors.

Turning to future tools, the following ideas were mentioned by EU institutions as enablers to improve levels of accessibility:

• Speech-to-text search agent: this tool would enable users to provide input to the website, thus improving the interaction between users and the website; moreover, artificial intelligence will help users to narrow their search and identify relevant documents among various OP publications. • Automatic checking of tags: this tool would check whether the tag correctly describes the content rather than being a random tag. • New player for videos: this tool would be more user-friendly compared with the one currently used.

At the EP, DG TRAD, the Digital Accessibility project started with tools for translators. Now it also involves tools from other DGs and the European Commission as well as tools used by citizens, such as the interinstitutional terminology database tool IATE. The aim of this project is to implement the universal design concept to support all categories of users. The project’s activities are conducted on a voluntary basis that depends on the commitment of the stakeholders (project managers, developers, etc.) and not yet on a centralized, EP-wide basis.

Finally, some of the interviewed institutions plan to improve their websites by enhancing the design and making the website more accessible. A new CMS with Drupal 8 will be implemented by some DGs of the European Commission34, e.g., DG COMM, and by the European Economic and Social Committee. The Council of the EU constantly reviews and improves the website and CMS. Within OP, EUR-Lex will switch from xHTML to HTML5 with improved accessibility as an integral part of HTML 5 specifications and requirements. At interinstitutional level, the design of the Europa.eu website will be changed to take into account accessibility aspects. Also, a fluid grid for mobile and desktop will be introduced to improve the level of website accessibility specifically for users with visual impairments who will be able to increase the size of the text and other web page elements.

Priorities in terms of document accessibility

34 About 100 websites out of 170 are in scope of the migration.

Page 31 of 112 When considering the priorities of the institutions specifically in terms of document accessibility, the following points emerged from the interviews:

• Increased accessibility of documents and material via easy-to-read content and an adapted layout. • Implementation of accessibility on a daily basis and not occasionally. • Adapted document style, avoiding footnotes, justified texts, and the use of sans serif font. • Avoidance of acronyms and jargon. • Use of simple language rather than technical words. • Production of accessible infographics. • Production of transcripts from processes and image files to be read by a screen reader.

Considering that documents could be published by EU institutions in all of the 24 official languages, it will be important for translators to be aware of the accessibility guidelines. The purpose is to provide users with accessible documents regardless of the language of publication.

Besides document accessibility, the institutions also aim to improve the accessibility of media content as mentioned by the European Commission, DG EAC. To provide an example, live streaming videos should have separate subtitles that can be read by a screen reader.

Typical users

The EU institutions were asked to describe the typical user accessing their websites and downloading publications. Overall, institutions do not collect and cannot therefore provide detailed information concerning user profiles. However, a distinction can be made regarding the typology of content accessed by users (e.g., general public, academia, EU officials). The typical end-user is a member of the general public who browses non-technical publications. The browsing of legal publications has increased.

Some illustrative statistics have been communicated by the interviewed institutions. OP explained that 9% of users are from EU institutions. The Council of the EU indicated that in 2018 the website had 9 million visits, corresponding to 6.5 million visitors. The European Economic and Social Committee website has about 2 million visits a year. In October 2019, the European Parliament’s websites had more than 989,000 visits. The European Union website (europa.eu) had 36.8 million visits in 201435, corresponding to 1.7 million visitors per month. Since 2015, EUR-Lex has published website usage statistics36. The Council of the European Union indicated that its website is mainly accessed by academics, journalists, students, EU officials, national diplomats, and delegates.

35 European Union, “Our visitors”, https://europa.eu/european- union/abouteuropa/infographic_en, [accessed on 27.04.2020]

36 EUR-Lex, “Usage statistics”, https://eur-lex.europa.eu/statistics/usage.html, [accessed on 27.04.2020]

Page 32 of 112 Based on the above statistics, it is evident that millions of visitors access the websites of EU institutions. Therefore, improved website and document accessibility would have a positive impact on a broad population.

OP is conducting a study with the University of Luxembourg in order to determine the behavioural patterns of users. However, it will not be possible to retrieve the social background of users. In addition, OP plans to conduct a survey in the near future to collect more detailed user information.

3.1.2. Current practices and available tools This subsection focuses on the current practices of institutions and on the tools available for use or in development. Specifically, this subsection provides information concerning:

• Published resources. • Sources, data, and metadata. • Distribution channels.

Published resources

Institutions use different formats for the publication of resources. In this subsection, we distinguish between published documents and published content. For both categories, institutions follow a homogeneous approach regarding the choice of the preferred format for publishing. Overall, it was noted that PDF is the most common format for publishing documents, while HTML is the most frequently used format for publishing content.

First, as regards the publishing of documents, the following formats are used:

• PDF. • MS WORD, ODT. • MS EXCEL. • MS POWERPOINT. • JPEG. • EPUB.

PDF seems to be the most common format. As an example, OP mentioned that 90% of the published documents are in PDF format. Documents are also published in MS WORD, MS EXCEL, MS POWERPOINT, JPEG, and ODT formats (European Commission). The European Economic and Social Committee indicated that documents are generally published in WORD and sometimes in PDF format. WORD is the main format for official documents such as opinions and PDF format is mostly used for publications.

EPUB appears to be the least common format for the publication of documents. This is mainly due to the fact that the authors do not generally ask for EPUB format, which is less well-known and less frequently downloaded. In addition, the general public seems to be less familiar with the EPUB format and it is estimated that only 1% of documents in EPUB format are downloaded from the OP Portal. Accordingly, the advantage of EPUB documents and PDF documents is that they can be read offline compared with content published in HTML format.

Some documents are available on a multi-channel and multi-format basis. Often, a printed version of documents is available upon request by users (OP, EC, Council of the EU). Neither the European Economic and Social Committee nor the European Parliament prints documents for dissemination. Documents can be downloaded and printed by users. The institutions indicated that the printed format enables them to target more

Page 33 of 112 citizens, including those who do not have ready access to internet, computers or mobile devices.

Turning to published content, the HTML format is generally used by all the interviewed institutions. The advantage of HTML pages is that they can easily be updated to reflect the latest up-to-date information. The Council of the EU explained that the source formats are HTML5 compliant.

Within OP, EUR-Lex (which is responsible for the website including summaries and consolidation) launched an accessibility project in 2016. The recommendations of this accessibility study led to the implementation of:

• A focus frame, to show the position of the cursor when navigating via TAB.

• Tool tips (interrogation mark) taken into account with the focus frame.

At OP level, a working group has defined specifications for accessibility in HTML5, which will cover all publications, with the main focus on legal texts. OP contracts for the production of general publications contain detailed accessibility requirements concerning PDFs and other formats.

In addition, a minority of the institutions also mentioned the use of the JSON (EP, DG COMM) and XML (OP, EUR-Lex) formats.

Sources, data and metadata

The institutions were asked to indicate the source(s), data and metadata of the published documents. They indicated that the following source formats are used:

• PDF. • HTML. • EPUBS. • XML. • InDesign. • MS Office tools. • BITS. • Mobile applications.

The most common metadata used by institutions for legal, non-legal, and general publications are:

• Title. • Author. • Language. • Date. • Description. • Reference. • Procedure number.

The title, the author and the language are considered to be the minimum metadata. The remaining metadata are optional.

OP provides the list of metadata to be used to the European Commission. The European Commission, DG COMM, mentioned that there is currently no metadata to flag the level of accessibility of resources. This statement was corroborated by the Council of the EU.

Page 34 of 112 OP also shares and promotes guidelines related to tagging and to the structure of data. In order to structure data, tagging is generally used. Institutions can add and/or translate tags or bookmarks.

The European Parliament, DG ITEC, mentioned that the structure of a legislative document is binding. Legislative documents are created from a word template that integrates tags, which are not, however, designed to make the document more accessible. Their purpose is to facilitate the automatic processing of documents by IT systems.

Some institutions format and structure the content of resources directly via CMS and Drupal (European Economic and Social Committee, European Parliament).

Distribution channels

There are two primary channels, physical (printed copies) and electronic, that are used for publishing and distributing legal and general documents along with other content. The electronic channels include:

• Websites. • Social media. • Mobile applications.

Within the European Commission, DG COMM (Unit B3) manages the domain and is responsible for the first three levels of the European Commission’s website. Each DG is then responsible for its own website. Overall, the European Commission has more than 800 websites, including pages for the Commissioners, regulation portals, and interinstitutional websites.

3.1.3. Expectations regarding the RDDA project All the interviewed institutions were committed to providing relevant input for the study and showed real interest in the reading disability and document accessibility topics. The expectations of the EU institutions as regards the outcome of the RDDA study can be summarised as follows:

• Promote guidelines on document accessibility among authors and webmasters. • Raise awareness among the staff of EU institutions as regards reading disability and document accessibility. • Share and learn best practices already implemented by the EU institutions. Overall, the institutions are also motivated to participate in and actively provide input for phase 2 of the RDDA project.

3.2. Summary and analysis of the documentation, end-users, priorities and practices of institutions This section summarises the key findings of the interviews with EU institutions and obtained from the analysis described in detail in section 3.1 of the report.

3.2.1. Key findings The key findings refer to 1) the awareness and engagement of the institutions, 2) limited sharing of best practices, 3) identified gaps in document accessibility, 4) extensive focus

Page 35 of 112 on website accessibility vs. document accessibility, 5) currently used formats, 6) actions and priorities for the future, and 7) target users.

KF1) The awareness and engagement of the institutions

Overall, the institutions are aware of the need for improved resource accessibility in order to provide people with reading disabilities with easier access to websites and documents. In addition, the institutions are motivated to take part in and provide input for phase 2 of the RDDA project, thereby demonstrating their interest and engagement regarding the reading disability and document accessibility topics.

The different approaches currently followed by the institutions to improve resource accessibility can be summarised for the sake of simplicity:

• Development and distribution of guidelines (provided by several of the interviewed institutions). • Internal testing, which is common among institutions. • Organisation of staff training and workshops, which are encouraged and promoted by the institutions. • Accessibility audits. • Implementation of corrective actions.

KF2) Limited sharing of best practices

Despite the willingness of the institutions to improve resource accessibility, there does not appear to be much sharing of best practices at this stage. This aspect is likely to be addressed in the future to enable the institutions to harmonise their approach as regards the level of resource accessibility.

KF3) Identified gaps in document accessibility

Gaps in document accessibility specifically refer to the limited implementation of existing guidelines, despite the fact that the latter are generally shared and promoted. The main reason for the poor implementation of guidelines is a lack of:

• Sufficient time dedicated to layouting. • Information regarding the availability and distribution of guidelines. • Knowledge of alternative text and image description. • Historical reasons, e.g., the legal documents published in the Official Journal are created according to rules that have not changed significantly since the Official Journal’s first publications.

The institutions would benefit from the promotion of the implementation of guidelines by all internal staff and specifically by staff involved in the production and publication of documents.

User complaints reported by EU institutions mainly concern:

Page 36 of 112 KF4) Extensive focus on website accessibility vs. document accessibility

Accessibility guidelines focus extensively on websites rather than on documents.

Furthermore, the evaluation and audit work also focuses more on the level of accessibility of websites as opposed to documents.

KF5) Currently used formats

The institutions use different formats for the publication of resources (documents and websites). The following formats are generally used for the publication of documents:

• PDF. • MS Word, ODT. • MS Excel. • MS PowerPoint. • JPEG. • EPUB.

The PDF format seems to be the most commonly used format, while EPUB appears to be the least frequently used format used for publishing documents.

Turning to published content, the HTML format is generally used by all of the interviewed institutions.

The institutions use the following source formats:

• PDF. • HTML. • EPUBS. • XML. • InDesign. • MS Office tools. • BITS. • Mobile applications.

KF6) Actions and priorities for the future

In order to improve resource accessibility, across both documents and websites, the institutions generally have an action plan and priorities for the future. The key aspects that are regarded as priorities by EU institutions in order to improve the level of resource accessibility are:

When considering document accessibility, the following aspects are also regarded as future priorities by EU institutions:

• Increased accessibility of documents and material via easy-to-read content and an adapted layout. • Implementation of accessibility on a daily basis and not occasionally.

Page 37 of 112 • Adapted document style, avoiding footnotes, justified texts and using sans serif font. • Avoidance of acronyms and jargon. • Use of simple language rather than technical words. • Production of accessible infographics. • Production of transcripts from processes and image files to be read by a screen reader.

Future tools that may be introduced by institutions as enablers for an improved level of accessibility are:

• Speech-to-text search engine. • Automatic checking of tags. • New video player.

OP also mentioned the possibility of introducing a certification process managed by an external provider for the award of an accessibility label for publications. The certification process would enable the institutions to assess the accessibility level of their publications in a harmonised manner.

KF7) Target users

Considering that millions of users access the websites and documents of EU institutions, an improved level of resource accessibility would have a positive impact on a broad population.

Page 38 of 112 4. Section III: Assessment of the tools This section is the deliverable of Task 3 of the RDDA project. It contains an assessment of current technologies, tools, formats, layout, fonts, best practices, and IT software that can be used to make existing documents/publications (e.g., PDF and ePub) and existing websites (mainly in HTML format) more accessible.

It describes the state-of-the-art solutions in the field of accessibility for users with reading disability, and provides full information about each tool: where to source it, cost, type of document to which it applies, fully automatic or semi-automatic implementation and targeted audience.

Throughout the rest of this document, the wording “solution” covers any technology, tool, format, layout, font, best practice, and IT software that can be used to read or to make accessible documents, publications and web pages.

Section III of the report is structured as follows: • Tools overview, long list of solutions. • Selection criteria to create the shortlist of solutions for interview. • Short listed tools with a detailed description.

The solutions were identified through workshops with associations and institutions, as well as through desk research. The shortlisted solutions are:

• OP Guidelines. • Accessibility features from Drupal. • DXP Cloud from Liferay. • OP Templates. • Accessibility solution from Siteimprove. • AbleDocs. • Accessibil-IT. • Acrobat DC by Adobe. • Equidox by Onix. • WordToEpub by DAISY. • FACIL’iti.

These solutions have been selected according to the following criteria:

• At least one solution from each type corresponding to the environment. • At least two solutions dealing with publications. • At least two solutions dealing with web pages. • At least one tool and one methodology.

Throughout the rest of this document, authors, contributors, publishers, webmasters, and end-users are defined as follows: • Authors and contributors are anyone creating content. • Publishers and webmasters are anyone in charge of the layout, including visual layout and dissemination of content. • End-users are anyone reading and accessing publications, documents, and web pages.

The input of associations:

Page 39 of 112 The associations mainly reflect the end-user’s point of view. They provide various types of tools, fonts, and formats that are the most dyslexia-friendly. Generally, one best tool/font that fits all does not exist. Dyslexic persons experience their disability in a different way individually and have their own reading preference and comfort levels. While some dyslexic people prefer to have a text-to-speech tool, others prefer a customised font-based tool. Text-to-speech tools cover both blind and reading disabilities. Font-based tools should allow users to customise the typeface, size of the text, spacing between lines, letters, words, and margins.

The associations did not recommend one specific font. However, some general preferences can be identified, such as sans serif font or low contrast between the text and the background.

Regarding the document format, the EPUB format was mentioned by associations as a more readable format for screen readers and font-related tools compared with Word and PDF. Therefore, in their opinion, the EPUB format should be promoted.

The associations also explained the difference between the tool and the environment. The tool is the technology that allows users to cover their needs while the environment is the external conditions or surroundings in which the tool is used. For example, where the tool is a wheelchair, the environment is either accessible, in the case of a ramp, or non-accessible in the case of stairs. In the case of document access and reading disability, the tool corresponds to the end-user tool, such as text-to-speech or font customisation for example, while environment is the accessible or non-accessible PDF that the tool will or will not be able to read.

According to the associations there are already many tools available on the market for end-users. In addition, each end-user will probably choose a different tool corresponding to individual preferences and needs. The associations recommend that the institutions should focus on providing an environment adapted to the use of the end-user’s tools.

The input of the institutions:

The main formats published by the institutions, available online and accessible by the general public, are either a document (e.g. PDF, Word) or a web page (mainly HTML).

Documents are drafted by authors and then forwarded to publishers for dissemination. Contributors write web page and webmasters manage the layout. Finally, the workflow of a document or a web page, as described in FIGURE 3, is the following: • Authors and contributors write the content. • Publishers and webmasters publish documents or web pages. • End-users read and access documents or web pages.

Page 40 of 112 FIGURE 3: WORKFLOW OF DOCUMENTS OR WEB PAGES

Authors & Publishers & End Users contributors webmasters

Publish documents Read and access Write content and web pages documents

As regards solutions, the institutions mentioned the following types: • Developing and distributing guidelines for authors or webmasters, and also sometimes the use of templates. • Testing: o With tools such as WAVE, Ainspector, Pa11y that allow automated testing to check the accessibility of websites. o With end-user tools, such as ReadSpeaker, VoiceOver, NVDA to check their compatibility with websites. • Organising staff training and workshops and external audits by companies such as Siteimprove, Access42, and AnySurfer that provide multiple accessibility related services, such as audit, user testing, reviews, support, training, and development. • Implementing corrective actions in terms of: o Format, such as creating documents in an open format such as XML in order to convert them easily to PDF, EPUB or Word. o Website features, such as modification of the text size, colour contrast, print-friendly, easy reading version, colour picker, export webpage in pdf, focus frame, tools tips, labelling element, skip links, non-justified alignment, stop carrousel. In addition, the institutions pointed out that a public sector accessibility directive exists, but unfortunately it does not as yet apply to the institutions.

Proposed classification:

Based on the input of the associations and institutions, the proposed classification is based on two levels. The first level corresponds to users of the solution and the second level corresponds to the type of solution.

For the first level, three categories of users of the solution have been identified: • Authors and contributors. • Publishers and webmasters. • End-users. For the second level, nine different types of solutions have been identified and are described in TABLE 3.

Page 41 of 112 TABLE 3: TYPES OF SOLUTION DEFINITION Type Definition Editing Any tools that help authors or contributors to edit or create an accessible document or webpage Guidelines Any guidelines for authors or contributors to create an accessible content Evaluation Any tools that assess the level of maturity in terms of accessibility either for web pages or documents Formats Any formats or tools that convert one format to another Fonts/layout Any fonts or tools that allow users to customise the font, spacing, size, layout, colour, contrast, etc. Speech Any tools with a speech feature, either text-to-speech or speech- to-text Image Any tools that manipulate images, text-to-images or text-in-image for example Paper-based Any tools that help users to read non-numerical documents Navigation agent Any tools that help users to navigate within a document or website

Finally, FIGURE 4 represents the classification of solutions based on level 1, user of the solution, and level 2, type of solution. In addition, the differentiation between tools and environment, as described by the associations, has been applied for each type of solution. The guidelines and editing for authors/contributors and evaluation and format for publishers/webmasters modify or impact the environment in which the tools for end- users, fonts, speech, image, paper based, navigation agent are used.

FIGURE 4: CLASSIFICATION OF SOLUTIONS

Solutions

Authors/contributors Publishers/webmasters End users Level 1: users of the solution

Guidelines Editing Evaluation Formats Fonts Speech Image Paper based Navigation agent Level 2: type of solution

Environment Tools

4.1. Tools overview The long list of solutions is presented in this subsection. This long list is based on the input from the associations and institutions, as well as internal research. This list is reduced to eleven solutions in the subsection 4.3 based on the criteria described in subsection 4.2.

The study endeavours to analyse both environment and tool solutions. In addition, it provides a high-level view of which types of tools exist on the market.

Page 42 of 112 4.1.1. State-of-the-art solutions Solutions that that have been identified on the market are listed in annex 9.4, List of solutions. The information provided for each solution on the long list is as follows:

• The name of the solution. • The type of solution based on the classification presented in FIGURE 4. • A description of the solution. • The solution provider. • The solution reference (URL) or/and contact. • Open source or not. • Free or not.

The long list of solutions is sorted by type of solution in accordance with the classification presented in FIGURE 4 to facilitate a better peer comparison.

The list and a description of providers are also included in annex 9.4, List of solutions. Providers are classified in three categories:

• Companies (large, medium or small) which, although their main business is not accessibility, provide accessibility feature for their products. • Consortia and communities, based on the creation of standards and sharing solutions. • Accessibility specialists, whose core business is accessibility.

The list of providers is in alphabetic order.

A list of additional solutions is also provided in annex 9.4, List of solutions. These solutions are not in the long list because either information was not available or the solution focuses more on writing disabilities or blind impairment than on reading disabilities and document access. Finally, this list provides a description of these additional solutions.

4.1.2. Analysis The analysis presented in this subsection is based on a subset of solutions. Some of the solutions could have been classified in more than one type of solutions. However, even if the solution covers multiple categories due to technology bundles there is usually a predominant feature. We decided therefore to follow a modular approach to functionalities and classify these solutions in only one category, the one with the most predominant feature.

4.1.2.1. Number of solutions per type of users

FIGURE 5 shows that end-user solutions (50) are easier to find than solutions for publishers/webmasters (43) and authors/contributors (15). This is in line with the input of the associations on the existence at the current time of numerous tools for end-users, while, according to them, the focus should be on the environment. It shows that there is a shortage of solutions for creating accessible content from sources.

Page 43 of 112 FIGURE 5: NUMBER OF SOLUTIONS PER TYPE OF USERS

108

4.1.2.2. Number of solutions per type of solutions

FIGURE 6 shows the distribution of the solutions per type of solution.

FIGURE 6: NUMBER OF SOLUTIONS PER TYPE OF SOLUTIONS

Page 44 of 112 24 23 22 21 8 Number of solutions Number 7 3 0 0

Guidelines Editing Evaluation Formats Fonts Speech Image Paper Navigation based agent Type of the solution

15 solutions for authors and contributors 43 solutions for publishers and webmasters 50 solutions for end users

Guidelines – editing

Guidelines and editing solutions are used by authors and contributors to create accessible content. Guidelines and editing solutions are mainly provided by consortia, communities and large companies and most of them are free. Evaluation

FIGURE 7: DISTRIBUTION OF EVALUATION SOLUTIONS

22 evaluation solutions

18 accessibility checker 2 European 2 reporting standards formats (on 13 websites accessibility features 4 services and accessibility testing rules)

4 documents

1 android application

Page 45 of 112 FIGURE 7 shows the distribution of the evaluation solutions from the long list. From the 22 evaluations tools, 18 are automated accessibility checkers, including one android applications checker, four document (pdf, EPUB) checkers and 13 website checkers. Among the 13 website checkers, four provide services such as manual testing, recommendations and roadmap, training programmes which are not free. There are two reporting formats:

• One for assisting buyers and sellers in identifying information and communication technology (ICT), products and services with accessibility features; this format is called VPAT (Voluntary Product Accessibility Template). • One for developing automated testing tools and manual testing methodologies; this format is called ACT (Accessibility Conformance Testing).

The accessibility checkers and reporting format on accessibility features are based on two European accessibility standards, EN 301 549 and WCAG. Formats

FIGURE 8: DISTRIBUTION OF FORMATS BASED SOLUTIONS

21 formats based solutions

3 accessible 18 convertors formats

FIGURE 8 shows the distribution of formats-based solutions. There are 18 convertors. Part of the conversion is based on the three accessible formats (EPUB, PEF, and DAISY DTBook (Digital Talking Book)) and other well-known formats, such as audio-to-text, text-to-audio, PDF to HTML, Word to EPUB, PDF to Word conversions are possible. Six of these convertors propose automated, semi-automated or manual conversion (services) to convert non-accessible PDF to accessible PDF. Fonts/layout

FIGURE 9: DISTRIBUTION OF FONTS AND LAYOUT SOLUTIONS

24 fonts/layout solutions

2 typefaces 21 1 guideline customization tools

FIGURE 9 shows the distribution of fonts and layout solutions. There are two typefaces targeting dyslexic people and 21 tools that customise fonts/typefaces or layout (spacing,

Page 46 of 112 zoom, and colours) in the long list. There is also one User Agent Accessibility Guidelines, UAAG (part of WAI guidelines), targeting end-users by providing guidelines on browsers, browser extensions, media players, readers, and other applications that render web content.

Furthermore, most of the operating systems (e.g. Windows, Mac, Android, iOS) provide accessibility settings on smartphones, tablets, and laptop devices. These settings allow end- users to control, for example, contrast, magnification gestures, captions for images, font size, display size or speak passwords. Speech

FIGURE 10: DISTRIBUTION OF SPEECH SOLUTIONS

FIGURE 10 shows the distribution of speech solutions. There are two voice recognition solutions, generally used to navigate within documents or applications. There are 21 text-to-speech tools in the long list that read aloud the content or the menu of a document or website. Image

No image-based solutions have been identified. In fact, text-to-image based tools are less developed than text-to-speech tools. The following two examples of text-to-image type tools demonstrate the lack of maturity of the technology and, indirectly, why no image-based tools have been identified: 1. Using Artificial Intelligence to generate images, charts and graphical representations to replace text. Unfortunately, an AI based image generator is a technology that is not yet sufficiently mature according to our current understanding. In fact, it is still in the research area as presented in (Xu, 2017),37 (Reed, 2016)38, (Tan, 2019)39. Multiple text-to-image generators are available

37 Tao Xu, Pengchuan Zhang, Qiuyuan Huang, Han Zhang, Zhe Gan, Xiaolei Huang, Xiaodong He, “AttnGAN: Fine-Grained Text to Image Generation with Attentional Generative Adversarial Networks”, https://arxiv.org/pdf/1711.10485.pdf [accessed on 31.01.2020]

38 Scott Reed, Zeynep Akata, Xinchen Yan, Lajanugen Logeswaran, Bernt Schiele, Honglak Lee,“ Generative Adversarial Text to Image Synthesis“, https://arxiv.org/pdf/1605.05396.pdf, [accessed on 31.01.2020]

Page 47 of 112 online such as runway 40or DeepAI41. Testing these generators shows that the technology is not yet mature as described by Mathew Olson in his article “Let Your Imagination Run Wild With This AI-Powered Text To Image Generator42” in Digg. Nikunj Gupta concludes his article “Text-to-Image Synthesis43” as follows: “Though AI is catching up on quite a few domains, text to image synthesis probably still needs a few more years of extensive work to be able to get productionalized”.

2. Using the “On hover” feature to display images/content when a cursor is placed over part of the text. It can display a preview of the underlying hyperlink of the text. For example, it can display a photo based on an individual’s name. However, it cannot, yet, generate an image, chart or graphic that does not already exist in a library.

Paper-based

The three paper-based tools are Claro ScanPen, OfficeLens, and Lexilight. Claro ScanPen and OfficeLens are digital tools that enable users to take pictures of paper and customise the font and layout directly on the screen. They also include a text-to-speech feature. In contrast, Lexilight is a lamp that enables dyslexic users to read directly on paper. Navigation agent

Tools that enable users to navigate correctly within a document have not been classified in the navigation agent solution‘s type. This is because the navigation is usually done by keyboard or voice recognition if the document is correctly formatted. Solutions that provide good formatting are classified in format solutions and voice recognition in speech solutions.

39 Fuwen Tan, Song Feng, Vicente Ordonez, “Text2Scene: Generating Compositional Scenes from Textual Descriptions”, https://arxiv.org/pdf/1809.01110.pdf, [accessed on 31.01.2020]

40 runwayML, “Generative Engine”, https://experiments.runwayml.com/generative_engine/ , [accessed on 31.01.2020]

41 DeepAI, “Text to image API”, https://deepai.org/machine-learning-model/text2img, [accessed on 31.01.2020]

42 Mathew Olson, “Let Your Imagination Run Wild With This AI-Powered Text To Image Generator”, https://digg.com/2018/text-to-image-generator-ai-cris-valenzuela, [accessed on 31.01.2020]

43 Nikunj Gupta, “Text-to-Image Synthesis”https://medium.com/ai-club-iiitb/text-to- image-synthesis-62eb44e65cd0#_bookmark16, [accessed on 31.01.2020]

Page 48 of 112 4.1.2.3. Price and distribution of the solutions

FIGURE 11 presents the percentage of free and open source solutions.

Accessibility features or guidelines, included with paid software at no extra cost, are considered as free. Adobe guidelines or accessibility features in Office are an example of this free solution via paid software. 61% of 108 solutions are free solutions. Free solutions are provided by large companies, via free features over paid software, by consortia and communities, via free standards and guidelines, and by disabled people.

Only software solutions, representing 89 solutions, have been evaluated as open source or not. 29% of 89 solutions are open source.

It shows there is a community working on accessibility; the solutions are therefore not only fee-based and profit driven.

FIGURE 11: PERCENTAGE OF FREE AND OPEN SOURCE SOLUTIONS

Free 61% 39%

Open Source 29% 71%

0% 10% 20% 30% 40% 50% 60% 70% 80% 90% 100% yes no

Page 49 of 112 4.1.2.4. Number of solutions per type of provider Companies

The eight companies are providers of 28 solutions from the long list. The medium-sized companies are Foxit, Liferay, Onix, and Orange. The large companies are Microsoft44, Google45, Apple46, and Adobe47. These companies run projects related to improving accessibility. They are present on all segments of disabilities and user needs. Globally, • Microsoft and Apple provide more end-user tools to improve the digital life of people with reading disabilities. • Adobe provides guidelines for authors, contributors, webmasters and publishers to create accessible documents. • In addition, among the specific accessibility products in the long list of tools, Google provides accessibility features for most of its products, enabling developers to create accessible applications and documents, and enabling end-users to use a screen reader.

Consortia, communities

The 11 consortia and communities are providers of 28 solutions from the long list. Consortia and communities are Access for All, Foundation; CEN, CENELEC, ETSI; DAISY Consortium; DRES, University of Illinois; Drupal community; Inclusion Europe; ISO; ITI; Publications Office; W3C; WordPress.

Guidelines and standards have been created by some of these consortia to make websites, applications, and other digital creations more accessible and usable for everyone. The following well-known consortia and projects work on accessibility: • World Wide Web Consortium48(W3C), which is an international community where member organisations, a full-time staff, and the public work together to develop Web standards. It is one of the authors of EPUB, WCAG, WAI and ATAG. • DAISY Consortium49, which is an international non-profit membership organisation working with over 150 partners around the world to improve access to reading for people with print disabilities.

44 Microsoft, “Accessibility”, https://www.microsoft.com/en-us/accessibility/, [accessed on 31.01.2020]

45 Google, “Accessibility”, https://www.google.com/accessibility/, [accessed on 31.01.2020]

46 Apple, “Accessibility”, https://www.apple.com/accessibility/mac/, [accessed on 31.01.2020]

47 Adobe, “Accessibility”, https://www.adobe.com/accessibility.html, [accessed on 31.01.2020]

48 W3C, “About W3C”, https://www.w3.org/Consortium/, [accessed on 31.01.2020]

Page 50 of 112 These consortia are non-profit-making, which shows that the demand is driven by the general public and that there is a real need to implement accessibility.

Accessibility specialists

The 33 accessibility specialists are providers of 48 solutions from the long list. Accessibility specialists are Abbie Gonzalez – OpenDyslexic, AbleDocs, AccessBe, Accessibil-IT, Access42, AnySurfer, AudioEye, axes4, Callas Software, Claro Software (Lingit AS), CommonLook, Dolphin, Dyslogiciel, EasyReading, EqualWeb, FACIL’iti, Freedom Scientific, Funka, Lexilife, Luz Rello, Make-Sense Inc., Numanis, NV Access, OpenAjax Alliance, Paciello group, ReadSpeaker, Recite, Siteimprove, Squiz Pty Ltd, Tingtun, Turnipsoft Limited, UserWay, and Voice Dream.

The size of these companies varies from one person such as Abbie Gonzalez working on OpenDyslexic typeface, to more than 500 employees, for example Siteimprove. Some of these specialists have a disability, such as Abbie Gonzalez or the creators of NVDA (NV Access) who have visual impairments.

Some of these specialists provide services, such as AnySurfer or Access42, while others focus on software development, such as Claro Software or ReadSpeaker.

Finally, an analysis of the number of solutions per type of provider shows that on average companies provide more solutions (28 solutions for eight companies) than consortia/communities (28 solutions for 11 consortia/communities) and accessibility specialists (48 solutions for 33 specialists).

4.2. Selection criteria This section lists the criteria used to select eight solutions from the long list to create the short list of solutions. Solutions from the short list are investigated in greater detail.

The associations recommended focusing mainly on the environment instead of on tools. For this reason, the short list has at least one solution from each type corresponding to the environment (guidelines, editing, evaluation and formats).

In addition, one of the key findings from the institutions is the lack of guidelines and evaluation tools for publications, and mainly for pdf documents. That is why at least two solutions dealing with publications, and ideally with pdf documents, are in the short list.

To achieve a good balance between document accessibility and web page accessibility, at least two solutions dealing with web pages are in the short list.

49 The DAISY Consortium, https://daisy.org/, [accessed on 31.01.2020]

Page 51 of 112 To achieve a good balance between software and methodologies, at least one tool and one methodology have been selected.

Both large providers with a significant impact on accessibility as well as free solutions are represented.

4.3. Shortlisted tools Based on the criteria described in the previous subsection 4.2, the shortlisted tools that have been selected are shown in TABLE 4. The list is arranged by type of solutions based on the classification of FIGURE 4 and then in alphabetical order.

TABLE 4: SHORTLISTED TOOLS Type Solution Description Interview date Guidelines OP Guidelines OP Guidelines are a set of guidelines, 10.01.2020 checklist and videos that enable authors to create accessible documents. Editing Accessibility features Beginning with Drupal 7, Drupal has 14.01.2020 from Drupal been designed to support the development of sites that comply with WCAG 2.0 and ATAG 2.0. The Drupal accessibility community will be involved in adopting best practices in Drupal 8 and the soon-to-be-released Drupal 9 as they evolve. D7AX and D8AX (and soon D9AX) hashtags allows identifying Drupal modules and themes that are accessible. Editing DXP Cloud from Liferay Liferay enables IT teams from 03.01.2020 organisations to merge digital processes on one platform. It is based on open source and highly flexible and expandable. Liferay helps organisations overcome data silos, not necessarily by migrating but by including existing data. Editing OP Templates OP Templates is a Word Plugin that 10.01.2020 helps to write structured manuscripts for accessible publications. It is in test phase and will be available for all EU institutions. Evaluation Accessibility solution With Siteimprove users can discover 20.01.2020 from Siteimprove and prioritise accessibility issues based on responsibility, conformance level, and severity. The solution pinpoints issues via on-page and in-code highlights and provides guidance and practical recommendations on how to fix them. Beyond Accessibility, Siteimprove offers an all-in-one platform covering content quality, Analytics, Data Privacy, Performance, SEO, and more. Formats AbleDocs Depending on the document type, 31.01.2020 AbleDocs applies one of the six following solutions: ADS service, ADG gateway, ADStream, ADScan, ADLegacy or ADForms. Formats Accessibil-IT Accessibil-IT provides fully accessible 29.01.2020 and compliant PDF documents from simple to high complexity.

Page 52 of 112 TABLE 4: SHORTLISTED TOOLS Formats Acrobat DC by Adobe Acrobat DC makes PDF documents and 28.01.2020 forms compliant with WCAG standard. It is used to create, convert, share, sign, protect and edit the smartest PDFs on both desktop and mobile devices, utilising cloud-based services. Formats Equidox by Onix Equidox is a semi-automated 30.01.2020 document conversion software tool. Formats WordToEpub by DAISY The WordToEPUB tool shows how Word 18.12.2019 can be leveraged to produce highly accessible EPUBs. It provides a simple but powerful method to create EPUB files from Microsoft Word documents. The EPUB files created with this tool can be used in reading apps on any platform, with great screen reader compatibility, and the ability to personalise visual features such as colours, font, text size, and layout. Fonts FACIL’iti FACIL'iti is a web plugin that modifies 12.09.2019 the text (of client websites) to the customised user’s preferences in terms of text size, font selection, letter groups (highlights these), space between letters, words, and lines.

Representatives of the identified solutions were contacted via email, by phone or via an online form with the purpose of presenting the study objectives to them and inviting a solution provider representative to participate in an interview with the project team. The document containing the interview questions was also provided to them to enable the solution representatives to prepare their answers prior to the interview. The detailed questionnaire for solution providers is included as an annex to the report (section 9.5). In the rest of this section, each solution from the short list is described according to the structure below: • General description. • Users. • Provider. The information provided in the following subsections is based on the input of providers collected during interviews and from their website.

4.3.1.OP Guidelines by OP

TABLE 5: OP GUIDELINES BY OP

General description Name of the solution: OP Guidelines Description of the solution: OP Guidelines are a set of guidelines, checklist and videos that enables authors to create accessible documents.

Page 53 of 112 TABLE 5: OP GUIDELINES BY OP Price: The solution will be free and available for everyone on a dedicated accessibility website from the OP Portal. Languages: The guidelines and checklist are in English. Part of the videos will be available in the 24 languages of the EU (subtitles) and part in English. Alphabets: The guidelines and checklist use Latin alphabet. Videos and subscripts will use Latin, Greek, and Cyrillic alphabet. Environment: The guidelines are currently available in PDF format. Videos will be published on OP Portal. Features: The guidelines and checklist facilitate the creation of accessible documents by providing recommendations on the following items:

• Clear structure (headings, tables, lists, columns, breaks, header/footer/page number, text boxes/text in images, anchored objects). • Images: alternative texts. • Colour and contrast. • Readability. • Navigation elements (table of contents, metadata, hyperlinks, endnotes, footnotes, citations, captions). • Clear content. • Converting to PDF. • Checking accessibility in Word and in Adobe Acrobat. Videos will cover the following subjects:

• Motivational: A. Introduction to accessibility. B. Legal aspects. C. Standards (1). D. Standards (EPUB and PDF). E. Case studies. • Technical: 1. Assistive technologies. 2. Screen readers: 2.1.Windows. 2.2.MacOS. 2.3.Ios. 2.4.Android. 3. Fonts, sizes, and colours. 4. Alternative text. 5. Text transcripts, captions, and sign language. 6. Plain language. • HOW-TO GUIDES: 1. The PDF standard: 1.1.Microsoft Word. 1.2.Adobe InDesign. 1.3.Other authoring tools. 1.4.Testing PDFs. 1.5.Repairing a PDF in Adobe Acrobat. 2. HTML/ARIA: 2.1.Web standards. 2.2.HTML coding. 2.3.HTML testing. 3. ePub: 3.1.Tools. 3.2.Testing. 3.3.Adobe InDesign. 4. Apps: 4.1.iOS.

Page 54 of 112 TABLE 5: OP GUIDELINES BY OP 4.2.Android. 4.3.Cross-platform development. 4.4.Summary. 5. Audio-visuals. Standards and guidelines: The guidelines reference standards such as the World Wide Web Consortium standards. Implementation: The guidelines should be implemented from the beginning of the creation of the document. Demonstration:

Users Example of users: The users of the solutions are authors that want to create accessible content. The primary target are authors from EU institutions, however, the guidelines will be available to all interested users. Provider Name of the provider: Publications Office Description of the provider: The Publications Office of the European Union was founded in 1969 and is an interinstitutional office whose task is to publish the publications of the institutions of the European Union. Size of the company: OP has around 500 employees. The EC has around 32,000 employees including OP and other DGs. Geographic coverage: European Union and all interested internet users in the world.

Page 55 of 112 4.3.2.Accessible features from Drupal CMS by Drupal association

TABLE 6: ACCESSIBLE FEATURES FROM DRUPAL CMS BY DRUPAL ASSOCIATION

General description Name of the solution: Drupal CMS Description of the solution: Drupal is a CMS. It is a modular and extensible platform for ambitious digital experiences.

Price: Drupal is free and open source. It uses GPL license version 2 or later. Users may require the support of a service provider, which will not be free. The Drupal community has grown an ecosystem of commercial service providers that can support a Drupal project at scale: https://drupal.org/services Drupal.org ranks these providers by their contribution score, which is a strong proxy for their expertise with the software. Languages: UTF-8 languages are used on the interface. Drupal offers more than 100 languages immediately available. Drupal’s automated language translation makes it possible to reach different audiences with localised content. Core modules in Drupal 8 make it possible to translate in full every part of a site. Multilingualism is supported by Drupal. Alphabets: UTF-8 alphabets are used on the interface and accepted by the solution. Environment: Drupal requirements are browser, database server, web server and PHP requirements. System requirements for Drupal 8 installation are available here50. Features: The core features available are: • Entity translation. • Accessibility maintainers that meet the WCAG guideline 2.0 standard and WAI-ARIA, in order to improve compatibility with assistive technology, search engine, keyboard navigating, level of contrast and skip navigation. • Semantic structuring of content. • Extensive documentation on http://drupal.org. • Control the order of tab elements. • Notification of available updates with new features. • Audible text presentation feature added and translated. There is a notable improvement in terms of accessibility between versions 7 and 8. Examples of improvement are a better semantic, tagging and translation entity in version 8. Drupal 9 is due to be released shortly, as an easy upgrade from Drupal 8. Drupal 9 will continue to have a six month cycle of feature

50 Drupal 8, “System requirements”, https://www.drupal.org/docs/8/system- requirements, [accessed on 31.01.2020]

Page 56 of 112 TABLE 6: ACCESSIBLE FEATURES FROM DRUPAL CMS BY DRUPAL ASSOCIATION enhancements and improvements.

Standards and guidelines: Drupal is developed based on standards from W3C foundation such as WCAG, WAI-ARIA and ATAG. Implementation: The accessible features are configurable using add-on by users interface, in code and API. Most of them can be done manually. In general, Drupal is not an out-of-the-box product. Customisation and personalisation configurations are needed. The following links are examples of Drupal implementation: https://www.drupal.org/case-study/huge-performance-gains-for- massgov, https://www.drupal.org/case-study/digital-democracy- redesign-drupal-8. Demonstration: Drupal association does not have any demonstration video. Large numbers of people from the community and service providers generate demonstration videos about specific features. Most of them are available on YouTube such as this small video on accessibility demonstration51. Users Example of users: Drupal is used by organisations that need ambitious users experience and ambitious type of content. Blogs and small websites usually do not use Drupal. It is used in government sectors, states in the USA, EU, educational institutions, high- tech, financial companies, e-commerce, and more. Examples of organisations using Drupal are the Mayor of London, Oxford University, NASA, Deutschland.de. More example can be found here52. Provider Name of the provider: Drupal/Drupal association Description of the provider: Drupal is a non-profit foundation. Individual users build and use Drupal. The project started in 2002. Drupal association, started in 2010, is between open source and trade association for end-users. Size of the company: Drupal association is a non-profit foundation with 15 employees. It provides support services to partners and Drupal-based users. Geographic coverage: The software is used all over the world.

51 Drupal association, “Drupal 8 Accessibility Demo”, https://www.youtube.com/watch?v=ipOc1km2uEc, [accessed on 31.01.2020]

52 Drupal, “Explore featured case studies”, https://www.drupal.org/case- studies/all/education/all?, [accessed on 31.01.2020]

Page 57 of 112 4.3.3. DXP Cloud by Liferay

TABLE 7: DXP CLOUD BY LIFERAY

General description Name of the solution: DXP Cloud Description of the solution: Liferay enables organisations to merge digital processes on one platform. It is based on open source and is highly flexible and expandable. Liferay helps organisations overcome data silos, not necessarily by migrating, but by including existing data. Among standard functionalities such as CMS, DMS, Roles & Permission management Liferay DXP is highly extensible. Price: Liferay is free and open source (OpenChain53 Specifiation2.0 compliant), however a standard subscription is available at 90k/y for cloud and 30k/y for on-premise. The cloud subscription includes 24/7 support while the on-premise subscription covers the basic setup and office hours support. However, it is possible to extend the on-premise subscription to a 24/7 support model. Languages: The interface of the solution supports more than 50 languages, including left-to-right languages. It is however possible to extend the solution with additional languages when needed and it therefore virtually supports an unlimited number of languages. Alphabets: The accepted alphabets and available alphabets on the interface of the solution are in line with UTF-8. Environment: The Liferay Digital Experience Platform 7.2 Compatibility Matrix is available here54. Features: Liferay is content-centric and creates templates with tool tips. It is then possible to create a template with required fields (for example improving accessibility, such as requiring alternative text on each image) before publishing. It is also possible to go through a publishing workflow so different people can extend the content with additional information such as translations, accessibility fields populated, etc. Liferay comes with hundreds of out-of-the-box features, and what is not available can, because of its open source nature, be developed. Plug-ins are available on Liferay Marketplace such as VoiceCommand, or-Actions, Voice Elements or aid plug-ins to read out text.

53 Shane Coughlan, “Liferay Announces OpenChain Conformance”, https://www.openchainproject.org/news/2019/10/29/liferay-announces-openchain- conformance, [accessed on 31.01.2020]

54 Liferay, “Liferay Digital Experience Platform 7.2 Compatibility Matrix“, https://web.liferay.com/documents/14/21598941/Liferay+DXP+7.2+Compatibility+Matri x/b6e0f064-db31-49b4-8317-a29d1d76abf7?, [accessed on 31.01.2020]

Page 58 of 112 TABLE 7: DXP CLOUD BY LIFERAY Standards and guidelines: Although Liferay DXP comes with out-of-the-box support for WCAG 2.0 Most of the items in standards (e.g. WCAG2.1 or Section 508) have to be implemented by the client due to the nature of custom UI design. Liferay provides the tools and support. Liferay products and implementation services use Bootstrap 4.0 for UI generation. It offers full WCAG compliance if correctly implemented. Implementation: To implement the solution users can contact a service provider, Liferay university or Liferay partners. The work involved to implement the solution depends on the number of templates/layout to display the content and the amount of content to migrate. Demonstration: A video can be found from YouTube55, and Liferay proposes to conduct a dedicated demo on a specific set of use-case(s).

Users Example of users: Liferay provides a horizontal platform for millions of users served by 2000 Liferay's clients at local, regional, country, and EU levels. Liferay is strong in many sectors, such as government, finance and insurance. Clients include the Publication Office and other EU institutions, as well as NASA, ESA, and the Ministry of Foreign Affairs in multiple countries. Provider Name of the provider: Liferay Description of the provider: The main business of Liferay is to provide a platform on which clients can create exceptional client experiences. Liferay feels it is important that any user of the sites built on Liferay should have an exceptional experience. Liferay is a socially engaged company that endeavours to support others to reach their full potential. Liferay was established in 2000 and incorporated in 2004. It has had an office in Europe since 2010 and a presence in the Benelux countries since 2012. Size of the company: Liferay has almost 1,000 employees and the Liferay community has millions of members. Geographic coverage: The organisation’s geographic coverage is global.

55 Liferay, “Liferay Digital Experience Platform“ https://www.youtube.com/watch?v=HOdbzGCI5ME, [accessed on 31.01.2020]

Page 59 of 112 4.3.4.OP Templates by OP

TABLE 8: OP TEMPLATES BY OP

General description Name of the solution: OP Templates Description of the solution: OP Templates is a Word Plugin that helps to write structured manuscripts for accessible publications. OP Template may use EUROLOOK 10 software as the main platform. EUROLOOK 10 is owned by DIGIT and developed by a private company. It provides templates but also other features that are not available in MS Word. Price: The solution should be free for EUROLOOK users in the Commission and for users of the stand-alone version in other institutions and agencies. The tool is not public because it is not possible to provide a support service to private users. However, author services may decide whether or not to share it with external contractors and provide them with support. Languages: The languages used are the same as in MS Word. Alphabets: The alphabets used are the same as in MS Word. Environment: The plugin works on Windows 10 and Word 2016 and higher. It has not been tested on previous versions of Word. Features: The main features are:

• Style organiser (to apply or create styles easily). • Special “bricks” to insert pictures and graphs with necessary elements for accessibility (alternate text) and many other elements e.g., lists, tables, cross-references, boxes etc. • Easy highlighting (by applied formatting, language, list of words). • Change of the document language in the text and styles. • Predefined and straightforward customisable clean-up rules. • Automatic compare function to verify the clean-up results. • List the hyperlinks in the file. • File information report.

Standards and guidelines: The tool is not based on an accessibility standard. However, it helps authors to create structured manuscripts containing elements for accessibility. It helps to insert a set of elements with a single click (e.g., image with placeholders for title, alternative text, and caption text). Implementation: The implementation of the plugin is easy. It only requires administrator rights. Demonstration: A screenshot of EUROLOOK 10 with OP Templates module (draft version)

Page 60 of 112 TABLE 8: OP TEMPLATES BY OP

Users Example of users: The users of the solutions are authors from EU institutions that create content. The tool is not used to provide ready-to-print files, but it focuses on creating structured content containing elements for accessibility. These elements are then used by layout experts to create printable files. Provider Name of the provider: OP for the OP Templates Description of the provider: The Publications Office of the European Union, which was founded in 1969, is an interinstitutional office whose task is to publish the publications of the institutions of the European Union. Size of the company: OP has around 500 employees. The EC has around 32,000 employees including OP and other DGs. Geographic coverage: European Union.

4.3.5. Accessibility solution by Siteimprove

TABLE 9: ACCESSIBILITY SOLUTION BY SITEIMPROVE

General description Name of the solution: Siteimprove accessibility Description of the solution: Siteimprove provides users with an easy-to-use platform for website optimisation. One part of the broader platform is Siteimprove Accessibility, which helps users discover and prioritise issues. It takes control of WCAG 2.1 barriers which prevent people from accessing content on the web, and provides users with guidance and practical recommendations on how to address issues. In addition to the platform, Siteimprove also provides manual testing services and educational resources that help to reduce compliance risks. Besides accessibility, the platform offers content quality, SEO, Google Ads, Analytics, website performance, and Data Privacy solutions. The solution is not open source, but Siteimprove is in the

Page 61 of 112 TABLE 9: ACCESSIBILITY SOLUTION BY SITEIMPROVE process of moving to a new accessibility-checking engine (Alfa) which will be partially open source: https://github.com/Siteimprove/alfa. Price: Pricing is available on request and depends on the modules of the platform that users want to purchase. Siteimprove Accessibility is licensed by number of pages, and includes unlimited users and simple on-boarding training for small teams. Languages: The Siteimprove platform supports the following languages: English, Swedish, German, Norwegian Bokmål, French, Spanish, Italian, Dutch, Portuguese, Finnish, and Japanese. It does not have any known language limitations with regard to accessibility testing. Any language dependent checks are verified by the users. Alphabets: The Siteimprove platform supports Latin, Greek and Cyrillic alphabets, but is not able to support symbol alphabets. Environment: Siteimprove’s Accessibility solution is cloud-based. It scans and tests public websites, intranets, and PDFs. Features: Features include:

• WCAG 2.1 accessibility testing of websites and PDFs. • Easy task coordination and resource allocation (difficulty ratings). • Guiding individuals of all skill-sets to carry out accessibility testing (potential issues, guided testing). • Supporting users in understanding what matters most to their visitors (analytics/issue coverage metrics). • Ensuring maximum remediation impact with the least effort (page sections, focus on most exposed/at risk content). • Remediation support (pass and fail examples for failing content). • Peer-reviewed, fully documented and transparent checks (W3C ACT accessibility checks). • Harmonisation of accessibility testing standards (ACT format). Standards and guidelines: Siteimprove follows WCAG 2.1 and Accessibility Conformance Testing (ACT) Rules Format for both websites and PDFs. Implementation: Siteimprove Accessibility is a hosted plug and play service. The Siteimprove platform automatically crawls user websites once an account has been created. The solution then breaks down accessibility issues that are discovered as part of the crawl into prioritised, manageable tasks, providing guidance and practical recommendations along the way. This makes it straightforward even for non-experts to start working towards making their websites accessible. Additionally, Siteimprove Client Success Managers will support new users through the implementation and on-boarding phase.

Page 62 of 112 TABLE 9: ACCESSIBILITY SOLUTION BY SITEIMPROVE Demonstration: Why Accessibility Matters56 Users Example of users: Siteimprove has approximately 70,000 users in both the public and private sectors. Many users have roles with web managerial or editorial responsibilities. They tend to be part of web, communications or marketing teams. Siteimprove has a very strong foundation in the public sector with a lot of government organisations and educational institutions amongst its clients. Provider Name of the provider: Siteimprove Description of the provider: Siteimprove was founded in 2003. It offers the world’s most comprehensive digital optimisation platform, providing its clients with actionable insights to improve their visitors’ digital experience. It supports organisations in driving digital accessibility, improving content quality, understanding and improving their visitors’ journey and optimising their digital marketing activities. Siteimprove empowers its clients to focus on initiatives that drive the biggest impact on their visitors’ digital experience. Siteimprove’s solution has been developed with accessibility in mind, and the majority of all features are accessible. Siteimprove is continuously optimising what it does and how it does it, and is committed to creating intuitive, barrier-free products that everybody can use, regardless of their abilities. Siteimprove partners with the European Commission, the W3C, and the European Disability Forum to improve digital accessibility. Siteimprove also provides manual testing services, and more generally educational content on accessibility such as the “All-in- One Accessibility Handbook57”, and digital academy courses to help train teams on accessibility and other subject matters. It also provides the free Siteimprove Chrome Extension which is used to test a single instance (page). Size of the company: Site improve has 575 employees. Geographic coverage: Siteimprove covers North America, Europe, Australia/New Zealand, and Japan.

56 Siteimprove Inc, “Why Accessibility Matters” https://vimeo.com/279619945, [accessed on 31.01.2020]

57 Siteimprove, “The All-in-One Digital Accessibility E-Book”, https://go.siteimprove.com/digital-accessibility-ebook, [accessed on 31.01.2020]

Page 63 of 112 4.3.6.AbleDocs

TABLE 10: ABLEDOCS

General description Name of the solution: AbleDocs Description of the solution: Depending on the document type, AbleDocs applies one of the following six solutions: • ADService is an on-demand remediation service that returns accessible and fully compliant documents. • ADGateway allows clients to transmit content directly into their proprietary production environment with embedded accessibility testing tools. • ADStream is a high-volume/high availability scaled solution for fully automated remediation of transactional documents, such as statements and standard types of content. • ADScan is a website crawling tool that tests files under PDF/UA standard. It helps to understand which documents are compliant and helps to design a document accessibility strategy. • ADLegacy is for old content that remains on websites. It provides on-demand 24 hours turnaround to every PDF. • ADForms provides forms services and solutions supporting AcroForm, XFA-LiveCycle, AEM, and HTML type. Price: The cost depends on the volume, the complexity of the files and the strategy. The price can range from 0.004 cents per page to €5 per page. AbleDocs recommends assessing the operating environment, the client capabilities and the file types to find the right solution for a cost sustainable document accessibility strategy. Languages: Today, 38 languages are supported by the solutions. The gateway interface is in English, French, Danish, Spanish or German. It is easy for AbleDocs to add new languages. Alphabets: All alphabets can be supported, even Cyrillic, Farsi and Asian character derived languages. Environment: ADGateway is accessible via any browser. ADStream can be installed on Windows, Linux, Unix, web based or on-premises. Features: Everything produced by AbleDocs is PDF/UA compliant. Some documents can be fully automated when the layout and the structure are similar (e.g., legal documents). Standards and guidelines: AbleDocs complies with PDF/UA, which does not conflict with WCAG2.1 AA. ADScan checks every component of PDF/UA as well as colour contrast (which is not part of PDF/UA) but will not modify the layout. Implementation: ADStream requires 2 weeks of on-boarding to configure the files and processing environment to be accessed. Other AbleDocs solutions are implementable on a same day basis. Demonstration: Users Example of users: AbleDocs has around 2,200 clients at every level of government in Canada, US, UK, Denmark, Switzerland, Germany, France, and Australia. Clients include, for example, governments,

Page 64 of 112 TABLE 10: ABLEDOCS multinational public companies, private companies, single graphic designers, freelancers, or suppliers for the blind. Provider Name of the provider: AbleDocs Description of the provider: AbleDocs has leading experts in PDF accessibility around the world. It was founded in 2019 with the merger of four accessibility companies. Size of the company: AbleDocs has around 130 employees. Geographic coverage: AbleDocs operates globally. It has four US offices and four EU offices.

4.3.7.Accessibil-IT

TABLE 11: ACCESSIBIL-IT

General description Name of the solution: Accessibil-IT Description of the solution: Accessibil-IT does not provide automated solutions. It provides services. Automated solutions available on the market target documents with low-to-moderate complexity, while Accessibil-IT provides full accessible and compliant PDF documents from simple to high complexity. Conforming to WCAG is really important but it does not guarantee that documents are usable through adaptive technologies. Manual checking is mandatory. Accessibil-IT tests the compatibility of documents with assistive technologies, such as popular screen readers, to check if they read out thoroughly and in the right order for example. Accessibil-IT offers accessibility strategies to help clients to create accessible documents by establishing a roadmap, identifying the most relevant documents to make accessible first and where in the process the accessibility should be addressed. Price: The price to make a PDF document accessible depends on the length and complexity of the document. The average price is as follows: • Basic complexity, around 5 dollars per page. • Medium complexity, between 7 and 10 dollars per page. • Complex document, from 10 dollars to 20 dollars per page. • Fillable forms from 50 to 125 dollars per page. The complexity is evaluated based on the need of extensive navigation, type of table, maps, complicated graphics, formulas, and forms. Languages: Accessibil-IT makes PDF accessible in all languages with the occasional help of translation partners. Accessibil-IT made the Canadian Charter of Rights documents accessible in 37 different languages. Alphabets: Documents in Greek and Cyrillic alphabets can also be made

Page 65 of 112 TABLE 11: ACCESSIBIL-IT accessible Environment: Accessibil-IT works mainly with PDFs since that is the most popular format posted online. Features: Accessibil-IT provides everything that is required for accessible documents. First, it tags documents to make them accessible. Then it checks: • The compliance with WCAG and PDF/UA ISO standards manually with automated tools. • The compatibility with assistive technologies. Standards and guidelines: Accessibil-IT makes documents compliant with WCAG and PDF/UA ISO standards. Implementation: Having a full accessible document requires knowledge, expertise, manual work (e.g., for complex graphics), and manual checks with assistive technologies. Legacy documents are the most difficult owing to the high volume and age of the documents. Legacy documents take time. The accessibility needs planning with a combination of approaches to be more efficient and faster, depending on the number of documents, the internal skill set of clients, and the age of the documents. On average, Accessibil-IT needs two business days to make a 50-page PDF document accessible. Demonstration: The demonstration provided by Accessibil-IT during the interview showed that: • The layout is not changed. • Tags are added to headings. • Alternative text is added to pictures so that it is not redundant with the content. • Tags are added to tables so that assistive technologies know exactly in which line and column it is. Users Example of users: Accessibil-IT has a several hundred clients. The clients are mostly large organisations, and most are large companies or governments. Clients include North American governments, financial institutions, educational institutions, private companies, consulting firms, and suppliers for these organisations. Users include Deloitte, Government of Canada, US Federal Government, Target, Drexel University, Bank of Montreal, The Canada Life Assurance Company, Navy Federal Credit Union, Princess Cruises, Mercer Consulting Firm, and Canadian National Institute for the Blind. Provider Name of the provider: Accessibil-IT Inc. Description of the provider: Accessibil-IT Inc. provides expertise in making documents accessible including PDF documents. The company is passionate about achieving full accessibility compliance and compatibility with assistive technologies of PDF documents. Accessibil-IT Inc. is a member of the PDF Association and participates on the ISO 14289 (PDF/UA) Committee. It continuously tests new technology to be sure the best tools available are used. It was founded in 2009. Size of the company: The company has 18 employees. Geographic coverage: Primary clients are in North America, some in Europe, and in other areas of the world as well.

Page 66 of 112 4.3.8. Acrobat DC by Adobe

TABLE 12: ACROBAT DC BY ADOBE

General description Name of the solution: Acrobat DC Description of the Acrobat DC is a solution for making PDF documents and forms solution: compliant with WCAG standard. It is used to create, convert, share, sign, protect and edit the smartest PDFs on both desktop and mobile devices, utilising cloud-based services. Acrobat DC comes with 100GB of storage to store, share, and access files online. Price: The solution is not open source. Acrobat DC is available on subscription, details available here https://acrobat.adobe.com/us/en/acrobat/pricing.html?promoid=TTGW L7MX&mv=other Acrobat Reader is free. Languages: A list of available languages is available here: https://helpx.adobe.com/be_en/acrobat/kb/DC-Language-Tiers.html Alphabets: Acrobat is used to view, search, and print PDF documents that contain many languages. See e.g. https://helpx.adobe.com/acrobat/using/asian-cyrillic-right-to-left.html Environment: Acrobat DC is supported on desktop and mobile using most of the operating systems. Features: Acrobat pro DC provides many features to make content accessible. For example, there are tools that: • Have different functionalities to tag, and fix those tags within the document, most of the work is done manually to allow users to adjust the tag. • Auto-generate the form fields to make easier the creation of accessible forms. • Organise pages. • Run OCR and tag PDF (Adobe Scan). Standards and The solution is based on WCAG 2.1 A & AA and EN 301 549 standards. guidelines: Implementation: The accessibility features from Acrobat are easy to implement. It does require specific training and knowledge to create accessible PDFs. Web seminars and help documentation are available online to gain knowledge. Demonstration: Adobe is happy to provide a demonstration to anyone anywhere at any time. It provides also a two-day training course on “how to teach accessibility to create accessible PDFs”.

Page 67 of 112 TABLE 12: ACROBAT DC BY ADOBE

Users Example of users: More than five million organisations around the world rely on Acrobat DC. Acrobat DC is used by almost everyone. Its clients are in the public sector, educational institutions, companies, and also independent remediation houses. Almost the entire Fortune 500 companies are users of Acrobat DC. Users include the European Commission, governments in the US and many countries in Europe. Provider Name of the provider: Adobe Description of the Founded in 1982, Adobe gives everyone — from emerging artists to provider: global brands — everything they need to design and deliver exceptional digital experiences. It provides the software and services to create, manage, mobilise, and measure any kind of digital content, and the analytics tools to understand how that content is being consumed. Adobe has three cloud-based businesses: • Creative Cloud, which is a subscription suite of tools for creating digital content. • Experience Cloud which is a digital marketing platform, to mobilise and measure the digital content. • Document Cloud, which is the digital document business that helps organisations drive business faster by making paper- based processes 100% digital. Size of the company: Adobe has around 20,000 employees. Geographic coverage: Adobe products are used worldwide.

4.3.9.Equidox by Onix

TABLE 13: EQUIDOX BY ONIX

General description Name of the solution: Equidox

Page 68 of 112 TABLE 13: EQUIDOX BY ONIX Description of the solution: Equidox is a semi-automated document conversion software tool. It works on any computer with internet connection. Everything is centralised in one hub, making documents easy to share and improving collaboration. As remediation is a new concept, Onix provides supports, training, end-users guides and information notes to help users with the solution. Equidox also provides remediation services for its clients. Documents are remediated to be fully ADA (Americans with Disabilities Act) compliant and 100% usable. Price: Equidox is not open source. The driver is the total number of users connected to the solution at the same time. Annual price examples are as follows: • For one person, the price is around $2,000. • For ten people, the price is around $12,000. • For big organisations with unlimited users, the price is around $30,000. Languages: The main language is English although Onix can readily create multiple languages for the interface. Equidox supports the production of accessible HTML and PDF in 240 languages. Alphabets: The main alphabet for the interface is the Latin alphabet. More alphabets are available on request. Normally all alphabets should be accepted by the solution. Environment: The solution is browser-based and works on Google Chrome and Safari. An internet connection is needed. Features: The features proposed by the solution are: • Read existing tags from the uploaded PDF. • Add tags (headings, tables, list) to text zone. • Change the sensitivity of a text zone, if user is not satisfied with how the data are structured. • Give alternative text to images from a single interface. • Preview mode, allowing for feedback from the HTML preview. • Heading templates, a time-saving feature when 200- page documents need to be made accessible. • Hide zone for non-relevant elements. • Reading order can be set automatically or manually. • Page notes. • Possibility to scroll a website to check for all URL with link to a PDF and upload them automatically into Equidox. Standards and guidelines: Equidox imports inaccessible PDFs, and exports WCAG 2.0 compliant PDF, Epub 2.0 or HTML files. In addition, many documents can be remediated successfully to meet PDF/UA standards. The user interface is under iterative development with features being updated to comply with ATAG (authoring tool accessibility guidelines). Implementation: As a web-based solution, Equidox can be accessed by users from any computer with internet access. It takes around 60 seconds on average to make one page accessible. Demonstration: During the full demonstration of Equidox, the Onix team presented the abovementioned features and the different settings such as: • Upload PDF documents (possibility from URL). • Documents are processed to recognise tags and text zones or to be OCR. • Possibility to export in accessible PDF, EPUB, and HTML. • Add users in different groups.

Page 69 of 112 TABLE 13: EQUIDOX BY ONIX Users Example of users: Equidox is used by a wide spectrum of organisations that need to meet section 508, EN 301 549 or WCAG accessibility standards; Equidox is used by government agencies, higher education institutions, corporations, and non-profit bodies around the world. Clients include California Dept. of Health, Orange County Government, California Community College System (114 campuses), Rick Hanson Foundation, MIT, Cornell University, Pella Windows, and many more. Provider Name of the provider: Onix Description of the provider: Onix delivers world-class solutions to organisations around the globe. It increases organisational efficiency through cloud computing solutions. Onix offers accessibility services that include website testing, auditing, report writing, VPAT completion. It was founded in 1992. Size of the company: Onix has 275 employees. Geographic coverage: The geographic coverage of Onix is global.

4.3.10. WordToEpub by DAISY

TABLE 14: WORDTOEPUB BY DAISY

General description Name of the solution: WordToEpub Description of the solution: The WordToEPUB tool provides a simple but powerful method of creating EPUB files from Microsoft Word documents. Created by the DAISY Consortium, careful attention has been paid to accessibility and compliance with current standards and best practice guidelines. The eBooks created with this tool can be used in reading apps on any platform. They are suitable for all readers, but persons with print disabilities will appreciate the ability to personalise visual features such as colours, font, text size and layout, and excellent compatibility with screen readers and other assistive technology. Price: WordToEPUB is free to download and use. There are no license restrictions on distribution of the tool or of the converted materials. The solution is currently not open source. Languages: The available languages for the interface are English, French, Spanish, Portuguese, and Dutch. Italian and German translations are in hand. The tool supports 122 languages. Alphabets: Translations use only Latin script. Scripts known to work are: - Latin (e.g. European languages). - Arabic (e.g. Arabic, Persian, Urdu). - Cyrillic (e.g. Belarusian, Bulgarian, Macedonian, Russian). - Greek and Devanagari (e.g. Nepali, Hindi, Sanskrit, and Marathi). Environment: Currently, the solution can be used on MS Windows 32 or 64 bit and Windows 7 upwards. The tool supports .docx extensions.

Page 70 of 112 TABLE 14: WORDTOEPUB BY DAISY Features: The interface of the tool is accessible. The tool generates digital publications with a focus on accessibility. For example, structural and semantic mark-up for ease of navigation, page level markup, image descriptions, navigable tables, and accessibility metadata. Standards and guidelines: The tool is based on the latest W3C specifications for EPUB and EPUB Accessibility. Implementation: The tool is designed to be simple to use for someone with a low level of IT skills. A button is placed on the ribbon of Word, and a file can be created in two clicks. The advanced features are only presented to users if they select them. Demonstration: Users Example of users: The solution is the most used by organisations with a focus on creating accessible digital documents. Users include US universities producing accessible materials for students with reading disabilities; Canadian network of school resource centres producing books for young people with reading disabilities; non- profit organisations in Ethiopia, Botswana, Burkina Faso, Algeria, Argentina, Columbia, India, Nepal, and Sri Lanka converting books for blind persons; the government of New Zealand creating accessible documents from Word. Provider Name of the provider: DAISY consortium Description of the provider: DAISY was founded in 1996. DAISY is a non-profit membership association operating under the Civil Code of Switzerland. Its mission is to develop global solutions for accessible publishing and reading, in partnership with civil society, publishing and technology industries, standards bodies and governments. Its vision is that people have equal access to information and knowledge regardless of disability; a right confirmed by the UN Convention on the Rights of Persons with Disabilities. Size of the company: DAISY has 15 staff in Canada, US, UK, France, Belgium, India, and Kenya. Geographic coverage: The association has over 170 member organisations (without counting the sub-organisations) from 84 countries.

4.3.11. FACIL’iti

TABLE 15: FACIL’ITI

General description Name of the solution: FACIL'iti Description of the solution: FACIL'iti is a web plugin that modifies the text (of client websites) to the user’s customised preferences in terms of text size, font selection, letter groups (highlights these), space between letters, words, and lines. This solution is not open source.

Page 71 of 112 TABLE 15: FACIL’ITI Price: The price is based on a monthly subscription fee according to website traffic, ranging from €350 to €900. A discount is available where access to several websites is required. Languages: FACIL’iti supports content in many languages, notably Cyrillic and Greek. However, the FACIL’iti interface is available in English, Spanish, French, German, Italian, Japanese, Russian, and Dutch. Alphabets Latin, Cyrillic, Greek, and Kana alphabets are supported by the tool. The interface is available in Latin, Cyrillic, and Kana alphabets. Environment: The solution is implemented on the server side (license) Features: • FACIL’iti does not work like a traditional zoom because it can result in obstructed text and field; instead, the changes occur on the CSS file layer. • FACIL’iti uses open source fonts that do not require a license. • Text-tospeech is not part of FACIL’iti’s features. However, the tool allows access to the alternative text for OCR tools. • FACIL’iti works by leveraging the use of TAGS. FACIL’iti covers everything in the HTML file. • Flash content will not work with FACIL’iti. Standards and guidelines: FACIL’iti focuses on the user side of WACG guidelines, providing a service that addresses several disabilities, in particular visual (such as colour blindness), movement (such as Parkinson’s disease), and cognitive (such as dyslexia) disabilities. It focuses on user needs and not on regulations in place. Therefore the use of FACIL’iti does not make a website fully compliant with regulations. FACIL’iti has co-developed its solution with relevant associations for each pathology and worked with thousands of users, testing and refining their product. Implementation: FACIL’iti’s integration level depends on the website’s accessibility/WCAG compliance. FACIL’iti does not provide accessibility services for improving a website’s code. FACIL’iti is easy and fast to setup; the process takes about 10 minutes. Demonstration: https://www.facil-iti.com/ https://youtu.be/BrbhjQPEfAw Users Example of users: Hundreds of entities use FACIL'iti including New York City, Tokyo, Kyoto, and Yokahama, as well as MPOD, Paris Tourist Office, TF1, and Total. The number of FACIL’iti users is close to 500,000. Provider Name of the provider: FACIL'iti Description of the provider: FACIL’iti has been on the market for two years with ongoing development. The current roadmap for FACIL’iti development focuses on delivering services aimed at different disabilities, including Alzheimer’s disease. According to FACIL’iti, over 90% of users interviewed find the tool to be useful to some extent. Size of the company: FACIL’iti has 16 employees in France and five in Japan. Geographic coverage: France, Japan, United States, Canada, amongst others.

Page 72 of 112 4.4. Summary of solutions This section summarises the key findings drawn from the long list of solutions and from the analysis described in detail in section 4.1.2 of the report.

4.4.1.Key findings The key findings refer to 1) Easier-to-find end-user solutions, 2) Free solutions, 3) Standards, and 4) Universal and inclusive design.

KF1) Easier-to-find end-user solutions

An analysis of the long list of solutions shows that it is easier to find solutions for end-users than for authors, contributors, webmasters or publishers. This is in line with the feedback from the associations and their advice to the institutions to focus on the environment.

KF2) Free solutions

61% of the solutions on the long list are free and 29% are open source. This shows that there are a large number of communities, and not just profit-making companies, working on accessibility solutions. Sharing solutions to help people with disabilities and raise awareness is one of the goals of the non-profit consortia, communities and people sharing free solutions.

Large companies usually develop free accessibility features around paying tools. This naturally increases their client base.

KF3) Standards

Digital accessibility standards such as WCAG and EN 301 549 are available. A public sector accessibility directive has been established based on these standards. These standards are also used by evaluation solutions to check the level of accessibility of websites and documents. Standardisation helps to create an accessible environment to enhance the use of tools for end-users.

KF4) No fully automated solution to remediate all types of existing PDF exists as yet

Interviews with editors of solutions show that fully automated solutions for the remediation of existing PDF do not as yet exist. The technology is not advanced enough to enable full compliance with PDF/UA and WCAG standards or to provide alternative text for images.

Page 73 of 112 5. Section IV: Mapping This section links the assessment of solutions, publications/websites and target user groups in a comprehensive manner with a view to describing the way in which the accessibility of the websites and documents of European institutions can be improved. This section is structured as follows:

• Links between the type of solutions and the content. • Links between the type of solutions and the end-user groups. • Links between the shortlisted solutions and the content. • Links between the shortlisted solutions and the end-user groups.

As a reminder, the end-user groups based on the classification of needs previously defined in Section I: User groups are: • Tailored text: bigger fonts, different fonts, word spacing, line spacing, colour contrast, colour backgrounds, and syllables highlight. • Audio needs: listen to the text, navigate the text with sections. • Search needs: speak to the text, navigate the text with sections. • Image comprehension needs: description of an image. • Additional time needed: more time needed to complete a document/online form.

The content is classified as follows:

• New content, to be produced in any of the formats mentioned below. • Paper-based content. • Accessible PDF, where the PDF is fully accessible with headings. • OCR PDF, where the characters of the PDF can be read using assistive technology, but where the headings are not defined. • Image PDF, where the PDF is an image and assistive technology cannot read it. • EPUB. • Word. • Other document content (e.g. Excel, jpeg). • HTML5. • HTML (excl. 5). • Other web content (e.g. JavaScript, flash).

It is important to note that, with the exception of the first category, other content typologies are considered as existing content. Paper-based and PDF content cannot be modified; new documents need to be created to become accessible.

5.1. Links between the type of solutions and the content

FIGURE 12 shows the links between the type of solutions and the content. A check sign indicates that a solution could apply to the checked content if correctly implemented. The tilde sign indicates that a solution does not natively apply to the tilde content, but could be implemented with the aid of plug-in.

This figure shows that:

• Guidelines apply only to non-existing content; in fact, it is usually too late to apply guidelines to existing content and, in this case, other solutions are used to improve accessibility.

Page 74 of 112 • The difference between accessible, OCR, and image PDF has an impact on the end-user solutions that can be used; in fact, not all end-user tools can be applied on an image PDF while fonts and speech tools can be applied on OCR PDF, and Navigation agent also on accessible PDF. • HTML5 is more accessible than HTML. • Other document and web formats are usually less accessible and not yet within the scope of accessibility. • EPUB and HTML5 are the most accessible content for end-user tools.

FIGURE 12: LINK BETWEEN THE TYPE OF SOLUTIONS AND THE CONTENT

✓ indicates that a solution could apply on the checked content if correctly implemented. ~ indicates that a solution does not natively apply with the tilde content but it could be with the aid of plug-in

Type of solutions

Environment Tools

Authors/contributors Publishers/webmasters End Users

Navigation Guidelines Editing Evaluation Formats Fonts Speech Image Paper based agent

New content ✓ ✓

Paper ✓

Accessible PDF ✓ ✓ ✓ ✓ ✓

OCR PDF ✓ ✓ ✓ ✓

Image PDF ✓ ✓

EPUB ✓ ✓ ✓ ✓ ✓ ✓ ✓ Content Word ✓ ✓ ✓

Other document ✓ ~ formats

HTML5 ✓ ✓ ✓ ✓ ✓

HTML ~ ~ ✓ ✓ ~

Other web ~ ~ ~ ✓ formats

5.4. Links between the shortlisted solutions and the end-user groups

FIGURE 15 shows the links between the shortlisted solutions and the end-user groups. The check sign indicates that the shortlisted solution targets the checked user groups.

Page 76 of 112 FIGURE 15: LINK BETWEEN THE SHORTLISTED SOLUTIONS AND THE END-USER GROUPS

Short listed solutions

Guidelines Editing Evaluation Formats Fonts

OP OP Drupal Liferay Siteimprove AbleDocs Accessibil-IT Acrobat DC Equidox WordToEpub FACIL’iti guidelines Templates

Tailored text ✓ ✓ ✓ ✓ ✓ ✓ ✓ ✓ ✓ ✓ ✓

Audio needs ✓ ✓ ✓ ✓ ✓ ✓ ✓ ✓ ✓ ✓

Search needs ✓ ✓ ✓ ✓ ✓ ✓ ✓ ✓ ✓ ✓

needs Image comprehension ✓ ✓ ✓ ✓ ✓ ✓ ✓ ✓ ✓ ✓ needs

End user groups based End useron groups based Additional time ✓ ✓ ✓ needed

FIGURE 15 shows that the shortlisted solutions target the same end-user groups as the type of solutions, except for those that focus on documents/publications, which do not address additional time needed. In the context of EU institutions, time constraint is more specific to web content such as online forms. This is why these solutions do not need to address the additional time needed aspect.

5.5. Summary of the mapping This section summarises the key findings of the mapping.

5.5.1. Key findings The key findings refer to 1) the most accessible content for end-user tools, 2) the least accessible content for end-users tools, and 3) paper and other content typologies.

KF2) The most accessible content for end-user tools

The most accessible content for documents is the EPUB format while the HTML5 format is the most accessible for web content.

KF1) The least accessible content for end-users tools

End-user tools, such as screen readers or font solutions, cannot access image pdf, Word and other documents and web content.

KF3) Paper and other content typologies

Based on desk research and on the interviews carried out, it is difficult to find environment solutions that improve paper-based and other documents and web content.

Page 77 of 112 6. Section V: Guidelines and roadmap This section presents the proposed roadmap and guidelines for establishing a ”reading disorder-friendly” environment for EU institutions. It includes a work plan identifying the “low hanging fruits” to be exploited and a roadmap with milestones. This section is structured as follows:

• Introduction to the proposed roadmap. • More detailed description of each phase of the proposed roadmap. • Guidelines.

6.1. Introduction to the proposed roadmap

FIGURE 16 presents the common and iterative proposed roadmap to improve accessibility content in European institutions. It contains three phases, to be implemented independently by each institution, following a phase-by-phase approach:

• Phase 01: evaluation. • Phase 02: prioritisation. • Phase 03: implementation.

The roadmap includes an ongoing synergy phase in parallel to these three phases. This phase is cross-cutting and applies to all institutions.

Upon completion of the development of the solution at the end of the implementation phase, the process starts again from the evaluation phase. The level of accessibility can be continuously improved with a view to reaching the highest level in the light of current standards and being ready for the new versions of standards. In addition, it is difficult to resolve several issues at once. Multiple iterations focusing on different issues are generally needed, with each iteration taking approximately one year, as shown in FIGURE 18.

FIGURE 17 illustrates the three roadmap phases. The evaluation phase has three steps. The first step corresponds to the analysis of the content with the results of the analysis displayed as a table (cf. section 6.2.1). The second step corresponds to the creation of the subset based on six guidelines (cf. section 6.2.2). The third step corresponds to the evaluation of the subset based on standards where the results are presented in table form (cf. section 6.2.3). The prioritisation phase has two steps. The first step is the generation of potential solutions and the calculation of the estimated cost and the gain in accessibility in order to place the solutions in the quadrant (cf. section 6.3.1). The second step is the list of the selected and prioritised solutions to be implemented in the last phase (cf. section 6.3.2). The implementation phase is the implementation of the selected solutions.

Page 78 of 112 FIGURE 16: ROADMAP TO IMPROVE RDDA IN EUROPEAN INSTITUTIONS

1. EVALUATION 2. PRIORITISATION 3. IMPLEMENTATION

• Objective Assess a sample of the content against WCAG criteria • List the primary solutions to implement • Implement the solutions

• List the type of content produced by the institution • List the non conformed criteria • Mobilize the resources

• Collect statistic (number of visits) for each content • Collect the information about the • Implement the solutions number of produced documents • Categorise the content based on its type, format, date of publication, that does not meet WCAG criteria authors/sources, targeting audience and number of visits • Generate ideas for potential solutions

Create a subset of content • Refer to the synergy phase, this Activities • report, association consultation • Mobilize resources (people and tools) • Calculate the cost • Assess the subset based on the latest version of WCAG standard • Calculate the gain in accessibility • Place the solution on the quadrant graph

• Retrieve the priority solutions • Content analysis • Quadrant graph of solutions • Implementation of the solution • Subset of content • List of priority solutions • Documentation about the solution Deliverables • Conformance level of the subset FOR EACH INSTITUTION EACH FOR based on WCAG criteria

In parallel of other phases SYNERGY

• Level 0: sharing entity • Level 1: controlling entity Objective – Govern accessibility within European institutions – Assess a sample of the content against WCAG criteria of each institution • Share knowledge, solutions and good practices • Create an entity responsible for the validation • Create a database of accessible projects within • Assess institutions content based on the latest version of WCAG standard institutions with person contacts Activities • Provide a label • Organise meetings, workshops and promote accessibility within institutions • Meet with associations • Presentations and minutes of workshops and meetings • Au dit Deliverables • Database of accessible project • Label FOR ALL INSTITUTIONS ALL FOR • Directory of people with accessible experience

Page 79 of 112 FIGURE 17: ILLUSTRATION OF THE ROADMAP

Page 80 of 112 FIGURE 18 shows that phase 01, evaluation, should last approximately three months. The second phase, prioritisation, should last approximately one month and the last phase, implementation, should last 8 months.

FIGURE 18: PLANNING AND MILESTONES

The proposed roadmap presented in FIGURE 16 is common and high-level across all institutions. Each institution may be at any one stage or another of the roadmap. For example, some of the institutions may not have started working on accessibility yet. In this case, these institutions are at the beginning of the evaluation phase. Other institutions may have already evaluated the accessibility of the website but have not started to prioritise the solutions; in this case, the institutions are in the prioritisation phase. Finally, some institutions have already evaluated, prioritised and implemented solutions to improve content accessibility. In this case, these institutions are in the evaluation phase of the second iteration of the roadmap. During this second iteration, the evaluation phase assesses the accessibility level of the first implementation. Depending on the results, the institution will continue focusing on the same issues or will work on others.

6.2. Evaluation phase The evaluation phase allows institutions to assess the accessibility level of their content. As the content involves a huge volume of documents, web pages and others, the evaluation is based only on a representative subset.

This subsection proposes a methodology for selecting a representative subset of content to assess. This subsection is structured as follows:

• Content analysis. • Subset creation. • Subset evaluation.

At the end of this phase, institutions will have determined which criteria of the WCAG standard can be enhanced for each content of the subset.

6.2.1. Content analysis In order to create a representative subset, the content needs to be analysed and statistics collected. TABLE 16 shows an example of how to analyse the content published

Page 81 of 112 by institutions. In this analysis, the content is not limited to only one document or one web page but involves multiple documents/publications (or web pages). The content is described with the following criteria:

• Identification: o Content ID. o Description and/or comments. • Technical criteria: o Type of content, such as news, events or legal publication. o Format, such as PDF, HTML or Form. o Targeting audience, such as general public, young or journalist. o Authors/sources, such as unit X, unit Y or external contractors. • Statistics: o Total number of pages/documents available online. o Average number of visits per year. o Estimated number of documents produced last year. o Estimated number of documents that will be produced next year.

Only one type of content, format, targeting audience and authors/source applies to one identified content. The table is MECE (Mutually Exclusive and Completely Exhaustive). For example, if one unit produces news in HTML and PDF for journalists, then two contents with two different identifiers need to be created, one for the HTML and one for the PDF. TABLE 16 is illustrative.

TABLE 16: SUGGESTED FRAMEWORK FOR CONTENT ANALYSIS

Identification Technical criteria Statistics Estimated Total Estimated number of number Average Authors number of content Type of Targeting of number ID Description Format / content that will content audience contents of visits sources produced be available per year last year produced online next year 01 PDF News News PDF Journalists DG 100 30 20 20 DG COMM COMM 02 HTML News News HTML Journalists DG 80 40 20 20 DG COMM COMM 03 PDF factsheets PDF General DG 90 50 20 20 factsheets public COMM SG 04 PDF factsheets PDF General SG 70 200 20 20 factsheets public SG 05 EU Descriptive HTML General DG 20 70 2 1 description public COMM

It is to be noted that the duration of the content analysis will be shorter from the second iteration as only new content will be integrated and updates on statistics will be needed.

6.2.2. Subset creation

Based on the content analysis of the previous steps and the guidelines presented in TABLE 17, a representative subset can be created. This subset is used for the content accessibility evaluation.

Note that the creation of this subset has some limitations such as:

• The statistics cover only two years (past year and next year), which does not represent the full content.

Page 82 of 112 • The subset should include the most visited content; however, this is skewed because if the content is not accessible then it is probably less visited.

These limitations could be mitigated by:

• Synergy. • Associations.

TABLE 17: PROPOSED GUIDELINES FOR SUBSET CREATION ID Guidelines G.1 The subset should have a good balance depending on the type of content, meaning that the percentage of content’s type should be representative of the estimated content. G.2 The subset should have a good balance between formats, meaning at least each format (if produced by the institution) should be evaluated and then the percentage of formats should be representative of the estimated content. G.3 The subset should have a good balance between recent and less recent content and representative of content expectations over the coming years. G.4 A large part of the subset should contain the most visited content. G.5 The subset should be representative of the website’s visitors (general public or specific audience). G.6 The subset should contain content produced by representative authors/sources.

6.2.3. Subset evaluation The evaluation of the subset has to be based on standards such as WCAG or EN 301 549. A universal approach is applied by covering more disabilities and including reading disability and document access.

As a reminder, WCAG 2.1, including guidelines on web content, electronic documents, and non-web software (such as native mobile apps), has been adopted by the European standard EN 301 549 that covers more than WCAG, with guidelines for non-web based information in mobile applications, documents, and hardware. The WCAG is based on criteria that are associated with one priority level:

• Level A: must be satisfied. • Level AA: should be satisfied. • Level AAA: may be satisfied.

Accessibility Conformance Testing (ACT) Rules Format 1.058 can be used by institutions to create rules for testing the conformance of web content with accessibility standards such as WCAG. It makes the iteration of the assessment more objective, transparent, and fully documented.

58 Shadi Abou-Zahra and Shawn Lawton Henry, “Accessibility Conformance Testing (ACT) Overview”, https://www.w3.org/WAI/standards-guidelines/act/, [accessed on 03.02.2020]

Page 83 of 112 The assessment has to be carried out using automated and manual solutions.

Automated tools usually cover around 15-20% (depending on the tool) of the WCAG standard. Manual testing is then essential to check full compliance with the standard.

TABLE 18 presents the proposed layout of the evaluation results. The conformance of each WCAG standard criterion is evaluated for each content of the subset (one sheet per content).

TABLE 18: PROPOSED LAYOUT OF THE EVALUATION’S FRAMEWORK Sheet number Content ID Description Estimated number of content produced last year Estimated number of content that will be produced next year Average number of visits Criteria Level Conformance Remarks 1.1.1 Non-text Content A Yes/No 1.2.1 Audio-only and Video-only (Prerecorded) A 1.2.2 Captions (Prerecorded) A 1.2.3 Audio Description or Media Alternative A (Prerecorded) 1.2.4 Captions (Live) AA …

The remainder of this section focuses on the gaps, meaning the non-compliant criteria.

Note that the content evaluation can be carried out by the institutions themselves or by external contractors.

6.3. Prioritisation phase The second phase, prioritisation, identifies which issues need to be prioritised. This subsection proposes a methodology to classify and prioritise solutions based on the non- compliant criteria of the WCAG standard. This subsection is structured as follows:

• Generation of potential solutions. • Prioritisation of the solutions.

At the end of this phase, the institutions have a list of prioritised solutions to implement.

FIGURE 19 presents the prioritisation phase process. Issues are identified at the end of the phase 1 evaluation. The first step of the prioritisation phase is to design solutions. These solutions may cover one or more identified issues. The second step of the prioritisation phase is to estimate the cost and the gain in accessibility for each designed solution. The third step is to prioritise solutions by placing them in the quadrant using the cost and the estimated gain in accessibility. Based on the budget and the position of the solutions in the quadrant, each institution can select solutions to implement in the last phase of the roadmap.

FIGURE 19: PRIORITISATION PHASE PROCESS

Page 84 of 112 6.3.1. Generation of potential solutions First, based on the evaluation results, a list of non-compliant criteria per content needs to be drawn up in order to generate ideas for potential solutions. The best way to generate potential solutions is to refer to:

• Resources available from synergies, materials, and people. • This report with suggestions of solutions. • Consultation of associations.

A list of potential solutions is established. For each solution on this list, the cost and the gain in accessibility are calculated. Two criteria are used to calculate the cost and four criteria are used to calculate the gain in accessibility as shown in TABLE 19.

TABLE 19: CRITERIA TO CALCULATE THE COST AND THE GAIN IN ACCESSIBILITY ID Criteria Points COST

C1 Estimated financial cost (including internal cost) -

GAIN IN ACCESSIBILITY

G1 Number of issues solved 25

G2 Number of issues prevented 25

G3 Sum of the visits of each impacted content 25

G4 Feedback from associations 25

The cost corresponds to the estimated cost in euros to implement the solution. The gain in accessibility is calculated on the basis of 100 points. When the points are allocated to each criterion, the gain in accessibility is calculated as follows: Gain in accessibility = 25 × G1 + 25 × G2 + 25 × G3 + 25 × G4

Page 85 of 112 6.3.1.1. C1 – Estimated financial cost Internal cost should be considered as financial costs. The estimated financial cost (including licenses fees, physical infrastructure to deploy, human resources, etc.) corresponds to the total estimated cost in euros.

6.3.1.2. G1 – Number of issues solved The number of issues solved per solution is calculated using the following formula: Number of issues solved = number of WCAG criteria solved × criteria level × number of contents produced in one year

Where,

• The number of WCAG criteria solved corresponds to the sum of non-compliant criteria that will be solved by implementing the solution; a criterion is counted only once even if it covers multiple contents. • The criteria level is equal to: 3 if at least one of the criteria solved is level A Criteria level = { 2 if at least one of the criteria solved is level AA 1 if at least one of the criteria solved is level AAA • The number of contents produced in one year corresponds to the sum of the estimated number of contents produced last year for each content from the subset where at least one non-compliant criterion will be solved (cf. TABLE 18).

When the number of issues solved is calculated per solution, G1 uses the following approach:

• 1 point is allocated to the solution with the highest number of issues solved. • Between 0 and 1 point is proportionally allocated to the other solutions based on the solution with the highest number of issues solved.

Points are allocated according to the following formula: number of issues solved by the solution G1 = highest number of issues solved

6.3.1.3. G2 – Number of issues prevented The number of issues prevented per solution is calculated using the following formula: Number of issues prevented = number of WCAG criteria prevented × criteria level × estimated number of contents produced in the next year

Where, • The number of WCAG criteria prevented corresponds to the sum of non- compliant criteria that will be solved by implementing the solution; a criterion is counted only once even if it covers multiple contents, • The criteria level is equal to: 3 if at least one of the criteria solved is level A Criteria level = { 2 if at least one of the criteria solved is level AA 1 if at least one of the criteria solved is level AAA

Page 86 of 112 • The estimated number of contents produced in the next year corresponds to the sum of the estimated number of content that will be produced next year for each content from the subset where at least one non-compliant criterion will be solved (cf. TABLE 18). When the number of issues prevented is calculated per solution, G2 follows the same approach as G1. The solution with the highest number of issues prevented is allocated 1 point and the others are allocated a score proportional to the number of issues prevented based on the following formula: number of issues prevented by the solution G2 = highest number of issues prevented

6.3.1.4. G3 – Sum of the visits of each impacted content The sum of the visits corresponds to the sum of the average number of visits of each content from the subset where at least one non-compliant criterion will be resolved (cf. TABLE 18).

When the sum of the visits is calculated per solution, G3 follows the same approach as G1. The solution with the highest sum of the visits is allocated 1 point and the others are allocated a score proportional to their sum of visits based on the following formula: sum of the visits of the solution G3 = highest sum of the visits

6.3.1.5. G4 – Feedback from associations Associations should rank the potential solutions by priority. The first 33% of potential solutions from this list with the highest priority are allocated 1 point. The next 33% are allocated 0.5 point, and the others are allocated 0 point. Finally, G4 is equal to 1, 0.5 or 0 depending on the rank of the solution.

6.3.2. Prioritisation of the solutions The potential solutions are placed on the prioritisation quadrant graph presented in FIGURE 20. The place of the solutions is based on the cost and the gain in accessibility calculated in the previous subsection. The quadrant determines which solutions are:

• Quick-win, when the cost is low and the gain in accessibility is high. • Low-hanging fruit, when the cost is low and the gain in accessibility is low. • Ambitious, when the cost is high and the gain in accessibility is high. • Inadequate, when the cost is high and the gain in accessibility is low.

Based on this chart and on the budget, each institution can establish a list of prioritised solutions to be implemented for the current iteration, in the next phase.

FIGURE 20: PRIORITISATION QUADRANT GRAPH

Page 87 of 112 6.4. Implementation phase The implementation phase corresponds to the implementation of the prioritised solutions determined during the previous prioritisation phase.

Resources should be mobilised before the implementation. After the implementation, the lessons learned concerning the implemented solutions should be shared with other institutions by using the database described in section 6.5.1.

In this section, examples of implementation are provided based on the shortlisted tools. The cost components depend mainly on whether the solution is free or not. Usually, in all cases, the implementation phase requires the mobilisation of internal resources. The cost drivers are elements or assumptions to be evaluated in order to define the scope of future projects and better estimate the implementation costs. FIGURE 21 shows the cost components and the main drivers of the shortlisted solutions.

Page 88 of 112 FIGURE 21: COST COMPONENTS AND MAIN DRIVERS OF THE SHORTLISTED SOLUTIONS

Short listed solutions

Guidelines Editing Evaluation Formats Fonts

OP OP Accessibil- Acrobat Drupal Liferay Siteimprove AbleDocs Equidox WordToEpub FACIL’iti guidelines Templates IT DC

Direct cost ✓ ✓ ✓ ✓ ✓ ✓

Internal efort ✓ ✓ ✓ ✓ ✓ ✓ ✓ ✓

Cost components Number of ✓ ✓ ✓ ✓ users Number of documents or ✓ ✓ ✓ ✓ ✓ ✓ ✓ ✓ PDFs Number of pages per v ✓ ✓ ✓ documents Complexity of ✓ ✓ ✓ ✓ the documents

Ad hoc or indu- ✓ ✓ strialisation of the process

Number of ✓ ✓ ✓ websites

Number of ✓ web pages

Number of templates ✓ ✓ Main driversMain Structure of the websites ✓

Use of modern technology/ ✓ formats (e.g. HTML5) Amount of content to ✓ ✓ migrate Level of ✓ ✓ support

Trafc received ✓ by websites

Page 89 of 112 One subsection per example of implementation describes:

- Assumptions. - Cost components evaluation: o Direct costs. o Internal effort.

6.4.1.OP Templates and OP Guidelines The following assumptions are made in relation to the implementation of the OP templates solution, which is provided as an example: • 100 users need a simple installation of OP templates on their computer. • 1,000 documents with an average of five pages will be created during the year. Based on these assumptions, the following is an illustration of the cost to implement OP templates:

• It is estimated that 20 man-days are required to setup the solution and provide guidelines for 100 users and that 0.05 man-days per user and per year are required to support users. Finally, the OP Templates solution should require approximatively 120 man-days for the first year.

6.4.2. Typical implementation of CMS with accessibility features The following assumptions are made in relation to the implementation of a CMS such as Drupal or Liferay solutions, which is provided as an example: • Three websites need to be created. • Ten templates need to be created. • 1,000 web pages need to be migrated and reworked to be accessible. • On-premise solution is chosen. • Three accessible modules need to be installed. • The complexity of the website and the publishing workflow is low. • OP has the necessary in-house knowledge to implement the solution and infrastructure is already available. Based on these assumptions, the following is an illustration of the cost to implement a CMS:

• An estimated 265 man-days as follows: o 30 man-days to install the solution and the environments (test, prod). o 5 man-days to install, configure, and train users on an accessible module. o 5 man-days per template. o 20 man-days to automate the migration. o 0.15 man-days per page with reworking for accessibility and proofreading.

Furthermore, prices are not available, but a significant number of service providers are available on the market to implement Drupal on cloud or on-premise. Liferay offers a standard subscription for cloud (€90,000/year) and for on-premise (€30,000/year) solutions.

Page 90 of 112 6.4.3.Siteimprove accessibility solution The following assumptions are made in relation to the implementation of the Siteimprove solution, which is provided as an example: • 1,000 web pages need to be assessed. • These pages include around 500 different elements (image, forms, and videos). Based on these assumptions, the following is an illustration of the cost to implement Siteimprove:

• Siteimprove pricing is available on request, and there will be a financial cost. • As the number of different elements is low, it is estimated that 2 man-days will be required to run the semi-automated solution that will check the different elements.

6.4.4.Typical implementation of existing PDF remediation The following assumptions are made in relation to the implementation of existing PDF remediation, such as AbleDocs or Accessibil-IT solutions, with very different features and options, which is provided as an example: • 1,000 PDFs need to be made accessible with an average of five pages per document with a medium complexity. Based on these assumptions, the following is an illustration of the cost to implement PDF remediation:

• The catalogue prices can vary from 0.004 cents to €125 per page depending on the similarity and the complexity of documents (simple text to forms) and on the strategy to be implemented. A quote needs to be obtained in order to estimate the correct price of the remediation.

6.4.5. Acrobat DC by Adobe The following assumptions are made in relation to the implementation of Acrobat DC solution, which is provided as an example:

• 100 users need Acrobat DC. • 1,000 PDFs need to be made accessible with an average of five pages per document with a medium complexity.

Based on these assumptions, the following is an illustration of the cost of implementing Acrobat DC:

• The estimated financial cost of access to Acrobat DC for 100 users for one year is €2,385 (€19.88/user/month). • It is estimated that 30 man-days would be required to make accessible 5,000 PDF pages, on the basis of three minutes per page.

6.4.6.Equidox by Onix As an example, the following assumptions are made in relation to the implementation of the Equidox solution:

Page 91 of 112 • 100 users need to access Equidox. • 1,000 PDFs need to be made accessible with an average of five pages per document with a medium complexity. Based on these assumptions, the following is an illustration of the cost to implement Equidox: • The estimated financial cost for an unlimited number of users is $30,000 per year. • It is estimated that 11 man-days would be required to make accessible 5,000 PDF pages, on the basis of one minute per page.

6.4.7.WordToEpub by DAISY The following assumptions are made in relation to the implementation of the WordToEpub solution, which is provided as an example:

• 100 users need a simple installation of WordToEpub on their computer. • 1,000 documents need to be converted.

Based on these assumptions, the following is an illustration of the cost to implement WordToEpub:

• It is estimated that 20 man-days would be required to install the solution for 100 users and convert 1,000 documents and that 0.05 man-days per user and per year would be required to support users. Finally, the WordToEpub solution should require approximatively 25 man-days for the first year.

6.4.8. FACIL’iti The following assumptions are made in relation to the implementation of the FACIL’iti solution, which is provided as an example:

• FACIL’iti is implemented on three websites. • These websites are correctly developed in HTML5 without flash. • The traffic received by the websites is standard (up to 5/10 million connections a year).

Based on these assumptions, the following is an illustration of the cost to implement FACIL’iti:

• The subscription could be around €500 per month, per website as the traffic is standard. A discount may be applied as three websites are involved, resulting in a price of €1,200 instead of €1,500 per month for the three websites. For one year, the financial cost of the subscription for FACIL’iti is estimated at €14,400.

6.5. Synergy phase The synergy phase is an ongoing phase in parallel with the three previous phases. This phase has two levels: • Level 0: sharing entity. • Level 1: controlling entity. Compared with the other phases where each institution progresses individually this phase is common to all institutions.

Page 92 of 112 It is important to note that both the sharing and the controlling entity need to work in a collaborative fashion without imposing any solutions on the other.

6.5.1. Level 0: sharing entity The purpose of this level is to share knowledge, solutions and good practices between institutions. This phase is cross-cutting and provides governance. Each institution should have one accessibility representative. Consideration could be given to establishing a new committee or this entity could be linked to an existing committee. Representatives should meet at least once a year to: • Keep up-to-date on the latest standard version and technologies. • Get feedback from the implementation of solutions. • Ensure good documentation and knowledge sharing between institutions. • Keep track of the development of accessibility at each institution and help and guide other institutions where applicable. • Gather resources and work together on similar topics in order to potentially save man-days and money. • Collect feedback from end-users on accessibility. • Define working topics and groups and schedule workshops every month. • Organise meetings with associations to get feedback. • Enhance the promotion of accessibility through events, advertisements, communication, and learning within the institutions.

To ensure good knowledge sharing, it would be advisable to establish a database of accessibility projects/implementation. This searchable database should provide the staff of EU institutions with access to a list of solutions already implemented by other institutions. The metadata of the solution in the database could be as follows:

• Solution identifier. • Year of implementation. • Solution’s name. • Description of the solution. • Type of solution, based on the classification in FIGURE 4. • Financial cost of the solution. • Estimated financial cost of the solution if implemented by another institution. • Man-days needed to create or implement the solution. • Estimated man-days needed to implement it by another institution. • The core benefits of the solution. • IDs of the content targeted by the solution, with a description of the content and the technical criteria in another table as shown in TABLE 16. • WCAG criteria with level of accessibility targeted by the solution. • The pros and the cons of the solution. • Feedback from associations and end-users. • The institution’s contact person in charge of the implementation of the solution.

A list of running projects or projects for future implementation could also be available in order to expand the collaboration between institutions.

6.5.2. Level 1: controlling entity The proposed level 1 of the synergy phase consists in creating a controlling entity, which:

Page 93 of 112 • Is different from the sharing entity. • Is formed by people from different institutions. • Evaluates the level of accessibility of each institution. • Provides a public label for each content evaluated.

During the evaluation phase, different solutions and rules (ACT) will probably be used depending on the institutions. This is why it is necessary to create a controlling entity that applies the same evaluation technique for the content of all institutions. The evaluation should be transparent for the institutions and be based on the latest version of the WCAG standard. Using ACT format could harmonise accessibility testing between institutions.

A label could be awarded for each evaluated content. A proposed label is presented in FIGURE 22. The label for each evaluated content could be displayed for consultation by the general public. Three key pieces of information should appear on this label:

• The version of the WCAG standard. • The percentage of compliant criteria. • The highest level of accessibility reached when all the criteria of this level and the above level are fully compliant, where applicable.

FIGURE 22: EXAMPLE OF LABEL

In the proposed examples of labels in FIGURE 22, the green colour is used to identify when at least the first level A has been reached. The label should be accessible and readable by a screen reader.

The controlling entity verifies only a subset of the content and not the solutions or the methodology used to create accessible content. The content subset could be selected either randomly or on the basis of the methodology presented for phase 1. A specimen evaluation report is presented in TABLE 18 in subsection 6.2.3. The report should be available for the institution that has been controlled for use during the prioritisation phase.

6.6. Guidelines Usually, institutions edit their content and outsource the rendering/production of publications. This section provides recommendations on directives, standards and guidelines that should be applied for institutions and imposed on subcontractors to deliver accessible content.

Page 94 of 112 6.6.1. Directive The Web Accessibility Directive (Directive (EU) 2016/2102)59 defines rules on the accessibility of the websites and mobile applications of public sector bodies. All EU institutions are encouraged to follow these rules for their websites and apps, even if the directive does not apply to them. This directive refers to the EN 301 549 V1.1.2 (2015- 04)60 European Standard.

6.6.2. Standards ISO 14289 – PDF/UA or PDF/Universal Accessibility61 is the International Standard for accessible PDF technology.

For web accessibility, W3C WCAG 2.162 level AA is recommended. It is produced by W3C as part of the Web Accessibility Initiative.

The Harmonised European Standard EN 301 549 v2.1.2 (2018-08)63 refers to WCAG 2.1 level AA, but also contains additional accessibility requirements for all types of content, ICT products and services.

Institutions are the editors and creators of content. Using suitable authoring tools to create accessible content that complies with WCAG 2.0 is important and possible by following ATAG 2.064 guidelines. It also helps to make the authoring tools themselves accessible.

59 European Parliament and the Council, “DIRECTIVE (EU) 2016/2102 on the accessibility of the websites and mobile applications of public sector bodies”, https://eur- lex.europa.eu/eli/dir/2016/2102/oj, [accessed on 28.02.2020]

60 CEN, CENELEC, ETSI, “Accessibility requirements suitable for public procurement of ICT products and services in Europe”, https://www.etsi.org/deliver/etsi_en/301500_301599/301549/01.01.02_60/en_301549 v010102p.pdf, [accessed on 28.02.2020]

61 ISO, “ISO 14289-1:2014 Document management applications — Electronic document file format enhancement for accessibility — Part 1: Use of ISO 32000-1 (PDF/UA-1)” , https://www.iso.org/standard/64599.html, [access on 28.02.2020]

62 W3C, “Web Content Accessibility Guidelines (WCAG) 2.1”, https://www.w3.org/TR/WCAG21/, [accessed on 28.02.2020]

63 CEN, CENELEC, ETSI, “Accessibility requirements for ICT products and services “, https://www.etsi.org/deliver/etsi_en/301500_301599/301549/02.01.02_60/en_301549 v020102p.pdf, [accessed on 28.02.2020]

64 W3C, “Authoring Tool Accessibility Guidelines (ATAG) 2.0 “, https://www.w3.org/TR/ATAG20/, [accessed on 28.02.2020]

Page 95 of 112 6.6.3. Guidelines The 10 golden rules on web accessibility65 provide a summary and a synthesis of the different standards. They provide a comprehensive understanding of web accessibility.

The European Commission’s Europa Web Guide is the official rulebook for the European Commission's web presence, covering editorial, legal, technical, visual, and contractual aspects. The accessibility chapter of the Europa Web Guide66 includes an accessibility overview and content accessibility checklist.

Guidelines from the Publications Office will be made available online. These guidelines facilitate the creation of accessible documents for everyone.

65 EDF, “10 golden rules”, http://www.edf-feph.org/edfs-electronic-resource-web- accessiblity, [accessed on 28.02.2020]

66 European Commission, “Accessibility chapter of Europa Web Guide”, https://wikis.ec.europa.eu/display/WEBGUIDE/01.+Accessibility+overview, [accessed on 28.02.2020]

Page 96 of 112 7. Conclusions

Accessibility is becoming an increasingly important topic, with both public and private sectors working on ways of ensuring equality of rights and access to documents and information. The general information provided by the European institutions should be accessible to all citizens, regardless of age or disabilities. This study represents a complete ecosystem involving numerous stakeholders (end-users, associations, authors, publishers from institutions, vendors of accessible solutions), created to understand the complexity and the role of each of them in improving accessibility.

The report shows the results of the first phase of the “Reading disability and document access, a possible approach” pilot project. Phase 1 involved a comprehensive study to assess the targeted audience, the targeted documents/publications and websites, and the relevant tools to enhance accessibility for users with reading disabilities. The main outcome of the study is a roadmap including guidelines to help European institutions to enhance their content. The planning of phase 1 is described in FIGURE 23.

FIGURE 23: PLANNING OF THE FIRST PHASE OF RDDA

The conclusions section of the report presents a summary, as well as key findings and outcomes from each section. Future work to enhance documents and web content is also presented.

Section I: User groups

The first section of the report assesses the target audience. Interviews with associations were conducted in order to identify the needs of end-users and gaps in accessible solutions and in accessibility at the level of the content of EU institutions. The outputs of workshops include the following key findings: • The main aspects of a document that may lead to reading difficulties are: o Fonts. o Long sentences. o Dense texts. o Long paragraphs. o Complex wording such as the use of double negatives. o Foreign languages. o Non-transparent languages.

Page 97 of 112 • Reading disability experiences of end-users are different; the level of disability and their needs are different. There is no one solution that fits all end-users. In fact, end-users have their own preferences for solutions and configurations. • There is a difference between the tool and the environment. If the environment is not accessible, the use of the tool is difficult, if not impossible. For example, a screen reader (the tool) does not work on a PDF image (the environment). • Many tools for end-users already exist and are available on the market. The associations interviewed recommend that institutions should focus on environment solutions. • Existing solutions facilitating document accessibility for persons with visual impairments and blindness can benefit users with reading disability. • A universal design should be prioritised so that all users can benefit from solutions. Section I proposes a user group classification based on user needs. The proposed classification is as follows: • Tailored text: bigger fonts, different fonts, word spacing, line spacing, colour contrast, colour backgrounds, and syllables highlight. • Audio needs: listen to the text, navigate the text with sections. • Search needs: speak to the text, navigate the text with sections. • Image comprehension needs: description of an image. • Additional time needed: more time needed to complete a document/online form. It is important to note that this classification may cover more than reading disabilities. For example, blind people also need audio, search features, image comprehension and/or additional time. Section II: Resources and EU institutions Section II assesses the targeted documents/publications and websites of EU institutions. Interviews were conducted with institutions willing to participate in the study and publishing documents and web content targeting the general public. The purpose of these workshops was to understand the publication process and the different contents available to the general public. The key outputs of the workshops are listed below: • Multiple stakeholders are involved in the process of creating content. Within EU institutions, the staff identified that could be involved in the process are authors, contributors, translators, publishers, and webmasters. All of these professionals should be aware of accessibility. • Institutions do not use or publish accessible formats as much as they could. For example, PDF format seems to be the most common format while the EPUB format appears to be the least used for publishing documents. Turning to web published content, the HTML format is generally used while HTML5 could be used to provide better semantics. • Accessibility guidelines focus extensively on websites rather than on documents. • Despite the willingness of institutions to improve resource accessibility, little effort seems to have been made at this stage regarding sharing best practices. This aspect may finally be addressed in the future to enable institutions to harmonise their approach to the level of resource accessibility. • Institutions reported complaints from end-users regarding images with no alternative text, non-accessible PDF documents, forms, and captcha. An end-user driven approach could probably resolve these problems. • Considering that millions of users access the websites and documents of EU institutions, an improved level of resource accessibility would have a positive impact on a broad population. Section III: Assessment of the tools

Page 98 of 112 Section III assesses relevant solutions that enhance accessibility. 108 solutions, that cover at least one end-user’s needs and target the type of content published by EU institutions, have been found based on the interviews with associations and institutions, as well as internal research. These solutions are organised according to the following proposed classification: • Guidelines for authors and contributors to create accessible content. • Editing solutions that help authors and contributors to edit or create an accessible document or web page. • Evaluation solutions that provide publishers and webmasters with the level of maturity in terms of accessibility, either for web pages or documents. • Formats or solutions that allow publishers and webmasters to convert one format to another. • Fonts/layout solutions that allow end-users to customise the font, spacing, size, layout, colour, contrast, and more. • Speech solutions that come with speech features, either text-to-speech or speech-to-text for end-users. • Image solutions that manipulate the image to improve the understanding of end- users. • Paper-based solutions that support end-users to help them read non-numerical documents. • Navigation agent that helps end-users to navigate within a document or within a website. From the long list of solutions, eight solutions have been selected based on the following criteria: • At least one solution from each type corresponding to environment solutions, as the focus should be on environment solutions as mentioned by the associations. • At least two solutions dealing with publications and ideally with PDF documents, to cover the lack of guidelines and evaluation solutions for publications and mainly PDF documents. • At least two solutions dealing with web pages, to achieve a good balance between document and web page accessibility. • At least one tool and one methodology, to achieve a good balance between software and methodologies. A more detailed description of the shortlisted solutions is provided in section V based on the interviews with editors and information available online. The shortlisted solutions are:

• OP Guidelines. • Accessibility features from Drupal. • DXP Cloud from Liferay. • OP Templates. • Siteimprove accessibility. • Acrobat DC by Adobe. • WordToEpub by DAISY. • Accessibil-IT. • Equidox by Onix. • AbleDocs. • FACIL’iti.

Finally, the research conducted in this section shows that: • It is easier to find end-user solutions than solutions for authors, contributors, webmasters or publishers. • Accessibility may benefit a larger population thanks to:

Page 99 of 112 o Free and open source solutions. o Standards from W3C such as WCAG 2.1. o Directives for the private and public sectors.

Section IV: Mapping

Section IV presents the mapping between the type of solutions and the shortlisted solutions with the type of content and user needs. It shows that: • The most accessible formats for the use of tools (assistive technologies) are EPUB and HTML5. • One size-fits-all solution covering user needs and/or formats does not exist.

Section V: Guidelines and roadmap Section V proposes guidelines and an iterative and common roadmap for EU institutions based on information and knowledge gathered in the previous sections. The objective of the roadmap is to improve the level of accessibility of content. The roadmap has three phases, following a phase-by-phase approach: • Evaluation phase, with the objective of understanding what content is not accessible and does not comply with the WCAG standard. • Prioritisation phase, providing a framework for prioritising the solutions to be implemented to resolve the issues identified during the evaluation phase. • Implementation phase, i.e., the implementation of the solutions retained in the prioritisation phase based on the gain in accessibility and the cost of the solutions and the institution’s budget. A synergy phase is implemented in parallel with these three phases. It contains a sharing entity that governs accessibility within European institutions and a controlling entity that assesses a sample of the content against the WCAG criteria of each institution.

Future work Future work that may lead to improved levels of accessibility includes the following suggestions: • Focus on the environment rather than on tools as mentioned by the associations. • Increase awareness about accessibility for all parties involved in creating content, by properly defining their role and the actions that can improve content accessibility. • Increase the use of the EPUB publishing format. • Target existing and non-existing documents, as well as documents and web content. • Follow guidelines and standards such as WCAG. • Follow the proposed roadmap.

Improving the levels of accessibility remains a challenge and cannot be achieved overnight. However, the results and suggestions included in the report can be a first step in that direction. The guidelines and the report could be used as a framework by European institutions and incentivise other organisations and private companies to improve the level of accessibility of their online content. The research carried out for this study shows that a large number of solutions could help European institutions enhance the accessibility of publications and web content. In the second phase of the RDDA project, some of these solutions will be applied to a subset of

Page 100 of 112 content from the institutions. The proof of concept is twofold: understanding the difficulty in implementing such solutions and the gain in accessibility. Finally, reading disability and access to web documents may be considered in the new European Disability Strategy 2020-2030, in accordance with the recommendations 4.1.3.1, 4.3.2 and 4.3.2.12 of Shaping the EU agenda for disability rights 2020-2030: a contribution from the European Economic and Social Committee (own-initiative opinion)67. This Disability Strategy should take into full account the UN Convention on the Rights of Persons with Disabilities (UNCPRD)68 and the Sustainable Development Goals69.

67 EESC, “Shaping the EU agenda for disability rights 2020-2030: a contribution from the European Economic and Social Committee (own-initiative opinion)”, https://www.eesc.europa.eu/en/agenda/our-events/events/shaping-eu-agenda- disability-rights-2020-2030-0/opinions, [accessed on 28.02.2020]

68 United Nations, “Convention on the Rights of Persons with Disabilities”, https://treaties.un.org/Pages/ViewDetails.aspx?src=TREATY&mtdsg_no=IV- 15&chapter=4&clang=_en, [accessed on 28.02.2020]

69 United Nations, “Sustainable Development Goals”, https://sustainabledevelopment.un.org/?menu=1300, [accessed on 28.02.2020]

Page 101 of 112 8. List of acronyms This section presents the list of acronyms alphabetically arranged.

TABLE 20: LIST OF ACRONYMS Acronyms Definition A11Y Accessibility ACT Accessibility Conformance Testing ADA Americans with Disabilities Act AI Artificial Intelligence ATAG Authoring Tool Accessibility Guidelines CAPTCHA Completely Automated Public Turing Tests to Tell Computers and Humans Apart CMS Content Management System DG COMM Directorate-General for Communication DG EAC Directorate General for Education and Culture DG ITEC Directorate-General for Innovation and Technological Support DG TRAD Directorate-General for Translation DTBook Digital Talking Book EC European Commission EDA European Dyslexia Association EDF European Disability Forum EESC European Economic and Social Committee EP European Parliament ePub electronic publication ETSI European Telecommunications Standards Institute EU European Union HTML HyperText Markup Language ICT Information and Communications Technology ID Identifier ISO International Organization for Standardization IT Information Technology JSON JavaScript Object Notation MEP Members of the European Parliament MS Microsoft OCR Optical Character Recognition ODT Open Document Format OP Publications Office OS Operating System PDF Portable Document Format PDF/UA PDF/Universal Accessibility PEF Portable Embosser Format

Page 102 of 112 TABLE 20: LIST OF ACRONYMS RDDA Reading Disability and Document Access, a possible approach SEO Search engine optimization SO Strategic Objective UAAG User Agent Accessibility Guidelines UN United Nations CRPD Convention on the Rights of Persons with Disabilities URL Uniform Resource Locator VPAT Voluntary Product Accessibility Template W3C World Wide Web Consortium WAI Web Accessibility Initiative WCAG Web Content Accessibility Guidelines XML Extensible Markup Language

Page 103 of 112 9. Annex

9.1. Questionnaire for associations

TABLE 21: QUESTIONNAIRE FOR ASSOCIATIONS Topic N. Question Reading disabilities that we have identified include dyslexia (developmental and acquired) as well as hyperlexia. To 1.1 your knowledge, what are the other reading disabilities that we should consider as part of the study? 1.2 Can you please share your common classification for different reading disability forms? 1.3 What is the known population for the different classification types? Are there other disabilities that are more common with individuals who have reading disabilities? How common are 1.4 User groups those disabilities? 1.5 Have you gathered specific needs for each reading disability classification type? 1.6 What research have you performed on user group identification? Can this be shared with the project team? 1.7 What research have you performed on needs identification? Can this be shared with the project team? Our understanding is that three alphabets are used within the European Union: Latin, Greek and Cyrillic. Do reading 1.8 disabilities affect users in the same way regardless of the alphabet that is used? 2.1 What is your opinion on EU document access? 2.2 What type of resources are most sought after by the user groups? 2.3 Are there any specific institutions that do a better job than others in terms of document access, and why?

Current gap in 2.4 What gaps and issues have you identified regarding EU document access? resources 2.5.1 Can you provide examples of institutions/organisations that do a better job in terms of accessibility? accessibility 2.5.2 What are the means used by the institutions/organisations you have mentioned? Are there current practices that make accessibility to EU resources particularly difficult? Which practices should be 2.6 considered as a priority to adapt? Are you aware of practices that should be avoided in terms of accessibility, wrong inclusions or examples not to be 2.7 reproduced? Possible solutions 3.1.1 What tools have you identified as potential solutions?

Page 104 of 112 TABLE 21: QUESTIONNAIRE FOR ASSOCIATIONS “Tools”: 3.1.2 What gap or need do the above listed tools address? technologies, tools, formats, layouts, 3.2 What research have you performed on "tools"? Can this be shared with the project team? fonts, best practices 3.3.1 How do font related tools perform in terms of needs coverage? and IT software 3.3.2 How does the tool Text to Speech perform in terms of needs coverage? Other relevant topics 4.1 Are there any points that have not been covered and that may be relevant?

Page 105 of 112 9.2. Questionnaire for institutions

TABLE 22: QUESTIONNAIRE FOR INSTITUTIONS Topic N. Question 1.1 What are the different distribution channels of "document" used? 1.2 What type of documents (pages, articles, documents and resources published on websites and portals) do you share? 1.3 Do you provide any printed documents to your users? 1.4 For each distribution channel/document type, what is the approximate quantity of documents? The target documentation that 1.5 What are the source formats that you use to store your documents? would need to be 1.6 What languages are documents produced and published in? adapted 1.7 Are resources produced and published in the Cyrillic and Greek alphabets? 1.8 What are the data sources for the content of document published? 1.9 How is your institution's data structured? 1.10 How do you use metadata regarding your published documents? The typical end user 2.1 How would you describe your typical end user who uses your documents? for these What is the frequency with which users access your documents? Are users generally recurrent users or are they 2.2 documentations mostly one-time visitors? 3.1 What tools have already been deployed? What users’ need are these tools targeting? Current practices and 3.2 What tools are planned to be deployed? What users’ needs do they target? tools already adopted in terms of 3.3 Are there any portal/website overhauls planned? If so, what will these change? accessibility Does your institution have experience concerning reading disabilities? Did you receive comments from persons with 3.4 reading disabilities on the accessibility level of your website? 4.1 Please list the various priorities your institution has set in terms of document accessibility. The institution’s priorities in terms of 4.2 Have you previously received accessibility concerns from your users? accessibility Would your institution be willing to participate in phase 2 of this study, including a proof of concept where selected 4.3 publications and websites are enhanced to be more accessible?

Page 106 of 112 9.3. List of associations dealing with dyslexia in Europe

TABLE 23: LIST OF ASSOCIATIONS Country Austria Austrian Federal Dyslexia Association Austria Styrian Dyslexia Association Austria Initiative LEGA Belgium Association of Parents of Children with Learning Difficulties Bulgaria Dyslexia Association Bulgaria* Croatia Croatian Dyslexia Association, HUD (Hrvatska udruga za disleksiju)* Cyprus Cyprus Dyslexia Association* Czech Republic Czech Dyslexia Association* Denmark Danish Dyslexia Association Estonia To be identified* Finland Finnish Diverse Learners' Association France French Federation of Dys France French Association of Parents of Children with learning disabilities in written and oral language Germany German Dyslexia and Dyskalkulia Association Great Britain British Dyslexia Association Great Britain Dyslexia Scotland Association of parents and guardians with children with dyslexia and learning difficulties of Thessaloniki and Northern Greece Greece Greece Hellenic Dyslexia Association Hungary Dyslex* Ireland Dyslexia Association of Ireland Italy Italian Dyslexia Association

Page 107 of 112 TABLE 23: LIST OF ASSOCIATIONS Latvia Latvijas Disleksijas Biedriba* Lithuania Lithuanian Dyslexia Association Luxembourg Dyslexia and Special Education Needs Malta Malta Dyslexia Association Netherlands National Parents association Balans Norway Dysleksi Norge Dyslexia Norway Poland Polish Dyslexia Association Portugal Associacao Portuguesa de Dislexia* Romania The Romanian Association for Children with Dyslexia* San Marino San Marino Dyslexia Association Slovakia To be identified* Slovenia Bravo Association for helping children and adolescent with specific learning difficulties Spain Catalan Association of Dyslexia Spain Dyslexia Canary Islands and other Learning Difficulties Spain Associación Dislexia y Familia Sweden The Swedish National Dyslexia Association Switzerland Swiss Dyslexia Association

* The association is not under the EDA umbrella.

Page 108 of 112 9.4. List of solutions The long list of solutions is presented in the attached Excel file named tools_identification.xlsx. This file has 3 sheets representing:

• The long list of solutions. • The list of providers. • The list of additional solutions corresponding to solutions either with not enough information or out of the scope of reading disabilities and document access project.

Page 109 of 112 9.5. Questionnaire for solution providers

TABLE 24: QUESTIONNAIRE FOR SOLUTIONS Topic N. Question

1.1 How would you describe your solution in a few words?

1.2 What is the price and the pricing model? (license)

1.3 Is your solution Open Source?

1.4 What are the languages used on the interface of your solution?

1.5 What are the languages of the contents accepted by your solution?

1.6 What are the available alphabets on the interface of your solution?

1.7 Which alphabets are accepted by your solution? General description of the solution 1.8 On which environment your solution can be used? (client/server side; OS; devices; specific software)

1.9 What are the features and functionalities of your solution in terms of accessibility?

1.10 What are the limitations of your solution? Is the solution based on standards and guidelines? Does it provide a better accessibility level of website or 1.11 documents? 1.12 Is the implementation of the solution easy? How to implement the solution?

1.13 Do you have a video that describes the solution? Could you make a demonstration?

1.14 When does the solution have been released? What is the current version?

2.1 Who are the users of your solution? Users 2.2 How many users/clients for this solution do you have?

Page 110 of 112 TABLE 24: QUESTIONNAIRE FOR SOLUTIONS

2.3 Do you have users/clients in the public sector?

2.4 Could you provide us with the name of some of your users/clients as an example?

2.5 Where is your solution the most used?

2.6 Did you receive feedback from users?

3.1 How would you describe your company/organisation?

3.2 When was it founded?

3.3 How many employees/members does it have?

Provider 3.4 What is the main business?

3.5 How does your company/organisation deal with accessibility matter?

3.6 Do you provide other solutions on accessibility?

3.7 What is the geographic coverage of the organisation?

Page 111 of 112 GETTING IN TOUCH WITH THE EU

In person All over the European Union there are hundreds of Europe Direct information centres. You can fnd the address of the centre nearest you at: https://europa.eu/european-union/contact_en

On the phone or by email Europe Direct is a service that answers your questions about the European Union. You can contact this service: – by freephone: 00 800 6 7 8 9 10 11 (certain operators may charge for these calls), – at the following standard number: +32 22999696 or – by email via: https://europa.eu/european-union/contact_en

FINDING INFORMATION ABOUT THE EU

Online Information about the European Union in all the ofcial languages of the EU is available on the Europa website at: https://europa.eu/european-union/index_en

EU publications You can download or order free and priced EU publications at: https://op.europa.eu/en/publications. Multiple copies of free publications may be obtained by contacting Europe Direct or your local information centre (see https://europa.eu/european-union/contact_en).

EU law and related documents For access to legal information from the EU, including all EU law since 1952 in all the ofcial language versions, go to EUR-Lex at: http://eur-lex.europa.eu

Open data from the EU The EU Open Data Portal (http://data.europa.eu/euodp/en) provides access to datasets from the EU. Data can be downloaded and reused for free, for both commercial and non-commercial purposes.

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