The Nordic Accessibility Community Group serves as an open forum to discuss challenges, network with accessibility professionals, and promote the importance of digital accessibility and inclusive design in the Nordic region.
Note: Community Groups are proposed and run by the community. Although W3C hosts these
conversations, the groups do not necessarily represent the views of the W3C Membership or staff.
Chairs, when logged in, may publish draft and final reports. Please see report requirements.
Kosie Oki, Pär Lannerö, Erik Gustafsson Spagnoli, Umut Gultekin, Robin Lienedeborg, Sander Nijsingh, Christer Janzon, Nadia Törnroos, Viet Ba.
Ethics — who can join this Community Group?
Especially, do we accept members from overlay tool companies? The topic is hard and subjective, where do we draw the line for ethics?
Level access owns the overlay tool UserWay, should people working there be excluded even if they do not work with an overlay tool?
We should not limit the group and it should be open to anyone. Even opposing parties can be good for discussions and to learn from. Some people could be joining to bridge their gaps in accessibility knowledge. If we would exclude them it does not benefit the group nor accessibility in general.
We should state the purpose of the group more clearly. Maybe add that company advertisement is not allowed. So if it is a problem we can point to it.
Draft a suggestion and present at next meeting and get feedback in Slack.
Monitoring updates
Erik Gustafsson has been reaching out to other countries monitoring agencies and is slowly but surely updating the table in the Github repository.
Robin wants to assist helping gathering information. Erik has email templates to use if anyone wants to contact monitoring agencies. Robin thought about doing a product when we have a more completed table. Norway and Iceland has been a topic for Nadia in discussions with clients, she can add information about those countries.
When the table is more mature, a goal could be if we can get country representatives to keep it updated, to lessen the burden.
Can we use the WAD list as help to find more monitoring agencies?
Any information that can be found, such as correct contact email addresses for monitoring agencies, helps the cause.
If you want to help out, reach out to Erik through Slack, email or LinkedIn.
In Sweden they are continuously monitoring more companies each week in E-commerce and for products.
Four testers are currently employed; two more positions are planned.
No consulting agencies are involved in the monitoring at this stage, and not expected in the near future.
The initial scope is small – mainly large companies active in Sweden.
There was agreement that consistency in testing across countries is important.
Denmark
Published some accessibility resources and reached out to several companies.
No central agency offering consulting or direct support to companies (unlike Estonia’s advisory approach).
Finland
No major updates reported.
Estonia
Government provides general guidance on accessibility but does not have dedicated staff for EAA monitoring.
Discussion about potential inclusion of parcel lockers as part of the e-commerce flow under the EAA.
Action
Erik & Tobias will both reach out to monitoring agencies (Sweden & Denmark) to ask about their testing language and monitoring status.
WCAG 2.2, which is now approved as an ISO/IEC international standard (source). It is unclear whether some countries are actually using this version of WCAG when monitoring.
2. Education & Outreach
Accessibility in Higher Education
General agreement that accessibility remains underrepresented in design and development curricula.
Universities are typically slower to adapt, but some two-year schools include accessibility more actively.
Anna-Liisa shared Maija Koivisto’s PhD defence on interpretation in higher education as an inspiring example (LinkedIn post).
Tobias Nyhuus Jensen, Jakob Rosin, Erik Gustafsson Spagnoli (taking notes), Kosei Oki, Anne Slott Thorborg, Robin Liendeborg.
Notes
Agenda for today
New members?
Keep on with using our GitHub repository and EN-standard theme for meetings.
Let’s again pick up the work on education, to get accessibility into the curriculum.
Co-chair topic.
Welcome Kosei Oki!
UX/ Ui Frontend student, originally from Japan, living in Denmark. Looking for an accessibility community in Denmark, met Tobias and joined in.
Co-chair topic
Cleaned up non-active co-chairs for the group after asking each person if they want to continue to contribute or step back as members. Currently Tobias and Erik are chairs. We’re looking for a co-chair to join in, it’s not a time consuming task and you can always step down at any time.
Estonia, not very good proactive enforcement, questions regarding parcel boxes. Jakob asked in France, they gave an answer that if has payment option it applies to the whole machine. Monitoring of government agencies has failed heading levels – where others put is at best practice.
Denmark, Tobias talked to a company that had been notified by the monitoring agency.
Sweden, companies need to report issues within 14 days. Have not started, expected to start mid October.
Other things
France discussion Disability organisations in France in July were serving four major supermarkets with notice for failings against the EAA. More info in the page about EAA enforcement tracking.
Tobias Nyhuus Jensen, Erik Gustafsson Spagnoli (taking notes), Sander Nijsingh, Byeongji Lim, Christer Janzon, Simo Hellsten, Anna-Liisa Mattila, Miia Kirsi, Viet Ba Hirvola, Jakob Rosin.
Main topics
Keep on with using our GitHub repository and EN-standard theme for meetings.
Let’s again pick up the work on education, to get accessibility into the curriculum.
Defining our scope
How strict do we want to be about the Nordic aspect of the group? With inviting Estonia this sparks a discussion. Where does it end?
It says now on our page:
The Nordic Accessibility Community Group serves as an open forum to discuss challenges, network with accessibility professionals, and promote the importance of inclusive design in the Nordic countries.
Agreement is upon being less strict. Renaming it to “Nordic region”.
Welcome our new members
Jakob Rosin, Estonia. Co-founded accessibility consultancy and is an AccessibleEU national expert. Board member in the European blind union. Wants to share thoughts and good ideas in this group. Lacking an Estonian accessibility community, so this is nice, getting a togetherness.
Viet Ba Hirvola, Finland. Accessibility lead at Elisa Corporation – a network operator. Background in computer science and user research.
Byeongji Lim, H&M Group. Frontend developer, part of their internal ‘Accessibility Circle’. Joined this group to network and connect.
EAA enforcement/monitoring
Denmark, nothing new about enforcement. Large companies are aware.
Estonia, monitoring not active. Will not enforce anything until January since they are still figuring it out. At an e-commerce conference, it was said that e-commerce actors should not worry about compliance. Jakob will set up a webinar series in the fall to inform them.
Finland, nothing new. Accessibility metadata for e-books is displayed in many stores now. Plan for national accessibility expert meeting.
Sweden, active monitoring starts in September due to holiday season delaying this.
Next session
Our next session will be September 23, 2025.
If you have any topics that you would like to have brought up, please suggest it in the Slack group, by email to the group, or to Erik Gustafsson Spagnoli or Tobias Nyhuus Jensen directly.
You have to report in 14 days from discovering the error.
Do you need to report everything, if you fix it straight away? The purpose of the law is to make things accessible. The law says you still have to report it within 14 days.
Some countries say they prefer reactive reporting instead of proactive reporting. How does PTS handle this?
Benefits, reporting probably shows you work with accessibility and probably not be the first.
Two different kinds of fines in Sweden
There are two different fines you can get in Sweden.
Formal requirements fine “Sanktionsavgift” for not reporting or collaborating with the market agency. 10ksek to 10 msek for each occurance.
Vite, for accessibility issues not fixed after a grace period of being able to fix it.
Monitoring discussion
They are starting with E-commerce and starting with the worst actors. Amazon is a large actor that is not doing accessibility in the same way. Compared to quite large actors H&M or large grocery stores Amazon has millions of pages. They would have to work together across the EU. Probably IKEA is an actor that will be targeted due to many countries… Maybe the Chinese actors that have other issues apart from accessibility?
Service depending on a product, can be used for five years.
Even if the company claims 5 years grace it old unaltered contracts. New customers are new contracts and they have to provide an accessible service. So it makes little sense to use that clause.
A Slack discussion regarding a talk at a conference where E-commerce union representant was claiming they have an agreement with the government that no fines will be delivered. Investigation further to the claim is ongoing.
E-books
Finland will have a meeting next week with authorities and actors on the market for discussing E-book metadata. W3C draft publication published for E-books, Miia will update the information on Github for E-book metadata. Metadata for e-books is quite well established so it is not very aligned with demands from the EAA.
Sweden are waiting with E-books since the consitution conflicts with changes. They do need to comply with the requirements anyways since Finland and other countries have the demands in place.
Although audio books are not included, if you provide E-books you still need to comply. And if you sell services, products or subscriptions you are an e-commerce provider and need to be accessible.
SL said 10 hours per document to fix accessibility with a total of 11 million Swedish crowns. Was not accepted as disproportionate burden and they have been sanctioned with 300 000 SEK.
French minister of culture calculated already published e-books cost in the ballpark of 200 million euros.
Courts reduced the fine for Pajala Bostäder, the court seems to have misunderstood the law. Ended up being reduced to 25 000 SEK from 1 100 000 SEK (source). Court decision: 4351-24 Härnösands förvaltningsrätten.
Erik Gustafsson Spagnoli (taking notes), Nadia Törnroos, Christer Janzon, Sander Nijsingh, Anna-Liisa Mattila, Robin Liendeborg, Robin Whittleton, Torbjörn Lahrin.
Meeting notes
(IAAP) Certifications in companies, is it a must?
University in Finland, not offering it to employees but requiring for services they buy. Most of participants says it is offered but not required. For procurements we see that companies are asking for it. In the future it will most likely be a hard requirement with certification. There’s advantages since it is an objective way to compare though it can still be uncertainty of level of knowledge. Would be great with alternative to IAAP that is more focused on Europe and the EAA.
Procurements discussion
It would be good to have a certification for the ones doing procurements. Putting too many demands can lead to no product available to buy. Maybe a partial support/ support with roadmap of fixes could be an alternative to ensure improvements are made. They do this in Netherlands. It will take a long time to get products accessible for public procurements.
It is still very vague how to document and report errors. Clarification of that if you sell to EU market you need to conform with the EAA. Placing on the market defintion.
The group continued discussions on spoken subtitles, referencing the ongoing discussion thread in the GitHub repository: GitHub Discussion #9.
Experiments and Examples:
Pär shared insights from his experiments with Able Player, which allows toggling and customizing spoken closed captions. Notably, it enables captions to pause the video’s audio when spoken:
Sander mentioned that in the Netherlands, an accessible video player has been developed by the government, supporting toggling audio descriptions, and downloading separate accessibility assets (video-only, transcript, or audio description). Example video: https://www.rijksoverheid.nl/documenten/videos/2022/10/10/video-tim-ter-haar
Requirements are Unclear:
The group discussed a key question: What are the actual requirements for spoken subtitles?
Should there be a button to enable spoken subtitles for all users (not just screen reader users)?
How should these be presented to ensure compliance?
EAA Uncertainties
The group exchanged thoughts on the upcoming EAA, which is set to take effect later this summer. Currently, much remains unclear across different countries.
Observations & Open Questions:
Sweden:
Companies must self-report accessibility shortcomings to the monitoring agency.
No official templates exist—only law documents, which are vague about reporting requirements.
Uncertainty around public disclosure:
How much detail should companies provide?
What level of transparency is required?
Enforcement & Penalties:
No clear answers yet on penalties for non-compliance.
Question: Will monitoring agencies collaborate across countries or operate independently? Likely the latter.
Cross-Country Collaboration:
The EAA mentions a collaboration group (Article 28) for enforcement coordination, but this group does not appear to have been established yet.
Accessibility of WAD Statements:
WAD (Web Accessibility Directive) statements are often written in complex, inaccessible language.
However, the process of creating them forces organizations to engage with accessibility, potentially improving their practices.
3. Upcoming Meetups & Events
Pär shared details on two upcoming accessibility meetups, external to the Nordic Accessibility Community Group, but open to all:
April 1st – Stockholm (Topic: Accessible Self-Service Terminals)
Time: 13:00–17:00
Free to attend
April 28th – Malmö & Online (Topic: Accessible Events)
Time: 13:00–17:00
Free to attend
4. Homework & Next Steps
Collect information on each country’s monitoring agency, enforcement expectations, penalties, and collaboration efforts. Put your findings in the GitHub discussion: GitHub Discussion #3
Any clarity—however small—is valuable.
Goal: For us to be able to map similarities/differences and provide better guidance for those navigating compliance.
It is hard to land common understanding regarding 11.7.
Wish for easy to use feedback: This is what 11.7 should be and why.
Pär will add a discussion thread in the repo.
Preconditions will probably sort out issues with websites/ app and ICT.
Example: “For ICT that has a physical button”.
Discussion about https://www.w3.org/TR/coga-usable/#support-a-personalized-and-familiar-interface-pattern and how different cognitive accessibility writings can be a bit confusing.
Summary This session focused on improving collaboration through the Github repository, drafting test procedures, and managing updates to accessibility standards. Until the next meeting, members should contribute to the repository, review drafts, and highlight key issues. The next session will address unresolved topics, refine methods, and plan the next steps.
Nordic-Accessibility-Community-Group
