---
title: 2nd Monitoring Period - Part II
author: Agência para a Modernização Administrativa, I.P
---

## Part II – Monitoring Results

### Simplified Monitoring of Websites

In total, 657 websites were analyzed, encompassing 40,215 pages, with an average of 61 pages per website.

#### Distribution of _EN 301 549_ Requirements by Website in the Simplified Monitoring

[Table 6](#T06) shows the number (and percentage) of websites violating each tested requirement.

table06.txt

From [Table 6](#T06), we conclude that compliance with the tested requirements of EN 301 549 was low. The requirements with the highest non-compliance rates were:

- 9.1.3.1 Info and Relationships with 98% of websites non-compliant;
- 9.4.1.2 Name, Role, Value with 93% of websites non-compliant;
- 9.2.4.4 Link Purpose (in Context) with 91% of websites non-compliant;
- 9.2.4.1 Bypass Blocks with 91% of websites non-compliant;
- 9.1.4.3 Contrast (Minimum) with 88% of websites non-compliant;
- 9.1.1.1 Non-Text Content with 73% of websites non-compliant;
- 9.4.1.1 Parsing with 57% of websites non-compliant.

#### Distribution of _EN 301 549_ Functional Performance Statements by Website in the Simplified Monitoring

The performance of websites concerning the functional performance statements was analyzed, focusing on requirements that support these statements (primary relationships). Based on the evaluated requirements, 7 of the 11 functional performance statements were considered.

[Table 7](#T07) presents the results.

table07.txt

From [Table 7](#T07), we conclude that non-compliance with functional performance statements is significant when assessed based on the primary relationships. The functional performance statement with the lowest non-compliance rate was:

- Limited Reach (LR) with 26% non-compliance among applicable websites.

#### Distribution of _EN 301 549_ Requirements by Web Page

[Table 8](#T08) shows the number (and percentage) of web pages violating each tested requirement, along with the average violations per page.

table08.txt

From [Table 8](#T08), we conclude that compliance with the tested requirements of EN 301 549 was also low at the page level. The requirements with the highest non-compliance rates were:

- 9.1.3.1 Info and Relationships with 85% of pages non-compliant;
- 9.1.4.3 Contrast (Minimum) with 80% of pages non-compliant;
- 9.2.4.4 Link Purpose (in Context) with 65% of pages non-compliant;
- 9.4.1.2 Name, Role, Value with 59% of pages non-compliant;
- 9.2.4.1 Bypass Blocks with 55% of pages non-compliant.

#### Analysis of Simplified Website Monitoring Results

The simplified monitoring method identified the most frequent non-compliances with the EN 301 549 requirements detectable by the automated tool used. Key findings include:

- The two most common issues, present in at least 80% of tested pages, are:
  - Non-compliance with the "9.1.3.1 Info and Relationships" requirement by 85% of pages (and 98% of websites), indicating various issues that prevent assistive technology users from correctly perceiving content and structure. Examples include inaccessible headers, table cells without headers, improper ARIA attributes, and unlabeled form fields.
  - Websites not adhering to minimum contrast ratios, affecting text readability. This issue was present on over 88% of websites and 80% of web pages.
- A second set of three issues affects over 90% of websites, though with lower prevalence at the page level:
  - The "9.2.4.1 Bypass Blocks" requirement, violated by 91% of websites and 55% of pages, causes difficulty for keyboard users who lack explicit mechanisms to skip repetitive menus and access main content directly.
  - Content creators fail to provide descriptive links, with issues in 65% of pages (and 91% of websites). Examples include repeated link texts like "Read More" or "Click Here," complicating navigation for users relying on link context.
  - Problems communicating accessible names or roles occur on 93% of websites and 59% of pages, highlighting a lack of consideration for assistive technology needs, leading to inadequate page interpretation.
- Lastly, the absence of alternative text descriptions for non-text content was observed on 73% of websites, though only 36% of pages. This impedes users who cannot view images from fully utilizing websites.

##### Comparison of Simplified Website Monitoring Results with Previous Period

[Table 9](#T09) compares the percentage of websites violating the success criteria in both monitoring exercises.

table09.txt

From [Table 9](#T09), we note a negative trend from the first to the second monitoring period. Violations increased for two requirements: "9.1.3.1 Info and Relationships" and "9.2.1.1 Keyboard." While the increase for the first may result from enhanced testing capabilities, the second reflects a lack of concern for keyboard accessibility.

On a positive note, compliance with requirements under the "Robust" WCAG principle, particularly "9.4.1.1 Parsing," improved. This may reflect the adoption of tools for syntactic validation. However, it's worth noting that modern browsers often correct such errors automatically, and this success criterion has been removed in the latest WCAG version.

### In-Depth Monitoring of Websites

This section describes the results for 54 websites. A total of 424 pages were analyzed, averaging 8 pages per website.

#### Distribution of _EN 301 549_ Requirements by Website in the In-Depth Monitoring

[Table 10](#T10) presents the number (and percentage) of websites violating each EN 301 549 requirement.

table10.txt

From [Table 10](#T10), compliance was low, with the following requirements having over 75% of websites non-compliant:

- 9.1.1.1 Non-Text Content with a 100% failure rate;
- 9.1.3.1 Info and Relationships with a 100% failure rate;
- 9.1.3.2 Meaningful Sequence with an 81% failure rate;
- 9.1.4.3 Contrast (Minimum) with a 100% failure rate;
- 9.2.1.1 Keyboard with a 96% failure rate;
- 9.2.4.4 Link Purpose (in Context) with a 96% failure rate;
- 9.2.4.6 Headings and Labels with a 94% failure rate;
- 9.2.4.7 Focus Visible with an 83% failure rate;
- 9.2.5.3 Label in Name with a 78% failure rate;
- 9.4.1.1 Parsing with an 81% failure rate;
- 9.4.1.2 Name, Role, Value with a 100% failure rate.

On the positive side, the following requirements had less than 10% of websites non-compliant:

- 9.1.2.4 Captions (Live) with all websites compliant;
- 9.1.3.3 Sensory Characteristics with a 2% failure rate;
- 9.1.3.4 Orientation with a 6% failure rate;
- 9.1.4.2 Audio Control with a 2% failure rate;
- 9.2.1.2 No Keyboard Trap with a 9% failure rate;
- 9.2.1.4 Character Key Shortcuts with all websites compliant;
- 9.2.2.1 Timing Adjustable with a 6% failure rate;
- 9.2.3.1 Three Flashes or Below Threshold with all websites compliant;
- 9.2.4.5 Multiple Ways with a 7% failure rate;
- 9.2.5.2 Pointer Cancellation with a 4% failure rate;
- 9.2.5.4 Motion Actuation with all websites compliant;
- 9.3.2.1 On Focus with a 7% failure rate;
- 9.3.2.2 On Input with a 6% failure rate;
- 9.3.2.3 Consistent Navigation with a 7% failure rate;
- 9.3.2.4 Consistent Identification with a 2% failure rate;
- 9.3.3.4 Error Prevention (Legal, Financial, Data) with a 2% failure rate.

#### Distribution of _EN 301 549_ Functional Performance Statements in the In-Depth Monitoring

This analysis considered all functional performance statements through their primary relationships. [Table 11](#T11) presents the results.

table11.txt

From [Table 11](#T11), we conclude that non-compliance with functional performance statements is high, even when assessed based solely on primary relationships. The only three statements not violated by all websites were:

- Usage with Limited Hearing with 28% of websites compliant;
- Usage with Limited Reach with 19% of websites compliant;
- Minimize photosensitive seizure triggers with 89% of websites compliant.

#### Analysis of Results from the In-Depth Website Monitoring

The in-depth monitoring method allowed the identification of the most frequent non-compliances with the requirements of EN 301 549 applicable to a manual analysis of websites. The following non-compliances stand out:

- The absence of alternative descriptions for non-text content, mostly images, was found on all analyzed websites. This poor practice prevents users who cannot see the images from fully using the website.
- Non-compliance with the requirement “9.1.3.1 Info and Relationships” in all analyzed websites reveals several types of issues that prevent users of assistive technologies from correctly perceiving the content and structure of the page. Examples of problems associated with this requirement include headings without accessible names, form fields without labels, or lists and tables without proper identification.
- Non-compliance with the requirement “9.1.4.3 Contrast (minimum)” represents a significant issue for the digital accessibility of the analyzed websites. This requirement ensures that text has sufficient contrast with the background, allowing reading by people with visual impairments, including low vision or color blindness. Failing to comply with this requirement can make accessing information and online services difficult.
- Non-compliance with the requirement “9.2.1.1 Keyboard” is another recurring problem on the analyzed websites. This requirement demands that all interactive elements on a page be accessible and usable exclusively via the keyboard, without relying on pointing devices such as a mouse. Violating this requirement can exclude users with reduced mobility or other conditions that prevent them from using a mouse, compromising equity in access to digital services.
- Content creators continue to fail to create hyperlinks with descriptions that allow users to understand the purpose of the link. Pages with hyperlinks without a comprehensible description outside of context are problematic for users who navigate pages through lists of links—this is the case for many blind users who rely on screen readers.
- Non-compliance with the requirement “9.2.4.6 Headings and Labels” is also a relevant issue in the analyzed websites, directly affecting the navigation and understanding of page structure for users with cognitive or visual impairments. This requirement states that headings and labels must be used clearly and consistently, facilitating identification and navigation between different sections of content. Violating this requirement can result in disorganized pages, making it difficult to locate information and interact with content, especially on complex platforms.
- Non-compliance with the requirement “9.2.4.7 Focus Visible” is a common failure on the analyzed websites, especially affecting users of keyboards and assistive technologies. This requirement demands that the focus, when navigating with the keyboard or other forms of interaction, be clearly visible, allowing users to easily identify where they are on the page and which elements they can interact with. The lack of a visible focus can cause confusion and frustration, especially for people with visual or motor impairments who rely on this indicator to navigate correctly.
- Two of the requirements associated with the WCAG principle “Robust” are among the most non-compliant requirements. This reflects the current state of the web—content that is not built with assistive technologies in mind. This situation prevents these technologies from communicating correctly to their users the content of the pages they wish to consult. Problems related to the communication of accessible names or roles (semantics) of elements occur on all analyzed websites. The same goes for issues related to the proper use of HTML elements—81% of the websites present HTML syntax errors.

##### Comparison of Results from In-Depth Website Monitoring with Results from the Previous Period

In [Table 12](#T12), the comparison of the percentage of websites violating the success criteria evaluated in both monitoring exercises is presented.

table12.txt

From the analysis of the results presented in [Table 12](#T12), we can conclude that the evolution from the first to the second monitoring period shows both progress and setbacks.

Regarding aspects related to the visual design of web pages, an increase in non-compliance with the following requirements was observed: Use of Color (9.1.4.1), Contrast (minimum) (9.1.4.3), Resize Text (9.1.4.4), and Focus Visible (9.2.4.7). This increase can hinder the experience of users, especially those with visual impairments. The lack of proper contrast and inappropriate use of colors can make content unreadable for people with color blindness or low vision, compromising the site's accessibility. Additionally, the absence of text resizing  can affect readability for users with vision difficulties. On the other hand, the decrease in non-compliance with Images of Text (9.1.4.5), Reflow (9.1.4.10), and Non-text Contrast (9.1.4.11) suggests an improvement in adapting content to the needs of users, especially on mobile devices and for those requiring more contrasting elements to better understand content structure.

Regarding keyboard interaction-related requirements, an increase in non-compliance was observed in the following cases: Content on Hover or Focus (9.1.4.13), Keyboard (9.2.1.1), Focus Visible (9.2.4.7), and Labels or Instructions (9.3.3.2). This increase can significantly harm the experience of users who rely solely on the keyboard to navigate, such as those with reduced mobility or visual impairments. The lack of visible focus, for example, makes efficient navigation difficult because users cannot identify where the focus is on the page, causing confusion and frustration. The increase in non-compliance with the requirement “9.2.1.1 Keyboard” suggests that many websites still do not allow full interaction via the keyboard, making them inaccessible to those unable to use a mouse. Additionally, the lack of clear labels and instructions (9.3.3.2) can make filling out forms or understanding functionalities more difficult, directly impacting the user experience. On the other hand, the decrease in non-compliance with the requirements for Identify Input Purpose (9.1.3.5) and Timing Adjustable (9.2.2.1) indicates an improvement in accessibility in terms of usability and time control, benefiting users who need more time or clear instructions to interact with the site's elements. The decrease in non-compliance with the requirement Multiple Ways (9.2.4.5) is also a positive sign, as it indicates that more sites are offering various alternatives for navigation and content searching, facilitating accessibility for users with different needs and preferences.

The analysis of the requirements related to page semantics reveals a mixed trend. The increase in non-compliance with the criteria Headings and Labels (9.2.4.6), Language of Parts (9.3.1.2), and Labels or Instructions (9.3.3.2) is concerning, as it suggests that more sites are not ensuring a clear and intuitive structure for users, which can make navigation and understanding content more difficult. The lack of proper headings and labels can make the navigation experience confusing, especially for screen reader users or those with cognitive impairments. On the other hand, the decrease in non-compliance with the criteria Identify Input Purpose (9.1.3.5), Page Titled (9.2.4.2), Language of Page (9.3.1.1), and Consistent Identification (9.3.2.4) is a positive development, as it indicates that websites are improving how they present content and ensure more predictable and understandable navigation, benefiting accessibility, particularly for users with cognitive and language impairments.

### In-Depth Monitoring of Mobile Applications

A total of 33 applications were analyzed, consisting of 17 Android applications and 16 iOS applications.

#### Results by EN 301 549 Requirement of Mobile Applications

In [Table 13](#T13), the number (and percentage) of applications violating each requirement is presented for all the applications, i.e., from both operating systems.

table13.txt

By analyzing the data presented in [Table 13](#T13), it is possible to determine the requirements most frequently violated:

- 11.1.3.4 Orientation - 97% of applications
- 11.1.4.3 Contrast (minimum) - 91% of applications
- 11.4.1.2 Name, function, value - 90% of applications
- 11.2.1.1 Keyboard - 88% of applications
- 11.1.3.1 Info and relationships - 84% of applications

##### Accessibility of Mobile Applications by Operating System

This section presents the results organized by operating system. In [Table 14](#T14), the percentage of applications violating each requirement per operating system is shown.

table14.txt

According to the data presented in [Table 14](#T14), it can be observed that both operating systems have similar non-compliance levels (24% for Android and 22% for iOS). However, it is important to highlight that some requirements show significant variations in their non-compliance levels between the two operating systems. These are:

- 11.1.3.1 Info and relationships - 94% of Android applications and 73% of iOS applications
- 11.1.4.4 Resize text - 50% of Android applications and 81% of iOS applications
- 11.2.4.7 Focus visible - 59% of Android applications and 7% of iOS applications

The differences observed in compliance with requirements 11.1.3.1 and 11.2.4.7 may be attributed to several factors. First, Apple’s design guidelines, such as the *Human Interface Guidelines*, more explicitly emphasize accessibility, including visible focus indicators and semantic structures, compared to Android's *Material Design*, which may allow more flexibility and inconsistency. Second, Apple's native tools and frameworks, like Xcode and UIKit, offer more integrated and easier-to-apply accessibility features, while Android developers may need to put in more effort to achieve similar results. Lastly, in multi-platform frameworks like Flutter or React Native, default configurations often favor iOS requirements, requiring additional customizations to ensure equivalent accessibility on Android.

On the other hand, development guidelines can also benefit the Android platform, as seen in the non-compliance results for requirement 11.1.4.4. Android promotes the use of scalable units like “sp” in *Material Design* guidelines, encouraging responsive design practices, whereas iOS developers may neglect dynamic text support due to less emphasis in the *Human Interface Guidelines*. Furthermore, frameworks like Jetpack Compose in Android provide native support for text scaling, making its application easier, while in iOS, developers need to manually configure Dynamic Type and ensure proper testing.

#### Distribution of Functional Performance Statements

Based on the results of the mobile application monitoring, support for functional performance statements was also analyzed, considering primary relationships. [Table 15](#T15) presents the results obtained from the first analysis, where only the requirements of primary relationships were considered.

table15.txt

By analyzing [Table 15](#T15), we can conclude that there is a high rate of non-compliance with the functional performance statements. Three of the functional performance statements are non-compliant in all of the mobile applications analyzed. Of the remaining ones, three statements are non-compliant in more than 85% of the applications, and the other two statements are non-compliant in more than 50% of the applications.

#### Analysis of the Results from In-Depth Mobile Application Monitoring

The in-depth monitoring method allowed for the identification of the most frequent non-compliances with the EN 301 549 requirements applicable to a manual analysis of mobile applications. Some notable non-compliances detected include:

- Applications regularly force the device into one orientation, limiting access for users with motor disabilities who benefit from other orientations.
- A large number of evaluated applications revealed issues with compliance with contrast levels (11.1.4.3 Contrast (minimum) and 11.1.4.11 Non-textual contrast). This means that many of these applications may not provide adequate support for users with visual disabilities, as the contrast between text and background or other elements may not meet the necessary standards for readability and accessibility.
- Content creators continue to fail to create interactive components with descriptions that allow users to understand their purpose. In particular, many interactive elements were used without a concrete definition of their function. For example, buttons were not announced as such, and texts were presented as interactive, which led users to test virtually every element to discover which ones were actually interactive.
- Most applications do not comply with the requirement “11.2.1.1 Keyboard,” meaning that many features are not fully accessible for people who rely on keyboards as their primary input device, making navigation and interaction difficult.
- Non-compliance with the requirement “11.1.3.1 Info and relationships” in several applications analyzed reveals various types of issues that prevent users of assistive technologies from having an accurate perception of the content and structure of the screen. Examples of problems associated with this requirement include headers without accessible names, form fields without labels, or lists and tables without proper identification.

##### Comparison of In-Depth Mobile Application Monitoring Results with the Previous Period's Results

[Table 16](#T16) presents a comparison of the percentage of mobile applications violating the success criteria evaluated in both monitoring periods.

table16.txt

By analyzing the results presented in [Table 16](#T16), we can conclude that the evolution from the first to the second monitoring period shows few changes in most requirements. However, there are notable changes in some requirements, both positive and negative. The requirements that evolved positively during this period are:

- 11.1.4.4 Resize text saw a decrease of 34% in non-compliant applications;
- 11.2.4.4 Link purpose (in context) saw a decrease of 72% in non-compliant applications;
- 11.2.5.1 Pointer gestures saw a decrease of 41% in non-compliant applications.

The requirements that evolved negatively during this period are:

- 11.1.3.2 Meaningful sequence saw an increase of 26% in non-compliant applications;
- 11.2.5.3 Label in name saw an increase of 40% in non-compliant applications;
- 11.4.1.3 Status messages saw an increase of 55% in non-compliant applications.

The positive aspects seem to focus on flexibility offered to users. In particular, the ability to resize text and not rely solely on pointer gestures. It is also positive to note an increased concern for the application's semantics, with a significant decrease in the number of applications non-compliant with requirement 11.2.4.4. However, a contradictory indication must be mentioned, observed in the increase of applications non-compliant with requirement 11.4.1.3. This requirement also negatively impacts assistive technology users and exemplifies what seems to be a negative trend of applications becoming less compatible with assistive technologies. Besides requirement 11.4.1.3, which reflects many cases where error messages are not announced by screen readers, issues are also evident in requirements 11.2.5.3 (where labels for various fields are presented visually but not available for assistive technologies) and 11.1.3.2 (where the sequence in which content is presented by assistive technologies does not match the sequence in which it is presented visually). This scenario appears to represent a reality in which mobile app developers do not know how to properly make the content of these applications available to the assistive technologies their users rely on.
