How confident are you that your accessibility statement is accurate?

Illustration showing two U-shapes representing UU, the abbreviation for Universal Design. The shapes are arranged to form a face with a downward-turned mouth and eyes depicted as red crosses.
Photo of Agency Director and Consultant Sverre Krogsrud at AG AlfGundersen

Sverre Krogsrud

Many people are surprised by just how complex it actually is to fill out an accessibility statement and to correct any errors they find on their websites. Just ask Helseplattformen.

Three years ago, universal design (UD) of websites became a legal requirement for the entire public sector. Everyone should be able to find information about municipal services, apply for a spot in daycare, schedule a doctor’s appointment, and find toll rates—including those who use screen readers, cannot use a mouse pointer, or need high contrast to read what’s on the screen.

Along with the stricter requirements came the obligation to publish an accessibility statement. It is a document you fill out yourself—in other words, a self-declaration—that must be posted on the website. The accessibility statement describes the extent to which the pages meet the accessibility requirements. The statement is the map, while the website is the terrain.

The reality is that the map is rarely actually checked against the actual terrain. This is a major problem, given that the accessibility statement is one of the best tools public agencies have to ensure they do not violate accessibility requirements.

By actually going through the points in the declaration and testing them in a professional and thorough manner, you can identify errors and violations of the universal design requirements before public regulatory authorities do. Then you can correct and resolve errors and deficiencies quickly and, in many cases, quite easily. This is good for users, it’s good for trust in your organization, and it can be good for your budgets. Failing to meet universal design requirements can actually be costly.

We do not believe it is a matter of will when public sector organizations take the accessibility statement too lightly. Rather, the problem is that few have the expertise and resources required—or the knowledge of what expertise and resources are needed.

It's easy to make a mistake, even when you mean well

The much-discussed Health Platform is responsible for HelsaMi, a digital service that nearly half a million residents of Trøndelag rely on to access their health information. When the Norwegian Authority for Universal Design of ICT tested the website in the summer of 2025, it found 119 individual errors across 12 of the 14 requirements it reviewed.

HelsaMi was ordered to make corrections and given a deadline, but when the deadline expired in December, the regulatory authority still found 64 errors. The company was fined 50,000 kroner per day until it corrected the errors after a relatively short period of time.

The most interesting thing is what Helseplattformen itself said when it was fined:

“We underestimated the complexity of the work. We should have prepared ourselves better and sooner, with greater expertise in this area, in order to follow up on all violations,” said CEO Siri Berg.

This admission comes from a large, well-resourced company that actually tried to do things right, but nevertheless realized that it had underestimated the amount of expertise the work actually requires.

Non-compliance in 98 percent of the web solutions tested

The health platform is not an isolated case. The UU Inspectorate has audited 88 ICT solutions, most of which are in the public sector. In a full 98 percent of them, they found violations of the minimum requirements. 98 percent. 86 out of 88. Our claim is that many of these violations could have been detected and corrected quickly and easily if the work on the accessibility statement had been done thoroughly and by someone with the right expertise.

We don't believe that anyone is trying to shirk their responsibility to meet the requirements that will ensure everyone can use their digital services. The reason is the one the Health Platform pointed out: complexity.

To complete the declaration correctly, the website must be tested against the 47 requirements of the WCAG standard. This requires expertise in web development, UX (user experience), and the relevant regulations.

It’s not enough to run the website through an automated testing tool. Many of the most serious errors only become apparent when a person actually goes through the user flows using a screen reader and keyboard.

The responsibility for ensuring that the work on the statement is done properly and that errors are corrected does not lie with a single web manager. It lies with the organization’s top executive.

The good news is that, despite its complexity, it doesn’t have to be a major undertaking—not when you know what’s required. And we do. We help public sector organizations test their websites in real-world conditions, accurately document their status in their accessibility statement, and develop a concrete plan to address any non-conformities.