What services and contents are covered by the Act?
Table of contents
Contents and functionalities covered by the Act
The key contents and functionalities to which the Act applies are listed below. The purpose is to help you understand that most of the functions and content of websites and applications fall in the scope of the Act. The list is an example which means that there may also be other content to which the requirements apply. Exceptions, i.e. content that is not covered by the accessibility requirements, are listed separately under another heading.
- Texts; news items, instructions, service descriptions, blog posts
- Images, graphs and infographics
- Interactive and dynamic graphics
- Videos and podcasts saved or embedded on the website or app or published on a social media channel (including video players)
- Navigation and the user interface in general
- Online forms (html forms)
- Appointment booking services
- Chat services embedded on the site
- Event calendars
- Office software files that are stored on the site, such as pdf and Word files and forms
How these contents and functionalities are made accessible depends on the content.
For example, a text should have clear, logical headings. The language should be easy to understand. Images and infographics must be given a description (alternative text) and videos must have subtitles. It must be possible to navigate and operate on the pages by only using the keyboard. Many things must be taken into account in regard to PDF and Word files, such as colour contrasts, headings and alternative text in images.
When a form has been implemented in accordance with the accessibility requirements, the customer should also be able to fill it in electronically.
Services covered by the Act
The accessibility requirements of the Act apply to all websites and mobile applications of the parties covered by the Act that are available online. The site or application may be open to everyone or require login.
From a legal point of view, the scope of the service or the target group does not really matter. In other words, a digital service aimed at other authorities or experts should also comply with the accessibility requirements. The purpose of the Act is to provide equal access to information for all people.
In practice, it is a good idea to start improving accessibility with services and content that are significant to the general public or, in particular, persons with disabilities, if you cannot do everything at once. An unreasonable burden allows for a discretionary, planned and temporary deviation from the accessibility requirements.
Read more about the types of actors that have an obligation to comply with the accessibility requirements.
Workplace intranets and extranets
Intranets and extranets used in workplaces by public authorities and institutions governed by public law are also subject to the requirements of the Act. These services are subject to their own transition period: Intranets and extranets that were published or fully reformed on 23 September 2019 or after must comply with the accessibility requirements.
The accessibility requirements do not apply to intranet and extranet services published before 23 September 2019 if they have not been fully updated.
Intranets and extranets refer to systems that are used in the workplace by the employees specifically.
With regard to the workplace intranet and extranet, the law applies to the content of the website, but not to the other systems included in it. In other words, when you switch from an intranet or extranet view to another system to e.g. enter working hours and travel claims or use the case management system, the Act no longer has the right to supervise such systems. Other binding legislation must still be taken into account.
An interaction between a limited group of people in order to perform tasks, such as a construction project or a development project, is considered a part of a workplace extranet. Even if these work tasks involve participants from several different organisations, it is a question of managing one shared task or project. This should distinguish between online services intended for other authorities or experts, which must comply with the accessibility requirements within the framework of normal transition periods.
It should be noted that the Act on Public Procurement and Concession Contracts already obliges ICT procurements to take accessibility into account. In addition, under the Non-Discrimination Act, the user may require reasonable adaptations to systems or interfaces in order to be able to carry out their work.
If the organisation uses social media channels, such as YouTube, Facebook and Twitter, the content published by the organisation is subject to the requirements of the Act. For example, YouTube videos should have subtitles according to the requirements. Content generated by users themselves, such as Facebook comments added to an organization’s page, is excluded from the requirements.
If there are shortcomings in the accessibility of social media channels or in the content published in them, the shortcomings should be described in the organisation’s accessibility statement, and the organisation should be prepared to provide any essential information published in the social media channel also in an accessible format on the website or, if necessary, in a manner that is suitable for the user.
It should also be noted that important content should not be published solely on social media. In any case, information that is important to users must also be available on the organisation’s own website.
The accessibility of social media content can be improved through the channels’ own functions: for example, Twitter makes it easy to set up a feature that allows you to write alternative text for your images, and YouTube has its own video captioning tool.
Social media feeds and embedded content on the website
Feeds or embedded content from social media channels may be added to websites. However, it should be ensured that the feed does not make the page too confusing and that the user can easily scroll past the feed if necessary, for example by only using the keyboard or a screen reader if the person is visually impaired. If a feed or its non-accessible content make it too difficult to access the site, it is not advisable to add the feed to the site.
More information and instructions on the accessibility of social media on Celia’s saavutettavasti.fi website (in Finnish only)
Content published in other organisations’ channels
If the organisation publishes or submits content for publication in another organisation’s online service, the content must comply with the accessibility requirements. For example, if the ELY Centre produces a PDF publication that is published in the National Library of Finland’s Doria archive, the ELY Centre is responsible for ensuring that the publication complies with the accessibility requirements.
This rule means that an organisation can not circumvent accessibility requirements by publishing non-accessible content on another organisation’s website or social media channels.
The contents and services listed below do not have to comply with the requirements. If the site or application contains exceptions that are not in the scope of the accessibility requirements, this must be stated in the accessibility statement.
Live video and audio broadcasts
According to the Act, live video and audio broadcasts do not have to comply with accessibility requirements. In practice, live broadcasts do not need to have subtitles or audio description.
Videos and audio broadcasts that are recorded or embedded on the website must be made compatible with the accessibility requirements within 14 days of publication.
More information on the accessibility of videos and audio broadcasts and accessibility requirements (in Finnish).
Contents temporarily used by a limited group in early childhood education and care and teaching
In teaching and early childhood education and care, teaching content may be used temporarily and in a limited group even if is does not meet the accessibility requirements. Temporary use includes, for example, a period lasting a school semester. Temporary use cannot continue for several years.
The exception makes it possible for teachers and pupils themselves to produce content that can be utilised in teaching without in-depth knowledge of accessibility requirements or technologies that would support the implementation of accessible content. The exception also makes it possible to test different new services and contents in a limited group.
If a digital study material or service that has been temporarily used is introduced permanently, it must be made compatible with the accessibility requirements. Learning environments and online courses are often used year after year, and should therefore be accessible. If a teacher uses the same teaching video every semester, this does not constitute temporary use and therefore the video must be accessible.
Other content of early childhood education and care and teaching, such as general websites or applications for managing or exchanging information between home and school or early childhood education and care, belong to the scope of the Act.
WCAG Success Criteria 1.1.1 Non-textual content allows an exception in alternative texts and subtitling requirements for specific tests and tasks, for example when the test is a listening skills exam or it involves testing, developing or practising visual skills. In other words, if it is not appropriate for the purpose or sensible to provide the test/task is in text format, it does not need to have subtitles.
Nevertheless, such online tasks should have a brief alternative text to describe the type of task. In addition, alternative ways of offering study material should be considered if the student wishes to participate in teaching but is not able to complete all assignments.
The accessibility statement must state why the service is not fully accessible. In addition, the statement must contain instructions on how users can give feedback on accessibility problems and how they can obtain alternative tasks or materials in an accessible format.
Maps and mapping services
Maps, mapping services and map applications are not in the scope of the Act. In practice, terrain or weather maps do not have to meet accessibility requirements.
However, if an online map is intended for navigation purposes, in practice to provide guidance on e.g. where an authority’s office is located, the essential guiding content must also be offered in a format that meets the accessibility requirements.
In practice, the location of the office (address, nearby landmarks or public transport stops) must also be indicated as text if the map view does not meet the accessibility requirements.
It should be noted that the exception only applies to maps and mapping services, not to cases in which the map has been used to visualise e.g. statistical data. For example, infographics showing Finland’s population growth regionally using the Finnish map do fall in the scope of the Act. In other words, alternative texts should be created for such maps, the same as for infographics.
If key information is not provided in the body text and the alternative text for the image would be too long, you can add a link to a separate accessible table or text file. In such cases, the alternative text should indicate that the infographic is explained in text format, for example in the next section or at the beginning of the page.
Archived website or content
A website that was archived before 23 September 2019 or its archived content are not subject to accessibility requirements. If a website or its contents were archived on or after 23 September 2019, the accessibility requirements must be complied with. No changes are made to the archived website or its content, it is not updated, and it is not required for active administrative processes.
The time when the website or material was archived determines
- at what level of detail the shortcomings in accessibility must be reported in the accessibility statement and
- in which section of the statement the shortcomings are listed.
The contents of a website archived before 23 September 2019 are described in the accessibility statement under the heading “Not within the scope of legislation”. This is content that is not subject to accessibility requirements. This may be a file, a blog post, a news item or other. However, the Act on the Provision of Digital Services applies to content on published and archived websites from 23 September 2019 onwards, and the content must be accessible regardless of whether it has been archived or not. If there are shortcomings in the accessibility of such content, it should not be listed in the statement under the heading “Not within the scope of legislation” but in the section “The website does not fully comply with the accessibility requirements”.
The entire website may also be archived. Accessibility requirements do not apply to websites archived before 23 September 2019. If the website was archived on 23 September 2019 or after, the website must comply with the accessibility requirements, and the website must have an accessibility statement and a feedback channel.
In some cases, the archiving might have taken place between 23 September 2019 and 23 September 2020, and the accessibility requirements for the website should be complied only on 23 September 2020 and after. In these cases, it is sufficient to publish an accessibility statement after the end of the transition period stating that the website has been archived before the accessibility requirements entered into force. In this case, there must still be a feedback channel available.
Content produced by an external party in the online service that is not funded, developed or supervised by the service provider is not covered by the requirements of the Act. The exception applies, for example, to social media content or other content produced by users themselves that cannot be modified to meet the accessibility requirements. If publishing such content on a website may interfere with site access, the organization should not publish it.
However, exceptions do not include content that the service provider has ordered from an external partner. In other words, the service provider should ensure the accessibility of, for example, reports or infographics commissioned by them.