What is Directive 2102?

  • The complete title is Directive (EU) 2016/2102 of the European Parliament and of the Council of 26 October 2016 on the accessibility of the websites and mobile applications of public sector bodies.
  • Just like GDPR was standardisation of privacy laws across EU, Directive 2016/2102 is standardisation of accessibility laws across the European Union.
  • And like GDPR it came into effect in 2016 already, 26 October 2016 to be exact.
  • However, unlike the GPDR, it is a directive, not a regulation. Quote, Wikipedia:
    A directive is a legal act of the European Union which requires member states to achieve a particular result without dictating the means of achieving that result. It can be distinguished from regulations, which are self-executing and do not require any implementing measures.
    Meaning: a directive does not automatically becomes law in all EU member states, but binds the states to adopt its content into national law. This has to happen for Directive 2102 until 23 September 2018. The following will also apply: Any new website of the public sector released after this date has to comply with Web Content Accessibility Guidelines (WCAG) 2.1, Level AA by 23 December 2018. See section Timeline for further deadlines.


  • The directive includes websites, mobile apps, intranets and documents of public sector bodies.
  • At the latest by 23 December 2018 a technical specification regarding accessibility of these channels and forms of media will be published by the European Commission.
  • Until then and as mentioned above, regarding web accessibility Directive 2102 orientates itself at Web Content Accessibility Guidelines (WCAG) 2.1, Level AA by taking reference to EN 301 549, PDF, Chapter 9: Web
  • The directive also regulates accessibility of mobile apps. Mobile accessibility is not heavily emphasized/considered in WCAG 2.0, but it's addendum WCAG 2.1. Some accessibility experts suppose Web Content Accessibility Guidelines 2.1 to be the basis for an supplemental European Standard/technical specification.
  • National governments must regularly supervise the public sector's adherence to the law. A standardized methodology for this supervision will be communicated by the European Commission at latest December 22, 2018.
  • Accessibility or non-accessibility of public sector websites, web and mobile apps, intranets and documents must be publicly stated and recorded. If digital products and services do not suffice WCAG 2.0 this accessibility statement has to offer an explanation and an accessible alternative.
  • The directive describes minimum accessibility requirements, but individual countries can also make more far-reaching regulations. Article 2 states: "Member States may maintain or introduce measures in conformity with Union law which go beyond the minimum requirements for accessibility of websites and mobile applications established by this Directive."


What is Covered?

The directive aims to laws relating to websites and mobile applications of public sector bodies. Quote Article 3, 1:

Public sector body means the State, regional or local authorities, bodies governed by public law [...]

For example:

  • Administrations
  • Courts
  • Police departments
  • Public hospitals
  • Universities
  • Schools
  • Libraries

What is NOT Covered?

However, the directive also formulates exceptions:

  • Websites and apps of public broadcasters or "other bodies or their subsidiaries fulfilling a public service broadcasting remit" (Article 1, 3 lit. a)
  • "Websites and mobile applications of NGOs that do not provide services that are essential to the public, or services that specifically address the needs of, or are meant for, persons with disabilities." (Article 1, 3 lit. b)
  • Live streaming
  • Office file formats published before 23 September 2018
  • Online maps
  • Third party content that is not under control of the public body


  • Directive 2016/2102 comes into effect
  • Member states of the EU are conferred power to adopt national law so as to make reference to a more recent version of that technical requirements.
  • All member states must have implementation laws based on directive 2102 in place. National infrastructure for supervision of compliance with Directive 2102 must be established. Office files published by public sector bodies after this date must be accessible. New websites of public sector bodies must be accessible.
  • Model accessibility statement will be published, technical requirements will be finalized. Standardized methodology of supervision and modalities of reporting from national level to the European Commission will be finalized.
  • Non public intranets and extranets must be accessible
  • Recorded time based media must be accessible. "Legacy" websites that have been published before September 23, 2018 must be accessible.
  • Mobile apps of public sector bodies must be accessible


This website is a private, non-official project - and by no means a complete neither a legal reflection of EU Directive 2016/2102. I, a web developer living in Europe interested in web accessibility, tried to wrap my head around this directive.

Since this project is open source and on GitHub feel free to join and correct formulations if necessary.