Abstract:

This study is the second in a research series examining digital accessibility from complementary perspectives. Article 1 of the series introduced the Weighted Accessibility Concern Index (WACI) through a cross-tool comparison applied to healthcare websites across five EU member states. The present study applies WACI to government websites to examine a related question: whether the self-declared accessibility statements that public bodies are required to publish under EU law actually correspond to their measured accessibility levels. The Web Accessibility Directive (WAD, 2016/2102) requires EU public sector bodies to publish accessibility statements declaring WCAG 2.1 AA conformance. The European Accessibility Act (EAA), in force since June 2025, extended these obligations to the private sector. However, it remains unclear whether self-declared statements reflect actual accessibility levels. This study examines the declaration–audit gap between self-declared and measured accessibility for 24 government websites across six EU member states: Poland, Germany, Sweden, Finland, Romania, and Italy. Four service types were audited using WAVE and the Weighted Accessibility Concern Index (WACI): patient portals, farmer portals, citizen portals, and national WCAG supervisory body websites. Results show that Romania is the only country in the sample where all four websites lack any WAD-compliant accessibility statement. Mean WACI scores range from 9.25 (Finland) to 131 (Romania), showing that a high Enforcement Maturity Index score is necessary but insufficient to guarantee low WACI. A key governance finding is that the national supervisory bodies in Sweden, Finland, and Italy all declare Partial conformance on their own websites and explicitly acknowledge they cannot supervise themselves. The study contributes cross-country evidence on EU accessibility statement credibility in the post-EAA regulatory context.