IRSID Web Accessibility Inspection under ZDSMA — a Regulator Documenting Its Own Limits (Slovenia)

The Inspectorate of the Republic of Slovenia for Information Society (IRSID) enforces the ZDSMA, Slovenia's transposition of the EU Web Accessibility Directive. Its statutory report for the second reporting period, covering 1 January 2022 to 23 December 2024, records 468 inspections of websites and mobile applications: 394 websites under the simplified method, 50 websites under the in-depth method and 24 mobile applications. A further 16 in-depth website checks and 4 in-depth app checks were carried out to clear a backlog left by understaffing in the first reporting period.
The in-depth method is thorough — all 137 conditions of SIST EN 301 549 V3.2.1 applicable to websites, and all 162 applicable to mobile applications. It found 518 violations across the 50 website audits (154 in 2022, 185 in 2023, 179 in 2024) and 134 violations across the 24 app audits (50, 45 and 39 respectively). Simplified monitoring of 394 websites found 982 violations (233, 376 and 373).
What makes this entry worth cataloguing is what the report says next. In 2022, 2023 and 2024 the inspectorate limited each simplified website check to a maximum of three identified errors of different types, and states the reason plainly: kadrovska podhranjenost — staff undernourishment. The published violation counts are therefore floors imposed by the regulator's own capacity, not measurements of how inaccessible the sites are. The staffing table shows the single Inspector III post occupied only until 3 May 2024.
Accessibility statements were checked at 465 obliged bodies: 110 had a compliant statement, 192 had a partially compliant one breaching at least one of the seven conditions, and in 163 cases no accessibility statement existed at all. In 2022 alone, of 139 bodies checked, only 9 had a compliant statement. The report also records that public sector bodies had still not supplied the inspectorate with any qualitative or quantitative data on user feedback.
The report is unusually candid about perverse effects. It observes obliged bodies shrinking or removing content from their websites and apps in the name of aligning with accessibility guidelines rather than making that content accessible; obliged bodies pleading lack of funds; contractors hired to build or update sites not knowing the accessibility requirements; and a recent rise in the use of accessibility overlay plugins, mostly marketed as tools that supposedly deliver conformance with the harmonised standard SIST EN 301 549 V3.2.1.
Independent reporting sharpens the picture. Slovenia's public broadcaster RTV SLO reported that the inspectorate had recently been strengthened from one to three inspectors, that it had received only two reports from the public between 2021 and 2023, that statutory fines range from €200 to €2,000, and that around 95% of websites remained inaccessible despite the law. No evidence was found of fines actually being issued. Read this as a cautionary case: the legal architecture and the inspection method are sound, and the enforcement capacity behind them is not.

Read the full analysis: https://www.gov.si/assets/organi-v-sestavi/IRSID/Porocanje-po-ZDSMA/Porocilo_IRSID_11-_cl-_ZDSMA_za_drugo_obdobje_porocanja-1.pdf