SEGA's Disability-Inclusive Accessibility Monitoring — Bulgaria Tests 220 Public Websites With Blind, Motor- and Cognitively-Impaired Users

Bulgaria's State e-Government Agency (SEGA) was the body responsible for monitoring Directive (EU) 2016/2102 in the first monitoring period (websites 1 January 2020 – 22 December 2021; mobile apps 23 June – 22 December 2021). Its report, published in November 2021, follows Commission Implementing Decision (EU) 2018/1524 and checks against EN 301 549 V2.1.2 (WCAG 2.1 A/AA).
The sample was 241 websites and 13 mobile apps: 220 websites under the simplified method (22 success criteria, automated tools such as WAVE, Tingtun and Lighthouse plus manual verification), 21 under the in-depth method (50 criteria) and 13 Android apps tested with TalkBack. Distinctively, SEGA, with the support of the Ministry of Labour and Social Policy and the National Council for People with Disabilities, had users with disabilities test all 220 simplified-method websites: SEGA's report records 184 checks with a screen reader and speech synthesiser, 44 by a person with a motor disability and 45 by a person with a cognitive impairment (the figures overlap, as sites were checked by more than one user type). Bulgaria's own Institute of Public Administration lists the practice as 'Involving people with disabilities in web accessibility checks'. Organisations with non-compliance received explanations and instructions to fix it.
Reported findings are sobering: non-compliance with non-text content on 88% of the 220 sites, contrast on 87%, link purpose on 81%, headings and labels on 70%. In the in-depth sample of 21 sites, 90.48% failed non-text content and 95.24% failed name/role/value; none of the 13 mobile apps met the standard. Only 12% of sites had published an accessibility statement; a November re-inspection found 30% with a statement and 55% with a site map (up from 35%).
Useful lessons: SEGA found that add-on 'accessibility widgets' (text resize, contrast) on some ministry sites did not significantly improve conformity, since browsers already offer them; it observed that some organisations planned entirely new websites after in-depth review; it translated EN 301 549 into Bulgarian and offered a federated portal template built to accessibility requirements (used by the National Revenue Agency). A two-stage complaint procedure lets citizens escalate to the SEGA chairman, who can issue binding instructions.
Caveats: this is a regulator's self-published report; automated tests cover only part of the criteria; the in-depth sample is only 21 sites; and the report does not show outcomes of remediation beyond the statement and site-map re-check. The IPA page lists the practice as inactive and gives no outcome data.

Read the full analysis: https://www.mtc.government.bg/sites/default/files/reportonthemonitoringofaccessibilityifwebsitesandmobileapp.pdf