Accessibility statement for the Bittimittari.fi service

Accessibility status of the browser interface and mobile applications

The Finnish Act on the provision of digital services 306/2019 (External link) (External link, in Finnish) stipulates that all public online services must be accessible. The service partly fulfils the requirements of critical A and AA requirements of the WCAG criteria. An external actor has audited the service, the assessment was conducted on May 25, 2023. Please see below for a list of non-conformities and exceptions applicable to the criteria.

Non-accessible content

The content discussed below is non-accessible for the specified reasons:
Non-compliance with the Act on the provision of digital services 306/2019 (External link) (External link, in Finnish)

The following content and/or functionalities do not yet meet the requirements:

Bittimittari.fi iOS application (version 1.0.0 and higher)

1.4.1 Use of Color [A]:

• There are links that are styled using color only to distinguish them as interactive elements.

1.4.11. Non-text contrast [AA], 1.4.3. Contrast (minimum) [AA]:

• The switch elements use color combinations in the OFF-position that do not meet minimum contrast requirements.
• There are some buttons that use background colours that may not pass the minimum contrast requirements with the background colours that the
  buttons are placed on top of. The button texts do pass contrast requirements though.

1.4.3. Contrast (minimum) [AA], 2.4.7. Focus visible [AA]:

• The default iOS system keyboard focus styles may not meet minimum contrast requirements.

1.4.3. Contrast (minimum) [AA], 1.4.4. Resize text [AA], 1.4.10. Reflow [AA]:

• There are some places in the layout where on high text zoom (200%), text is obscured by a background element, resulting in minimum contrast
  requirement not been met.
• There are instances where text in high zoom may not be fully visible and is truncated using ellipsis (...).
• Text may also be obscured by other elements such as adjacent text or containers or run out of the viewport.
• There are some buttons that contain text that cannot be re-sized.

2.1.2. No Keyboard Trap [A]:

• There may instances when keyboard focus gets trapped in the main navigation.

2.1.3. Keyboard (no exception) [AA]:

• On larger text size settings or higher text zoom, the main navigation element can cover an element receiving keyboard focus. This can cause
  users not to know which interactive element is being focused.

2.4.3. Focus order [A]:

• There may be instances where visible keyboard focus appears to surround other elements, in addition to the element that ia being focused.

2.4.4 Link Purpose (In Context) [A], 4.1.2. Name, role, value [A]:

• In the survey questions element, there are buttons that use duplicate names. The buttons are grouped to minimize the impact the duplicate
  names may cause users.

2.4.6. Headings and labels [AA]:

• Some buttons may have long names and contain punctuation (button text), which may pose difficulties for people using speech commands to interact with the application.

4.1.2. Name, role, value [A], 2.5.3. Label in name [A], 3.1.6. Pronunciation [AAA]:

• There are some cases where abbreviations of terms (like s for second or ms for millisecond) are not pronounced correctly by a screen reader.

Bittimittari.fi Android application (version 1.0.1 and higher)

1.3.1. Info and relationships [A], 1.3.5. Identify input purpose [AA]:

• The accordion buttons in the the FAQ view may now inform users of their actual state (opened or closed).
• The sorting buttons in the the Help view may now inform users of their state (which option is seected).

1.4.11. Non-text contrast [AA]:

• The disabled switch elemeent uses colour that is close to the active switch color, especially in its luminocity value. This may cause some users to not understand the switches state.
• There are some buttons that use background colours that may not pass the minimum contrast requirements with the background colours that the
  buttons are placed on top of. The button texts do pass contrast requirements though.

1.4.3. Contrast (minimum) [AA], 1.4.4. Resize text [AA], 1.4.10. Reflow [AA]:

• There are some places in the layout where on high text zoom (200%), text is obscured by a background element, resulting in minimum contrast
  requirement not been met.
• There are instances where text in high zoom may not be fully visible and is truncated using ellipsis (...).
• Text may also me obscured by other elements such as adjacent text or containers or run out of the viewport.
• There may be some buttons that contain text that cannot be re-sized.
• There is some text in the Licenses-view that cannot be re-sized.

2.4.3. Focus order [A]:

• Keyboard focus can remain in the main navigation after a button has been activated, requiring keyboard and screen readers users to move backwards in order to access the view’s content.
• In some instances, focus may skip the main heading after a view is loaded.
• In the “What do these results mean?” view keyboard tab order does not follow visual order.

2.4.4 Link Purpose (In Context) [A], 4.1.2. Name, role, value [A]:

• In the survey questions element, there are buttons that use duplicate names. The buttons are grouped to minimize the impact the duplicate
  names may cause users.
• There may be some links that open a new browser window or tab but this information is not available to users before they click on the link.

2.4.6. Headings and labels [AA], 4.1.2. Name, role, value [A]:

• Some headings are not semantically marked as headings
• Some buttons may have long names and contain punctuation (button text), which may pose difficulties for people using speech commands to interact with the application.

2.4.7. Focus visible [AA], 1.4.3. Contrast (minimum) [AA]:

• Visual focus styles may not pass the minimum contrast requirements.

4.1.2 Name, role, value [A]:

• Some buttons may be missing an accessible role, resulting in screen readers not announcing the interactive element’s type.

4.1.2. Name, role, value [A], 2.5.3. Label in name [A], 3.1.6. Pronunciation [AAA]:

• There are some cases where abbreviations of terms (such as “Mbit/s”) are not pronounced correctly by a screen reader.

4.1.3. Status messages [AA], 1.3.1. Info and relationships [A]

• In the Measurement-view, while measurement is in progress there may not be any announcementsby the scree reader of the progress.
• If text size used is larger than the default, the screen reader may not finish announcing the measurement being completed.

Bittimittari.fi browser interface 

1.3.1. Info and relationships [A]:

• There may be some interactive elements which look disabled but still receive keyboard focus.

1.3.1. Info and relationships [A], 2.4.4. Link purpose (in context) [A]:

• There may be some elements that appear to be interactive but are not clickable.

2.1.1. Keyboard [A]:

• The survey element in the website cannot be accessed using keyboard only.

2.4.3. Focus order [A]:

• After closing a modal, keyboard focus might not move to the expected next element in the visual order.
• In the history view, the keyboard focus order is not the same as the perceived visual element order.

1.4.4. Resize text [AA], 1.4.10. Reflow [AA]:

• There are some places in the layout where on high text zoom (200%), text is obscured by a another element, resulting in minimum contrast
  requirement not been met.
• Text and other content may also run out of the viewport in some places when using high text zoom.

1.3.1. Info and relationships [A], 1.3.5. Identify input purpose [AA]:

• The accordion element has buttons that show and hide content, but their states are not are not announced by a screen reader or they are not
  announced correctly.
• The main navigation uses color to show sighted users which view is active but for screen reader this information is not available.

2.4.4 Link Purpose (In Context) [A], 4.1.2. Name, role, value [A]:

• In the survey questions element, there are buttons that use duplicate names. The buttons are grouped to minimize the impact the duplicate
  names may cause users.
• There may be some links that open a new browser window or tab but this information is not available to users before they click on the link.

2.1.1. Keyboard [A], 2.4.1. Bypass blocks [A]:

• The skip-link used to bypass repeating questionnaire steps is not visible for keyboard users.

2.4.7 Focus Visible [A], 2.4.4 Link Purpose (In Context) [A]:

• There may be some links that do not receive visual focus or where the visual focus style is not visible.
• There may be some links that open a new browser window or tab but this information is not available to users before they click on the link.

2.4.6. Headings and labels [AA]

• There are places where headings may skip levels or are not organized in a hierarchical manner.
• There may be text that is marked as a heading but should not be.

2.4.6. Headings and labels [AA], 4.1.2. Name, role, value [A]:

• Some buttons may have long names and contain punctuation (button text), which may pose difficulties for people using speech commands to interact with the application.

4.1.2. Name, role, value [A], 1.3.1. Info and relationships [A]:

• Screen reader users may not be notified when they have performed an action with an audible notification or a prompt.
• There is instruction text in a form element in the questionnaire section that is hidden from screen readers using aira-hidden=”true” which shoudn’t be.

The aim is to rectify the main shortcomings during 2023.

Accessibility statement preparation

This statement was prepared on 25 May 2023.

The statement is based on a third-party assessment of whether or not the website meets the requirements of Directive (EU) 2016/2102.

The latest review of the statement was carried out on 25 May 2023.

Bittimittari.fi-website accessibility status

This website partly fulfils the requirements of the Finnish Act on the provision of digital services 306/2019 (External link). However, it meets the critical A and AA requirements of the WCAG criteria. Please see below for a list of non-conformities and exceptions applicable to the criteria.

Non-accessible content

The content discussed below is non-accessible for the specified reasons:

Non-compliance with the Act on the provision of digital services 306/2019 (External link) 

The following content and/or functionalities do not yet meet the requirements:

1. (WCAG 1.3.1) The website contains table structures with column headings that are not programmatically determined.
2. (WCAG 1.3.1) There are minor shortcomings in the use of heading levels. Some levels have been skipped, and not all headings have been programmatically determined as headings.
3. (WCAG 1.1.1) Graphs with no text alternatives have been used in some PDF documents.
4. (WCAG 1.3.1) Some PDF documents have layout issues that hamper screen reader use (for example, unnecessary line breaks and headings with no heading levels).
5. (WCAG 1.3.1) Table structures in some PDF documents have issues that hamper screen reader use (for example, table structures are used for text layout, there are no programmatically determined column headings, and similar data have been divided into several tables).
6. (WCAG 1.3.1) There are no links to the footnotes in the text of some PDF documents, and interpreting them is difficult when using a screen reader.
7. (WCAG 1.4.3) Some PDF documents have contrast issues (white text on a blue background and links shown in the same colour as the body text).

The aim is to rectify the main shortcomings during 2023 and 2024.

Certain content is excluded from the applicable legislation

The following content and/or functionalities are not accessible as they are not covered by the applicable legislation (Act on the provision of digital services 306/2019).

1. A YouTube channel administrated by Traficom and the Dreambroker service have video content published before 23 September 2020. Some of this video content does not have subtitles and/or audio description. Under the Act, video content published before 23 September 2020 need not be made accessible retroactively or taken down.

E-services

Certain e-services that required the user to log in are part of a separate entity. These e-services do not fulfil all of the accessibility criteria. The systems are currently being rebuilt.

Accessibility statement preparation

This statement was prepared on 13 September 2022.

The statement is based on a third-party assessment of whether or not the website meets the requirements of Directive (EU) 2016/2102.

The latest review of the statement was carried out on 5 May 2023.

Feedback and contact details

Did you notice an accessibility problem on our website? Let us know about it, and we will do our best to offer the information and content in an accessible format as soon as possible! You can contact us either by using our online form or by email.

Use this online form to give feedback on accessibility (External link)

Email address for providing feedback: kirjaamo(at)traficom.fi

Traficom's Communications department is responsible for accessibility on the Finnish Transport and Communications Agency Traficom’s website and for processing any feedback. 

Implementation procedure

If you notice accessibility issues on the website, first give feedback to the website administrator. Receiving a response may take 14 days. If you are not satisfied with the response or you receive no response within two weeks, you can provide feedback to the Regional State Administrative Agency for Southern Finland. The Agency’s accessibility requirements website (saavutettavuusvaatimukset.fi) explains how you can lodge a complaint and how the matter will be processed.

Supervisory authority’s contact details

Regional State Administrative Agency for Southern Finland
Accessibility oversight unit

• www.saavutettavuusvaatimukset.fi (External link)
• saavutettavuus(at)avi.fi
• Telephone +358 295 016 000 (exchange)