Monitoring and supervision

The Agency for Digital Government is responsible for conducting a number of simplified and in-depth monitoring of public sector bodies’ compliance with the accessibility demands according to Danish and European law.


In accordance with the Web Accessibility Directive, the Danish government must monitor public bodies' compliance with accessibility demands. For this reason, the Agency for Digital Government conducts three types of monitoring: simplified monitoring of 250 websites, in-depth monitoring of 23 websites, and monitoring of 12 mobile applications (apps) annually. The practical part of the monitoring is outsourced to an external supplier.

Simplified monitoring

The simplified monitoring is an automatic assessment of 16 WCAG 2.1 criteria, and should therefore be regarded as a sample, which indicates the level of accessibility of the website in question.

The table below lists the 16 WCAG 2.1 criteria, which are tested in the simplified monitoring, and the corresponding EN 301 549 clauses.

EN 301 549 clause (ver. 3.2.1)WCAG 2.1 success criteriaName 1.1.1 Non-text Content 1.3.1 Info and Relationships 1.3.4 Orientation 1.3.5 Identify Input Purpose 1.4.3 Contrast (minimum) 1.4.4 Resize text 1.4.12 Text Spacing 2.1.1 Keyboard 2.2.1 Timing Adjustable 2.4.2 Page Titled 2.4.4 Link Purpose (in context) 2.5.3 Label in Name 3.1.1 Language on Page 3.1.2 Language of Parts 4.1.1 Parsing 4.1.2 Name, role, value

The current technology and Accessibility Conformance Testing Rules (ACT rules) limit the number of tested criteria. The Danish Agency for Digital Government uses the free and open source Portuguese tool ‘QualWeb’ developed by the University of Lisbon to conduct the simplified monitoring.

Go to QualWeb at GitHub

Read more about Accessibility Conformance Testing (ACT) Rules at

In-depth monitoring

The in-depth monitoring is a manual assessment of the website or app. This means that a selection of pages or screen dumps are tested. In-depth monitoring of a website will always be based on simplified monitoring, whereas in-depth monitoring of an app is based only on manual testing.

In-depth monitoring verifies interaction with forms, flows, user interface, modals, confirmation of data entries, error messages and other feedback from interaction with the user. Furthermore, in-depth monitoring assesses content such as videos and self-service solutions.

Because PDF is the most common document format on the websites of public sector bodies in Denmark, the Agency for Digital Government primarily focuses on these documents when conducting in-depth monitoring. The documents are evaluated based on the EN 301 549 chapter 10. The documents are assessed both manually and automatic.

The accessibility statement

As part of the simplified monitoring procedures, it is assessed whether the accessibility statement is updated. The in-depth monitoring contains a full evaluation of the accessibility statement, including the use of derogations.


The Danish Agency for Digital Government is responsible for the supervision process according to the Danish Web Accessibility Act:

  • That the websites and apps of public sector bodies are “perceivable, operable, understandable and robust” according to section 3
  • Whether the public sector bodies are entitled to derogate content based on “disproportionate burden” according to section 3 subsection 2. This means that, in justified cases, it might not be reasonably possible for a public sector body to make specific content fully accessible.
  • Whether the accessibility statement is updated, detailed, comprehensive, clear and published correctly according to section 4 subsection 1-3.

According to section 6 subsection 4, the agency can issue three different orders:

  • To make specific content accessible.
  • To make sure that the accessibility statement is adequate and updated.
  • To assign an accessible alternative.