Appendix C: Overview of PAS 78 Guide to Good Practice in Commissioning Accessible Websites by Bruce Lawson

On March 8, 2006, the British Standards Institution (BSI) launched a Publicly Available Specification (PAS) as a guide to good practice in commissioning accessible websites. The document was commissioned by the UK's Disability Rights Commission, which describes itself as "an independent body established in April 2000 by Act of Parliament to stop discrimination and promote equality of opportunity for disabled people." 

The BSI develops and owns the copyright for PAS 78. It costs £30 plus sales tax and is available in a variety of formats, including accessible PDF, from

The Background of PAS 78

In April 2004, the UK Government-funded Disability Rights Commission (DRC) conducted a formal investigation into the state of web accessibility in the UK, discovering that 81 percent of sites failed to uphold the simplest World Wide Web Consortium (W3C) Web Content Accessibility Guidelines (WCAG) recommendations. 

Based on the DRC's findings, the authors of the Formal Investigation: The Web: Access and Inclusion for Disabled People report (in conjunction with City University) offered some additional advice to developers:

The report also courts controversy with Finding 5:

Nearly half (45%) of the problems experienced by disabled users when attempting to navigate websites cannot be attributed to explicit violations of the Web Accessibility Initiative Checkpoints. Although some of these reflect shortcomings in the assistive technology used, most reflect the limitations of the Checkpoints themselves as a comprehensive interpretation of the intent of the Guidelines.

The W3C responded, claiming that the report's authors didn't really understand the guidelines:

W3C/WAI's examination of the DRC data available as of 14 April 2004 shows that 95% of the barriers reported are indeed covered by existing checkpoints in WAI Guidelines ... Essentially, the interpretation of the data in the report fails to account for the role of browser and media player accessibility, and the role of interoperability with assistive technologies, in ensuring that people with disabilities can use Web sites effectively.

The fact that none of these questionable technical recommendations are repeated in PAS 78 suggests that the DRC no longer stands by them (and rightly so, in my opinion).

The DRC report is quasi-available at Ironically, however, the DRC seems incapable of publishing it in HTML, so Joe Clark has converted it and hosts it at

After the formal investigation into accessibility, the DRC decided that businesses needed some guidelines on how to begin making accessible websites, which eventually became the PAS.

This specification was initially authored by Julie Howell, an accessibility campaigner who works for the Royal National Institute for the Blind, and a Steering Group consisting of representatives of groups like the BBC, UK Cabinet office, IBM, Tesco, University College London, and the Usability Professionals' Association. It was then reviewed by a large team of stakeholders (including this author), and launched on March 8, 2006.

What PAS 78 Is Not

It is important to stress that PAS 78 is not a British Standard. Standards take a long time to develop because they require unanimity from all participants. A PAS is reviewed every two years, and may therefore be amended if circumstances change. In the fast-moving pace of the Web, this isn't a bad thing. 

The DRC's announcement explains:

A PAS is not a full British Standard but is developed using the same rigorous processes. We are supporting a PAS on website accessibility as it can be introduced more quickly than a British Standard which can often take several years to be introduced. The other advantage of supporting a PAS is that it can be updated frequently.

A further cause of confusion is the audience for PAS 78. While it was originally intended for developers, the terms of reference were changed early in the process. The PAS is intended to help people who commission web design, rather than developers themselves. There's little in the PAS that an experienced web professional who has read this book wouldn't know. It is written as a document that commissioners can understand and can use to discuss accessibility issues with web design project managers. Thus, PAS 78 is not a technical document, although reference is made to Web Accessibility Initiative (WAI) guidelines, usability testing, automated checking tools, and so on.

It is also vital to note that PAS 78 is not compulsory.

The Guidance in PAS 78

The PAS makes various recommendations regarding commissioning accessible websites, which I'll briefly summarize here (numbers refer to the paragraph of the PAS, which I can't quote, as the copyright belongs to the BSI).

The PAS states that developers should follow the lead of the W3C and WCAG 1.0 (7.1.1). It also explicitly advises the use of Cascading Style Sheets (CSS), as a way to separate content from presentation (7.1.2–4).

The PAS notes that PDF and Flash are proprietary (but published) formats that have significantly increased their accessibility in recent releases ( The PAS recommends that PDF/Flash be used to benefit the end user, not the content authors. It is generally accepted that well-thought-out Flash can benefit some users with cognitive disabilities, so this is a point well made. However, a common reason for using PDFs is to quickly repurpose printed documents to be on the Web, without all that tedious HTML coding. Additionally, some organizations favor PDFs because they believe that format can preserve branding, corporate typefaces, and the like. These particular reasons are perceived to benefit the originating organization, but generally are of no benefit over HTML to the end users, regardless of their disability.

The PAS draws the distinction between technical accessibility and real, usable accessibility, and advises involvement of users at all stages of the design process. It advocates the publication of an accessibility policy prominently on the site (6.1.1). The policy should be a working document that can form the basis of contracts with third-party suppliers (6.1.4). It should also explain the level of accessibility supported, who to contact with problems, and an honest statement of what is inaccessible, along with a reasonable estimate of when the repairs will be made and how people with disabilities can access this information or these services via alternative means (6.2.4).

Refreshingly, the PAS cautions against overreliance on automated accessibility testing suites, noting that they assist checking for technical accessibility (8.3.1), but manual checks should always be undertaken and nothing replaces actual user testing (4.3.1–2). Throughout the document, considerable emphasis is placed on involving people with disabilities at all stages of design and testing, using a user-centered design methodology.

Therefore, like the authors of this book, the PAS recommends designing for accessibility wherever possible, rather than attempting to retrofit a website after it's built (8.1.6) and that the site, once built, should be regularly checked (8.5.1). All organizations, large or small, should make certain that it's not only the developers who do the testing.

Not all the responsibility for accessibility is placed on the author, however. Annex G is a checklist for those purchasing authoring tools to ensure that it is even possible for proposed off-the-shelf content management systems to separate the content and styling, add alt-text, and so on. Suppliers are referred to an organization's accessibility policy (Annex C3), and it is suggested that suppliers list circumstances where their system will not generate sufficiently compliant documents, and how they propose to repair these shortcomings.

The PAS also recognizes that it takes two to tango— if you do your bit to author accessibly and design to meet the standards, the user must come equipped with a browser and any necessary assistive technologies that are smart enough to understand your pages, specifically noting that this is beyond the control of the developer (

The Impact of PAS 78

It is possible that the cost alone may prevent momentum towards PAS 78's adoption by opinion formers. The cost inhibits the number of people who can debate and discuss its content, particularly as the BSI vigorously enforces its copyright. 

Also, compliance with the PAS is voluntary (it is simply guidance, after all). It doesn't have the force of a full-fledged British Standard, although the names of the BSI and DRC should give it some prestige.

Nevertheless, I believe PAS 78 offers some good advice, including practical checklists on how to choose prepackaged software and how to choose a developer. It contains many sensible, practical suggestions to nontechnical commissioners, and the material describes best practice that is applicable far beyond the borders of the UK.

The Business Case for Accessibility

While not in the PAS, a most illuminating presentation at the document's London launch came from David Rhys Wilton, Intranet Marketing Manager at Legal and General, a large UK financial services company. Mr. Wilton explained that Legal and General was concerned about its exposure to litigation under disability discrimination laws, and rewrote the company's consumer sites to be more accessible. As a side effect, the company noted the following benefits:

The Legal Impact of PAS 78

Some in the UK have complained that it costs £30 for a document upon which "legal cases may be brought,"but this is a false argument. The legal criteria that a UK website must meet are defined by the Disability Discrimination Act. It is perfectly possible to make accessible websites without reading the PAS.

However, PAS 78 is sponsored and supported by the DRC, and it would therefore seem likely that a business in the process of implementing the PAS could claim that it was attempting to do its duty under the Disability Discrimination Act, if it came to court.

Struan Robertson, of the legal firm Pinsent Masons, and editor of the useful, commented:

The DRC's endorsement of PAS 78 is significant and it could be used in court to illustrate whether a business has complied with the Disability Discrimination Act. A failure to follow it could be damaging to an organisation's case; but compliance would be evidence of steps being taken to fulfill the legal duty.

It will be interesting indeed to see whether the PAS is cited in any court cases in the next few years, or whether the DRC and its successors will remain in the role of toothless watchdog.