WCAG 2.2 AA Partial Audit of the Eemnes Municipality Website Content

This report describes the results of the sub-study on the accessibility of the content on the eemnes.nl website, commissioned by Bel Combinatie.


 

Eemnes Municipality Logo

Summary

This study was conducted by Shift2 between March 30, 2026, and April 13, 2026. For this sub-study, a representative sample of 20 published web pages featuring various types of content was compiled.

The content reviewed does not fully comply with WCAG 2.2 Levels A and AA. In this sub-study, 30 success criteria were evaluated. Twenty-five of these 30 success criteria (83%) were met. Deviations were identified in 5 success criteria.

The Eemnes municipal website is already quite accessible, but there are still a few areas that could be improved. Some sections of the website are not structured clearly enough, making it difficult for assistive technologies such as screen readers to properly interpret the page. Examples include headings that do not clearly indicate what a section of text is about, or lists and tables that are not technically set up correctly.

Most of the problems lie in the PDF documents. These are often not properly tagged, making it difficult for people who use assistive technology to read or understand the content.

We recommend periodically reviewing content for recurring patterns of accessibility issues and embedding accessibility into the publication process.

About this study

A partial audit was conducted on the website to assess the accessibility of its content and determine the extent to which it complies with WCAG 2.2 Levels A and AA (EN 301 549).

This research report is valid for three years. In the event of substantial changes to the content, we recommend commissioning a supplementary or new study.

Scope of the sub-study

This sub-study pertains exclusively to the content of the website that the organization can enter or modify via the content management system.

This study evaluated 30 of the 55 success criteria of WCAG 2.2 Levels A and AA.

The remaining 25 success criteria relate to the technical aspects of the website and are evaluated in the separate technical sub-study.

Together, these two sub-studies constitute the complete evaluation of the website.

Success criteria assessed in the technical sub-study

The following success criteria were not evaluated in this content study and are covered in the separate technical sub-study:

SCNameLevelReason for exclusion
3.3.1Error identificationAForm validation is handled entirely by the system
3.3.3Suggested correctionAAError suggestions are generated by the system
3.3.7Unnecessary importsAThe reuse of previously entered data within processes is technically enabled within the platform and is managed centrally.

Scope and Methodology

The study was conducted using a representative sample. Within this sample, the accessibility issues identified were described as specifically as possible. Where possible, recommendations were included to address the issues.

This study does not provide an exhaustive overview of all possible accessibility issues. The findings represent a snapshot of the situation at the time of the study.

What is WCAG?

WCAG (Web Content Accessibility Guidelines) are internationally recognized guidelines for digital accessibility, based on four principles: Perceivable, Operable, Understandable, and Robust. Measurable success criteria have been established within these principles.
More information: WCAG 2.2 (Dutch translation)

Summary of results

The results are presented in two tables: by success criterion and by WCAG principle.

Results by success criterion

Success criterionLevelResult
1.1.1 Non-textual contentADoes not meet the requirements
1.2.1 Audio-only and video-only (pre-recorded)Anot available
1.2.2 Captions for the deaf and hard of hearing (pre-recorded)Anot available
1.2.3 Audio description or media alternative (pre-recorded)Anot available
1.2.4 Captions for the Deaf and Hard of Hearing (live)AAnot available
1.2.5 Audio description (pre-recorded)AAnot available
1.3.1 Information and RelationshipsADoes not meet the requirements
1.3.2 Meaningful orderAMeets the requirements
1.3.3 Sensory propertiesADoes not meet the requirements
1.3.5 Identify the purpose of the importAAnot available
1.4.1 Use of colorADoes not meet the requirements
1.4.2 Sound ControlsAAnot available
1.4.3 Contrast (minimum)AADoes not meet the requirements
1.4.5 Images of textAADoes not meet the requirements
1.4.10 ReflowAAMeets the requirements
1.4.11 Contrast of non-textual contentAAMeets the requirements
2.1.2 No keyboard dropAMeets the requirements
2.1.4 Single-character keyboard shortcutsAMeets the requirements
2.2.2 Pause, stop, or hideAnot available
2.3.1 Three flashes or below the threshold valueAMeets the requirements
2.4.2 Page TitleADoes not meet the requirements
2.4.4 Link target (in context)ADoes not meet the requirements
2.4.6 Headings and labels AADoes not meet the requirements
2.5.3 Label in the nameADoes not meet the requirements
2.5.8 Size of the selection area (minimum)AAMeets the requirements
3.1.1 Page LanguageAMeets the requirements
3.1.2 Language of componentsAAMeets the requirements
3.2.4 Consistent identificationAADoes not meet the requirements
3.3.2 Labels or instructionsAMeets the requirements
4.1.2 Name, role, and valueAMeets the requirements

Research scores

The table below shows, for each WCAG principle and each WCAG level, how many success criteria were tested and how many of those were approved.

WCAG PrincipleLevel ALevel AATotal
Observable3 / 95 / 78 / 16
Operable4 / 71 / 25 / 9
Understandable2 / 22 / 24 / 4
Robust1 / 11 / 00 / 1
Total10/198 / 1118/30

Findings

The identified issues are described below. For each issue, the location and a description of the problem are provided, followed by the impact on the user and a recommendation for resolving the issue.

1.1.1 Non-textual content A

Provide meaningful text alternatives for images and other non-text content.
Information about Success Criterion 1.1.1 Non-text Content

Result: Does not meet requirements

Finding 1 (SC 1.1.1)

https://www.eemnes.nl/robbert-kouwenhoven

The page contains a portrait photo of Robbert Kouwenhoven with an empty alt text (alt=""). As a result, screen readers skip over the image. This is incorrect because the image shows a portrait of the person who is the focus of the page. Consequently, screen reader users are not informed that there is an image on the page or who is depicted in it.

Recommendation: 

Provide the portrait photo with an appropriate text alternative that includes the person's name, for example: alt="Robbert Kouwenhoven".

Finding 2 (SC 1.1.1)

https://www.eemnes.nl/bewust-hout-stoken

The page features an image of a person putting wood into a wood-burning stove. This is a stock image that supports the page’s content but does not provide any additional information.The information conveyed by the image is already present in the page title and the text on the page. The image now has descriptive alternative text ("Person placing wood in a wood-burning stove with a fire burning inside."). This describes what is visually visible, whereas alt text is intended to convey the meaning of the image. Because the image does not add any additional meaning, this alt text duplicates information for screen reader users.

Recommendation: 

Give the image an empty alt attribute (alt=""), so that assistive technology skips the image and duplicate information is avoided.

Finding 3 (SC 1.1.1)

https://cuatro.sim-cdn.nl/eemnesbe64f5/uploads/Informatieavond%20voor%20omwonenden%20over%20toekomstplan%20voor%20Ocriet%20-%20Sterk%20-%2028%20januari%202025_0.pdf?cb=JUh8jyOY

The PDF document contains the Eemnes Municipality logo on page 1. Although the image is marked as an image, it lacks a text alternative (/Alt attribute). As a result, screen reader users are unable to determine that there is a logo on the page or which organization it represents.

Advice

Add a text alternative to the logo in the source file, for example: “Municipality of Eemnes”. Then export the document again as a PDF.

Finding 4 (SC 1.1.1)

https://cuatro.sim-cdn.nl/eemnesbe64f5/uploads/Collegebesluitenlijst%20Eemnes%2031%20maart%202026.pdf?cb=cOjqGiUk

The PDF document features the Eemnes Municipality logo at the top. This logo is not tagged as an image and is therefore ignored by screen readers.

Advice

Tag the logo on page 1 as an image and provide a text alternative, such as "Eemnes Municipality Logo." Include the text alternative in the source file, and then re-export the document as a PDF.

Finding 5 (SC 1.1.1)

https://www.eemnes.nl/strooien-bij-gladheid

The page includes an interactive map showing the snow-plowing routes for the municipality of Eemnes. This map is embedded via an iframe. Online maps and mapping services are subject to an exception to the accessibility requirements, but this exception applies only to the mapping technology, not to the information provided via the map. The information about the snow plowing routes is currently available only via the map. The page lacks a text alternative that makes this information accessible.The map includes a search function, but this does not constitute a demonstrably accessible alternative. As a result, there is no guarantee that the information is accessible to all users.

Advice

Ensure that the key information from the map (such as which streets are covered by which snow-clearing routes) is also presented in an accessible format, for example through a text-based overview, a table, or a search function that is demonstrably accessible.

1.3.1 Information and Relationships A

The information, structure, and relationships in the content that you can see must also be available in the code for assistive technology. 1.3.1 Information and relationships

Result: Does not meet requirements

Finding 1 (SC 1.3.1)

https://www.eemnes.nl/

On the homepage, under the heading “Or are you looking for...”, there is a list of twelve links, such as News, Municipal Taxes, and Moving. Visually, this appears as a list. However, in the code, these links are not formatted as a list. As a result, assistive technology cannot recognize that it is a list. 

In the footer, under the heading “Follow the municipality,” there are two links to social media (Facebook and Instagram). These links are placed within a p element, even though they visually form a list. As a result, the list structure is not defined programmatically, and assistive technology cannot determine that this is a list containing multiple items.

Recommendation: 

Place the links in an unordered list (ul) with list items (li) so that assistive technology can recognize that it is a list and how many items it contains.

Finding 2 (SC 1.3.1)

https://www.eemnes.nl/groente-fruit-tuinafval-gft

In the accordion section titled “Tips for Separating Organic Waste,” the subheadings are formatted as lists with only one item. As a result, the structure is incorrect. Visually, these appear as standard subheadings with text, but in the code, they are structured as separate lists.

Recommendation: 

Remove the headings and place them directly within the body of the text, with the corresponding text below them.

Finding 3 (SC 1.3.1)

Robbert Kouwenhoven | Municipality of Eemnes
https://www.eemnes.nl/robbert-kouwenhoven

On the Robbert Kouwenhoven page, the heading structure is not logically organized. The page title appears as a . The headings “Additional Roles” and “Contact” appear directly below it as . This skips a level (the is missing).For users of screen readers and other assistive software, the heading structure is important for navigating the page quickly. Because a level is skipped, the page structure is incorrect and this can be confusing.

Recommendation: 

Make sure the headings “Additional Roles” and “Contact” are moved up one level in the structure. To do this, use instead of

Finding 4 (SC 1.3.1)

The page contains a button labeled “Sign up for the residents’ panel.” The entire text is formatted with a element. This element indicates that the text has extra emphasis, but on a button, this adds no meaning. This also occurs on the tree felling page, where the table column headers are formatted with inside the elements. The column headers are already marked as headings, making extra emphasis with superfluous.

Recommendation: 

Remove the - character from the link text and the column headers.

Finding 5 (SC 1.3.1)

https://www.eemnes.nl/evenementenkalender

The page contains a table in which the month names (such as “April” and “May”) are placed as headers () within the table cells. This is incorrect, because a table has its own structure for headers (using ). Using within table cells disrupts this structure. In addition, there are also empty elements (containing only a space), which screen readers read aloud as empty headers.

Recommendation: 

Remove the headers from the table. There are two ways to do this: - Create a separate table for each month with the month’s name as the header, or - Include the month in the date (for example, “April 5 and 6, 2026”). Also, remove any empty rows.

Finding 6 (SC 1.3.1)

https://www.eemnes.nl/evenementenkalender

The page contains a table whose top row is visually formatted as column headers but consists of regular data cells (td) in the code. As a result, assistive technologies cannot determine which column corresponds to which information.

Recommendation: 

Turn the top row into real headings by using . Remove the -elements.

Finding 7 (SC 1.3.1)

https://cuatro.sim-cdn.nl/eemnesbe64f5/uploads/Informatieavond%20voor%20omwonenden%20over%20toekomstplan%20voor%20Ocriet%20-%20Sterk%20-%2028%20januari%202025_0.pdf?cb=JUh8jyOY

The PDF document contains visually recognizable headings, such as "Proposal from the Municipal Executive," "Atmospheric Images," "New Road," and "Number of Homes." These are formatted as regular paragraphs () rather than as headings. As a result, the sections cannot be distinguished from one another programmatically. This prevents screen reader users from navigating through the document using headings.

Recommendation: 

Edit the five headings in the source file so that they are formatted as actual headings (for example). Then save the document again as a PDF.

Finding 8 (SC 1.3.1)

https://cuatro.sim-cdn.nl/eemnesbe64f5/uploads/Collegebesluitenlijst%20Eemnes%2031%20maart%202026.pdf?cb=cOjqGiUk

The PDF document is not tagged. This means that no structure has been specified in the file using tags. As a result, assistive technology (such as a screen reader) cannot identify headings, lists, and similar elements, and will ignore images.

Recommendation: 

If the file is properly tagged, assistive software can better determine its structure and relationships. For example, it can then announce that certain text is a heading. In many cases, this problem can be resolved by re-exporting the document from the source file (usually in Word or InDesign) to PDF, but this time including tags or labels. Because the tags are currently missing, other success criteria such as 1.1.1 and 1.3.2 cannot be assessed. Therefore, be aware that resolving this issue may create new accessibility problems.

2.4.2 Page Title A

All pages have a clear title that describes the topic.
2.4.2 Page Title

Result: Does not meet requirements

Finding 1 (SC 2.4.2)

https://cuatro.sim-cdn.nl/eemnesbe64f5/uploads/Informatieavond%20voor%20omwonenden%20over%20toekomstplan%20voor%20Ocriet%20-%20Sterk%20-%2028%20januari%202025_0.pdf?cb=JUh8jyOY

The PDF document does not have a title. Instead, the file name is used. As a result, screen reader users do not hear a clear title, but rather the file name.

Recommendation: 

In the source file, enter a descriptive document title, such as “Ocriet-Sterk Information Evening Report, January 28, 2025.” Also, set the PDF to display the document title instead of the file name. Then export the document again as a PDF.

Finding 2 (SC 2.4.2)

https://cuatro.sim-cdn.nl/eemnesbe64f5/uploads/Collegebesluitenlijst%20Eemnes%2031%20maart%202026.pdf?cb=cOjqGiUk

The PDF document does have a title listed in its file properties, namely “Anonymized document.” However, this title does not adequately describe the document’s content. For PDF documents, it is important to include a clear and descriptive title that accurately reflects the document’s content.

Recommendation: 

Set a meaningful and descriptive title that accurately reflects the document’s content. It is best to do this in the source file (such as Word or InDesign) before exporting to PDF. In Adobe Acrobat Pro, verify that the title is correctly entered in the document properties, and then save the document again to apply the changes.

2.4.4 Link target (in context) A

Provide clear text for links so that users know what will happen when they click on them.
2.4.4 Link target (in context)

Result: Does not meet requirements

Finding 1 (SC 2.4.4)

https://www.eemnes.nl/melding-openbare-ruimte

On the page, the link "on the website of the Province of Utrecht" appears in a separate paragraph, distinct from the paragraph describing what the information is about. The link text describes the destination but not the purpose of the link. A screen reader user who encounters the link out of context will not know that it refers to information about nuisance reports.

Recommendation: 

Include the link and the descriptive text in a single paragraph, or make sure the link text is understandable on its own, for example, "Information about reporting nuisances on the Province of Utrecht’s website."

2.4.6 Headings and Labels AA

Use clear headings and text labels that describe the subject or purpose.
2.4.6 Headings and Labels

Result: Does not meet requirements

Finding 1 (SC 2.4.6)

https://www.eemnes.nl/

The homepage features an H2 heading that reads "Or are you looking for...". This heading does not describe the section's content; instead, it asks a question. As a result, users who navigate by headings cannot tell what this section contains.

Recommendation: 

Replace the heading with a descriptive title that indicates what the section contains, such as "Frequently Asked Questions" or "Popular Topics."

Finding 2 (SC 2.4.6)

https://www.eemnes.nl/form/contactformulier-eemnes/contactformulier-eemnes-0

On the page, the h1 and the first h2 are virtually identical. The h1 reads “Contact Form - eemnes” and the h2 reads “Contact Form eemnes.” The h2 does not describe the content of the form section but merely repeats the h1 (page title). As a result, the heading does not provide clear information about the content.

Recommendation: 

Replace the h2 with a descriptive heading that explains what happens in this section of the form, such as “About this form.”

Comments

The comments below do not result in a rejection, but contain suggestions that could further improve accessibility or user-friendliness.

1.4.3 Contrast (minimum) AA

All text must have sufficient color contrast. Tip: Use the Color Contrast Analyzer to determine the color contrast.
1.4.3 Contrast (minimum)

Result: Satisfactory , but with a comment

Note 1 (SC 1.4.3)

The website offers a high-contrast version. This can be enabled using a "contrast switch." This success criterion has been fully tested in high-contrast mode. The high-contrast version is considered an alternative to the standard version.

This may cause contrast issues in the standard version. These issues have not been further evaluated.

Advice

We recommend ensuring that the standard version also includes sufficient color contrast in all text. This improves the website’s accessibility for visitors with visual impairments.

Texts with sufficient color contrast are also easier for all readers to read. This makes reading less taxing, requires less energy, and is (subconsciously) perceived as more enjoyable. As a result, readers are more likely to take action.

The high-contrast version can then be used to provide "enhanced contrast," thereby meeting the WCAG 1.4.6 Enhanced Contrast success criterion (Level AAA).

1.4.11 Contrast of non-textual content AA

Non-text content on your website has sufficient color contrast (3.0:1). Examples include important images and form fields.
1.4.11 Contrast of non-text content

Result: Satisfactory , but with a comment

Note 1 (SC 1.4.11)

A high-contrast version is available on the website. It can be enabled using a "contrast switch." This success criterion has been fully tested in high-contrast mode. The high-contrast version is considered an alternative to the standard version. As a result, there may be contrast issues in the standard version. These have not been further evaluated.

Advice

Ensure that the standard version also provides sufficient color contrast for all graphic elements. This improves the website’s accessibility for visitors with visual impairments. The high-contrast version can then be used to provide “enhanced contrast.”

Ensuring compliance and follow-up

Since the study was conducted using a sample, similar issues may also exist on pages that were not examined. It is therefore advisable to check the entire website for similar patterns and to monitor them on an ongoing basis.

In addition, changes to the content or the publication process may introduce new accessibility risks. Therefore, a consistent focus on accessibility and periodic reassessment remain essential.

Study Details

This chapter contains the research methodology: the scope and sample of the study, the methodology used, and the tools employed in the testing.

Scope

The URL indicates the reason why a particular section was or was not included. This is in accordance with the rules for determining the scope in the WCAG-EM evaluation method.

https://www.eemnes.nl/ (URI base)

Outside the scope

Additional scope information

The following content falls outside the scope of this study pursuant to the Accessibility Act:

  • Not online maps and mapping services, unless they are intended for navigation (legal exception for government agencies)
  • Not office files created before September 23, 2018, unless they are part of an administrative process (legal exception for the government).
  • Not the live videos (legal exception for the government)
  • Excluding audio and video files uploaded to the digital channel before September 23, 2020 (legal exception for the government)
  • Content not provided by third parties (legal exception for the government)
  • Not the contents of archives (legal exception for the government)
  • Not the content behind a login
     

Research Methods and Techniques

This study was conducted in accordance with the WCAG-EM evaluation method . This method is recommended by DigiToegankelijk (Logius). In conducting this study, it was assumed that all W3C techniques are supported and may therefore be used.

Test environment

The basic level of support includes common web browsers and assistive technologies. The study was conducted using:

  • Google Chrome, version 143 (primary)
  • Mozilla Firefox, version 146
  • Microsoft Edge, version 143
  • Adobe Acrobat Pro
  • PDF Accessibility Checker (PAC)
  • NVDA (Windows) in combination with Google Chrome

Technologies

  • DOM
  • HTML
  • CSS
  • SVG
  • PDF