WCAG 2.2 AA Partial Audit of the Heerlen Website Content
This report describes the results of the WCAG 2.2 AA sub-study on website content, which assessed the accessibility of the content on the website www.heerlen.nl, commissioned by the Municipality of Heerlen.

Summary
This study was conducted by Shift2 between April 20, 2026, and May 4, 2026. For this sub-study, a representative sample was compiled consisting of 19 published web pages with various types of content.
The content reviewed does not fully comply with WCAG 2.2 Level 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.
During the review, it became apparent that the Heerlen website is already well-designed in many respects. The main areas for improvement are in the footer. The social media links are not presented as a list, and the link text does not indicate that they lead to the municipality’s page. Additionally, the language selection options (NL/EN/DE/FR) are not clear to screen reader users.
The main issues are found in the PDF document of the City Newspaper. This document is not tagged, and in several places the color contrast between the text and the background is too low.
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:
| SC | Name | Level | Reason for exclusion |
|---|---|---|---|
| 3.3.1 | Error identification | A | Form validation is handled entirely by the system |
| 3.3.3 | Suggested correction | AA | Error suggestions are generated by the system |
| 3.3.7 | Unnecessary imports | A | The 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 criterion | Level | Result |
|---|---|---|
| 1.1.1 Non-textual content | A | Does not meet the requirements |
| 1.2.1 Audio-only and video-only (pre-recorded) | A | not available |
| 1.2.2 Captions for the deaf and hard of hearing (pre-recorded) | A | Meets the requirements |
| 1.2.3 Audio description or media alternative (pre-recorded) | A | Meets the requirements |
| 1.2.4 Captions for the Deaf and Hard of Hearing (live) | AA | not available |
| 1.2.5 Audio description (pre-recorded) | AA | Meets the requirements |
| 1.3.1 Information and Relationships | A | Does not meet the requirements |
| 1.3.2 Meaningful order | A | Meets the requirements |
| 1.3.3 Sensory properties | A | Meets the requirements |
| 1.3.5 Identify the purpose of the import | AA | Meets the requirements |
| 1.4.1 Use of color | A | Meets the requirements |
| 1.4.2 Sound Controls | AA | not available |
| 1.4.3 Contrast (minimum) | AA | Does not meet the requirements |
| 1.4.5 Images of text | AA | Meets the requirements |
| 1.4.10 Reflow | AA | Meets the requirements |
| 1.4.11 Contrast of non-textual content | AA | Meets the requirements |
| 2.1.2 No keyboard drop | A | Meets the requirements |
| 2.1.4 Single-character keyboard shortcuts | A | Meets the requirements |
| 2.2.2 Pause, stop, or hide | A | not available |
| 2.3.1 Three flashes or below the threshold value | A | Meets the requirements |
| 2.4.2 Page Title | A | Does not meet the requirements |
| 2.4.4 Link target (in context) | A | Does not meet the requirements |
| 2.4.6 Headings and labels | AA | Meets the requirements |
| 2.5.3 Label in the name | A | Meets the requirements |
| 2.5.8 Size of the selection area (minimum) | AA | Meets the requirements |
| 3.1.1 Page Language | A | Meets the requirements |
| 3.1.2 Language of components | AA | Meets the requirements |
| 3.2.4 Consistent identification | AA | Meets the requirements |
| 3.3.2 Labels or instructions | A | Meets the requirements |
| 4.1.2 Name, role, and value | A | Meets 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 Principle | Level A | Level AA | Total |
|---|---|---|---|
| Observable | 7 / 9 | 6 / 7 | 13 / 16 |
| Operable | 5 / 7 | 2 / 2 | 7 / 9 |
| Understandable | 2 / 2 | 2 / 2 | 4 / 4 |
| Robust | 1 / 1 | 0 / 0 | 1 / 1 |
| Total | 15 / 19 | 10 / 11 | 25/30 |
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.heerlen.nl/anne-rose-orbons
The page contains a portrait photo of Anne Rose Orbons with an empty alt text (alt=""). As a result, assistive technology skips over the image. This is incorrect because the image is a portrait of the person who is the focus of the page. Screen reader users are therefore unable to tell that there is an image on the page or who is depicted in it.
Advice
Provide the portrait photo with an appropriate alt text that includes the person's name, for example, alt="Portrait of Anne Rose Orbons".
Finding 2 (SC 1.1.1)
https://www.heerlen.nl/circular-building-convert-oud-dsm-kantoor-wordt-woningen
The page displays the Interreg project logo. The text alternative is "Interreg North-West Europe logo." However, the logo also includes the name "Circular Building Convert" and the phrase "Co-funded by the European Union." This information is missing from the text alternative, which means that screen reader users are unable to determine which project and which funding body are represented in the logo.
Advice
Provide the logo with a text alternative that includes all the names appearing in the logo, for example, alt="Interreg North-West Europe – Circular Building Convert, co-funded by the European Union".
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)
In the footer, under the heading "Follow us," there is a row of four links to social media: LinkedIn, Facebook, Instagram, and YouTube. Visually, this appears as a list, but in the code, the links are listed one after another in a paragraph (p element) rather than in a list (ul with li). As a result, assistive technology cannot identify that this is a list or determine how many items it contains.
Advice
Place the social media links in an unordered list, with each link in its own list item.
Finding 2 (SC 1.3.1)
https://www.heerlen.nl/trouwen-en-partnerschap
On the page, under the h2 heading "Wedding Officials," there are nine cards listing the names of the wedding officials, such as Anne Rose Orbons, Arris Matlega, and Eva Tholen. These names are formatted as h2 headings. Since they are subordinate to the h2 heading above them, they should be h3 headings. As a result, the heading hierarchy is incorrect, and screen reader users cannot properly determine the structure of the page.
Advice
Make the names of the marriage officiants into h3 headings, so that they are subordinate to the h2 heading "Marriage Officiants".
Finding 3 (SC 1.3.1)
The PDF document "Heerlen City Newspaper March 2026" 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 determine what constitutes headings, paragraphs, lists, and other elements.
Advice
Tag the PDF document. Make sure the structure (headings, paragraphs, lists, images) is marked up with tags so that assistive technology can read the content aloud and search through it effectively.
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: Does not meet requirements
Finding 1 (SC 1.4.3)
The PDF document contains text with insufficient contrast in several places:
The cover features the handwritten text "In the mood?!" in light blue (#3BADEB) on a white background (#FFFFFF). The color contrast is 2.5:1. On page 2 (right side of the spread) in the article "Working Together in Eikenderveld," white text (#FFFFFF) appears on a green gradient that transitions from light to dark green. On the light green sections (#92BD10), the color contrast is 2.2:1. The orange headlines (#EC9100) on a white background (#FFFFFF), for example on page 4 (left side of the spread). The color contrast is 2.4:1. On page 5, the headline "Heerlen makes its voice heard" in white (#FFFFFF) on a soft pink background (#F1B8D5). The color contrast is 1.7:1.
As a result, the text is difficult to read for people with impaired vision.
Advice
The contrast ratio for standard text must be at least 4.5:1, and for large text, at least 3.0:1. Darken the green background color so that the contrast with the white text meets the requirement.
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)
The PDF document "Heerlen Stadskrant" has a title entered in the file properties ("Heerlen Stadskrant"). However, this title does not specify which issue it refers to (March 2026). In addition, the display setting is set to "filename," causing PDF readers and assistive software to display the filename instead of the title. As a result, screen reader users do not hear a descriptive document title.
Advice
Enter a descriptive title that also mentions the issue, for example, "Heerlen City Newspaper - March 2026 - In a good mood?!". In addition, in the PDF properties (File > Properties > Initial View), set the "Show" option to "Document Title" so that the title is displayed instead of the file name. It is best to do this in the source file before exporting to PDF.
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)
In the top-right corner of the header, there are four links to other language versions of the website: NL, EN, DE, and FR. The link text consists solely of a two-letter abbreviation. Screen readers announce "link, NL," "link, EN," and so on; this does not make it clear that these are language selection links or exactly which language is being referred to. Furthermore, the links are located in a navigation bar with the aria-label "Quick Menu" alongside "Contact." Consequently, the surrounding text also does not indicate anywhere that this is a language selection.
Advice
For each language link, use the full name of the language in that language itself, for example, "Nederlands," "English," "Deutsch," and "Français." Add the lang attribute to each link with the correct language code (lang="en", lang="de", lang="fr") so that assistive technology can pronounce the name in the correct language.
Finding 2 (SC 2.4.4)
In the footer, under the heading "Follow us," there are four links to social media platforms, each labeled simply by the platform’s name: "LinkedIn," "Facebook," "Instagram," and "YouTube." A screen reader announces "link, LinkedIn." This indicates that the link leads to LinkedIn, but does not specify that it is specifically the Heerlen municipality’s page on that platform.
Advice
Add the organization's name to the display name of each link, for example, "Heerlen Municipality on LinkedIn" or "Heerlen Municipality LinkedIn page."
Comments
The comments below do not result in a rejection, but contain suggestions that could further improve accessibility or user-friendliness.
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: Satisfactory , but with a comment
Note 1 (SC 1.1.1)
The PDF document is not tagged. As a result, informational images are not marked as "Figure" and do not have text alternatives. This means that people who are blind and use a screen reader do not receive this information. Because the document is not tagged, it is impossible to determine whether the images have been processed correctly. For this reason, the document is not currently being rejected. Once the document is tagged, it can be reviewed again.
Advice
Make sure the PDF includes a complete tag structure, and distinguish between informational and decorative images. Tag informational images as "Figure" and provide them with a short, descriptive text alternative. Mark decorative images as "Artifact" so that assistive technology can skip them.
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: Satisfactory , but with a comment
Note 1 (SC 1.3.1)
https://www.heerlen.nl/contact
On the contact page, under the headings "Visit us:" and "Mailing address:", the addresses are listed as single items. A list should contain two or more items. The text would be better formatted as a paragraph.
Advice
Replace the list under the heading with a paragraph.
Note 2 (SC 1.3.1)
https://www.heerlen.nl/ondernemershuis
On the page, under the heading "Make an appointment," the phone number and email address are listed in a single paragraph (p element), separated by a br tag. These are two different types of contact information that should each be in their own paragraph, or would be better placed in a list (as on the Contact page).
Advice
Place the phone number and email address each in their own paragraph, or better yet, in a bulleted list, as on the Contact page.
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 with graphic elements in the standard version. These have not been further evaluated.
Advice
We recommend ensuring that the standard version also provides sufficient contrast for graphic elements, such as icons, buttons, and form fields. This improves the website’s accessibility for visitors with visual impairments.
The high-contrast version can then be used to provide “enhanced contrast.”
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: Satisfactory , but with a comment
Note 1 (SC 2.4.4)
The header features the Municipality of Heerlen logo as a link to the homepage. The text alternative is "Logo of the Municipality of Heerlen" (in the English version: "Logo of the Municipality of Heerlen"). This describes the type of graphic element and not the link destination. A screen reader reads "link, Logo of the Municipality of Heerlen"; it is not immediately clear from this that the link leads to the homepage.
Advice
Replace the text alternative with just the organization's name, for example, "City of Heerlen." A screen reader user will then hear a brief and clear description of where the link leads.
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: Satisfactory , but with a comment
Note 1 (SC 2.4.6)
Several pages feature the heading "Or are you looking for…" above a list of topics, for example on the homepage with topics such as "Non-residents (RNI)", "Parking", and "Extracts". This is not a descriptive heading. The heading does not make it clear what information follows.
Advice
Choose a heading that describes the content below, such as "Topics" or "By Topic."
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.heerlen.nl (URI-based)
Outside the scope
- https://digiforms.heerlen.nl
- https://parkeren.heerlen.nl/Account/LogOn?ReturnUrl=%2f
- https://heerlen.mijnafspraakmaken.nl/
- https://vacatures.heerlen.nl
- https://centrum.heerlen.nl
- https://iburgerzaken.heerlen.nl/gaas-web/server/continue/StartVermissingReisdocument#burgerzaken
- https://heerlen.bestuurlijkeinformatie.nl/
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
Sample
This study was conducted using a sample. The method used to determine the sample is specified in the WCAG-EM evaluation document. If a process was included in the study, all pages related to that process are listed in the sample. See: https://www.digitoegankelijk.nl/toegankelijkheidsverklaring/onderzoek
Complete sample
- https://www.heerlen.nl
- https://www.heerlen.nl/contact
- https://www.heerlen.nl/trouwen-en-partnerschap
- https://www.heerlen.nl/organisatie-gemeente-heerlen
- https://www.heerlen.nl/anne-rose-orbons
- https://www.heerlen.nl/strooiroutes
- https://www.heerlen.nl/circular-building-convert-oud-dsm-kantoor-wordt-woningen
- https://www.heerlen.nl/ondernemershuis
- https://en.heerlen.nl
- https://en.heerlen.nl/geldzorgen
- https://www.heerlen.nl/form/aanvragen-boekje-steuntje-in-de-rug/aanvraagformulier-0
- https://www.heerlen.nl/form/aanvragen-boekje-steuntje-in-de-rug/per-post-1
- https://www.heerlen.nl/form/aanvragen-boekje-steuntje-in-de-rug/overzicht-3
- https://www.heerlen.nl/stadskrant
- https://www.heerlen.nl/vrije-openingstijden-horecabedrijf-deel-heerlen-centrum
- https://www.heerlen.nl/steenbreek
- https://www.heerlen.nl/trouwen-en-partnerschap
- https://www.heerlen.nl/paspoort-of-identiteitskaart-aanvragen
- https://digitaalpubliceren.com/heerlen/21179/1/files/assets/common/downloads/Heerlen%20Stadskrant.pdf
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)
- Color Contrast Analyzer
- NVDA (Windows) in combination with Google Chrome
Technologies
- DOM
- HTML
- CSS
- SVG