Accessibility  Appendix 4: European Accessibility Act conformance document

This document outlines the University of Leeds’ conformance status with the European Accessibility Act (EAA). 

The products and services in scope of the EAA provided by or supplied through the University partially meet the requirements of the act. All these products and services have been available prior to the EAA coming into force on 28 June 2025.

How to contact the University about issues or the EAA

If you want to make the University aware of accessibility issues in its digital estate, need something in an accessible format, or are part of a relevant authority and need to contact the University in relation to the EAA, use one of the following methods:

• Web: Use either the contact form for people who cannot log in to the IT site or the contact form for people who can log in.
• Phone: Call the IT Service Desk on 0113 343 3333.

We’ll look at your request and get back to you as soon as we can.

Ways the EAA applies to the University

The University believes the following parts of the EAA apply to its products and services in the ways noted. All these products and services have been available prior to the EAA coming into force on 28 June 2025.

EAA Article 2: Scope

Consumer banking services

• Payment services: Executing direct debits for course fees, accommodation and memberships for The Edge sport and fitness complex.
• Electronic money: Purchase of funds on the GFaL (Great Food at Leeds) Rewards portal for use on the mobile app, and purchase of funds for the MyPrint printing portal.

E-books and dedicated software

• E-books: EPUB and PDF formats, primarily made available through the Library.
• Dedicated software: Browser-based e-reader platforms and mobile e-reader apps that allow the viewing of e-books made available through the Library.

E-commerce services

E-commerce site: The University online store, store.leeds.ac.uk.

How accessibility requirements are met

The University aims for its websites, browser-based systems, and mobile apps it controls and purchases to meet the Web Content Accessibility Guidelines 2.2 to the AA standard (WCAG 2.2 AA). Compliance here is referenced against this WCAG 2.2 AA due to its close overlap with the EN 301 549 standard. 

Consumer banking services: Payment services 

Executing direct debits for course fees or accommodation

The University offers a range of courses in its role as a higher education institution. The University provides the ability to pay course fees via direct debit (payment services). See Tuition fee payment schedule for more information about paying course fees via direct debit at the University.

The University offers a range of accommodation to students. The University provides the ability to pay accommodation fees via direct debit (payment services). See Charges and payment dates for more information about paying accommodation fees via direct debit at the University.

The EAA references the Payment Services Directive as providing the definition for payment services. This includes the “execution of direct debits” as a payment service. Payment via direct debit brings relevant payment of course fees and accommodation in scope of the EAA.

Direct debit payments for course fees and accommodation are both set up via the same browser-based portal, Arrangement to Pay Fees in Instalments. This portal is based on the SAP platform and developed by the University. This portal will be replaced by a new SAP solution before the end of 2026, developed to ensure it will be compliant.

Compliance with harmonised standards and technical specifications

• We know some parts of the Arrangement to Pay Fees in Instalments payment portal are not fully accessible. Although more non-compliances may exist, the following items are non-compliant for the displayed reasons:
• Some informative images are incorrectly coded as decorative. This fails WCAG 2.2 success criterion 1.1.1 Non-text Content (Level A).
• There are images containing text that do not have alternative text and the particular presentation isn’t essential. This fails WCAG 2.2 success criteria 1.1.1 Non-text content (Level A) and 1.4.5 Images of Text (Level AA).
• Form elements and inputs do not have accessible names and/or labels that can be programmatically determined. This fails WCAG 2.2 success criteria 1.3.1 Info and Relationships (Level A), 2.5.3 Label in Name (Level A) and 4.1.2 Name, Role, Value (Level A).
• Text is styled as a heading but not coded as a heading. This fails WCAG 2.2 success criteria 1.3.1 Info and Relationships (Level A) and 2.4.6 Headings and Labels (Level AA).
• There are several links where the link text isn’t descriptive enough. This fails WCAG 2.2 success criteria 1.3.1 Info and Relationships and 2.4.4 Link Purpose (In Context).
• This portal will be replaced by a new SAP solution before the end of 2026, developed to ensure it will be compliant.

Executing direct debits for memberships for The Edge sport and fitness complex

The Edge is the University’s on-campus sport and fitness complex, providing related leisure services to students, staff and the public. The University provides the ability to pay for memberships to The Edge via direct debit (payment services). Guidance for making a booking contains detail around how to add a membership via direct debit for The Edge.

The EAA references the Payment Services Directive as providing the definition for payment services. This includes the “execution of direct debits” as a payment service. Payment via direct debit brings relevant purchases of memberships to The Edge in scope of the EAA.

Compliance with harmonised standards and technical specifications

We know some parts of the membership purchase process are not fully accessible. Although more non-compliances may exist, the following items are non-compliant for the displayed reasons:

• Some interface items and inputs don’t have strong enough contrast against their backgrounds to meet requirements. This fails WCAG 2.2 success criterion 1.4.11 Non-text Contrast (Level AA).
• Form elements and inputs do not have accessible names and/or labels that can be programmatically determined. This fails WCAG 2.2 success criteria 1.3.1 Info and Relationships (Level A), 2.5.3 Label in Name (Level A) and 4.1.2 Name, Role, Value (Level A).
• Text is styled as a heading but not coded as a heading. In some cases, text is coded as a heading but doesn't function as a heading. This fails WCAG 2.2 success criteria 1.3.1 Info and Relationships (Level A) and 2.4.6 Headings and Labels (Level AA).
• Some informative images are incorrectly coded as decorative. This fails WCAG 2.2 success criterion 1.1.1 Non-text Content (Level A).
• Supporting information for form inputs cannot always be revealed via keyboard. This fails WCAG 2.2 success criterion 2.1.1 Keyboard (Level A).

Compliance of this portal is controlled by its supplier. Refer to the supplier and its documentation to determine the complete, up-to-date level of compliance.

Consumer banking services: Electronic money

Purchase of funds on the GFaL (Great Food at Leeds) Rewards portal for use on the mobile app 

The GFaL (Great Food at Leeds) Rewards mobile app allows customers of the University’s catering facilities to collect loyalty stamps, earn points, and access offers. 

Users can buy credit (electronic money) through the browser-based GFaL Rewards credit portal to make purchases using the mobile app. Purchasing of electronic money places GFaL Rewards in scope of the EAA.

The GFaL Rewards credit portal and mobile app are supplied to the University by a third party, Lolly. The University doesn’t directly control the compliance of the credit portal or mobile app.

Compliance with harmonised standards and technical specifications

We know some parts of the GFaL Rewards credit portal are not fully accessible. Although more non-compliances may exist, the following items are non-compliant for the displayed reasons:

• Some page titles are styled as headings but not coded as headings. This fails WCAG 2.2 success criteria 1.3.1 Info and Relationships (Level A) and 2.4.6 Headings and Labels (Level AA).
• Some input fields have visible labels that aren’t programmatically determinable. This fails WCAG 2.2 success criteria 1.3.1 Info and Relationships (Level A) and 2.5.3 Label in Name (Level A).
• Some decorative images are incorrectly coded as meaningful. Some informative images aren’t provided with alternative text that appropriately communicates the image content. This fails WCAG 2.2 success criterion 1.1.1 Non-text Content (Level A).
• Some text doesn’t have strong enough contrast against its background to meet requirements. This fails WCAG 2.2 success criterion 1.4.3 Contrast (Minimum) (Level AA).
• Some interface items don’t have strong enough contrast against their backgrounds to meet requirements. This fails WCAG 2.2 success criterion 1.4.11 Non-text Contrast (Level AA).

Compliance of this portal is controlled by its supplier. Refer to the supplier and its documentation to determine the complete, up-to-date level of compliance.

Purchase of funds for the MyPrint printing portal

The MyPrint system allows students and staff to print, copy and scan documents in University libraries, computer clusters and some student residences. Users can print to MyPrint from any device with an internet connection, and then can log in at any MyPrint printer to collect their document. Users can also save scanned documents directly to their university email account or OneDrive cloud storage. 

Users are charged when they print, copy, or scan a document. Users can log in to the MyPrint portal to buy credits (electronic money) to use the service. Purchasing of electronic money places MyPrint in scope of the EAA.

The MyPrint portal uses a combination of the Papercut product supplied to the University by a third party, Konica Minolta, and a payment process provided by another third party, Epay. The University doesn’t directly control the compliance of these products.

Compliance with harmonised standards and technical specifications

We know some parts of the MyPrint portal and Epay payment process are not fully accessible. Although more non-compliances may exist, the following items are non-compliant for the displayed reasons:

• Some text doesn’t have strong enough contrast against its background to meet requirements. This fails WCAG 2.2 success criterion 1.4.3 Contrast (Minimum) (Level AA).
• Some interface items and inputs don’t have strong enough contrast against their backgrounds to meet requirements. This fails WCAG 2.2 success criterion 1.4.11 Non-text Contrast (Level AA).
• Some decorative images are incorrectly coded as meaningful. Some informative images aren’t provided with alternative text that appropriately communicates the image content. Some images that need to be coded as either decorative or informative are coded as neither. This fails WCAG 2.2 success criterion 1.1.1 Non-text Content (Level A).
• Some text links do not have strong enough contrast with associated regular text. This fails WCAG 2.2 success criteria 1.4.1 Use of Color (Level A) and 1.4.11 Non-text Contrast (Level AA).
• Supporting information for form inputs cannot always be revealed via keyboard. This fails WCAG 2.2 success criterion 2.1.1 Keyboard (Level A).
• Some backgrounding coding of ARIA roles isn’t correct. This fails WCAG 2.2 success criteria 1.3.1 Info and Relationships (Level A) and 4.1.2 Name, Role, Value (Level A).
• On the log-in page, empty tab stops may interfere with the meaning and operability of the page. During the payment process, page focus starts on the 'Continue' button at the bottom of the page, moves backward to the 'Back' button, and then moves to the top of the page. This fails WCAG 2.2 success criterion 2.4.3 Focus Order (Level A).
• The log-in page has two Heading 1s. This fails WCAG 2.2 success criteria 1.3.1 Info and Relationships (Level A) and 2.4.6 Headings and Labels (Level AA).
• Link purpose isn't always clear from each link's text. This fails WCAG 2.2 success criterion 2.4.4 Link Purpose (In Context) (Level A).
• On the log-in page, content does not reflow to accommodate smaller screen or window sizes. This fails WCAG 2.2 success criterion 1.4.10 Reflow (Level AA). 
• Some important interface items have been coded to be hidden from assistive technologies. This fails WCAG 2.2 success criterion 4.1.2 Name, Role, Value (Level A).
• During the payment process, there is no method for keyboard users to bypass repeated content. This fails WCAG 2.2 success criterion 2.4.1 Bypass Blocks (Level A).

Compliance of this portal and payment process are controlled by the relevant suppliers. Refer to the suppliers and their documentation to determine the complete, up-to-date level of compliance.

E-books and dedicated software: E-books

EPUB format

The University makes e-books from third-party publishers available in EPUB format via its Library. It doesn’t have direct control of the compliance of EPUB e-books.

The University also co-publishes e-books in EPUB format through the White Rose University Press, of which it does have some direct control.

Compliance with harmonised standards and technical specifications

Compliance of EPUB e-book publications is controlled by their respective suppliers. Refer to the suppliers and their documentation to determine their complete, up-to-date level of compliance.

For the EPUB e-books over which it has some control, the University is in the process of establishing its level of compliance. This document will be updated as appropriate.

PDF format

The University makes e-books from third-party publishers available in PDF format via its Library. It doesn’t have direct control of thecompliance of PDF e-books. 

The University also co-publishes e-books in PDF format through the White Rose University Press, of which it does have some direct control.

Compliance with harmonised standards and technical specifications

Compliance of PDF e-book publications is controlled by their respective suppliers. Refer to the suppliers and their documentation to determine their complete, up-to-date level of compliance.

For the PDF e-books over which it has some control, the University is in the process of establishing its level of compliance. This document will be updated as appropriate.

MOBI format

The University co-publishes e-books in MOBI format through the White Rose University Press, of which it does have some direct control.

Compliance with harmonised standards and technical specifications

For the MOBI e-books over which it has some control, the University is in the process of establishing its level of compliance. This document will be updated as appropriate.

E-books and dedicated software: Dedicated software

Browser-based e-reader platforms

The University makes several browser-based e-reader platforms from third parties available. It doesn’t have direct control of the compliance of these platforms.

The platforms are as follows:

• Overdrive.
• RNIB Bookshare.
• Edinburgh University Press.
• Perlego.

Compliance with harmonised standards and technical specifications

We know some parts of these browser-based e-reader platforms are not fully accessible.

Compliance of these platforms is controlled by their respective suppliers. Refer to the suppliers and their documentation to determine their complete, up-to-date level of compliance.

Mobile e-reader apps

The University makes the Libby mobile e-reader app available from a third party, Overdrive. It doesn’t have direct control of the compliance of this app.

Compliance with harmonised standards and technical specifications

We know some parts of these mobile e-reader apps are not fully accessible.

Compliance of these apps is controlled by their respective suppliers. Refer to the suppliers and their documentation to determine their complete, up-to-date level of compliance.

E-commerce services: E-commerce site

University Online Store, store.leeds.ac.uk

The University of Leeds Online Store offers a way to pay for products, services and events. This includes access to conferences, events and concerts, as well as consumables, CDs, staff publications and more. The University of Leeds Online Store is available to students, staff and general public. Certain products are restricted to students and staff.

The University Online Store is supplied to the University by a third party, Flywire. The University doesn’t directly control the compliance of the website.

Compliance with harmonised standards and technical specifications

We know some parts of the University of Leeds Online Store are not fully accessible. Although more non-compliances may exist, the following items are non-compliant for the displayed reasons:

• Most pages have headings where the programmatic level doesn’t match the level that's presented visually. This fails WCAG 2.2 success criterion 1.3.1 Info and Relationships (Level A).
• The search function has a visible label that isn’t programmatically determinable. This fails WCAG 2.2 success criteria 1.3.1 Info and Relationships (Level A) and 2.5.3 Label in Name (Level A).
• Some decorative images are incorrectly coded as meaningful. This fails WCAG 2.2 success criterion 1.1.1 Non-text Content (Level A).
• Some text doesn’t have strong enough contrast against its background to meet requirements. This fails WCAG 2.2 success criterion 1.4.3 Contrast (Minimum) (Level AA).
• It's not possible to navigate to all interactive components, such as the navigation sub-menus, using only the keyboard. 
• The site does not have an appropriate language set in code. This fails WCAG 2.2 success criterion 3.1.1 Language of Page (Level A).
• It's not possible to navigate to all interactive components, such as the navigation sub-menus, using only the keyboard. This fails WCAG 2.2 success criterion 2.1.1 Keyboard (Level A).
• Several interface components receive focus in a way that affects the meaning and/or operability of the page. This includes the search submit button, and the basket button. This fails WCAG 2.2 success criterion 2.4.3 Focus Order (Level A).
• There's no way to skip repeated navigation and other repeated parts of a page. This fails WCAG 2.2 success criterion 2.4.1 Bypass Blocks (Level A).
• Link purpose isn't always clear from each link's text. This fails WCAG 2.2 success criterion 2.4.4 Link Purpose (In Context) (Level A).
• Content does not reflow to accommodate smaller screen or window sizes. This fails WCAG 2.2 success criterion 1.4.10 Reflow (Level AA). 

An update to the website by the supplier is being explored. This is anticipated to significantly improve the compliance of the site.

How compliance with the EAA is ensured

Point 3 of Annex V requires the University to “provide information demonstrating that the service delivery process and its monitoring ensure compliance of the service with point 1 of this Annex and with the applicable requirements of this Directive”.

The University has institution-wide processes that contribute to ensuring compliance across all the in-scope services. These are briefly explained here. Any service-specific service delivery processes or monitoring are highlighted as appropriate. 

Service delivery process

Purchasing

The University high-value procurement process includes requirements that allow the assessment of bids from potential suppliers against compliance with the Web Content Accessibility Guidelines 2.2 AA. Bids that would result in services covered under the EAA are subject to these requirements.

Purchases that don’t meet the high-value threshold are subject to a separate governance process that also allows an opportunity to challenge compliance with the Web Content Accessibility Guidelines 2.2 AA. Services covered by the EAA would be subject to these checks.

IT architecture

Consideration around digital accessibility is also built into IT architecture processes. This means IT planning and solutions are prompted to assess and address compliance with the Web Content Accessibility Guidelines 2.2 AA. Services covered by the EAA would be subject to this.

Development

University-built solutions and websites are routinely subject to internal digital accessibility testing against the Web Content Accessibility Guidelines 2.2 AA. Services covered by the EAA would be subject to this testing.

Monitoring

Active monitoring

The University conducts checks on websites and browser-based systems controlled by the University and by third parties. They are assessed for compliance with the Web Content Accessibility Guidelines 2.2 AA. Services covered by the EAA are subject to these checks.

Passive monitoring

The University uses an automated digital accessibility tool to monitor a high-profile portion of the digital estate against some WCAG 2.2 AA criteria.

In addition, during purchase renewals, the University will routinely request updates from suppliers about progress against compliance with the Web Content Accessibility Guidelines 2.2 AA. In some circumstances, accessibility testing may be conducted to determine the effectiveness of any updates towards compliance made by the supplier. 

Preparation of this document

This statement was first prepared on 26 June 2025. It was last reviewed on 26 June 2025. 

Consumer information

The University of Leeds is a UK higher education institution established in 1904. It’s part of the Russell Group of research-intensive universities.

• How to find the University.
• How to contact the University.

To contact the University about accessibility issues in its digital estate, if you need something in an accessible format, or are part of a relevant authority and need to contact the University in relation to the EAA, use the contact methods noted in the section ‘How to contact the University about issues or the EAA’.

The main characteristics of the relevant products and services are provided in web pages directly associated with those products and services. Summaries are provided in this document throughout the ‘How accessibility requirements are met’ section.

All information about the functionality of digital content and any relevant interoperability of digital content with hardware and software that the University is aware of is covered throughout the ‘How accessibility requirements are met’ section.

All information about charges, prices, costs, payments, contracts, complaints and related detail noted in the consumer information requirements of Directive 2011/83/EU of relevant products and services are provided in web pages directly associated with those products and services.