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Accessibility

Which accessibility law actually applies to your museum?

By Thøger Elung-Jensen
12 minutes

If you have read about accessibility requirements for museums over the past year, you have probably met two laws in the same sentence. The Accessibility Act (Tilgængelighedsloven), which implements the EU's European Accessibility Act. And the Web Accessibility Act (webtilgængelighedsloven), which applies to public bodies. They are about different things. They have different supervisory authorities. And it is the Web Accessibility Act that actually binds most state-recognised museums' digital interpretation.

The practical walkthrough of website, booking and audio guides as visitor contact points sits in European Accessibility Act for museums. Here is the legal overview: which law applies where, and what supervision actually measures.

Two laws that keep being mixed together

The Accessibility Act is the Danish implementation of the European Accessibility Act. It applies from 28 June 2025 and covers products and services aimed at consumers. It does not set out how accessibility is achieved. It sets out the result: accessibility for as many people as possible. A central requirement is that information must be deliverable through more than one sensory channel. Supervision sat with the Danish Safety Technology Authority (Sikkerhedsstyrelsen), which from January 2026 has been merged with the Danish Business Authority (Erhvervsstyrelsen).

The Web Accessibility Act applies to public authorities and bodies governed by public law. That includes most state-recognised museums. The Act sets requirements for websites, intranet, extranet and mobile applications. The legally binding standard today is EN 301 549 version 3.2.1, which refers to WCAG 2.1 Level AA. Supervision sits with the Agency for Digital Government (Digitaliseringsstyrelsen).

The difference is concrete. The first law is about consumer products and services on a European market. The second is about public bodies making their digital content accessible. When a supplier text writes that "the EAA applies to the museum's website and audio guide", it collapses the two. That is the mix-up you need to be able to unpick before you buy advice, write requirements into a tender or update the accessibility statement.

What the Accessibility Act actually covers in a museum

The Accessibility Act has a defined list. It covers, among other things, computers, smartphones, e-books, banking services, e-commerce and certain transport services. In a museum, self-service terminals such as ticket machines are clearly covered. A visitor who has to buy a ticket at a machine must be able to do so even if she uses a screen reader, a keyboard or magnification.

Museums' own audio guides, by contrast, are not on the list. We have gone through the Act and the available guidance and cannot confirm that a museum interpretation solution as such is covered by the Accessibility Act. That is a gap that several supplier texts fill with a yes. That yes does not hold if you are asked to point to the paragraph.

Interpretation still has to be accessible. You need the right law when you argue internally, write to the board or answer a supervisor. For digital interpretation the anchor is the Web Accessibility Act. For physical access and the overall duty there is also a requirement in the Museum Act (museumsloven), which we return to.

If you have hardware in the foyer that sells tickets or issues information, check it as consumer-facing self-service. If you have a web-based guide, a QR page or a booking flow, check it as a digital service under the Web Accessibility Act. The two checks are different, and they have different consequences if something is missing.

The Web Accessibility Act is the one that binds interpretation

Most state-recognised museums are public authorities or bodies governed by public law. Then the Web Accessibility Act applies to what the visitor meets digitally: the website, the ticket page, the page a QR code opens, and the app you may still ask people to download.

The applicable technical reference is EN 301 549 version 3.2.1, harmonised 12 August 2021 (18 August according to the European Commission). The standard's requirements for web content point to WCAG 2.1 Level AA. That is the package you need to be able to document today. The Agency for Digital Government writes it itself in its material on the Act's requirements: always remember to set requirements according to the latest applicable version of EN 301 549.

Then comes the deadline that is making autumn busy. The agency's own slide material puts EN 301 549 version 4.1.1 at 30 November 2026, "reportedly". When the new version is cited in the Official Journal of the European Union, WCAG 2.2 becomes the requirement you have to meet. There is no confirmed date. Phrase it therefore as an expectation, both internally and towards suppliers. "Reportedly 30 November 2026" is the agency's own reservation, and you should take it with you.

WCAG 2.2 adds six new success criteria at Level A and AA. Two of them hit museum websites and QR pages directly. 2.5.8 Target Size requires that clickable targets are at least 24 by 24 pixels. 2.4.11 Focus Not Obscured requires that the element the keyboard is on is not hidden behind a fixed header, a cookie banner or a chat button. The standard is backwards compatible. What you have already done for 2.1 AA you do not have to redo. You add the new criteria on top.

What supervision actually found in 2025

The Agency for Digital Government published the results of its web accessibility supervision in 2025. 255 websites received simplified monitoring. 23 websites and 11 mobile apps received an in-depth test.

In the simplified monitoring, 71 of 255 complied with the Act. That is 28 per cent. 90 of 255 complied with most requirements. 94 of 255 did not comply with the Act. That last figure is the one you need to be able to say out loud in a management meeting: 94 public websites in the sample did not meet the Act.

The in-depth tests show where it goes wrong. Information and relationships failed for 82 per cent. Name, role and value failed for 74 per cent. Contrast of non-text content failed for 65 per cent. And language of parts of the content failed for 65 per cent.

That last requirement is success criterion 3.1.2, Language of Parts. It is exactly what you break when you place English or German interpretation text on a Danish page without a correct lang attribute. A screen reader set to Danish will then speak the German sentence with Danish pronunciation. The visitor who uses an assistive tool gets a worse experience than the one who can skim the text with their eyes. The error is technically small. It is legally precise. And it is common, because museums work with several languages on the same page.

The Agency for Digital Government can issue three types of order. You can be asked to make specific content accessible. You can be asked to ensure a complete and up-to-date accessibility statement. Or you can be asked to point to a concrete accessible alternative. The statement is therefore not decoration. It is one of the three points supervision can act on.

13 per cent say they meet an older standard

In February 2026 the Knowledge Centre on Disability (Videnscenter om handicap) published the report How do museums become for everyone?. It draws on answers from 97 museum staff and interviews with seven museums, and it contains ten recommendations. The Organisation of Danish Museums (Organisationen Danske Museer) covered it on 13 April 2026.

Only 13 per cent of the museum staff surveyed state that they meet WCAG 2.0. The requirement in the Web Accessibility Act is already WCAG 2.1 AA. The expectation is that it will tighten to WCAG 2.2 when the new EN 301 549 is cited. The gap between what staff themselves say and what the law already requires is large. The gap to what is expected late in 2026 is larger.

The report holds several figures that tell you where the work stands. Only 18 per cent state that accessibility is an integrated part of the museum's strategy. The rest work more ad hoc. 54 per cent point to leadership and staff backing as what has made the biggest difference. 51 per cent have worked with alternative content formats, and 56 per cent want to do so going forward. Many museums lack an overview of their own accessibility.

That is why a checklist for interpretation leads is worth more than yet another strategy workshop. You do not need to wait for accessibility to become a chapter in the next four-year plan. You can fix the places supervision already measures, and the places the visitor already drops off.

The Museum Act already requires you to strive for accessibility

Beside the two digital laws stands the Museum Act. In LBK nr. 1017 af 7. juli 2025, § 14, stk. 1, nr. 14, it states that the museum shall strive for the greatest possible accessibility for persons with disabilities. The Agency for Culture and Palaces (Slots- og Kulturstyrelsen) elaborates that this can include access to buildings, sign-language interpreting, special programmes and opening hours.

The paragraph is discretionary. It says "strive", not "shall document WCAG". It covers both the physical and what the visitor meets in the house. It does not replace the Web Accessibility Act. It means that accessibility is already part of what a state-recognised museum must be able to answer for, also when the conversation is about ramps, guided tours, opening hours and HTML.

The same paragraph requires free admission for school pupils in a teaching context and for everyone under 18. Accessibility and audience access therefore sit in the same provision. That is useful when you need to explain why digital interpretation belongs with what the museum is already obliged to do.

Where multilingual interpretation typically breaks the law

Many museums have done the right thing: they have translated exhibition texts, written an English about-us page and put German on the most visited rooms. The problem arises when those languages sit on the same Danish page, in the same accordion or in the same QR landing, without the code telling which language each piece is written in.

A Danish page typically has lang="da" on the html element. That is correct for the Danish body text. An English paragraph needs lang="en". A German paragraph needs lang="de". Without that marking you fail 3.1.2. That is the requirement 65 per cent failed in the in-depth tests.

The same applies if you embed a player that shows track titles in several languages, or if a language selector changes visible text without changing lang. A browser-based guide that opens on the visitor's phone is still a website in the Act's sense. The QR code merely moves the visitor onto a page you are responsible for.

Plain language is the other half of the same task. A correct lang attribute helps the screen reader with pronunciation. Plain language helps the visitor understand the content, also when she is listening in a noisy room or reading on a small screen. The two belong together, and neither requires a new IT project.

A checklist for interpretation leads

You do not need to start with a full audit. Start with what you can see yourselves, and what supervision already measures.

1. Establish whether the museum is covered by the Web Accessibility Act.
Most state-recognised museums are, because they are public authorities or bodies governed by public law. If you are in doubt, ask your municipality, state supervisor or legal adviser before you write "does not apply to us" in the statement. The doubt needs to be resolved, not guessed.

2. Find the accessibility statement and check the date.
Is it there, is it complete, and is it updated after the latest change to the site? One of the three orders the Agency for Digital Government can issue is precisely about the statement. A statement from 2022 that describes a site you have relaunched is a problem you can fix without touching the code.

3. Go through every page where you mix languages.
Exhibition pages, "plan your visit", press room and QR landings. Mark each foreign-language passage with the right lang attribute. That is the requirement 65 per cent failed, and it is the requirement multilingual museum interpretation hits most often.

4. Open the site on a phone and walk it with a keyboard.
Can you reach opening hours, ticket purchase and the current exhibition without a mouse? Does focus get stuck in the menu? Does the fixed header cover the field you are in? That last one becomes a separate requirement when WCAG 2.2 is expected to take effect.

5. Measure buttons and links on mobile.
Are they at least 24 by 24 pixels, and is there enough space between them for a visitor with motor difficulties to hit the right one? That is 2.5.8, and it hits older designs especially, with small text links in the footer and tight language selectors.

6. Move the most important information out of PDF.
Opening hours, prices, access and "how to get here" should sit as HTML. A PDF can be a supplement. It is rarely a good primary format on mobile, and it is hard to make accessible afterwards.

7. Scan your own QR codes.
Does the visitor arrive directly at the right content? Is the page readable in exhibition light? Does it have a visible language selector, and does lang change when the language changes? A QR code that lands on the homepage is an interpretation problem before it is a legal problem. The practical setup is described in the guide to QR codes for museums.

8. Check contrast on buttons, icons and graphics.
65 per cent failed contrast of non-text content in the in-depth tests. That is arrows, icons, focus rings and buttons without a visible edge. It is also what fails when you use light text on an exhibition photograph.

9. Give audio and video an alternative.
Captions, a text version of the audio guide, a short description of what the image shows. The Knowledge Centre's report shows that 51 per cent have already worked with alternative formats, and that 56 per cent would like to. It is one of the places interpretation and the law meet without your having to wait for the IT department.

10. Write the Danish source text so it can be understood at first reading.
Short sentences, ordinary words, specialist terms explained when they are necessary. A clear source text is easier to translate, easier to read aloud and easier to mark up with lang. It is the fastest improvement you can make this week.

11. Write accessibility into the next tender or the next supplier contract.
Set requirements to the latest applicable version of EN 301 549, as the Agency for Digital Government recommends. Ask for documentation of 2.1 AA now, and ask for a plan for 2.2 when the new standard is cited. Do not write "EAA-compliant audio guide" unless you can point to which part of the Accessibility Act you mean.

12. Make accessibility a management item, not a side project.
Only 18 per cent of those surveyed in the Knowledge Centre's study have it in the strategy. 54 per cent say that backing from leadership and colleagues was what moved most. A standing item on the interpretation meeting, a named person responsible and a date for the next review of the statement are worth more than a workshop that is not followed up.

What you can get done before the requirement is expected to tighten

The Agency for Digital Government writes "reportedly 30 November 2026". Take that as a working date, not as a fact. If you already now fix language marking, contrast, keyboard navigation and the statement, you stand better, whether the citation comes in October, in November or a little later.

WCAG 2.2 is backwards compatible. You do not discard what you have done for 2.1. You add measurable button size and visible focus on top. That is manageable if you know which pages the visitor actually uses: homepage, ticket, plan your visit, the current exhibition and the QR pages that stand out in the rooms.

Use the supervision figures when you need time in the calendar. 94 of 255 websites did not comply with the Act in 2025. 65 per cent failed the language of parts of the content. 13 per cent of the museum staff surveyed say themselves that they meet WCAG 2.0. Start with the errors you can point to in your own material.

If you work with multilingual interpretation on the page or via QR codes, language marking is one of the places you can fix at once. A browser-based audio guide that opens directly on the visitor's phone at least removes the download step and gives you one page you can mark up, test and declare.

See how the solution works, and try it on your own text.

Sources

About the author: Thøger Elung-Jensen is co-founder of Audioguiden and works to help museums use AI to take their interpretation to more people.

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