Overview
During our audit, we determined that the first focusable element of 46 webpages out of our sample of 80 webpages was not a bypass block but was the cookie banner. WCAG criteria states that the first focusable element of a webpage must be a bypass block to the main content. At the same time, however, General Data Protection Regulations require that users be given the option to protect their privacy when logging on to a website (including from cookies). The cookie banner should not take priority over the bypass block, the bypass block should be configured to override the cookie banner so it is most accessible to users.
A lack of bypass blocks that allow users to skip to the main content of a webpage without first selecting their cookie settings may keep disabled users from easily obtaining the information they need.
Authoritative Guidance
Success Criterion 2.4.1 Bypass Blocks (Level A)
A mechanism is available to bypass blocks of content that are repeated on multiple Web pages.
Reasons for Issue
Cookie settings have been commonplace since 2018 and were implemented in response to the European Union General Data Protection Regulation, which required them. The competing standards between General Data Protection Regulations and WCAG has caused a lack of clarity regarding accessible implementation, leading to institutions designing cookie banners to be the first focusable element.
Recommendation
Accessibility industry sources suggest that the best practice would be to ensure that the skip link to main content comes first, followed by a skip link that allows users to skip to the cookie banner. UMass Amherst should consider adding these skip links to its website.
Auditee’s Response
The University will take this under consideration; however, it is required to follow European Union General Data Protection Regulations that require its users be given the option to protect their privacy when initially logging on to a website, including from cookies.
Auditor’s Reply
Based on its response, UMass Amherst is taking measures to address our concerns regarding this matter.
| Date published: | December 30, 2024 |
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