Management Action Plan - Evaluation of the Office of the Commissioner of Lobbying’s website on its accessibility and usability for people with disabilities
Background
In 2024, the Office of the Commissioner of Lobbying (OCL) requested an evaluation from Shared Services Canada’s Accessibility, Accommodation and Adaptative Computer Technology (AAACT) of the accessibility and usability of the Office of the Commissioner of Lobbying’s website for people with disabilities. A subset of 6 key pages were chosen based on web traffic to the page and importance of the page:
- Home
- Lobbyists' Code of Conduct (2023)
- Lobbying at the federal level — at a glance
- Annual report 2023-24
- Investigation report - Dan Lovell
- Registration and reporting requirements during an election campaign
The final report was completed in October 2024.
Objective
The objective of this document is to present the management response and action plan based on the comments, issues noted, or warnings made in the AAACT’s report on the accessibility evaluation of the Office of the Commissioner of Lobbying’s website.
General notes
| Comment #1 | ||
|---|---|---|
| “Switch to basic HTML” and “Switch to standard version” links not functioning. | ||
| Affected pages from audit (issue found in master template) | ||
| Home | ||
| Lobbyists' Code of Conduct (2023) | ||
| Lobbying at the federal level — at a glance | ||
| Annual report 2023-24 | ||
| Investigation report - Dan Lovell | ||
| Registration and reporting requirements during an election campaign | ||
| Action | Responsible official | Target completion date |
| Remove the links until the functionality is fixed (as recommended by AAACT). | Manager, IT Operations and System Management | 2025-03-31 |
Usability comments
| Comment #1 | ||
|---|---|---|
| Line breaks used for styling purposes. | ||
| Affected pages from audit | ||
| Home | ||
| Action | Responsible official | Target completion date |
| Remove <br> when only used for presentational effects. Replace with | Webmaster, Communication Services |
2024-11-30 Completed: 2024-11-28 |
| Comment #2 | ||
|---|---|---|
| Inconsistent text versions for the same infographic found on two separate pages. | ||
| Affected pages from audit | ||
| Lobbying at the federal level — at a glance | ||
| Annual report 2023-24 | ||
| Action | Responsible official | Target completion date |
| Ensure text versions for the same infographic are consistent | Webmaster, Communication Services |
2024-11-30 Completed: 2024-11-28 |
| Comment #3 | ||
|---|---|---|
| 12 headings have duplicate ID attributes | ||
| Affected pages from audit | ||
| Lobbyists' Code of Conduct (2023) | ||
| Action | Responsible official | Target completion date |
| Replace duplicate IDs with unique IDs or remove entirely. | Webmaster, Communication Services |
2024-11-30 Completed: 2024-11-28 |
WCAG 2.2 accessibility issues levels A and AA
1. Text alternatives
1.1 Non-text content (Level A)
| Issue #1 | ||
|---|---|---|
| 10 images are missing an alt attribute | ||
| Affected pages from audit | ||
| Annual report 2023-24 | ||
| Action | Responsible official | Target completion date |
| When an image conveys information, we will represent the meaning in the alt attribute. When an image is decorative, the alt attribute will be left empty (alt=""). |
Webmaster, Communication Services |
2024-12-31 Completed: 2024-12-19 |
2. Adaptable
2.1 Info and relationships (Level A)
| Issue #1 | ||
|---|---|---|
| Nested list not nested correctly. | ||
| Affected pages from audit | ||
| Annual report 2023-24 (French page only) | ||
| Action | Responsible official | Target completion date |
| Replace the code snippet with suggested code | Webmaster, Communication Services |
2024-11-30 Completed: 2024-11-28 |
2.2 Sensory characteristics (Level A)
| Issue #1 | ||
|---|---|---|
| Graphical symbols as the only content conveying information | ||
| Affected pages from audit | ||
| Registration and reporting requirements during an election campaign | ||
| Action | Responsible official | Target completion date |
|
Remove the aria-hidden=”true” attribute and ensure the images have a text alternative using correct attributes.
|
Webmaster, Communication Services |
2024-12-31 Completed: 2024-12-19 |
3. Distinguishable
3.1 Use of color (Level A)
| Warning #1 | ||
|---|---|---|
| Only colour used to convey information / put emphasis | ||
| Affected pages from audit | ||
| Lobbying at the federal level — at a glance | ||
| Action | Responsible official | Target completion date |
| To emphasize text, use the <strong> element. | Webmaster, Communication Services |
2024-11-30 Completed: 2024-11-28 |
3.2 Contrast (minimum) (Level AA)
| Issue #1 | ||
|---|---|---|
| Hover state colour of links not satisfying minimum required contrast ratio. | ||
| Affected pages from audit (issue found in master template) | ||
| Home | ||
| Lobbyists' Code of Conduct (2023) | ||
| Lobbying at the federal level — at a glance | ||
| Annual report 2023-24 | ||
| Investigation report - Dan Lovell | ||
| Registration and reporting requirements during an election campaign | ||
| Action | Responsible official | Target completion date |
|
Hover state colour of links to be changed in the master template to exhibit a contrast ratio of 4.5:1. |
Manager, IT Operations and System Management |
2025-03-31 |
| Issue #2 | ||
|---|---|---|
| Some text colour not satisfying the minimum required contrast ratio. | ||
| Affected pages from audit | ||
| Home | ||
| Annual report 2023-24 | ||
| Action | Responsible official | Target completion date |
|
Replace the #fff (white) text used on #0a95aa with #000 (black) or bold the text (small text only). We currently provide text equivalents for images of text to ensure content is available to screen readers. |
Webmaster, Communication Services |
2025-01-31 Completed: 2025-01-15 |
3.3 Images of text (Level AA)
| Warning #1 | ||
|---|---|---|
| Images of text used instead of text | ||
| Affected pages from audit | ||
| Lobbying at the federal level — at a glance | ||
| Annual report 2023-24 | ||
| Action | Responsible official | Target completion date |
|
No action required. The report states that some graphics are simple enough to be converted to HTML; however, these images include elements that can’t easily be coded without compromising the information being conveyed. For these complex images of text, we had hard coded graphics and provided text equivalents for the images of text to meet accessibility requirements. |
N/A |
N/A |
3.4 Reflow (WCAG 2.1 Level AA)
| Issue #1 | ||
|---|---|---|
| Content not optimized for small screens | ||
| Affected pages from audit | ||
| Annual report 2023-24 | ||
| Action | Responsible official | Target completion date |
|
Make charts and graphs responsive so they are available on smaller screens and text doesn't become too small to read. |
Webmaster, Communication Services |
2025-01-31 Completed: 2025-01-15 |
3.5 Non-text contrast (WCAG 2.1 Level AA)
| Issue #1 | ||
|---|---|---|
| Non-text content fails to have a 3:1 contrast ratio with adjacent colours | ||
| Affected pages from audit | ||
| Registration and reporting requirements during an election campaign | ||
| Action | Responsible official | Target completion date |
|
Change the shade of the checkmarks from light green (#2eb130) to a darker green (#228723), which meets contrast ratios. |
Webmaster, Communication Services |
2024-11-30 Completed: 2024-11-28 |
4. Navigable
4.1 Link purpose (in context) (Level A)
| Issue #1 | ||
|---|---|---|
| Image has no accessible name and is the only content in a link (Twitter and YouTube icons) | ||
| Affected pages from audit | ||
| Home | ||
| Action | Responsible official | Target completion date |
|
Add alternative text to the icons using a title tag and aria-label tag. |
Webmaster, Communication Services |
2024-11-30 Completed: 2024-11-28 |
| Issue #2 | ||
|---|---|---|
| Link purpose not available within the link text | ||
| Affected pages from audit | ||
| Home | ||
| Action | Responsible official | Target completion date |
|
Add screen reader only content using the aria-label attribute. |
Webmaster, Communication Services |
2024-12-31 Completed: 2024-11-28 |
4.2 Headings and labels (Level AA)
| Issue #1 | ||
|---|---|---|
| Table headings with the same text as regular headings | ||
| Affected pages from audit | ||
| Annual report 2023-24 | ||
| Action | Responsible official | Target completion date |
|
Change table headings from <h> tags to captions <caption>. |
Webmaster, Communication Services |
2024-12-31 Completed: 2024-12-19 |
5. Readable
5.1 Language of parts (Level AA)
| Issue #1 | ||
|---|---|---|
| Visible English text in French screens | ||
| Affected pages from audit | ||
| Annual report 2023-24 | ||
| Action | Responsible official | Target completion date |
|
Replace the English content that is found on the French page. |
Webmaster, Communication Services |
2024-12-31 Completed: 2024-12-19 |
| Issue #2 | ||
|---|---|---|
| Hidden English text in French screens | ||
| Affected pages from audit (issue found in master template) | ||
| Home | ||
| Lobbyists' Code of Conduct (2023) | ||
| Lobbying at the federal level — at a glance | ||
| Annual report 2023-24 | ||
| Investigation report - Dan Lovell | ||
| Registration and reporting requirements during an election campaign | ||
| Action | Responsible official | Target completion date |
|
Update the master template to include French text for French screens and English text for English screens. |
Manager, IT Operations and System Management |
2025-03-31 |
6. Compatible
6.1 Name, role, value (Level A)
| Issue #1 | ||
|---|---|---|
| Images as the only content in a link without accessible names. (same issue as 4.1 issue 1) | ||
| Affected pages from audit | ||
| Home | ||
| Action | Responsible official | Target completion date |
|
Provide accessible name. (addressed in 4.1). |
Webmaster, Communication Services |
2024-11-30 Completed: 2024-11-28 |
6.2 Incorrect ARIA usages
| Issue #1 | ||
|---|---|---|
| The copyright statement uses incorrect ARIA attributes and the <summary> element was given the role=”tab” which requires an additional structure and attributes to be implemented correctly. | ||
| Affected pages from audit | ||
| Annual report 2023-24 | ||
| Investigation report - Dan Lovell | ||
| Action | Responsible official | Target completion date |
|
Use the Details/summary polyfill (expandable / collapsible content) component from WET. |
Webmaster, Communication Services |
2024-11-30 Completed: 2024-11-28 |
7. Accessibility testing with JAWS screen reader - Annual report 2023-24 only
7.1 Table of contents
| Comment #1 | ||
|---|---|---|
| Table of contents formatting / convention. | ||
| Action | Responsible official | Target completion date |
|
No action required. Works as intended. Does not detract from navigating the document as anchor links work well and are properly identified by screen readers. |
Webmaster, Communication Services |
N/A |
| Comment #2 | ||
|---|---|---|
| No "return to top" links (not required, but beneficial in large reports). | ||
| Action | Responsible official | Target completion date |
|
Add "return to top" links at end of each larger section. |
Webmaster, Communication Services |
2024-12-31 Completed: 2024-12-19 |
7.2 Graphics
| Comment #1 | ||
|---|---|---|
| Missing alt tag on the graphic of the Investigation Report | ||
| Action | Responsible official | Target completion date |
|
Add alt tag to the image. |
Webmaster, Communication Services |
2024-11-30 Completed: 2024-11-28 |
| Comment #2 | ||
|---|---|---|
| Increase screen reader visibility for infographics. | ||
| Action | Responsible official | Target completion date |
|
Include a note in the alt tag that there is a description available. |
Webmaster, Communication Services |
2025-03-31 |
7.3 Tables
| Comment #1 | ||
|---|---|---|
| Missing table headers (tables are semantically incorrect) | ||
| Action | Responsible official | Target completion date |
|
Add a scope attribute in the header row of each table. |
Webmaster, Communication Services |
2024-12-31 Completed: 2024-12-19 |
| Comment #2 | ||
|---|---|---|
| The table under Who was lobbied through an oral communication arranged in advance is “semantically incorrect” (wrong element used to define table). | ||
| Action | Responsible official | Target completion date |
|
Re-code the table according to the Web Experience Toolkit. |
Webmaster, Communication Services |
2024-12-31 Completed: 2024-12-19 |
| Comment #3 | ||
|---|---|---|
| Lists nested in table cells. | ||
| Action | Responsible official | Target completion date |
|
Restructure the table so that there is only one element per cell. |
Webmaster, Communication Services |
2025-01-31 Completed: 2024-11-28 |
7.4 Links
| Comment #1 | ||
|---|---|---|
| Link text doesn't make sense out of context. | ||
| Action | Responsible official | Target completion date |
|
Use more descriptive language for link text or use screen reader only text using the aria-label attribute. |
Webmaster, Communication Services |
2025-01-31 Completed: 2025-01-15 |
7.5 Read aloud and immersive reader
| Comment #1 | ||
|---|---|---|
| ReadAloud not working for content in drop-downs on Microsoft Edge. | ||
| Action | Responsible official | Target completion date |
|
No action required. This is caused by the browser (Microsoft Edge) and not an issue we can address. The auditor will follow up with Microsoft. |
N/A |
N/A |
7.6 Has details
| Comment #1 | ||
|---|---|---|
| One screen reader (JAWS) returns an unusual report. | ||
| Action | Responsible official | Target completion date |
|
No action required. Auditor states that “from a screen reader perspective, this does not detract from reading the report.” which may confuse screen reader users. |
N/A | N/A |
Approval
The Management Response and Action Plan was approved by the Commissioner of Lobbying on December 4, 2024.
- Date modified: