European Union’s Mandate M 376

The European Union’s Mandate M 376 is a rough equivalent to an EU-wide version of the U.S. Section 508 requirements. The European Commission’s (EC) Mandate M 376 directs the three European standards organizations– CEN, CENELEC and ETSI– to develop a unified set of requirements for public-sector procurement of accessible information and communication technologies (ICT). Currently, the standard is in its third draft format, and the goal is to have a version published by February 28, 2014.

Mandate M 376 should be roughly familiar to U.S. developers, as on a broad scope, it takes a similar approach as the Section 508 Refresh. The current draft version contains a series of ten functional performance statements and a set of nine product function areas that cover various technical conformance requirements. Furthermore, requirements for web based content, web applications and electronic documents will also be familiar, as they target WCAG 2.0 A and AA conformance requirements. Finally, the Mandate will define explicit conformance claim requirements made either by first, second or third parties about the procured product

To determine compliance, the Mandate will require that developers make a claim of conformance against WCAG 2.0 A and AA requirements. The assessment approach has not yet been defined, but a variety of options are on the table, ranging from a first party attestation to accredited attestation. At one end of the spectrum, manufacturers may only be required to provide an informal statement of compliance; at the other end, they may be required to provide a full, formal statement of compliance by an accredited, third party organization. In practice, it appears that the EU expects that the majority of claims will be made through first party attestation supported by a third party declaration of conformance. These documents can readily be provided via SSB’s consulting methodology.