Dr Sofia Celic, Web Accessibility Consultant, Accessible Information Solutions [HREF1], National Information and Library Service [HREF2], 454 Glenferrie Road, Kooyong, 3144, Australia. Email: sofia.celic@nils.org.au
Mr Steven Faulkner, Web Accessibility Consultant, Accessible Information Solutions [HREF1], National Information and Library Service [HREF2], 454 Glenferrie Road, Kooyong, 3144, Australia. Email: steven.faulkner@nils.org.au
Dr Andrew Arch, Manager Online Accessibility Consulting, Accessible Information Solutions [HREF1], National Information and Library Service [HREF2], 454 Glenferrie Road, Kooyong, 3144, Australia. Email: andrew.arch@nils.org.au
The Australian Banker's Association prepared an internet banking standard in April 2002 and recommended certain levels of conformance with their standard within 6 months and 18 months. A bank's home page is usually the most important entry point to their online services - any accessibility issues on this page will create access problems for some user groups. In December 2003 we examined the home pages of eight Australian banks for accessibility. Our findings show that while none of the banks met the standard, some of them had good levels of technical conformance. We cannot ascertain the impact of the introduction of these standards as there are no previous studies to benchmark against. However, we hope that this comparative study will encourage the banks further in their accessibility endeavours.
This paper reports on a comparative study of the accessibility of the home pages of the major retail banks operating in Australia. While the study does not profess to pass judgement on the accessibility of the banks' entire websites, the accessibility of the home page is probably a good indicator of the attention the banks pay to this issue. It is also the key entry point to the banks' online services; most people will pass through the home page on their way to find out about available services or to undertake some transactional activity.
In April 2002 the Australian Banker's Association (ABA) released a Banking Industry Action Plan to improve the accessibility of electronic banking by their members and other financial institutions by developing Industry Standards [HREF3]. The Industry Standard covers Automated Teller Machines (ATMs), Electronic Funds Transfer at the Point of Sale (EFTPOS), Automated Telephone Banking and Internet Banking. The Standard was developed in consultation with the Human Rights and Equal Opportunity Commission (HREOC) and organisations of and for older Australians and people with disabilities, to incorporate the best information, guidance and new research. The objective was to describe best practice in accessibility consistent with the Disability Descrimination Act (DDA). Adopting the standard would provide organisations with some confidence against DDA complaints, but not guarantee fulfilment of legal responsibilities under the DDA.
Adoption of the standard was cited as voluntary and that it could be used by
banks to develop their own standards. HREOC state that: "Subsequently
a number of ABA members have committed to adopting the standards,
in part or in full."
in a
request for feedback [HREF4]. HREOC are now (two years
post release) in the process of assessing the initial impact and awareness of
the standards. They requested feedback from people with disabilities and representative
organisations by February 6th 2004.
The results of the HREOC assessment have not been made public to date (early April 2004). However, discussions with two organisations that responded to HREOC's request for feedback have provided variable comment on the accessibility of Internet Banking. One of these provided some detail of website accessibility, indicating a lack of ability to vary the font size and unclear link phrases as the biggest issues.
Accessible Internet Banking has the potential to make a very big difference to many people with disabilities in addition to the advantages it provides for the population as a whole. Internet Banking has the potential to provide people that have accessibility problems with other means of banking (such as access to a "walk-in" branch or telephone banking) a means to remain independent and more in control of their own financial requirements.
The Australian Bureau of Statistics
Disability, Ageing and Carers report [HREF5] estimates that 19.2% of Australia's
population (ie, 3.6 million people) have a recognised and ongoing disability.
While not all of these people will have trouble using a computer, a significant
number of the population will benefit from more accessible banking web sites.
A study undertaken in the U.S., 'The Wide Range of
Abilities and Its Impact On Computer Technology' [HREF6], has found that
57% of working-age computer users are 'likely'
or 'very likely'
to benefit from the use of accessible technology due to experiencing 'mild'
or 'severe'
difficulties or impairments.
Accessible Information Solutions (AIS) web accessibility team, at the National Information and Library Service, has undertaken various projects on accessibility for financial organisations and has conducted a comparative study of the accessibility of the home page of eight Australian banks. The scope of this study is only a small part of assessing the accessibility of banking websites, providing a glimpse into the potential accessibility or not of each website.
This study is an examination of each home page as at December 2003. It does not assess improvements (or not) in Internet Banking because of the lack of a corresponding assessment at an earlier date. It is hoped that this study, along with the findings from the HREOC review and the ABA's stated commitment to accessibility, will prompt greater attention to accessibility issues in the future.
The ability of users to access information and services from the web is dependent on many factors. These include the content format; the user's hardware, software and settings; internet connections; the environmental conditions and the user's abilities and disabilities.
The term "web accessibility"
generally relates to the implementation
of website content in such a way as to maximise the ability of users with disabilities
to access it. For example, providing a text equivalent for image content of
a web page, allows users with some visual disabilities access to the information
via a screen reader. The techniques and approaches that create more accessible
web pages for people with disabilities also address many other access issues
such as download speed and discoverability.
Many governments, industries and groups around the world have designated the Web Content Accessibility Guidelines (WCAG) version 1.0 [HREF7], developed by the Web Accessibility Initiative of the World Wide Web Consortium, as the accessibility standard for their web content or use this as the basis for their own standard.
WCAG 1.0 offers these user scenarios to consider in making web content more accessible:
The Internet Banking section of the ABA Industry Standard includes the following scope (paraphrased):
The implementation requirements of the ABA Internet Standard reference both W3C's WCAG 1.0 [HREF7] and US Public Law 508 [HREF8] (paraphrased):
"scripted information shall be identified with functional text that can be read by assistive technology".
"the (online) form shall allow people using assitive technology to access the information, field elements, and functionality required for completion and submission".
"a method shall be provided that enable users to skip repetitive navigation links".
"when a timed response is required, the user shall be alerted and given sufficient time to indicate more time is required".
The accessibility of the home page of 8 major and regional Australian Banks,
as rendered in Internet Explorer 6, was assessed against WCAG
1.0 Checkpoints at all priority levels in December 2003. This was done by examining
the page's appearance and the code for each page for any Checkpoint failure.
To aid this process we used the AIS
Accessibility Toolbar [HREF9], the W3C HTML Validator [HREF10] and Juicy Studio's colour
contrast tools [HREF11]. A 'pass', 'fail' or 'not applicable' result was
determined for each Checkpoint. Some Checkpoints were assigned 'not applicable'
due to a) their incompatibility with the assessment of a single web page, or
b) the feature was not used on the page. For example, Checkpoint 14.3 (create
a style of presentation that is consistent across pages) requires assessment
across multiple pages and therefore was rated as 'not applicable'
for
all bank home pages in this review.
The 8 banks assessed were:
The results for technical conformance to WCAG 1.0 Checkpoints are presented in the following tables. This is a summary of the number of Checkpoints passed, failed or which were not applicable, at each priority level, for each home page. An average figure provides an indicative figure for the eight Australian banks as a whole.
WCAG 1.0 contains 14 guidelines and 65 Checkpoints. The Checkpoints are classified into three priority levels (the degree of severity of some accessibility issues may alter the classification of associated Checkpoints to a different Priority level):
These clasifications were established in 1998; the web is quite different now with its online service delivery. Many Priority 2 and Priority 3 Checkpoints are now essential for access by people with disabilities, especially those people relying on assistive technologies.
| ANZ | CBA | NAB | Westpac | BankWest | Bendigo | St.George | Suncorp |
|---|---|---|---|---|---|---|---|
|
23
|
16
|
18
|
16
|
25
|
24
|
24
|
16
|
| Priority Level |
Compliance status |
ANZ | CBA | NAB | Westpac | BankWest | Bendigo | St.George | Suncorp | Average |
|---|---|---|---|---|---|---|---|---|---|---|
| 1 | Pass | 3 | 3 | 3 | 3 | 3 | 1 | 3 | 4 | 2.9 |
| Fail | 2 | 3 | 2 | 1 | 5 | 6 | 3 | 1 | 2.9 | |
| NA | 12 | 10 | 11 | 12 | 8 | 9 | 10 | 11 | 10.4 | |
| 2 | Pass | 8 | 9 | 9 | 15 | 11 | 6 | 7 | 10 | 9.3 |
| Fail | 14 | 9 | 11 | 8 | 15 | 13 | 16 | 11 | 12.1 | |
| NA | 8 | 10 | 9 | 7 | 4 | 11 | 7 | 9 | 8.1 | |
| 3 | Pass | 2 | 4 | 5 | 2 | 4 | 3 | 6 | 5 | 3.9 |
| Fail | 7 | 4 | 5 | 7 | 5 | 5 | 5 | 4 | 5.3 | |
| NA | 10 | 11 | 9 | 10 | 10 | 11 | 8 | 10 | 9.9 |
The following sections present each bank's home page and discuss the following aspects:
Within each sub-section, we have given a "heads up" on accessibility through a "smile" or "frown" icon as indicated below:
| Icon | Explanation |
|---|---|
| |
Accessibility for this issue has been well implemented |
| |
Accessibility for this issue could have been implemented better; somtimes a bank may fail one aspect and pass another, or the implementation could generally be improved. |
|
|
Accessibility for this issue has been poorly implemented |
This page had many images with missing 'alt' attributes or
with inappropriate 'alt' attribute values. These were limited to decorative
images, of which there were many, and so a user needing textual information
would not actually miss important information but their experience of using
the page is impacted negatively. For example, a user browsing with a screen
reader may have the large number of decorative images announced as path and
file names. In addition, other information will be repeated, making the page
more tedious and time consuming to get through. The user may not be aware that
the images with missing 'alt' attributes do not contain any important information.
Without JavaScript support, logging on to the Internet Banking
area of the website was not possible. The JavaScript-dependent log on was still
presented to the user when JavaScript was not supported. Information was not
provided about the JavaScript support required, either beforehand or in response
to selecting this element of the page.
The JavaScript-dependent link to Internet Banking could be
activated by keyboard when JavaScript was supported.
The main navigational items across the centre of the page
were images of text that could easily have been implemented as text with style
sheet specifications. A text link to the same targets was available, but it
consisted of the phrase "more...". A clearer link phrase (e.g. "more individuals
information...") would provide a link to these main navigational items that
could be altered in size and colour use.
The size of the layout was fixed. The content, at default font
size, fit within 1024 X 768 pixels. Vertical scrolling was required at 800 X
600 pixels for the bottom quarter of the page content.
The central navigational area had an incorrect linearisation
order. The headings "Individuals", "Financial Advice", "Business", "Corporate"
and "Rural" were contained in one layout table row and their corresponding sub-link
lists were contained in the next table row. This results in grouping all of
the headings together and then all of the sub-link lists together, breaking
the required non-visual association between a heading and its corresponding
list.
The textual component of the page content was implemented
with fixed size units throughout.
All navigational items were included in the keyboard tab order.
This page contained a few images with missing text alternatives.
These appeared to be part of a counter function for the page and did not include
any images containing important information.
A couple of images contained a text alternative that repeated
information already provided in text content. The images were linked to the
same target as the text portion but were not included in the one link element.
The text alternative is appropriate if the current implementation is maintained,
but one link containing both the image and the text phrase is preferable.
The page contained many images using the 'longdesc' attribute
incorrectly. Some images used this attribute to provide an extended textual
description of the image-link target and other images repeated the image-link's
target URL as the value. The purpose of this attribute is
to provide a URL to a page containing a longer description
of the image itself. This attribute was not required for the images on this
home page.
The home page contained two links to Internet Banking. The first was a "log on" text link under the 'NetBank online banking' heading and the second was from the list of links presented in the drop-down box for "Log in to...".
If JavaScript support was not available, navigating to the
Internet Banking area of this site from either link was not possible. Information
was not provided about the JavaScript requirement.
The JavaScript-dependent links to Internet Banking could be
activated by keyboard when JavaScript was supported. However there appeared
to be a time limitation with the drop-down box (see 'Tab inclusion' section).
Images of text were identified as the main navigational items
in the left-hand column. In addition, images of form drop-down boxes were used
instead of actual form drop-down boxes. All of these could have been implemented
as text or form elements, as appropriate, with style sheet specifications.
The layout of this page was fixed. The content fit comfortably
at a resolution of 1024 X 768. A quarter of the page content was off the screen
vertically at a resolution of 800 X 600 pixels.
The linearisation order of this page was contrary to the visual
expectation. The linear order begins with the 'For your information...' section,
followed by the marketing content ('5.99% p.a.
for five months' and 'Save without sacrifice' sections), the bank logo and name,
the log-in section on the right-hand side of the central image, the search box
area, the top row of links, the left-hand navigational links, the "drop-down
box" images, and ending with the footer information.
The textual component of the page content was implemented
with fixed size units throughout.
Most interactive elements were within the tab order. Selection
of the images of drop-down boxes would present a list of links, but these were
not all included in the tab order. There appeared to be a time limitation for
presentation of these links, because the list would disappear after a short
while. The time period for display was insufficient to allow tabbing through
the list of links.
This page had some decorative or spacer images with alt="".
In theory, this is the correct 'alt' attribute value for images that do not
convey important information. However, many current screen readers will treat
this implementation as though no 'alt' attribute has been used at all and may
announce the file name and path instead.
Images that conveyed important information had appropriate
text alternatives.
The link to the Internet Banking area was non-functional when
JavaScript support was unavailable. The JavaScript-dependent function is still
presented when JavaScript is not supported. Information was not provided about
the JavaScript support required, either beforehand or in response to selecting
this element of the page.
The JavaScript-dependent link to Internet Banking could be
activated by keyboard when JavaScript was supported.
This page contained one image with text that could have been
implemented as text with style sheet specifications. All of the main navigational
items were implemented as text and not images, an implementation that improves
a user's ability to alter aspects such as size and colour.
This page had a flexible layout but contained a lot of information.
It required scrolling to get to key features even at its default text size and
1024 X 768 resolution. This would be exaggerated with increased font size or
lower resolutions. Half of the page content was off the screen vertically at
a resolution of 800 X 600 pixels.
The 'Internet Banking' and 'OnLine Trading' sections of links
at the top of the page did not linearise appropriately. The 'Internet Banking
Login' and 'OnLine Trading Login' links were within one table row, while their
related links 'Register' and 'More Info' for each section were in the next table
row. The appropriate associations were lost when the content was linearised.
The rest of the page appeared to linearise appropriately.
The textual component of the page was implemented with fixed
font size units throughout.
All navigational items were included in the keyboard tab order.
This page had many images with missing 'alt' attributes or
with inappropriate 'alt' attribute values. These were limited to decorative
images, and so a user needing textual information would not actually miss important
information but their experience of using the page is impacted negatively. For
example, a user browsing with a screen reader may have the large number of decorative
images announced as path and file names.
Navigation to Online Banking sign-in was not
dependent on JavaScript support.
The link to Online Banking was not within the keyboard tab
order and therefore could not be activated by keyboard.
The four links implemented as images of tabs at the top of
the page contained text that could have been implemented as text with style
sheet specifications. There did not appear to be a non-image way to view links
to those targets. The remaining navigational items have been implemented as
text.
The layout of the page content was of fixed size. At 800 X
600, half the page content was vertically off the screen. At 1024 X 768, one
third of the page content was vertically off the screen.
The page content appeared to linearise appropriately.
The font size for the content area of the page was flexible
but not for the top and left navigational areas, making a key aspect of the
page difficult to adjust for users that need to alter this aspect.
The left-hand list of navigational items were omitted from
the keyboard tab order. This would prevent many user groups from accessing most
areas of this site.
This page had a Flash movie in the center of the page. No
textual alternative was available for users without Flash support or other user
groups (such as screen reader users). The movie was only used to provide an
animation and could have easily be implemented as an image with appropriate
'alt' text instead.
The link to the Internet Banking area was non-functional when
JavaScript support was unavailable. The JavaScript-dependent function was still
presented to the user and information was not provided about the JavaScript
support required in response to selecting this element of the page.
The JavaScript-dependent link to Internet Banking could be
activated by keyboard when JavaScript was supported. However, there was a potential
issue with getting to this link via keyboard (see 'Tab inclusion' section).
The page had some images in the top right-hand corner consisting
of an icon with text underneath. The text component could be separated and implemented
as text with style sheet specifications. However, there were textual links on
the page to the same targets, making this less important.
The layout was a fixed size. One third of the page content
was vertically off the screen at 800 X 600 pixel resolution. The page content
fits within 1024 X 768 pixels.
The content appeared to linearise appropriately.
The text content of the page was implemented with fixed font
size units throughout.
The Flash movie in the center of the page will trap keyboard
focus for users without Flash Player version 7. This makes the page effectively
inaccessible to keyboard users without the right plugin. The movie was only
used to provide an animation and could have easily be implemented as an image
instead, avoiding this potential issue.
Many of the images in this page did not have a text alternative.
This included the important navigational images along the left hand side of
the page.
Internet Banking was not available if JavaScript was not supported.
Information was provided about the JavaScript requirement when a user attempted
to access Internet Banking in this situation. However, the information was limited
to describing how to turn JavaScript support on in Internet Explorer 5 &
6 and Netscape 7. No provision was made for users that are not in a position
to do this (which is often the case when JavaScript support is not available).
The JavaScript-dependent link to Internet Banking could be
activated by keyboard when JavaScript was supported.
Important navigational links (at the top and left of the page)
have been implemented as images of text. In addition to the issue this presents
resizing and altering colours for this text, the colours chosen for the left-hand
menu would have been problematic for some users.
This page had a flexible layout. However, more than half of
the page content was vertically off the screen at the default text size and
a resolution of 1024 X 768 pixels. At 800 X 600 pixels, three-quarters of the
content was off the screen vertically.
The content or each frame appeared to linearise appropriately.
The text component of the page (the main content area) was
implemented with flexible font size units.
All navigational items were in the keyboard tab order.
This page had a number of images without text alternatives
or with inappropriate text alternatives. Many image icons or bullets had text
alternatives that repeated the textual information following it. Some had the
name "St George" at the start, adding unnecessary information.
Internet Banking was not available when JavaScript was not
supported. The JavaScript-dependent function was still presented to the user
and information was not provided about the JavaScript support required in response
to selecting this element of the page.
The JavaScript-dependent link to Internet Banking could be
activated by keyboard when JavaScript was supported.
Images of text were used for the navigational elements.
The layout was flexible to a degree, having a minimum size
requirement. At 1024 X 768 pixels, a quarter of the page content was vertically
off the screen. At 800 X 600 pixel resolution, almost half of the page content
was off the screen vertically and a small amount horizontally. In addition,
because of fixed width and height of containing elements, some content overlapped
when the text size was forcibly increased.
The content appeared to linearise appropriately.
The text content of the page was implemented with fixed font
size units throughout.
All interactive elements were in the keyboard tab order.
Only two images on the page had text alternatives. This did
not include images with important information such as the company name (logo),
contact details, finding a branch or email images.
Direct links from this page to Internet Banking were available in two places - the first was in one of the left-hand menu "fly-outs", the presentation of which was dependent on JavaScript, and the other was along the right-hand side of the page in a form-based element.
The second link allowed the user to progress to the log on
screen when JavaScript was not supported. The user was presented with information
about the JavaScript requirement for using online banking at this point.
The JavaScript-dependent link (first Internet Banking link)
to Internet Banking could be activated by keyboard when JavaScript was supported.
The site contained a few images that could have been implemented
as text with style sheet specifications, such as "find a branch", "email us",
"online services" and "latest news".
The layout of the content was flexible for window size. At
1024 X 768 pixels, approximately a fifth of the page content was off the screen
vertically. At 800 X 600 pixel resolution, almost half was off the screen vertically.
Some content did not linearise appropriately. The headings
'Calculators', 'Apply' and 'Interest Rates' were contained within one table
row and their associated sub-links were contained in the next table row, resulting
in the loss of association when this content was linearised. The remainder of
the content appeared to linearise appropriately.
The text content of the page was implemented with flexible
font size units. This includes the flyout menu items - a commendable effort
because in many implementations these often end up overlapping when text size
is increased.
All interactive elements were included in the keyboard order.
But this page used a navigation system of flyout menus where all levels of sub-menus
were included in the tab order. This meant that there were hundreds (over 450
on the day we assessed this home page) of links to get through in the left-hand
navigation. A "skip to content" link to bypass this area was not provided.
The overall status of the accessibility of Australian banking web sites, using the accessibility of their home pages as an indicator, is less than desirable. None of the banks assessed has met the ABA recommended timetable of addressing all applicable WCAG 1.0 Priority 1 and Priority 2 checkpoints within 18 months of the Standard being released (April 2002).
| ANZ | CBA | NAB | Westpac | BankWest | Bendigo | St. George | Suncorp |
|---|---|---|---|---|---|---|---|
|
16
|
12
|
13
|
9
|
20
|
19
|
19
|
12
|
In the UK, AbilityNet recently released their "eNation" report on online banking, ' On-line banks score one out of ten for accessible websites' [HREF20]. This report indicated that UK banks also still have a long way to go to meet the needs of people with disabilities trying to bank online. While the methodology was not provided, it would appear at face value that Australian banks are, on average, slightly ahead of their UK counterparts in providing accessible websites.
The next step in assessing bank websites for their accessibility is to assess the website as a whole. While an assessment can be made of a bank's informational pages, it is also highly desirable to follow through on some processes such as using their Internet Banking service. After all, this is why most people would be visiting a bank's web site. The ABA Internet Standard lists transactions covered by the standard, such as balance enquiry, statement viewing and bill pay.
User testing with people that utilise assistive technology is a highly effective way to identify accessibility issues, particularly those that may not be covered by standards such as WCAG, and to identify useability issues associated with accessibility. These latter issues can be just as important in a user's acceptance of utilising online services as the more traditional accessibility issues.
Other issues often overlooked in accessibility such as page weight and cross-browser functionality are also important to assess.
Access to the interactive service areas of these websites generally requires an account with the bank. Some bank websites offer a "demonstration" mimicking their actual internet banking facility but this is often limited in functionality. A "dummy" account, or similar, is required to undertake further testing . Therefore, testing of these interactive service areas would be subject to the agreement by each bank to provide such access to their internet banking facility.