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EN 301 549 and WCAG 2.2 AA

Chatbot for government

Built accessible, processed inside the EU and a supplier who backs up your statement.

The chatbot counts towards your accessibility statement

As a public body, everything you offer on your channel falls under the government accessibility decree, which points to the EN 301 549 standard and therefore to WCAG level AA. A chat widget you purchase is part of that. The exemption for third-party content only applies to content you do not finance, do not develop and that does not fall under your responsibility; with a paid subscription on your own domain none of those conditions is met.

So you remain responsible for the statement, but the evidence has to come from the supplier. We provide that evidence and are open about where we are not yet: the widget is built to WCAG 2.2 AA and an independent audit using the WCAG-EM method is planned.

Built accessible

Keyboard, screen reader, contrast and language, plus optional read-aloud

Processing in the EU

Data processing agreement, European hosting and clear sub-processors

AI transparency

Visitors see from the first message that they are talking to an AI assistant

What you are assessed on

Government accessibility decree

Mandatory since 23 September 2020 for websites and 23 June 2021 for apps. It also covers cloud applications and embedded parts such as a chat widget.

EN 301 549 and WCAG

Currently WCAG 2.1 level AA. A new version of the standard with WCAG 2.2 AA has been published; as soon as the European Commission cites it, 2.2 applies to you automatically.

Accessibility statement

Public in the register, with a status from A to E. An audit may be at most three years old and must be carried out by hand, not with a scanner alone.

Procurement terms

Municipalities set this out through the GIBIT quality standards, central government and provinces through the requirements annexed to ARBIT. Usually with a duty to fix throughout the contract.

AI Act article 50

Since 2 August 2026 a visitor must know they are talking to AI. The widget shows this on every reply with the AI assistant label.

GDPR and data processing agreement

Chat conversations are personal data. You receive a data processing agreement with an overview of sub-processors, and the data stays inside the EU.

Who does what

Item WillieChat delivers You arrange
Accessible widget to WCAG 2.2 AA Yes Brand settings
Audit report of the widget Planned Audit of your own site
Accessibility statement in the register Supporting evidence Publication
List of deviations and fix dates Yes Include in statement
Accessible alternative channel Handover and email Phone and front desk
Notice when the widget changes Yes Update the statement

What you get from us for your file

A description of the accessibility features per WCAG criterion
An independent WCAG-EM audit report once it is completed
A remediation plan with dates for any open points
Data processing agreement with an annex of sub-processors
A description of the accessible alternative for your statement
A fixed contact point with a response time for accessibility complaints

How a project runs

1

We set up a trial on your own website so you can test the chat with keyboard and screen reader before signing anything.

2

You put your requirements next to our documentation. Whatever is not ready yet we name with a date, not with a hedge.

3

After going live we deliver the audit report and the wording you need to include the chat in your accessibility statement.

Frequently asked questions

Does a purchased chatbot fall under the third-party content exemption?

No. That exemption requires the content not to be financed by you, not developed by you and not under your responsibility, and those conditions apply together. With a paid subscription on your own domain none of the three is met.

Is a read-aloud function mandatory for government?

No. The Dutch accessibility authority states explicitly that read-aloud software is not mandatory. What is required is that the chat works with the screen reader, keyboard and magnification the visitor already uses. We offer read-aloud as an extra service for people with low literacy and dyslexia.

Can we reuse the audit report?

Yes, that is exactly the intention. A report on the technical part of a platform may be published as a general audit so every public sector client can refer to it. You combine that with the audit of your own website.

Where are the conversations processed?

Inside the EU. You receive a data processing agreement with an annex listing all sub-processors, including the AI service that generates the answers. Feel free to ask us for that annex before you decide.

What if the chat turns out not to comply fully?

Then you record that in your statement with a measure and a date, which is a valid status in the register. We supply the wording and fix it within the agreed period. That beats a supplier promising full conformity without a report.

Read on

A demo on your own website

We put the chat on a test page of your organisation so you can judge for yourself, with keyboard and screen reader, whether this works.

Get in touch