Is the Covid-19 vaccination portal simple and for everyone? Ministry of Health ignores all fundamental standards of web accessibility 

The Covid-19 Vaccination Registration website is currently a public administration portal of great importance. But why are relatively simple sites prepared regardless of the barriers they place on people with specific disabilities or impairments and do not comply with applicable laws?
Cover image for the article with screens of several Covid-19 vaccination websites and headline: The accessibility statement roast: Covid-19 vaccination portals

Published: February 10, 2022

In a series of articles on the state of accessibility of public sector websites in Czech Republic, we regularly address bugs and discrepancies that may affect users with specific needs. We focus on adhering to standards that help prepare websites so that they do not create unnecessary barriers to their use. We only choose from websites managed by authorities and institutions that have already been legally bound by the obligations of the European Union under the rules of EN 301 549 V2.1.2, since 2020. The statutory standard contains the criteria that the website should meet. The criteria are divided into four categories: Perceivable – Operable - Understandable – Robust.


Why follow web accessibility rules?

Compliance with the standard is the best functional requirement that helps to remove most barriers for people with disabilities. It is not just a matter of dull compliance with the valid Act No. 99/2019 Coll., On the accessibility of websites and mobile applications. The specific needs of users can be caused by various disabilities, impairments, or handicaps that real people suffer from. According to statistics, between 20% and even 25% of people globally may be affected by their ability to experience online services. This means that up to 1 in 4 people can face barriers when browsing a website if it does not meet the accessibility rules. If the website is prepared compliant with the rules, the user experience is also significantly better. And far from just for users who may have specific needs when using the Internet.

Which websites did we review?

We consider the Vaccination Portal of the Ministry of Health to be a very important site, especially at this time. It contains the following websites:

  • – Central reservation system – Vaccination Portal of the Ministry of Health
  • - Central covid-19 vaccination booking system - registration
  • - Citizen Vaccination Portal – certificates download

For evaluation purposes, we use the internationally recognized WCAG 2.1 standard, which is the basis for the EN 301 549 V2.1.2 standard. A brief look at some errors is not a fully conducted audit according to the valid methodology and does not provide a full description of compliance with the standard. We focus on the obvious discrepancies that an experienced web accessibility auditor may recognize at first glance. For each success criterion, we indicate their level of compliance: lowest (Level A) or medium (Level AA).

Revealed shortcomings

Central reservation system – Vaccination Portal of the Ministry of Health (

Criterion 1.4.5. Images of Text (Level AA) - FAIL

Images of text are used, they cannot be visually customized (font, size color, background)

 images of text in

Criterion 1.4.11. Non-text contrast (Level AA) - FAIL

Some user interface components and graphical objects do not have a sufficient contrast ratio against adjacent color.

Insufficient contrast in buttons

Criterion 2.4.7 Focus Visible (Level AA) - FAIL

Some interactive elements do not have a visible focus (logos in the footer).

invisible focus of logos in the footer

Keyboard shortcuts

When navigating using the keyboard, the option to open the keyboard navigation help appears, but the help page does not exist.

interactive element that appears when navigating using the keyboard and error message of not existing shortcuts help page

Accessibility statement - FAIL

The accessibility statement shall conform to the model set out in an implementing act of the European Commission issued in accordance with Article 7 (2) of Directive (EU) 2016/2102 of the European Parliament and of the Council.

The statement is identical for the websites and and is located at

This document does not meet the mandatory requirements, either formally or in terms of content.


Central covid-19 vaccination booking system - registration (

Criterion 3.1.1 Language of Page (Level A) - FAIL

The value of the lang attribute does not reflect the primary language used by the webpage (English and Vietnamese). Incorrect settings affect the behavior of some assistive technologies, such as screen readers.

the language setting attribute of the page does not change for language versions

Criterion 1.3.1 Info and Relationship (Level A) - FAIL

Heading markup from <h1> to <h6> is not always used when content is a heading, and the heading markup indicates the appropriate heading level for the content.

E.g., first heading: “Central covid-19 vaccination booking system - registration to the system” (should be H1 which is missing in the structure)

This shortcoming affects the screen readers.

Keyboard shortcuts

Although we can get to the keyboard shortcuts help on this page, the keyboard shortcuts do not work. Returning from to the home page is problematic, as there is no link or visible button to return to the main page. It is hidden under the logo of the Ministry of Health and labeled with wrong alternative text.

In any case, to meet the success criterion “2.1.4 Character Key Shortcuts,” at least one of the three rules must be met:

  1. Turn off: A mechanism is available to turn the shortcut off;
  2. Remap: A mechanism is available to remap the shortcut to use one or more non-printable keyboard characters (e.g., Ctrl, Alt, etc.);
  3. Active only on focus: The keyboard shortcut for a user interface component is only active when that component has focus.

Such options are not mentioned in the shortcut help, so we assume that this functionality would not meet the success criterion.

keyboard shortcuts page without Home button or return link

Citizen Vaccination Portal – certificates download (

Criterion 2.4.7 Focus Visible (Level AA) - FAIL

Some interactive elements do not have a visible focus (main buttons).

invisible focus of the button in

Criterion 3.1.1 Language of Page (Level A) - FAIL

The Czech version does not reflect the Czech language in html (lang attribute) used by the webpage.

incorrectly set language attribute on the Czech language version of the page

Criterion 2.1.1 Keyboard (Level A) - FAIL

Some functionality cannot be accessed using only a keyboard - which is essential.

Specifically, a radio button with the option to use an alternative way to sign in through mobile phone number and email address.

Criterion 1.1.1 Non-text Content (Level A) - FAIL

Text alternative (e.g., ‘aria-label’ or ‘aria-labelledby’) is missing for non-text content that is interactive or accept user input.

Specifically, language switcher.

Criterion 1.4.11 Non-text Contrast (level AA) - FAIL

The contrast between input field and adjacent colors is not sufficient (1.48:1)

insufficient contrast in the form

Accessibility Statement - FAIL

The accessibility statement is completely missing from the website.

The purpose of the accessibility statement is to provide users with information on how accessible the site is, which parts are not and why. At the same time, it can provide users with information about who to contact if they need assistance due to lack of accessibility.


Although we did not perform a full accessibility audit according to the WCAG 2.1 methodology, it is clear that the Vaccination portal web was not prepared in accordance with regulations and standards. We also find discrepancies in basic level A. As a result, the revised pages are non-accessible. To fulfill the accessibility obligation rules by simply stating that the site "meets all the rules" like we see in the Statement, even though it clearly ignores them is, in our opinion, laziness or hypocrisy.

The main vaccination portal of the Ministry of Health is intended for all citizens and is absolutely essential to the current effort to manage the covid pandemic. By failing to comply with the legal rules of Internet accessibility, the Ministry of Health creates barriers to the use of the site and thus bans some users from using it.

Sadly, most of the shortcomings could have been easily prevented. In addition, these are not very complex sites in scope. It is not quite understandable why neither the Ministry of Health nor the National Agency for Communication and Information Technologies (NAKIT) communicate about such a critically important website with the highest authority on accessibility in the Czech Republic, i.e., the eGovernment department of the Ministry of the Interior. This department is not only the author of the Methodological Instruction binding on all obligated public sector entities, but it is also responsible for monitoring compliance with the accessibility rules.


Actum Digital is an International Association of Accessibility Professionals member

logo of IAAP



Older articles about hypocrisy of public sector in accessibility:

The State of Web Accessibility in the Czech Republic Public Sector

The Ministry of Interior is set to lead by example, but it is already failing in its foundations

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