Your Accessibility Problem Might Live on Someone Else's Website
When DIGG audited the website of Sweden's Equality Ombudsman, it flagged a PDF that DO doesn't own, doesn't host and can't edit. Here's why that matters for every business with third-party content on its site.
Published October 2026 · Based on DO's formal response to DIGG (DO case no. 2026/881, DIGG case no. 2026-00916)
The short version
- DIGG, Sweden's Agency for Digital Government, audited do.se in spring 2026 against the European accessibility standard EN 301 549 V3.2.1 and found 229 remarks.
- Five of them concerned a brochure DO only links to. It's hosted on 1177.se, and DO says it neither owns it nor has the right to edit it.
- The auditor counted those issues against do.se anyway.
- For businesses under the European Accessibility Act, the lesson is direct: auditors assess what your users experience, not just what you built yourself. Linked documents, embedded tools and third-party widgets are part of that experience.
On this page
- What happened
- The PDF DO couldn't fix
- Why external content counts
- Where external content hides on your site
- What to do about it
- Frequently asked questions
What happened
DO (Diskrimineringsombudsmannen) is Sweden's Equality Ombudsman, the authority working against discrimination, including discrimination through inadequate accessibility. In spring 2026, DIGG audited do.se under the DOS Act, Sweden's law on accessibility of digital public services.
The audit covered 28 subpages and 3 documents and produced 229 remarks. Most concerned DO's own components: the complaint form (111 remarks), a missing dark mode (28) and the cookie function (12). DO says it is rebuilding or replacing all three during 2026.
But one group of findings stands apart, because DO says it can't fix it at all.
The PDF DO couldn't fix
Of the 10 remarks on documents, five concerned a single file: Broschyr Taltjänst Sverige, a brochure about Sweden's speech-to-text service.
DO's response to DIGG is clear about its position:
- The PDF is only linked to from do.se.
- It is published on 1177.se, not on DO's site.
- DO doesn't own it and has no ability or right to edit it.
DIGG still included it in the audit, and the five remarks still count toward do.se's total.
Why external content counts
From the user's point of view, there is no difference between a document you host and a document you link to. A visitor on do.se who needs information about the speech-to-text service clicks the link, opens the PDF and either can or cannot read it with their screen reader. Where the file is stored doesn't change that.
That is how auditors look at it too: they test the journey a user takes, not the organisational chart behind it.
The same logic applies to businesses under the European Accessibility Act, which uses the same technical standard, EN 301 549. If a customer can't complete a purchase because an embedded payment step, chat window or booking widget isn't accessible, the service as a whole isn't accessible. In Sweden, the EAA is enforced through Lag (2023:254), with sanction fees of up to SEK 10 million. (See Sweden's EAA penalties →)
Where external content hides on your site
Most websites carry far more third-party content than their owners realise. Common examples:
- Linked documents: PDFs, brochures, terms and product sheets hosted by partners, suppliers or authorities.
- Embedded tools: booking systems, calculators, maps, store locators and forms.
- Checkout and payment steps provided by an external payment service.
- Chat and support widgets.
- Cookie and consent banners, which often come from an external tool and appear on every page, so one flaw is counted again and again.
- Video players and social media embeds.
Each of these sits inside a user journey you are responsible for, even if you never wrote a line of its code.
What to do about it
- Map your external content. List every embedded tool, widget and frequently linked document on your key pages.
- Test it as part of your site. Include third-party components in every accessibility audit, not just the code you wrote.
- Put accessibility in your contracts. Require suppliers to meet EN 301 549 and to fix issues within a set time.
- Choose what you link to. If an external document isn't accessible, ask the owner for an accessible version, or provide the key information yourself in accessible form.
- Document what you can't control. Your accessibility statement should be honest about third-party content and what you're doing about it.
DO's response shows that "we don't own it" may explain a problem, but it doesn't remove it from the audit.
For how penalties work in every EU country, see our overview of EAA fines across all 27 member states.
Frequently asked questions
Does linked content really count in an accessibility audit?
In DIGG's audit of do.se, it did. Five remarks concerned a PDF hosted on another site, which DO only linked to.
What is DIGG?
Myndigheten för digital förvaltning, Sweden's Agency for Digital Government. It supervises the accessibility of digital public services in Sweden.
Does this apply to private companies?
The do.se audit was under the DOS Act, which covers the public sector. Private companies under the European Accessibility Act are measured against the same standard, EN 301 549, and the same principle applies: what matters is whether the user can complete the service.
What if a supplier won't fix their component?
Raise it contractually, look for an accessible alternative, or offer the same information or function in another accessible way. Document the issue and your plan in your accessibility statement.
Source: DO's statement on DIGG's accessibility audit of do.se, dated 20 July 2026 (DO case no. 2026/881).
