FOI enquiry - withdrawal of domains

As part of the preparation for my talk at Techshare earlier this month I made an FOI enquiry to the COI on 15th September about the conditions of use for domains.

I have a question about the conditions of use for names, which appear on the Cabinet Office at

These conditions state in section 4 that websites which do not comply with current UK disability legislation will have their domain names withdrawn. Other circumstances when domain names may be withdrawn are also detailed.

Could you please tell me:

  1. How many domains have been withdrawn during the lifetime of these conditions for failure to comply with disability legislation.
  2. How many domains have been withdrawn for other reasons listed in the conditions.

To give a little more context, Section 4a of the conditions of use state:

The applications (Web, email, etc) using a domain name must comply with current UK legislation and support channels that provide accessibility for disabled people, members of ethnic minorities and those at risk of social/digital exclusion. Legislation includes Copyright, Data Protection Act and Disability Discrimination Act. Abuse of will result in the name being withdrawn.

Today I received this response from the COI:

Firstly, it is important to understand the legislative context and the guidance for compliance with it. In your letter you state in relation to the conditions of use of a domain name that, 'websites which do not comply with current UK disability legislation will have their domain names withdrawn.' This isn't the case for a number of reasons. Firstly, we are not just looking at whether a website complies with disability legislation, we are also looking at whether a website meets the minimum standards for accessibility. The guidelines state that websites should 'comply with the accessibility recommendation for public sector sites, that is, W3C WAI Level AA.'

Secondly, it should be stressed that disability legislation is in place to protect the rights of the individual, not to detail the specific requirements on websites (both within and outside the namespace). Even if websites meet the recommended minimum standard, this is no guarantee that the user experience for people with disabilities will be problem free. This fact was highlighted in the formal investigation carried out by the Disability Rights Commission and re-iterated in the 2005 survey of public service eAccessibility commissioned by the Cabinet Office.

Thirdly, the guidelines go on to say that, 'Failure to comply with this may result in the name being withdrawn.' This implies that websites will be considered for withdrawal if they fail to meet the minimum standard, not automatically withdrawn.

Having said that, the Government has been working with industry, academia and the third sector to build a robust approach to delivering inclusive websites. To ensure that government pays due regard to current disability legislation (the Public Sector Disability Equality Duty) and in order to meet European objectives for inclusive e-government (Riga Ministerial Declaration 2006), COI has updated Chapter 2.4 of the Guidelines for UK Government Websites and proposes that all government websites must meet Level Double-A of the W3C guidelines by December 2008. The updated guidance has recently been sent out for formal consultation and is attached for your information.

In answer to your question,

  1. No website domain names have been withdrawn for failure to comply with disability legislation; and
  2. No website domain names have been withdrawn for the other reasons set out in the conditions of use.

However, the government has taken a proactive approach to reducing the overall number of websites it owns and in the future we can expect to see increased focus on raising the standards for government websites, including inclusivity and accessibility. This is part of the Transformational Government Strategy to converge websites around audience channels including Directgov and BusinessLink. This will be reflected in the updated policy on naming and registering websites, which will go for formal consultation later this month.

The most telling part of the response for me is that the conditions of use for domains have never been enforced. Given that section 4a explicitly states that sites not complying with current legislation will have their name withdrawn, one can only conclude that the agency responsible for upholding the conditions considers every website ever to be published under a domain to be compliant with current UK legislation around accessibility. (Or am I being unduly harsh and literal?) More support for the view that the proposal in Delivering Inclusive Websites to use WCAG as a measure and domain withdrawal as a consequence is a waste of time and needs to be replaced with a more positive and realistic scheme?

Perhaps more revealing of the government's future strategy is the final paragraph, which refers to the reduction in the number of government websites and an increased focus on raising standards. It's likely that the recently issued consultation around web accessibility is a thinly disguised ploy to encourage as many sites as possible to move into the loving arms of DirectGov, or at least onto the technical platform it now shares with several other large, high profile departmental sites. If it happened it wouldn't be a bad thing.


Dan thanks for this update. I can't but be cynical about the COI's pipe dreams. Do we really believe in a few years time there will only be directgov and businesslink, using the same platform? Common sense is bound to prevail somewhere along the line and a decision to spread the load needs to be taken otherwise these sites will end up as monolithic messes.

Back to the main subject, I don't think COI are saying that all UK gov sites are currently compliant, I just think they haven't any mechanism in place to carry out such checks which poses another FOI question - will there be such a body to police and enforce this threat?

Posted by: Darren Taylor at October 18, 2007 12:37 PM

My eyes! My eyes are bleeding!

Sorry. All that italicisation got to me.

Less, please!

Posted by: Andy Mabbett at October 18, 2007 4:41 PM

I've been meaning to fix that for ages Andy (honest!). Fixed now, thanks for the shaming. :-)

Posted by: Dan at October 18, 2007 5:39 PM

Blimey. To paraphrase Homer Simpson: they took a long time to say nothing.

It's interesting that this FOI response (and I suppose others) don't contain just raw facts but rather include an explanation of the situation.

The cynic in me would say it's a type of spin-doctoring, but the nicer side would suggest they're just trying to put it into context.

Posted by: Matt at October 18, 2007 8:02 PM

I can completely understand not wanting to withdraw a domain name from a major government department / institution -- to do so would surely have to be an action of last resort. However, one might expect the powers that be to at least keep tabs on whether sites follow the rules, and be directly suggesting work towards compliance where sites are found to be lacking.

So perhaps a more interesting follow-up question would be to ask who's responsible for ensuring/checking that sites comply with the CO's "comply with current UK legislation" rule, whether they've actually checked any sites in the past, and what the outcome of any such checks were...

Posted by: Robert Whittaker at October 19, 2007 3:33 PM

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