The Presidential Circular and the Ministry checklist.

The Turkish Presidential Circular dated 24 June 2025 references WCAG 2.2 level A for the websites and mobile applications of public institutions.

This page explains what the circular says and what it means in practice. A warning up front: nothing here is legal advice. The scope of your obligation depends on your institution’s status and your contracts; a binding answer requires a lawyer. What follows is the technical frame.

What the circular says

The circular put the accessibility of public institutions’ websites and mobile applications on the agenda, pointing to WCAG 2.2 as the technical reference and level A as the conformance level. Not an abstract “make it accessible,” but a reference to an international standard and to a specific level of that standard.

That reference matters because it brings measurability. “An accessible site” is a debatable concept; “a site meeting the 31 success criteria of WCAG 2.2 level A” is not — it either meets them or it does not, and every criterion can be tested one by one.

The Ministry checklist: 31 criteria, 126 questions

Following the circular, the Ministry of Family and Social Services published an assessment checklist. It takes the 31 success criteria of WCAG 2.2’s level A and expands them into 126 assessment questions, grouped under the four principles: perceivable, operable, understandable, robust.

The expansion from 31 to 126 is no accident. A success criterion usually covers more than one situation — the “non-text content” criterion, for example, concerns images, icons, charts, CAPTCHAs and decorative elements separately. By turning these situations into individual questions, the checklist removes subjectivity from the audit.

The list’s real value is not its coverage but that it ends the argument.

In practice, for a team entering a tender or an audit this means: preparation is not interpreting the WCAG text but producing a documentable answer to each of the 126 questions. The answers should not be “yes/no” but “met on this screen, in this way.”

Whom it binds, whom it affects

The circular directly binds public institutions. But its effect does not end there — and this is the point most private sector teams miss.

1. Public institution — directly in scope. Website and mobile application.
2. Supplier selling software or sites to the public sector — indirectly in scope through the contract. The delivered product has to satisfy the buyer’s obligation.
3. Agency entering a public tender — should expect to see an accessibility clause in the technical specification.
4. Private company selling to corporate buyers — the circular does not bind it, but the buyer’s supplier audits may.
5. SMEs and personal sites — outside the circular’s scope. An indirect effect is still possible when working with a client subject to the EU Accessibility Act.

So the right question may not be “does this circular bind me” but “does it bind my client.” Delivering accessible work as a supplier is what gets the client through the audit — and that is increasingly turning into a sales argument.

Is level A enough

The circular references level A. But A is the floor: it covers the criteria whose absence makes content completely inaccessible for some users. For a usable experience it is generally not enough.

A concrete example: the contrast ratio does not appear at level A at all. 1.4.3 “Contrast (Minimum)” sits at AA. A site targeting only A could publish its body text at 2:1 contrast against its ground and count as technically conformant — yet that text is unreadable for someone with low visual acuity, and unreadable for everyone on a phone in the sun.

The same goes for the focus indicator: 2.4.7 “Focus Visible” is at AA. Level A requires keyboard access but does not require the focus to be visible — a site you can navigate by keyboard without ever seeing where you are can conform to A.

The practical advice is therefore: even though A satisfies the circular, set the target at AA. In most projects the cost of reaching AA amounts to a contrast fix and a focus ring — a few days of work. As of 2026, AA already counts as the de facto standard for the public sector and large-scale businesses.

Preparation: a practical order

For a team preparing for an audit, there are four things to do before walking the checklist question by question. They close a large share of the questions in bulk.

1. A keyboard tour — use the site end to end without a mouse. Most questions under the operable principle are answered here.
2. Semantic cleanup — heading hierarchy, landmark structure, form labels. The foundation of the robust and understandable principles.
3. An alternative text inventory — every image’s status must be decided: informative or decorative. The decorative one gets an EMPTY alternative, not an omission.
4. An evidence file — for each question, not a screenshot but a repeatable measurement. When the audit is renewed, the same evidence must be reproducible.

The last item is the most skipped and the most expensive. A one-off accessibility fix silently decays within the next three deployments. If the evidence is tied to a reproducible measurement — an automated test, a check script — the decay shows immediately. If it is not, it is rediscovered at the next audit.

What the 126 questions ask under the four principles

The checklist distributes its questions across the four principles, and the distribution shows where the audit puts its weight. Knowing it helps allocate preparation time correctly.

1. Perceivable — alternatives for non-text content, transcripts for audio and video, information not carried by color or shape alone, text that can be resized.
2. Operable — every function doable by keyboard, no focus traps, adjustable time limits, no flashing that could trigger seizures, meaningful page titles.
3. Understandable — the page language declared, focus not causing unexpected context changes, errors identified, form fields labeled.
4. Robust — markup interpretable by assistive technologies, interface components correctly reporting the name-role-value triple.

Note one thing: none of these principles carries the heading “visual design.” Level A is an almost entirely structural and semantic audit — it checks whether the HTML is written correctly. The visual items (contrast, focus visibility) begin at AA.

The clauses most often failed in audits

The recurring defects on Turkish public sites and corporate projects resemble one another. Four of them explain most of the list, and all four are cheap to fix.

Form labels. Text that looks like a label visually but is not programmatically tied to the field is the most frequent defect. The screen reader says “edit field” and cannot say which field. The fix is binding the label element to the field; placeholder text is no substitute for a label.

Image alternatives. Errors sit at both extremes: the informative image left without an alternative, and the decorative image labeled with a file name or a meaningless text like “image.” The correct alternative for a decorative image is EMPTY — so the screen reader skips it.

Heading hierarchy. Heading levels chosen for visual size (using h4 to make it look small) break the document structure. The screen reader user navigates the page by headings; a broken hierarchy breaks their table of contents.

Page language. A missing or wrong language declaration on the root element makes the screen reader mispronounce the text. Turkish content read by an English voice engine produces something unintelligible to the listener. A one-line fix, a large effect.

The relation to the European Accessibility Act

The circular in Türkiye does not stand alone; it is part of an international trend. The European Accessibility Act brings accessibility obligations for businesses offering products or services to the EU market, and its technical reference is again WCAG’s AA level.

This carries direct meaning for Turkish companies exporting or serving EU clients: even where the circular does not bind them, their clients are bound, and the obligation flows down the supply chain into contracts. When a manufacturer building a multilingual B2B site cares about accessibility, the reason is not charity — it is market access.

The practical conclusion: taking AA as the floor more than satisfies the circular in Türkiye and meets the expectation on the EU side. Working to one standard instead of running two separate compliance efforts is markedly cheaper in the long run.

Conformance is continuous, not one-off

The most expensive part of accessibility audits is not the fix itself but the fix decaying. A one-off improvement is silently undone within the next three deployments: a new component removes the focus ring, a new color lowers the contrast, a new image arrives without an alternative.

The only real solution is tying accessibility decisions to code rather than to human attention. If contrast ratios are computed in the palette file and bound to a test, the wrong color pair cannot reach deployment. If the focus ring is a token, it cannot be forgotten. If alternative text is a required field, it cannot stay empty.

Passing the audit takes a day; staying passed takes a system.

The concrete form of this approach: every accessibility decision gets a guard, and the guard runs on every deployment. When a defect appears, it shows in that deployment, not at the next audit — and fixing it takes minutes, not days.