Declaration

of Accessibility

Introduction and Scope

ITR Services EOOD declares its commitment to ensuring the accessibility of all its digital products and services, including the gtrace.eu, in accordance with the requirements of Accessibility Requirements for Products and Services Act (ARPSA), regulations and international accessibility standards, including the Web Content Accessibility Guidelines (WCAG) version 2.1, level AA.

This statement covers all publicly accessible sections of the website and services offered through the website to ensure equal access to information and functionality for all users, including persons with disabilities.

Accessibility principles

ITR Services EOOD accepts and is guided by the following basic principles:

  1. Perceptibility: Providing content that can be perceived through various sensory channels (visual, auditory, etc.).
  2. Functionality: Providing access to all functions through multiple interaction methods, including keyboard navigation.
  3. Comprehensibility: Providing content and functions that are clear and easy to understand.
  4. Stability: Ensuring technological compatibility that allows the use of current and future assistive technologies
Level of compliance

This website is partially compliant with WCAG 2.1, Level AA. For partial conformance, all identified non-conformances are detailed in Section IV.

Identified non-conformities and measures taken

4.1. Table of non-conformities

Element Description of the problem Reason for non-compliance Corrective actions Deadline for correction
Headlines/links/buttons Low contrast Corporate company identity Coordination for changing the shade of the main colour on the website 31.12.2025
Heading elements Lack of consistent descending order Template restriction by the platform Monitoring for updates to the semantic structure of the template 31.12.2025
Hyperlink elements Lack of aria-label descriptions Limited ability to edit the element Testing alternative methods for adding the aria-label attribute 31.12.2025
Icons No alternative text descriptions Template restriction from the platform Addition of appropriate alternative texts 31.12.2025
Note: The table describes only those requirements of the standard that are not covered, partially covered, or not applicable. Fully covered requirements of the standard are not described, in accordance with the requirements for completing the declaration of conformity.
4.2. Exempt content According to Article 15 of the ARPSA, certain content is exempt from the requirements due to excessive burden for its adaptation. This includes:
  • Old archived materials that are not actively used for administrative or communication purposes.
  • Content generated by third parties over which ITR Services EOOD has no direct control.
4.3. Compatibility with browsers and assistive technologies

The website is designed to be compatible with the following most used assistive technologies:

  • the latest version of Google Chrome, Microsoft Edge, Mozilla Firefox, and Apple Safari browsers;
  • in combination with the latest version of NVDA 2025.1.2.

Preparation and methodology of the declaration

This declaration has been prepared based on:

  1. Self-assessment: Conducted by a team of internal experts using automated and manual accessibility audit tools.
  2. Regular reviews: Regularly updating accessibility assessments whenever there is a significant change to the website.

Feedback and Alerts

ITR Services EOOD encourages its users to provide feedback on website accessibility issues.

*The end user (initiator) of the “0700” number pays the cost of the call according to their subscription plan.

Reports will be processed within one month of receipt, and a response will be prepared within the same period, containing a description of the actions and measures taken to remedy the accessibility violation and the deadline by which the specified accessibility violations will be remedied, or a reasoned refusal in cases where the request is deemed unfounded and unlawful.

Where the person submitting the report has provided an email address, the response shall be sent, signed with a qualified electronic signature certificate, and in other cases, on paper, to the address indicated in the report. Where an incorrect or non-existent address is provided, the information shall be deemed to have been received on the date of dispatch.

Dispute Resolution Procedure

If the response to your alert is unsatisfactory, you may contact the Chairperson of the State e-Government Agency through the SEGA office.

A complaint should be submitted in one of the following ways:

  • to the SEGA registry at the following address: 6 Gen. Yosif V. Gurko Street, Sofia 1000;
  • electronically to help@e-gov.bg (with the subject line: “Complaint regarding violation of website accessibility”);
  • by post on paper to the address of the SEGA, 6 Gen. Yosif V. Gurko Street, Sofia 1000.
Date of publication and updates

Date of initial preparation of the declaration:

04.09.2025 г.

Date of annual update (revision) of the declaration:

01.08.2026 г.

Date of update of the declaration after evaluation and substantial redesign of the website or mobile app:

04.09.2025 г.
ITR Services EOOD strives to present its users with a website that fully meets the available accessibility standards. However, this is not always possible. If you are experiencing difficulties with the site, some content is not accessible or incomprehensible, please contact us. 

User feedback, recommendations, and criticism are very important so that together we can build an even more useful and accessible website. 

ITR Services EOOD is committed to ensuring a higher degree of accessibility by addressing any identified inconsistencies in the accessibility requirements of published information.
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