Accessibility statement
GL Trans carries passengers across the border and sells tickets to consumers in the European Union. This page states honestly how accessible our website, electronic tickets and transport information are to people with disabilities: what has been measured, what has not, and what is missing.
What this statement covers
This statement covers the public GL Trans website in all three language versions — Ukrainian, Romanian and English — and everything a passenger does on it: searching departures, choosing a seat, making a booking, the electronic ticket and its confirmation, and the timetable, destination and border queue information.
That is precisely the list Article 2 of Directive (EU) 2019/882 names for passenger transport services: websites, mobile device-based applications, electronic ticketing, electronic tickets and the delivery of transport service information.
Not covered: the dispatcher back office at /crm — an internal tool, not a consumer service — and content we neither create nor control, including third-party flight data.
The benchmark we measure ourselves against is the European standard EN 301 549, on which the Directive relies, and — where it goes further — WCAG 2.2 level AA.
Conformance status
The site is PARTIALLY conformant with EN 301 549 and WCAG 2.2 level AA. "Partially" means exactly what it says: most requirements are met, but not all of them. The ones that are not are listed below, by name.
We deliberately do not claim full conformance. A claim of full conformance that the first person to try the site with a screen reader can disprove is worse than no statement at all.
The assessment was carried out in-house: automated markup and colour checks that read the very same HTML and CSS the browser receives, plus a manual keyboard-only walk of the entire booking flow with the accessibility tree read out. There has been no third-party audit, and the site has not been tested with real users of assistive technology.
What is not accessible yet, and why
This list is not decorative. Each item is a specific, measured, checkable thing — not a general caveat that "some parts may be imperfect".
- The bottom action bar on phones. On the home page, at screen widths up to 720 pixels, a bar carrying the booking button is pinned to the bottom. The padding meant to keep content clear of it is declared on an element that is not a scroll container, so it has no effect. As a result an element that has just received focus can end up underneath the bar — a failure of WCAG 2.2 "Focus Not Obscured" (2.4.11). The cause is technical and local: one line of CSS is not where it would work.
- The state of the sort controls in search. The selected sort order is marked with an attribute that is not supported on an element with the "link" role, so the accessibility tree drops it. A screen reader announces the selected sort order exactly like an unselected one — a failure of "Name, Role, Value" (4.1.2). The same redundant attribute appears on the strip of dates, but there the state is conveyed correctly by other means, so the dates are announced properly.
- There is no third-party audit. Everything written on this page was measured by us. No independent external review has been carried out, and this statement rests on no certificate.
- There is no user testing. The site has not been walked by people who use screen readers, text magnification or mouse-free control every day. An automated check sees the shape of the markup, not the experience: it will confirm that an image has a description and say nothing about whether that description means anything.
- There is no published contact point. This is itself a failure to meet Article 13 — see section 5. We say so plainly rather than passing over it.
What you can already rely on
These are not promises but measured properties — each is verified by an automated test or a manual walk, described in section 7.
- The entire booking flow can be completed with the keyboard alone. Verified end to end — from the home page to a finished ticket, with a real booking created without touching a mouse.
- The seat map is not a picture. It is a grid with a single tab stop, arrow-key movement and Home/End, and every seat has a full spoken name — for example "Seat 2B, aisle, free". An occupied seat is announced and does not block arrow navigation.
- State changes are announced. Choosing a seat, the "booking…" state and form errors all have live regions, so a screen reader reports them without taking focus away from where you left it.
- Every field has a label, every image has an alt attribute, every page has exactly one first-level heading, and there is no positive tabindex anywhere to break the tab order.
- Contrast is verified, not asserted: every colour pair across the light and dark themes — text never below 4.5:1, controls and borders never below 3:1. Nothing is exempt.
- The smallest text size on the site is 11 pixels and the smallest tap target is 24 pixels. Both floors are held by an automated check, not by an agreement.
- If "reduce motion" is enabled in your system, every animation and transition is switched off completely, decorative elements included.
- The ticket is an ordinary text web page, not an image and not a PDF. The booking code is written out as text beside the QR code, and the QR code itself carries a text name containing that same code, so a screen reader reads it.
The site works in three languages, and the language version changes none of these properties.
How to report a barrier
Article 13 requires a contact here to which inaccessibility can be reported and accessible information can be requested. We do not give one, because the carrier’s legal details — legal entity name, address and a working email address — are not yet published on this site.
An invented address would be worse than an admitted absence. It would look like a requirement met, collect messages from disabled passengers and deliver them to nobody — while the person who wrote believed they had been heard.
As soon as those details are published, this section will carry an email address a human reads, a response time and a fallback channel. The same applies to the contact page page, which today likewise carries no contact rather than a wrong one.
If our answer does not satisfy you
Annex V requires this section to name the authority that enforces the accessibility requirements and to which you can turn if the carrier’s answer does not satisfy you. We do not name one yet — and that too is deliberate.
Which national authority is competent depends on which legal entity provides this service and in which Member State the service is treated as provided. Neither question has been settled — see section 9. Naming an authority at random would send a passenger’s complaint to the wrong place, and the time lost would be theirs, not ours.
This section will be filled in together with the carrier’s legal details, once a Romanian lawyer has answered the questions in section 9.
How exactly this was assessed
A statement is worth exactly what the measurements behind it are worth. Here they are, with numbers that can be reproduced.
- Automated markup check
- The public pages are fetched exactly as a browser sees them — the home page, the search, the routes, the FAQ, the border page and the booking step among them — and seven things are checked: a description on every image, a spoken name on every icon-only button, a label on every field, exactly one first-level heading, no positive tabindex, a caption on every table, and that every ARIA reference to an id points at an element that is really on the page. A single finding fails the whole run; what the run found is either fixed or listed in section 3.
- Colour contrast
- Every colour pair across the light and dark themes, with values read out of the same file the browser receives. The threshold is 4.5:1 for text and 3:1 for non-text elements. One pair below its threshold fails the whole check — not one of them is.
- Layout and motion
- Eighteen style checks: an 11-pixel font-size floor, a tap target of at least 24 pixels, navigation reachable at every screen width, animation fully switched off under the "reduce motion" setting. Result: 18 out of 18.
- Manual keyboard walk
- The whole booking flow was walked with real key presses, reading the accessibility tree: 10 checks, 20 defects found. Most have already been fixed — the skip link, moving focus to the main content, the page header landmark, arrow movement past an occupied seat, live regions, link roles. What remains is listed in section 3.
- Phone review
- Pages were reviewed at a 390-pixel screen width: tap target sizes, text size, contrast and horizontal scrolling. What that review found has either been fixed or is listed in section 3.
They do not judge whether text is understandable, whether an image description is meaningful, or whether the focus order is logical. And they are neither a third-party audit nor testing with real users of assistive technology. That is exactly why the conformance above is called partial rather than full.
Keeping this statement current
Article 13 requires this statement to be maintained for as long as the service is offered. In practice that means the following.
- A review at least once every five years.
- And out of turn on any material change to the service: a new booking step, a new payment method, a new page, a change of visual design.
- The assessment date at the top of this page is updated together with the review. If it is stale, so is the statement — and that is visible from the first line, without any explanation from us.
Two questions that are not settled
Being honest here means naming what we do not know. Two questions about the Directive’s own applicability are still open, and we resolve neither of them in our own favour.
- Whether this service counts as "regional" transport. Article 2 of the Directive carves urban, suburban and regional transport out of most of the requirements, and those terms are defined through Regulation (EC) No 1370/2007. Our service crosses a national border, so the answer is not obvious and needs a lawyer’s opinion.
- Which legal entity provides this service. Article 4(5) exempts microenterprises providing services — fewer than 10 persons AND a turnover or balance sheet total of no more than €2 million. The carrier’s legal entity is not yet published on this site, so that threshold cannot currently be checked, by us or by you.
GL Trans relies on neither exemption. However they are resolved, the accessibility requirements apply here in full: if an exemption does apply, this page is a voluntary commitment; if it does not, this page is the Article 13 statement. The outcome for the passenger is the same either way, and no legal answer can make anything written above untrue.
The contact point for accessibility reports will be published together with the carrier’s legal details. The contact page likewise offers no channel that does not actually exist.