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Abstract
Digital technologies are increasingly embedded in democratic processes, reshaping how citizens access information, express preferences, deliberate, and influence public decision-making. Across Europe and beyond, mechanisms such as e-consultations, participatory budgeting platforms, online deliberation tools, and AI-mediated public services are promoted as instruments to widen participation, enhance transparency, and rebuild trust in democratic institutions. Yet, the inclusion promised by these tools is not guaranteed. Digital accessibility—understood as the extent to which digital platforms and public services can be effectively perceived, understood, and used by all citizens—is a prerequisite for meaningful participation. When engagement relies on complex interfaces, inaccessible documents, high cognitive load, or opaque AI-mediated interaction (e.g., chatbots and automated filtering), citizens may be formally invited to participate while being practically unable to do so. This paper argues that accessibility should therefore be treated not as a secondary technical requirement, but as a core democratic condition: without accessible, comprehensible, and accountable participation systems, digital participation risks institutionalising unequal citizenship and undermining democratic legitimacy.
Depending on whether digital accessibility is treated as prerequisite for democratic participation or as a technical compliance requirement, this paper examines how digitally mediated engagement can simultaneously enable empowerment and contribute to exclusion. Grounded in European accessibility standards—particularly EN 301 549 (v3.2.1), which incorporates WCAG 2.1 requirements for web and mobile content—it conceptualises accessibility barriers as forms of invisible exclusion produced by interface design and AI-mediated participation workflows rather than by explicit denial of participation. These barriers may include inaccessible information formats, complex information architectures, cognitively demanding interactions, and limited transparency regarding how citizen input is received, processed, and prioritised.
Empirically, the paper draws on the Portuguese context, focusing on two institutional mechanisms of digitally mediated participation—e-consultations and participatory budgeting—to examine how design choices and interaction frictions shape who participates, how contributions are expressed, and whose voices become visible in decision-making. Using national consultation platforms (e.g., Participa.pt and ConsultaLEX) and participatory budgeting experiences at municipal and/or national level as reference points, the analysis shows how inaccessible documents, demanding information formats, authentication hurdles, and cognitively intensive interfaces can narrow participation toward more digitally skilled and socially advantaged publics, raising concerns about inclusion, procedural fairness, and legitimacy. Rather than positioning AI as a third equal pillar, the paper treats AI-mediated public-facing features (such as virtual assistants, automated ranking, and content filtering) as a transversal layer increasingly present in public-sector digital ecosystems, highlighting how limited explainability, language barriers, and opaque interaction flows may further shape access to information, participation support, and trust.
In response, we argue that digital accessibility should be treated as a condition for democratic equality and procedural justice in digital and mediated contexts. Therefore, it must not rely only on the formal availability of participatory channels, but primarily on whether citizens can effectively access, understand, and use them to shape outcomes. This perspective clarifies how design and AI-mediated interfaces can function as political gatekeepers, influencing whose voices become visible, whose contributions count, and how trust in participation processes is sustained. These findings will inform future work aimed at formalising a systematic approach to analysing accessibility-driven exclusion as a challenge to democratic legitimacy.
