Draft: Comparison of UAAG 1.0 and Section 508
Status of this document
This document has been produced as a tool for developers to
understand where the requirements of Section
508 and the User Agent Accessibility
Guidelines 1.0 converge and depart. These are initial notes by
the authors; this document does not represent UAWG consensus.
It is also important to note that the United States Access Board (or The
Architectural and Transportation Barriers Compliance Board) has not
reviewed or sanctioned this document. The Access Board was the
agency designated in (Section 508(a)(2)(A) to publish standards
setting forth a definition of electronic and information technology
and the technical and functional performance criteria necessary for
accessibility for such technology, for the United States
This document is part of a series of accessibility documents
published by the Web Accessibility
Initiative (WAI) of the
World Wide Web Consortium (W3C). WAI
Accessibility Guidelines are produced as part of the WAI Technical
Activity. The goals of the User Agent Accessibility
Guidelines Working Group are described in the charter.
Summary of relationships between two documents
The two documents are sufficiently different that we attempt
only a rough comparison here, limiting ourselves to these
relationships: subsumes, roughly equivalent to, and has no
Section 508 paragraph 1194.21 requirements
- (a) is subsumed by 1.1
- The following has no equivalent in UAAG 1.0: "Applications
shall not disrupt or disable activated features of other products
that are identified as accessibility features, where those features
are developed and documented according to industry standards."
- The following subsumes 7.1 and 7.2: "Applications also shall
not disrupt or disable activated features of any operating system
that are identified as accessibility features where the application
programming interface for those accessibility features has been
documented by the manufacturer of the operating system and is
available to the product developer."
- The following is roughly equivalent to parts of 9.1, 9.2, 9.3,
and 10.2: "A well-defined on-screen indication of the current focus
shall be provided that moves among interactive interface elements
as the input focus changes."
- The following is roughly equivalent to part of 6.5: "The focus
shall be programmatically exposed so that assistive technology can
track focus and focus changes"
- The following is subsumed by 6.4: "Sufficient information about
a user interface element including the identity, operation and
state of the element shall be available to assistive
- The following subsumes checkpoint 1.3: "When an image
represents a program element, the information conveyed by the image
must also be available in text".
- (e) has no equivalent in UAAG 1.0. However, it is likely that
the P2 checkpoint 7.3 relates (as it involves UI design and
- The following is subsumed by 6.3 and 6.4: "Textual information
shall be provided through operating system functions for displaying
text." Note that UAAG 1.0 allows user agents to exchange text
programmatically through higher-level interfaces instead.
- The following has no equivalent in UAAG 1.0: "The minimum
information that shall be made available is text content, text
input caret location, and text attributes." UAAG 1.0 does not
require implementation of a text caret. Access to content is
assured through checkpoints of Guideline 6. Character encoding is
assured through checkpoint 6.7, but no other text characteristics
are required by UAAG 1.0.
- (g) is subsumed by checkpoint 4.3.
- (h) has no equivalent in UAAG 1.0 since it seems to assume that
the author has provided alternative content for a different display
mode: "When animation is displayed, the information shall be
displayable in at least one non-animated presentation mode at the
option of the user." However, UAAG 1.0 requires that the user be
able to turn animations off in 3.2.
- (i) subsumes parts of 10.2, 10.3, 10.4 (P2), 10.7.
- (j) is subsumed (for text) by 4.3, since 4.3 makes a broader
color range requirement.
- (k) has no equivalent in UAAG 1.0 since UAAG 1.0 only talks
about blinking text content (not UI controls). However, P2
checkpoint 7.3 is expected to cover this (related to UI
- (l) is subsumed by 6.1 and 6.2.
Section 508 paragraph 1194.24 requirements
- a-d have no equivalents in UAAG 1.0
- (e) is subsumed by 2.5.
Section 508 paragraph 1194.25 requirements
- (b) is subsumed by 2.4.
- (f) is subsumed by 4.13 (although specific decibel levels are
not part of UAAG 1.0).
- g, h, and i are covered by 1194.21 requirements.
- Other requirements have no equivalent in UAAG 1.0.
Section 508 paragraph 1194.41 requirements
- (a) is subsumed by 12.1.
- (b) is roughly equivalent to 12.2.
- (c) has no equivalent in UAAG 1.0.
- Whichever specification the user agent conforms to, it has to
do a lot to conform to the other.
- If a user agent satisfies Section 508 paragraphs 1194.21,
1194.24, 1194.25, and 1194.41, it also conforms to UAAG 1.0 Level A
(for all content types, etc.) if it satisfies these checkpoints:
1.1 (for all functionalities), 1.2, 2.1, 2.2, 2.3, 2.4 (unless
interaction is available in a time-independent manner), 2.6, 2.7,
2.8, 2.9, 3.1, 3.2, 3.3, 3.4, 3.5, 4.1, 4.10, 4.12, 4.13, 4.14,
4.17, 4.2, 4.3, 4.4, 4.5, 4.6, 4.9, 6.1, 6.2, 6.3, 6.4, 6.5
(bullets 2 and 3), 6.6, 6.7, 8.1, 8.2, 9.1 (bullet 2), 9.3 (bullets
2 and 3), 9.4, 10.1, 10.2 (bullets 3 and 4), 10.7 (bullet 1), 11.1,
11.2, 12.1, and 12.3.
- If the user agent satisfies UAAG 1.0 Level A (for all content
types, etc.) it conforms to 508 if it does the following:
- 1194.21 if you satisfy b (first sentence), d (second sentence),
e, f (second sentence), h (unless 3.2 counts), i, and k.
- 1194.24 if you satisfy all other requirements than e.
- 1194.25 if you satisfy all other requirements than b, f, g, h,
- 1194.41 if you satisfy (c) and accessible documentation is
available at no additional charge.
Ian Jacobs and Jon Gunderson
Last modified: $Date: 2002/02/08 19:58:01 $ by $Author: ijacobs