From HTML WG Wiki
Correct <img> Conformance Checker Guidance
Editor: Laura Carlson (firstname.lastname@example.org)
Date: July 7, 2010. (Last Updated August 13, 2010)
Please address feedback to the HTML Working Group mailing list (email@example.com).
This HTML5 change proposal corrects the current <img> element conformance checkers guidance  by:
This proposal helps resolve HTML ISSUE-31: missing-alt :
The <img> element section of HTML5 allows instances where the <img> element may have no text alternative, not just a null alt attribute for eye candy, but no text alternative for content. The issue involves ensuring HTML5 provides a way for automatic validators to programmatically determine the presence or absence of short text alternatives on the <img> element.
Requiring a set of machine testable, programmatically valid options helps ensure that images have complete structure. If no accessible option can be determined, then the resulting structure should be considered invalid as it is not perceivable to some people. Text alternatives are essential for accessibility. Enabling automatic validators to programmatically detect the presence or absence of text alternatives raises public awareness of Web accessibility in general and aids in accessibility education in particular.
Text alternatives (even if that alternative is to indicate an image is presentational) for the <img> element are needed to provide equal access to users.
To this end,
- HTML5 should require structural integrity for the <img> element.
- HTML5 should help facilitate accessibility awareness and education.
- HTML5 should not facilitate the creation of inaccessible content.
- HTML5 should not make rules beyond its scope.
- HTML5 should not provide inaccessible text alternative features.
HTML5 Should Require Structural Integrity for the <img> Element
Requiring a set of programmatically determinable validity options helps ensure that images have complete structure. Complete structure of the <img> element requires both src and text alternatives.
Lowering standards to move away from a situation that explicitly requires the language of the web to be non-discriminatory, to one where the language of the web allows discrimination to be valid would be a step backward. "There is little dispute that we should work towards a Web for All" as Jeff Jaffe said in the The Mission of W3C . United Nations Article 9 declares people with disabilities shall be ensured equal access to information and communications technologies and systems .
Addressing the Authoring Tool Rule
The authoring tool rule states, "Authoring tools and markup generators must generate conforming documents. Conformance criteria that apply to authors also apply to authoring tools, where appropriate." .
It grants an exception to the address element because, "authoring tools are not yet able to determine author intent".
As in the case of an authoring tool not knowing author intent for an address element, it cannot know author intent in the case of text alternatives. Gez Lemon has stated the situation clearly ,
When an authoring tool doesn't have anything useful to put in for the alt text, the tool shouldn't put anything in. A good authoring tool will check for missing alt text and offer to assist the user in repairing the content. If an author is adamant they're not going to provide alt text, there is no requirement that says the authoring tool should provide it in place of the author. In fact, it's just the opposite, as the authoring tool could not possibly know the author's intent. In this scenario, the authoring tool should not include the alt attribute at all, and the resulting markup should be considered invalid. It should be considered invalid because it is inaccessible, and not perceivable by some people. If the tool allows alt text to be provided, then the tool would be considered compliant (on this particular issue), even though the resulting markup would not be compliant, as the user chose not to make the content compliant.
HTML5 Should Help Facilitate Accessibility Awareness and Education
Enabling automatic validators to programmatically detect the presence or absence of text alternatives (as HTML4 did with alt) raises public awareness of Web accessibility in general. It is an undeniable advertisement that text alternatives are needed and a chance to educate the author about proper usage. More people use the W3C validator than read the specs. It has been said that the W3C HTML4 validator has done worlds more than the HTML4 specification for increasing the quality of HTML documents on the web .
Requiring a set of programmatically determinable validity options aids in accessibility education . In other words, validators create a teachable moment. Indeed, the W3C validator is currently used for university classes as a valuable teaching and learning tool. For example, a first lesson in teaching good authoring practice is to have developers and students validate HTML on the W3C site to be sure that it is error-free and that they have indeed examined each image. It makes a big impression that text alternatives are mandatory not just for WCAG but for valid HTML as well. When accessibility is an integrated part of authoring good HTML, the outcome is more perceivable content.
People fix errors. Directly pointing authors who encounter a missing text alternative error to advice on how to fix it will offer an especially powerful learning method exactly when it is needed called Just-in-Time Training (JITT). Mike Smith is working on a pilot validator implementation for missing text alternative error reporting. As the accessibility task force recommendation stated, the "error text is expected to reference additional guidance on text alternatives in WCAG support materials".
HTML5 Should Not Facilitate the Creation of Inaccessible Content
The generator mechanism not only allows incomplete and inaccessible structure of single <img> elements, it facilitates the creation of full documents of content not perceivable to some people.
The current spec pardons complete pages of content containing from one to an infinite number of missing text alternatives and allows them to be valid when software automatically inserts meta name="generator". A few samples include:
- <meta name="generator" content="Dreamweaver">
- <meta name="generator" content="Adobe InDesign">
- <meta name="generator" content="Microsoft Word">
- <meta name="generator" content="WordPress">
- <meta name="generator" content="BBEdit">
- <meta name="generator" content="TextMate">
- <meta name="generator" content="StarOffice/OpenOffice">
- <meta name="generator" content="Joomla!">
This would affect an astronomical quantity of pages.
The generator mechanism is actively harmful to accessibility. If the generator option is left at document level, it would be far too easy for authors to have the software automatically insert "generator" and then forget to provide any text alternatives for images. Well meaning authors, do indeed do the right thing when confronted with an error. "Conformance is about trying to advise authors to do the right thing", as Ian Hickson has said .
The generator mechanism emasculates the vaildator as learning tool and renders it worthless for teaching text alternatives for all pages created with an authoring tool that inserts meta name="generator".
The generator mechanism breaks standards and guidelines requiring text equivalents on an individual element basis. These include but are not limited to:
- 508: Standards issued by the Access Board under Section 508 of the Rehabilitation Act cover access to electronic and information technology procured by United States Federal agencies and require a text equivalent for every non-text element .
- Section R-pd.7.1: Dutch Accessibility Law English Translation - "Alt (alternative) attribute must be used on every img (image) and area element and must become to provide with an effective alternative text" .
- States and State Agency Policy and Standards: For instance many University Web Standards such as the University of Minnesota Standard state "Include alternative text for all graphics" .
- WCAG: Text alternatives are required for "any non-text content" .
If any generated or missing mechanism is included in HTML5, it should only be included at the element level where it could be dealt with on an image-by-image case with a detection method such as a generated or missing attribute, rather than at the document level. At least an attribute would provide a practical method of detection and handling on an individual element, granular basis rather than sweeping a whole inaccessible page under the rug and proclaiming it valid. This would:
- Allow each image without a text alternative to be honestly labeled for what it is: missing, incomplete, lacking substance.
- Provide a machine checkable mechanism to pinpoint incomplete <img> elements and enable tools to quickly discern where "missing" has been used so mistakes can be fixed.
- Provide assistive technology an image level "missing" hook.
- Have possibilities for crowdsourcing .
- Support ethical accountability by promoting the development of responsible tools and by advocating an effective enabling environment.
Allowing text alternatives to be optional in the structure doesn't address the problem of text alternatives being provided by the author or the authoring tool they use - it is lowering the integrity requirements for the sake of tools passing the validator. The only benefit is that most tool vendors will automatically adhere to HTML5, as very few adhere to existing standards. The exception is a way to codify and bless bad tools. It sanctions them at the sacrifice of accessibility.
HTML5 Should Not Make Rules Beyond Its Scope
Private communication and email exceptions undermine text alternatives as a needed structural part of the <img> element, and goes beyond the scope of HTML5. It clutters the specification with an off-topic assertion:
When an image is included in a private communication (such as an HTML e-mail) aimed at a specific person who is known to be able to view images, the alt attribute may be omitted.
The HTML specification should be about the markup.
- It is an author's prerogative not to provide text alternatives for images because they're writing for themselves, close friends or relatives. However, a HTML <img> element without both src and text alternative is still not complete. Therefore, it should not be considered valid.
- It is a company's prerogative to allow inaccessible content on a private intranet. However, a HTML <img> element without both src and text alternative is still not complete. Therefore, it should not be considered valid.
- It is a tool's prerogative not to follow ATAG . However, a HTML <img> element without both src and text alternative is still not complete. Therefore, it should not be considered valid.
The out of scope rule itself makes assumptions regarding:
- Profiling, targeting, and discriminating between people on the basis of ability or disability.
- Degrees of disability. It may vary over time. The rule takes a static approach to visual impairment.
- Lifetime of messages and private documents: Emails get forwarded. The addressed recipient isn't always the actual recipient. Documents can go from being private to being public.
- Sighted recipients. They
- May have a slow connection and turn off images to speed download.
- May have an expensive data roaming connection (that is not slow).
- May have images turned off to decrease bandwidth use in order to lower their Internet usage fees.
- May have a text-only user agent.
- May be listening to the page being read out by a voice browser or other voice output, for example, as they drive or otherwise cannot read the web page.
In addition the United States Twenty-first Century Communications and Video Accessibility Act of 2010 (S. 3304) requires accessibility of advanced communications equipment and services, such as text messaging and e-mail .
HTML5 Should Not Provide Inaccessible Text Alternative Features
The title attribute is not an acceptable text alternative as it's content is not displayed to the user unless they can use a mouse and beforehand know the content is there. The content of the image title attribute is also often not detected by AT by default unless the user makes an explicit choice in their preferences to announce the attribute contents.
Authors are advised to only use the title attribute for "additional information" and not as a full equivalent alternative. Removing title would make the HTML specification in line with WCAG, and previous authoring practices .
Steve Faulkner's Change proposal for ISSUE-80: title-alternative provides full rationale for removing this exception .
Replace the Current Text:
A conformance checker must report the lack of an alt attribute as an error unless one of the conditions listed below applies:
- The title attribute is present and has a non-empty value (as described above).
- The img element is in a figure element that contains a figcaption element that contains content other than inter-element whitespace (as described above).
- The conformance checker has been configured to assume that the document is an e-mail or document intended for a specific person who is known to be able to view images.
- The document has a meta element with a name attribute whose value is an ASCII case-insensitive match for the string "generator". (This case does not represent a case where the document is conforming, only that the generator could not determine appropriate alternative text — validators are required to not show an error in this case to discourage markup generators from including bogus alternative text purely in an attempt to silence validators.)
With Suggested Text
A conformance checker must report the lack of an alt attribute as an error unless the <img> element is located within a <figure> element that has a non-empty <figcaption> element.
- Declares resulting structure invalid, if one of the listed options is not determined.
- Upholds the structural integrity of <img> element.
- Enables automatic validators to programmatically detect occurrences of the presence or absence of text alternatives. Bug 8716, Bug 9218.
- Facilitates accessibility awareness and education.
- Corrects the spec to disallow <img> to be valid with the email exception Bug 8646.
- Corrects the spec to disallow <img> to be valid with the title attribute.Bug 7362. Also Bug 9215 (WebCam), Bug 9216 (CAPTCHA).
- Corrects the spec to disallow <img> to be valid with the generator mechanism. Bug 9212.
- Strengthens the spec to allow <img> to be valid with aria-labelledby. Bug 6496.
- Guidance for conformance checkers (HTML5 Version 20100624) 
- ISSUE-31 What to do when a reasonable text equivalent is unknown/unavailable? 
- The Mission of W3C 
- United Nations Article 9 
- Authoring tools and markup generators 
- HTML5 Alternative Text, and Authoring Tools - Gez Lemon 
- Comments on HTML WG face to face meetings in France Oct 08 
- Why Validate? Point 2.d: Validation helps teach good practices 
- Bug 8000 Comment 1 
- Section 508 1194.22(a) 
- Dutch Accessibility Law Section R-pd.7.1 
- Policy and Standards 
- WCAG 2.0, Guideline 1.1. Text Alternatives (normative) 
- Crowdsourcing 
- Authoring Tool Accessibility Guidelines (ATAG) 2.0 Principle B.2 
- U.S. Senate Passes S.3304 by Unanimous Consent - Coalition of Organizations for Accessible Technology .
- H33: Supplementing link text with the title attribute 
- ISSUE-80: title-alternative Change Proposal by Steve Faulkner 
Detailed Three Year History of the Issue
A detailed three year history of the issue includes issue description, time line, proposed solutions, rationale - pros and cons, research, advice from WAI, use cases, policies/guidelines/law, and email threads:
- Short Text Alternatives on <img>
- Bug 9217: "Remove the Paragraph-Section-Heading loophole for not providing a text alternative.
- Bug 9216: "Provide a CAPTCHA example that is in accord with WCAG 2 or Defer to "HTML5: Techniques for providing useful text alternatives"
- Bug 9215: "Provide a Webcam example that is in accord with WCAG 2 or Defer to 'HTML5: Techniques for providing useful text alternatives"
- Bug 9212: Remove the "generator" option.
- Bug 8646: Private communication exception
- Bug 7362: Inclusion of the title as a case where the alt may be omitted is problematic