Edit comment LC-2702 for Accessibility Guidelines Working Group

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Comment LC-2702: Comment Shortname:; Commenter: Ken Salaets <ksalaets@itic.org> on behalf of Information Technology Industry Council; Message-id:; Section of the document concerned:

or; Refinement of the section concerned:; Status:
assigned to; Type:; Comment:
WCAG2ICT deliverables should clearly state that WCAG 2.0 was not designed to be a complete standard for non-web ICT; other requirements may be needed

Inherent in the nature of web content is that it is necessary for a user agent to be present in order for the web content to be consumable. It is likewise necessary for an operating system to be present to support the relevant user agents and assistive technologies. Given this, WCAG 2.0 appropriately focused solely on matters relevant to web content. But non-web ICT accessibility standards inherently need to address architectural matters more specific to the context of software, operating systems, and other aspects of ICT that are beyond the scope of WCAG. For example, Section 508 in its current form and various drafts contain provisions far beyond the scope of WCAG. This is also the case for various drafts of the M376 standard. In short, WCAG 2.0, even after interpretation beyond the Web, would be an incomplete set of guidelines in these non-web contexts. W3C should therefore make it clear in this document that the use of WCAG 2.0 for non-web ICT cannot be considered a complete set of accessibility guidelines, and that efforts such as M376 EN and Section 508 refresh must necessarily consider additional provisions if they are to develop an appropriate and complete accessibility standard for non-web ICT.

Many WCAG 2.0 SCs, even after interpretation, may not be suitable in a variety of non-web ICT contexts
Many of the WCAG 2.0 success criteria necessarily assume the presence of a browser, an operating system, and some form of assistive technology. This is not an appropriate assumption in many non-web ICT contexts (for example, the context of ICT functions closed from assistive technologies such as most ATM machine functions). All success criteria containing the term “programmatically determined” were constructed to allow assistive technologies to better decipher the web content. But when assistive technologies are not present, these success criteria are not applicable. Indeed, it should still be necessary for the content to be presented in a way that users with disabilities can consume. But implementing such solutions in a programmatically determined nature is not necessary in such a context. We recognize that the WCAG2ICT TF has not considered ICT with closed functionalities from assistive technologies yet, but the TF should make this limitation clear to its audience.; Related issues: LC-2687. LC 2665 LC2670 LC-2662
(space separated ids); WG Notes:; Proposed Resolution: RE: Stating that other standards are needed along with WCAG: We agree that additional requirements are needed especially for software acting in platform role(s). The focus of the work is on "content" as it occurs in both electronic documents and software. Other aspects of software are outside the scope of the Task Force and are covered in separate provisions being drafted for Section 508 (in the US) and Mandate 376 (in Europe). As you point out, these are the purview of the US Access Board and the EU M376 standards development team. It would be inappropriate for us to step beyond our role of discussing how WCAG would be applied to ICT and into the Access Board and M376 standard team's role and make comments on what the overall requirements for ICT should be or what portion of this WCAG would cover. We have, however, included a statement in the introduction explaining that WCAG 2.0 may not be sufficient to ensure accessibility for non-web ICT. Specifically, "This document does not address gaps in requirements that could potentially materialize when WCAG 2.0 is used with non-Web ICT; it is therefore important to note that WCAG 2.0 may not be sufficient by itself to ensure accessibility in non-Web ICT." RE: Many SC may not be suitable especially for closed products . We have created a specific section in the introduction that discusses closed functionality and how to handle them since "programmatic determinability" won't work if assistive technologies cannot be used . It is included below: <insert paragraph on closed functionality> @@@@; (Please make sure the resolution is adapted for public consumption)