W3C

– DRAFT –
AGWG-2025-08-12

12 August 2025

Attendees

Present
Adam_Page, AlinaV, Azlan, Ben_Tillyer, Charu, ChrisLoiselle, elguerrero, filippo-zorzi, Francis_Storr, Frankie, Gez, giacomo-petri, graham, hdv, Jen_G, Jennie_Delisi, jtoles, julierawe, kenneth, kevin, Laura_Carlson, LoriO, LTSzivos, Makoto, maryjom, Rachael, Rain, sarahhorton, shadi, stevef
Regrets
Bruce B, Jennifer Strickland, Mike G, Patrick Lauke, Todd L
Chair
Chuck
Scribe
elguerrero, hdv, Chuck

Meeting minutes

<Chuck> agena?

<Rachael> Ways of Asserting Conformance https://docs.google.com/presentation/d/1MXiAC90NJ6IA1j2HzjAJ5fJRe880hIoX9dxn2undmCU/edit?slide=id.g34514bbb5f4_0_12#slide=id.g34514bbb5f4_0_12

<Chuck> https://lists.w3.org/Archives/Public/w3c-wai-gl/2025JulSep/0061.html

I can scribe :)

Eloisa: )

Chuck: Announcements — had an idea of educating the group about intersectional disabilities. We have not yet been able to do these presentations yet, but remains something we intend to do.

Chuck: Second announcement — some bots or AI agents have been joining the AGWG to record meetings — they are out of policy and we have been removing them.

Chuck: If anyone uses bots for accommodation, please let us know so we can set something up for you.

Chuck: Third announcement — we have 2 styles of queueing, conversational allows back and forth between presenter and person in queue and then move on; when it gets too long, we do linear queueing — make your point as briefly as possible and move on and allow anybody to participate in the conversation. If someone's point is running too long, I

may interject/cut them short — goal is that everyone who wants to participate / join the conversation is able to.

<julierawe> Chuck Can AG subgroups agree to use Zoom's AI companion to take notes of meetings that the subgroup leader will clean up before distributing? Our subgroup has been experimenting with this...

WCAG2ICT Review CFC: https://services.w3.org/htmldiff?doc1=https%3A%2F%2Fwww.w3.org%2FTR%2Fwcag2ict-22%2F&doc2=https%3A%2F%2Fw3c.github.io%2Fwcag2ict%2F

julierawe: About the bots — can AG subgroups use Zoom AI companion to take notes?

<Rachael> at+

kevin: We haven't switched on AI assistant for everything but as long as everyone in the meeting is fine with it, it's okay.

<Ben_Tillyer> I'll email instead

<julierawe> Thank you

<Zakim> Chuck, you wanted to react to julierawe

kevin: Good practice to check that it is okay with everyone first.

<Jennie_Delisi> Some government agencies as well.

Chuck: Some organisations do not allow to participate in such situations; if you have a member of an organisation that has those restrictions, please check with them first.

Rachael: Additional announcement — Julie has taken on role for co-facilitator for coga along with Lisa.

<Jennie_Delisi> * Julie rocks!

<LoriO> Go Julie!!

<LoriO> Go Julie!!

<kenneth> this is great, Julie is great

<Laura_Carlson> Congratulations, Julie!

Chuck: Last week we announced the pre-CFC for WCAG2ICT Group Note, it is an opportunity to try to address any major changes before we do the formal CFC.

Chuck: We're trying to resolve any objections, and today we hope to go to CFC.

maryjom: During this week, our TF took a close look and there were a few editorial things to get into the document before publishing. The list of them will be added to the bottom of the review issue with links to what actually changed. Hopefully nothing controversial.

Chuck: Plan to send out the CFC today and give it a 5-day review period before it can be published. We encourage everyone to review.

WCAG 2.x issues

<Chuck> https://lists.w3.org/Archives/Public/w3c-wai-gl/2025JulSep/0061.html

Chuck: Alistair or Michael usually review those issues for us, but they are not here today.

Chuck: We will refer you to the email sent out by Bruce Bailey regarding updates proposed in the WCAG 2.x issues, and encourage you to review.

<kenneth> (the email indicates the review feedback window is extended by a week)

Chuck: Some of them are normative, mostly editorial. All of them should have your review.

Conformance - Ways of Asserting Conformance https://docs.google.com/presentation/d/1MXiAC90NJ6IA1j2HzjAJ5fJRe880hIoX9dxn2undmCU/edit?slide=id.g34514bbb5f4_0_12#slide=id.g34514bbb5f4_0_12

Rachael: Presenting her screen to show her slides.

Rachael: Today we are doing Ways of asserting conformance.

Rachael: Summary of last week's meeting in the slides — please take a look and add comments.

GreggVan: Are we talking about claiming or assertions of conformance?

Rachael: We are talking about what we talk about when we talk about conformance.

Rachael: Amends the title of the slide to "Ways of assertin (stating, discussing) conformance"

Rachael: We would like to have a shared understanding of conformance and compliance.

Rachael: Conformance, compliance, reporting — what are we talking about?

Rachael: Conformance — satisfying all the requirements of the guidelines.

GreggVan: We have requirements and guidelines — are you talking about the requirements listed under the guidelines?

Rachael: Yes (amends slide for definition of conformance)

<Zakim> hdv, you wanted to say progress

hdv: Would reporting make sense to talk about progress, as 'making more accessible' is what the EU Web Accessibility Directive requires

hdv: Instead of mentioning what the state is, how are you improving?

Rachael: Next slide is reporting.

<Rain> +1 to the conformance definition

GreggVan: The law/regulations require reporting against but we shouldn't make it a conformance claim to report progress because progress will change all the time.

Rachael: Reporting — accessibility conformance report of how close to conforming a thing is, or how something is conforming.

LoriO: "How close" — who will define this? This is different for everyone.

Rachael: In VPAT, we say partially supports or supports… it depends on the reporting structure.

Rachael: When we talk about reporting, it's just to define what we're talking about.

GreggVan: A report could tell you how you're progressing.

<hdv> +1 to Gregg, that helps address my concern too!

<hdv> (re: 'or progressing')

kevin: A big thing about who determines how "close" means, it's determined by rulemakers wherever you are in the world and which legislative framework to comply with.

Rain: "How close" feels subjective and maybe a language tweak "The state of conformance" or "how conformant a thing is" — remove "how close".

<Zakim> Rachael, you wanted to ask if the () addresses Loris point

Rachael: Compliance — how well something satisfies regulation or policy; relates to laws, regulations, and policy; providing hooks for compliance within our scope.

Rachael: Exception for online maps and mapping services.

GreggVan: "Or procurement" — add to the statement.

GreggVan: Online mapping as exception — would this be in the standard or in the use of the standard document?

<JobA> I’m hesitant to list exceptions.

Rachael: None of these are intended to be within the standard — just clarify what each of these things are, and what the general big examples are.

<JobA> That isn’t in en301 but EAA ?

<Rain> +1 to Lori. Procurement is part of a process that will use compliance as a factor.

<JobA> What about policy rather than procurement ?

<Zakim> Chuck, you wanted to answer Lori

LoriO: Under Compliance, I don't think "procurement" is what we're looking for in compliance — if you start talking about, you're looking at a customer looking at a product. Will be different for every product — I don't think procurement should be in that statement.

Chuck: There are procurement requirements put on public sector such as in Section 508.

Chuck: There may be another way of expressing it, but EN301549 (?) has a lot of procurement-related requirements in there as well

LoriO: Wouldn't you say "procurement requirements" instead?

<sarahhorton> +1, wouldn't procurement be a type of regulation or policy?

Jennie_Delisi: There are procurement and contract requirements.

<JobA> I think folks are getting the standard and directives and laws crossed.

Jennie_Delisi: Not sure if it's also procurement policies that maybe covers that — this is still important in terms of ensuring this area is hammered out well. I don't have the specific language.

Ben_Tillyer: Section 508 is part of an act, and the act is law, so it's covered when we say "law or policy" — could add words like "regulations" or "company requirements", etc.

<Zakim> GreggVan, you wanted to say "other contract or procuement requirements"

<Frankie> Why not just "other requirements"? That is inclusive of company and legal methods.

GreggVan: We have places that are not covered by 508 that want to be accessible and require this in their procurement and purchase contract. Can be required by law, regulation, or for any other reason, bound by contracts.

<Zakim> hdv, you wanted to say comply with law vs conform to standard

<Ben_Tillyer> +1 to hdv

hdv: Conforming is something you do with a standard, and compliance is something you do with a law. We're making it confusing by making it longer, so agree with GreggVan, use "regulation policy" or "contract requirements" could cover it.

<shadi> +1

ChrisLoiselle: Are we highlighting ITI, VPAT, ACR, or a WCAG EM Report would be another example for reporting.

ChrisLoiselle: For me, a report is a statement in time of when this statement was made, versus a progressing which would be continuous.

Chuck: With these 3 terms, we're trying to come up with an understanding for our benefit/ frame of reference for us all.

<Rachael> poll: 1) procurement requirements 2) law 3) other contract or procurement requirements 4) other

<LoriO> 1

<GreggVan> 3

<Ben_Tillyer> 2

<hdv> 3

3

<Jennie_Delisi> 3

<LoriO> 3

<Azlan> 3

<Rain> 3

<Charu> 3

<sarahhorton> 3

<Makoto> 3

<shadi> 3

<Frankie> 2

<joryc> 3

<LTSzivos> 3

<Laura_Carlson> 3

<Gez> 3

GreggVan: "Law" should be before regulation, shouldn't be at the end.

<Frankie> +1 to law being the first item in the list

<Charu> +1 to Law being first

Rachael: Are we comfortable with "how well something satisfies law, regulation, policy, or other contract or procurement requirements"

<Frankie> "How well something meets legal or other requirements" to get rid of the loaded verb "satisfies"

<Frankie> "Satisfies" feels problematic for globalization of the definition

Rachael: "reporting is active and ongoing, a report is a static result of reporting"

Rachael: In Compliance, change "satisfies" to "meets"

Rachael: "How well something meets law, regulation, policy, or other contract or procurement requirements"

ChrisLoiselle: Is the use of requirements similar or different in terms of how you're listing them — when reading altogether, might cause confusion to someone?

<Jennie_Delisi> * Suggest adding quotes maybe? "procurement requirements"

<Jennie_Delisi> * to support defining it as a term...but still not sure

<Ben_Tillyer> Suggestion as a "2" voter: conformity with statutory and institutional requirements

Rachael: To keep them clear, we can add contract requirements or procurement requirements so that each type of requirement is specific.

Ben_Tillyer: Wanted to cover everything that a government can put on you, or a company could put on you.

<jtoles> Suggestion: "or other requirements (such as for procurement or contracts).

Ben_Tillyer: Too much focus on procurement over development.

GreggVan: Remove "other" — "how well something meets law, regulation, policy, contract, or procurement requirements"

<Frankie> +1 to what Gregg just said

<Zakim> Rachael, you wanted to suggest new bullet

<GreggVan> +1

<GreggVan> q_

Rachael: In Compliance, we could add "associated with statutory or institutional requirements"

Rain: Law, regulation, and policy cover contract and procurement requirements.

<Ben_Tillyer> +1 to Rain, what I was originally saying

<hdv> +1

<Frankie> +1 to what Rain said

<sarahhorton> +1 to Rain

<Rain> But in that example from Gregg, is that "compliance?"

<Ben_Tillyer> Sounds like a personal policy (a course or principle of action adopted or proposed by an organization or individual.)

<GreggVan> +1

Rachael: Does Compliance also include "when an organisation or individual sets a set of requirements that reference a technical standard."

<Laura_Carlson> +1 to Kevin

kevin: We conform to the standard, we comply with a law, or a policy, and that policy could be government or internal or your own, but the distinction I'd make is you can conform against a standard but you comply with a policy, regulation, or law.

Chuck: Contractual or procurement requirements in US are civil, not criminal or legal, matter, therefore distinct enough to merit their own mention in here

GreggVan: We can set our own internal policies, but not others.

<GreggVan> +1

<Chuck> +1

Jennie_Delisi: Example, I live in a state with a digital accessibility law, and the agency I work for has apolicy related to a level of accessibility, a project could specify requirements in their contract for a tool. that goes above and beyond the law and the policy because of that use case.

<Frankie> +1 to Jennie's point

<Laura_Carlson> +1 to Jennie

<GreggVan> jennie -- really well stated.

Chuck: Any objections to what is written at the moment in the slide for purposes of common understanding?

(No objections)

<Zakim> Rachael, you wanted to suggest we take 5 more minutes on this

GreggVan: "What is hooks for compliance"?

Rachael: Part of what we're designing has to support someone in compliance using it, what hooks means is if we want people to be able to report on levels, there has to be something that regulators can point to in the technical standard to be able to make some of these decisions.

Rachael: Next slide, "How do people assert / report on conformance or compliance"

Rachael: What are other ways that people report on the state of their product?

hdv: For WCAG EM Report Tool — add "or similar"; many companies have their own WCAG EM report tools that may or may not be similar to it

<Ben_Tillyer> https://www.w3.org/WAI/standards-guidelines/wcag/conformance-logos/

Ben_Tillyer: Badges on websites

<Zakim> Chuck, you wanted to ask for scribe change

ChrisLoiselle: on slide 9, not sure if ATAG Report Tool would be folded into this?

(https: //www.w3.org/WAI/atag/report-tool/)

<ChrisLoiselle> request for proposals

GreggVan: another thing you'd report on would be on a purchase contract / RFP checklist, where folks report how they meet the accessibility requirements

Jennie_Delisi: comes down to the size and maturity of the reporting company, as well as size an complexity of the tool. Very small companies might not be so formal

Ben_Tillyer: in monitoring tools, automated tools and dashboard people may find accessibility scores. Similar tools are built into CI/CD pipelines.

<Zakim> Rachael, you wanted to ask Jennie where those statements are made

Rachael: question to Jennie, when you do that kind of narrative statement, where would you do it, where do you encounter those?

Jennie_Delisi: the governance process we use for validating conformance for something that is procured or required, we take something that we need to capture in a formal way. Eg posted on a website, or emailed. We have documentation somebody could use later. It has to be a communication that can be kept, compliance has to be auditable in some scenarios so we may have to produce what we use to valide compliance

<Zakim> Chuck, you wanted to ask if "Public narrative statement" would suffice

Chuck: it is static and somebody could be held to account for that communication

Jennie_Delisi: an example would be an AT company that has not had to produce a VPAT in the past… they may not have something on their website, in that case an email would be sufficient

Rachael: next slide… what things could people report against in WCAG 3?

Rachael: this is talking about possibilities, not decided yet which parts of this will go to normative docs. I captured progress from the earlier convo. My goal would be to be pretty open about this list and brainstorm possibilities here

Rachael: what different things are possible for reporting against?

ChrisLoiselle: would this be where you capture the convo around assertions in reporting? vs conforming?

Chuck: the bullet 'functional needs supported', to me that is somewhat different but has a relation to the first bullet number

Chuck: there is a hybrid for two of those

Chuck: ah if it represents level achieved that's fine

GreggVan: date of report, eg archival vs active

GreggVan: if you acquire a company and then you have a billion videos, there is no way yoou could make them accessible in a day

Rachael: so functional needs reporting would be based on conditions passed or failed

Rachael: if we wanted to map them, we could map them to provisions

Rachael: it's the next step abstraction from disability supported

GreggVan: let's say I have a site for people who are deaf, I may put sign language in place even if not required. In such cases you may report you've gone above and beyond in that area

Ben_Tillyer: what about error density?

Ben_Tillyer: and scope of testing?

Ben_Tillyer: and the level of risk associated with their error density?

Ben_Tillyer: or org impact?

Ben_Tillyer: am also thinking back to what we have to do in public sector bodies: we need to include a roadmap

Ben_Tillyer: and what about AT compat?

Ben++

<Zakim> GreggVan, you wanted to say remediation poilicy or timeline

<Jennie_Delisi> Version as part of their report? Along with date.

<elguerrero> Ben_Tillyer++

GreggVan: remediation policy or timeline

<Ben_Tillyer> +1 to giacomo

giacomo-petri: responsibilites, eg which team is responsible to address or remediate

Jennie_Delisi: I think it's important to note the version that was tested

<Zakim> hdv, you wanted to talk version of report and reported

<Jennie_Delisi> +1 to HDV - e.g. using an older VPAT changes things

hdv: Regarding version, in version of WCAG EM, we are thinking of including test version.

<GreggVan> tools used

hdv: so the version of the test carried out, vs the version of the product being tested

hdv: as people may test again

hdv: this also helps with progress

<Ben_Tillyer> Accessibility adjacent info?

shadi: I'm thinking about EU energy consumption scores, labels from A to E… in that report, depending on the product, it provides certain aspects, like for washing machines, how loud it is or how many clothes it takes

<Ben_Tillyer> +1 to classification

<elguerrero> Who the stakeholders are?

<elguerrero> Limitations of software/tooling

shadi: also important to think about who am I reporting to. Eg on a technical basis to authorities, or am I reporting to an end user and want to explain the features

shadi: thirdly… reporting on the alternatives could be helpful. Eg 'if you switch on this mode, the site has larger text'. That could be a type of reporting too

<Ben_Tillyer> +1 to this idea

giacomo-petri: we could consider subdividing things people could report, based on who is reporting. Eg a third party / contractor, where somebody is asking me to validate… there are things I can validate and others that I cannot.

<elguerrero> giacomo++

giacomo-petri: I also wonder if we should define what methodologies you used to validate the requirements, eg manual, semi automated, automated

<Zakim> GreggVan, you wanted to say "tools used" and to say 1) Tools used and 2) Challenges and to say 1) Tools or organizations used and 2) Challenges

GreggVan: in addition to methodologies, also tools used

GreggVan: challenges could be interesting to add too… may not change whether you conform or not, but would still be helpful to include in a report

Ben_Tillyer: qualifications of the author … eg I'd rather read the report from someone on this call than my plumber

Ben_Tillyer: another one: was AI used to generate the report or some other method

<Zakim> Jennie_Delisi, you wanted to discuss AI

<Frankie> +1 to Ben's point re AI

<Ben_Tillyer> +1 to Jennie's concerns

<elguerrero> +1 Jennie

Jennie_Delisi: I agree re the AI point. I want to caution how it gets written, because at this time there is AI baked in at so many different levels. there is AI-assist vs outright AI written etc. Can be very hard to describe and that's difficult from a compliance standpoint

giacomo-petri: just one more point re AI… potentially a service I used uses AI, but I don't know what or how. The answer may be 'unknown'

Rachael: next steps… we'd like to put this in a table and start thinking about it

Rachael: and where to use it

Rachael: I tried to capture today's convo in the slide, do people miss anything from our conversation?

Minutes manually created (not a transcript), formatted by scribe.perl version 244 (Thu Feb 27 01:23:09 2025 UTC).

Diagnostics

Succeeded: s/pre-CFC/pre-CFC for WCAG2ICT Group Note/

Succeeded: s/by/is extended by/

Succeeded: s/progress?/progress, as 'making more accessible' is what the EU Web Accessibility Directive requires/

Succeeded: s/captur/capture

Succeeded: s/scrbie-//

Maybe present: (https, Chuck, Eloisa, GreggVan

All speakers: (https, Ben_Tillyer, ChrisLoiselle, Chuck, Eloisa, giacomo-petri, GreggVan, hdv, Jennie_Delisi, julierawe, kevin, LoriO, maryjom, Rachael, Rain, shadi

Active on IRC: Adam_Page, AlinaV, Azlan, Ben_Tillyer, Charu, ChrisLoiselle, Chuck, elguerrero, filippo-zorzi, Francis_Storr, Frankie, Gez, giacomo-petri, graham, GreggVan, hdv, Jen_G, Jennie_Delisi, JobA, joryc, jtoles, julierawe, kenneth, kevin, Laura_Carlson, LoriO, LTSzivos, Makoto, maryjom, Rachael, Rain, sarahhorton, shadi, stevef