Meeting minutes
RM: Welcome everyone.
introductions
RM: First of all, is there anyone here who is new?
Sam: I'm here on behalf of Level Access. I've spent the better part of a decade focusing on emerging technologies and the intersection with accessibility, so happy to be here.
announcements
<Adam> Policy subgroup participation survey
Heather: I am rejoining. this group is an invited expert.
Adam: have one announcement. We will be starting up a new subgroup in late May to begin work on the policy explainer for WCAG 3.
<kevin> https://
Adam: will have a New survey to gather interest in that
<Ben_Tillyer> 1am to 11am Monday+Tuesday for us staying in the UK and dialing in... Red Bull will be procured. :D
Kevin: there is an AC meeting next week, which is a general meeting for the AC representatives and others to meet up.
AWK: related to the charter update. Any part of the AC meetings that are happening?
Essential Exception https://docs.google.com/presentation/d/1Vov5k9XXlQSy7AtVuBVQvhSMDIOPA0kj69xJoq71BSQ/edit?slide=id.g3d616ce2730_2_5#slide=id.g3d616ce2730_2_5
kevin: advisory committee meetings, kind of a general meeting. The any charter progress happens through other channels, so mostly directly to AC members via email and survey.
RM: We weren't able to get enough participation to make it make sense for us to have a meeting at AccessU., so instead we are looking at holding a two-day. virtual meeting in May, with the topics being the charter and creating an outline for the policy document.
… will have a survey.
… So the question for discussion today, is about whether we should pursue a universal essential exception, or just leave it on a requirement-by-requirement basis.
Gregg: are you talking about essential exceptions to? we already have one that you can have an alternate page. are you saying that if it's essential to not have an alternate page, or are you talking about essential exceptions to individual provisions?
RM: I'm talking about what is currently in the provisions themselves as an exception when something is essential.
<kirkwood> I’d rather see terminology “functional exception” because of how loaded in policy that term is
RM: (Slide 30)
Gregg: We shouldn't be putting in things like exceptions for testing or this or that, because we should also put them in for airplane pilots, and for fighter jets, etc. I mean, that's all policy.
… But putting a blanket one on it sounds very dangerous to me. If we can't think of any reason why it would be essential.
JK: I have a problem with the terminology essential exception, because it is so wrapped in policy, and so used I would much rather see something more like functional exception.
CH: but I could see the value of a global level... are a universal essential exception. That is its purpose. And and I'm I'm not sure how best to explain this, but in the context of like harm, for example.
<julierawe> Adding to Charles suggestion: Such as a tool designed to demonstrate, analyze, and test for the photosensitive epilepsy flashing threshold (WCAG 2.3.1) like the Trace Center Photosensitive Epilepsy Analysis Tool (PEAT): https://
CH: if the content is known to cause harm.
like flashing content
<kirkwood> defining as “essential to the purpose of pag e” is clearer, well said
Gregg: I think CH meant to demonstrate the content that would cause harm. But that, again, turns into the same thing as a test. That's an example of something that's not accessible. So you don't put it in there saying, this page is accessible.
<kirkwood> “essential (to the purpose of the page) exception”
RM: I'm going to try to pivot here for a minute.
And restate this exercise, because I do want it to just be a brainstorming exercise.
<kevin> "exception for content that is already an alternative for other content"
RM: Let's just come up with a list and it doesn't even have to be a list from a universal standpoint. What are the kinds of exceptions?
that we have within WCAG 2 or may have within WCAG 2.
<Zakim> AWK, you wanted to ask if people agree to any essential exceptions. For example logotypes not needing to meet contrast
SK: one that comes to mind is if you had a page that was its purpose was something like the Ishihara test for color perception. Where test for like different color deficiencies in perception that would wear providing an accessible alternative to it would seemingly defeat the purpose of that exercise.
awk: One of the examples that we have as logotype exception. One of the things that's considered essential.
… another one is talking about a piano, which is for orientation
<Zakim> GreggVan, you wanted to say here are some examples of places we do need it
Heather: external Factor constraint like something, legalize, or security-wise.
But then if there's an outside factor, that would
make that not attainable, then that would be an exception.
SC: I was thinking about an exception, potentially, for third party or user-generated content.
<kirkwood> AR, VR?
Gregg: Financial, legal is one. Another one is timing.
… playing a key, uh, piano is a good one.
… All sorts of authentication
… If you're trying to authenticate a signature
… there's also authentication of with face, with, with, um...
Facial movement,
<ShawnT> +1 to the language exception
CH: All of these examples that we now have bulleted out in this thought exercise are examples of the statement I was trying to make. Each one of those examples, the reason it is an exception is that is its purpose.
<Zakim> kevin, you wanted to suggest exception for content that is an alternative and labelled as such
<kevin> ack
SO: two-dimensional layout that conveys meaning or functionality exception for things like reflow.
<Zakim> AWK, you wanted to raise target size essential exception
<AWK> demonstration or test of physical or sensory limits
SO: when you have words from a different language that have become known in, you know, the primary language.
… playing a game or performing a test to measure reaction time.
… pointer cancellation, because if the point is to measures someone's reaction time. You shouldn't allow them to un do their reaction time.
Ben: pages designed to be read by machines, whether that's an APl or whether it's agentic Al.
Kevin: exception around about content that is actually an alternative.
AWK: Reaction time. Physical or sensory limits.
<AWK> We aren't calling it "accessible" we are calling it "conforming"
Gregg: I think purpose is too vague.
<kevin> +1 AWK
SK: I just wanted to provide an example to the one that is content that is itself an alternative, because I personally find it helpful is when you have a sign language video that is serving as an alternative to the text that is on the page.
LO: a combination of both trying to get authenticated and timing.
<Zakim> joryc, you wanted to say that might be essential (timing)
Gregg: We have a timing provision. that would have applied there, so that would have been not accessible, because you didn't have timing.
<Rachael> (Last one for this)
<ljoakley> +1
Gregg: I think we had in 2 and have in 3, the alternatives do not have to have alternatives, because they are already alternatives.
<kevin> Current definition of 'essential exception'
Jory: essential is slippery here. security person might argue that . having, you know, sort of authentication token that was starting to get created, timeout would be, essential for their security.
RM: 3 purposes to this list in this exercise.
1 we want to look through this. Step one is to look through this, and is there anything?
… The second question would be, are there things like the security or other areas that we should have a section in WCAG 3 that is separate
… Then for everybody who's working in subgroups,
Do any of these fit well at a universal level?
<Ben_Tillyer> the bot one?
This is a great list to come back to and ask yourself, does any of these apply to my
particular SC.
CH: questions, I'm wondering if we missed one in this list, which is when the input modality is limited by the device itself.
FS: I'm looking at logo exception
<scott> is it worth noting that even with what's been written on the slide, that it does not necessarily represent an exhaustive list? i'm sure there'll be things that could be added / were forgotten
Heather: I would take the third party and user-generated and put those on two lines. I think user-generated could be considered potentially universal if the user is doing something that makes it not accessible, then that's on them.
… A third party could alter an entire system, which makes something inaccessible
<kevin> +1 to Gregg that UGC being a policy issue
Gregg: I don't think user-generated should be on here, because the user-generated is a policy issue
Gregg: Alternatives don't have themselves to be accessible sounds funny. What you really mean is we shouldn't be using the word accessible, we should say conformant.
Giacomo: One consideration. Basically, all of these exceptions are somehow atomic. I mean, they are also universal, but they rely on specific functionalities.
RM: That's probably more in the conformance and policy issues section than in the Exceptions section.
<kirkwood> art?
JT: On the content that is an alternative.
I think we're assuming that the only way that the alternative is not conforming.
RM: What I want to do here is just identify the ones we want to talk about more, not actually talk about each of them individually. I'll open a discussion on WCAG discussion board, WCAG 3 discussion board on GitHub.
CH: I agree with Gregg that purpose isn't quite the right word here to replace information and functionality, but that also doesn't quite.
capture the concept
… But still think that one is a good potential for being universal because it could apply to a scenario where the purpose or the reason the entire page exists is to demonstrate an inaccessible page.
… so it wouldn't have atomic exceptions within it. The whole reason the whole thing exists.
JR: I think we definitely need more discussion about things like financial, legal, security and authentication
Kevin: So I would be hesitant to suggest that user-generated content would be something that would be a universal issue.
… think it's certainly an issue that needs to be considered as part of
policy making.
Gregg: Somebody talked about types of products that wouldn't have to meet this, or should be exceptions. That's policy. That has nothing to do with us.
Gregg: I don't think we need to have an exception for examples of things that are not accessible.
<Zakim> Adam, you wanted to react to GreggVan
Gregg: user-generated content, and if it doesn't conform, it doesn't conform. User-generated content should not be in any way an exception of any kind. that is up to policy to say that user generated content is the responsibility of the user not the app used. but WCAG should still be used to see if user generated content (e.g. email) that is sent to a whole org is conforming to WCAG..
… We want WCAG to be a measure of what that user needs to do if they're going to be sending that content.
Rachael: Anything in the universal exceptions list for defining the universal exception question, please put yourself upfront in the queue. Do we want to continue to considering if there is a universal exception definition?
kirkwood: Was thinking about art, art creation, art experience, expression, experiential. Example: Captions on video.
<kirkwood> art abstract immersive creative art experience. much like signature
Rachael: [Verbalized the bold items on slide 32 to consider for a universal exception definition]. Turning queue back over for concerns about the current list, or comments to support.
<Charles> point of clarity: i interpret the word exception in this exercise as an exception to the entirety of conformance since it is at a universal level. so my thoughts were at conceptual level versus atomic.
stevekerr: Clarification question, when things have been discussed, there are comments about policy and the difference about the exceptions. Are these intended to be exceptions to conformance?
Rachael: Is it actually a conformance thing, which is very centered on the standards and access and the ability to meet those standards versus is it a compliance thing, which is the larger question, should the standard themselves even apply to the situation? which is a subtle distinction.
<AWK> +100 to\ Steve
stevekerr: Don't have a fleshed-out conformance model yet, this is a policy question or if we don't have a conformance model yet, and we're determining exceptions to conformance without that model it's a difficult thing to dismiss these concerns until we have that defined.
Rachael We do have a conformance model, we're continuing to iterate and come up with alternatives to a conformance model, and it's an ongoing process.
Ben_Tillyer: User generated content and the user customizing the UI is something I do. I wonder if the user modification of the UI is within the scope of the callouts. Another point, I think I agree with Greg on most of this, I feel you should be able to confidently say, using frameworks that we give site owners, we should be confident in saying,
yes, this does not conform, this is not the best for people with disabilities, and this is the reason why and then list out the reasons why.
<kirkwood> WCAG is a specification, Complying with WCAG is a policy
<kirkwood> +1 to Gregg
<Rachael> previous conversations on conformance and compliance which may help clarify https://
<kevin> +1 to distinction between conformance/compliance
GreggVan: Regarding the question of what is policy and what is WCAG? WCAG is a measure of whether if something is or isn't accessibility, or does or doesn't meet a minimum accessibility standard. We do not define who must do it or what types of content. Policy requires what needs to be accessibility. We're not saying who needs to do it - this is
defined in policy. WCAG defines if something is accessible. Whether it's accessibility or not is what WCAG tells you. Whether or not you need to make it accessibility is policy. If it is an exception in WCAG, then it conforms to the standard. It shouldn't be an exception of any kind, global or otherwise.
<kirkwood> +1
<kevin> Good example of policy distinction is the provision in EU Web Accessibility Directive for archived content
<AWK> Everything _could_ be policy. We can and should establish some constraints also.
<kirkwood> should we have any exceptions at all? Can’t the individual sc be written differently?
GreggVan: User generated, you're saying if it's accessible or not, you're saying who needs to follow. Thinks user generated needs to be removed. Legal should be there. It should be a policy in our policy document that you never require that people don't violate the laws. Content itself is the alternative, and this is tricky. It should only be an
exception on an item-by-item basis. The alternative needs to be specific to provisions and not globally, and keep in mind multiple disabilities. For artistic creation expression, that goes into policy. Content only displayed on one single type of device, and the input can't do it - that's called technical feasibility, and it's already an exception.
<laura> +1 to Gregg.
<shadi> [I disagree with "WCAG defines if something is accessible" -- rather, it defines levels of accessibility]
GreggVan: of the entire list, I don't see anything that needs to be global. I only see individual ones and not global.
<kirkwood> +1 to Greggg
<kevin> +1 to Gregg
Rachael: Note that everything could be policy and we and should establish constraints.
Charles: Asks for clarification for an exception to conformance or an exception that is?
GreggVan: Isn't an exception to conformance? By definition, policy, whether something has to conform or not. Excpetions would be that it conforms that you fall into the exception.
Rachael: We are considering whether there are exceptions hat would all requirements to conform if they were not met.
Charles: Allow to conform.
<Charles> doesn’t making it universal automatically mean not atomic or provision based?
AWK: When we have exceptions today, there's a success criterion. Which has words that need to be true or false for a given webpage. And by incorporating an exception, we're making it so there's a broader class of content that can meet a give criterion. Provides example with video with captions and provides exception.
<kirkwood> if an exception is written into conformance, then it still WOULD conform. correct. (i don’t like ultimate frisby either)
AWK: We don't really have a conformance model, we've got an exploratory conformance model, but there's lots of work going on right now, and will be presenting back to the group.
<sam-estoesta> As an ultimate frisbee wife (with a husband who is going to 2026 World Masters Ultimate Club Championship in the United Kingdom), I feel compelled to defend the sport.
stevekerr: If I have a theoretical product with the goal that the product publishes blog posts. I am a fully conforming product until someone tries to use it. The initial evaluation could claim that it is conformant because no one has used it yet. This scenario is not being considered in the work right now. Why are we not considering the
requirements that should be in place to allow products to be able to consider creating conforming content. We are signaling to policymakers that they need to be able to determine this very complicated and nuanced thing that we can do more work at the AG level. What needs to be left for a policy doc and what should be considered within the scope of
the conformance model.
<Charles> this entire exercise is then part of the conformance model
Rachael: Clarification that user-generated content is considered its own topic. And a topic that we will both discuss in policy. Straw poll for continuing to define universal exception.
<Rachael> +1 that much of user generated content will fall as methods below requirements
GreggVan: Provides user generating content and authoring tools. We've talked about if an app needs to be conforming. An authoring tool needs to be both accessible and allow users to generate accessible content. The creator is responsible for determining if they are required to make something is responsible as it relates to the policy they fall
under. It's different for individuals or families or companies.
<Zakim> kevin, you wanted to mention ATAG
<kevin> https://
Kevin: We have a recommendation for authoring tools, and a community group for authoring tools and we're looking at developing this a little bit further. Link provided above.
Kevin: There's a question of responsibility for the content, and on checking, it is non-conformant with WCAG. The question then becomes who is responsible for that if the functionality of that website is essential to me? That's the important bit and that's not for us to determine. Responsibility is within the competence of policymakers. The
policymakers determine who is responsible for the content.
stevekerr: Within WCAG 2, we do make a statement for that live captions, the responsibility for providing them falls on the host caller, and not the application.
<kirkwood> Live caption is a good example
<stevekerr> +1 giacomo-petri
giacomo-petri: We talked about in the past about the addition of assertions to make improvements and not just using levels. If vocab essentially provides a level, potentially the user generated content impacts the output of an evaluation. So how can companies understand where they are, and if it's influenced by the user-generated content. Because
at the end of the evaluation you are failing or passing, and it's a policymaker's choice.
Example of policy: for Title II 3-Party Content Exception says that content posted by third parties does not need to meet accessibility standards, unless it is posted under a contract or agreement. This means that if the government entity does not control the content, they are not responsible for ensuring its accessibility.
Kevin: Cycling back on the live captions first - I don't disagree that there is mention of responsibility. We're not indicating who is responsible within the conformance model. It's within the intent, and outlines a little bit more about the intention of the success criteria. In terms of the guidance and support for giving people who are looking to
interpret, but it doesn't dictate what the conformance is, because that would be appropriate.
<Rachael> Straw poll: Is there a benefit to continuing to explore creating universal exceptions or do we want to move forward with only provision-by-provision exceptions? Yes, we should continue conversations about universal exceptions or No, we should focus on provision-by-provision exceptions
<GreggVan> no - there are no identified universal that are not policy so don't fit into WCAG
<kirkwood> no
Rachael: Asks for responses to the straw poll.
<Charles> no
no
<Heather> Yes
<ShawnT> no
<MGaines> no
<Ben_Tillyer> yes - although we don't have anything for that category now, we might do later on.
<CClaire> no
<GreggVan> we can bring it up later -- if we discover somthing to dscuss
<ljoakley> yes
ljoakley: We don't see something that's a combination of the two. There could be edge cases and very specific use cases to have an exception.
<Detlev> shelve now, think about it later once we have an agreed conformance model
<AWK> No, not because everything goes in policy but because we can create exception types that apply to individual criteria later also.
<jkatherman> no
<julierawe> No, I think provision by provision is the way to go
<BrianE> no
<Makoto_U> no
<LenB> no
<jtoles> No
Heather: If one example exists, then a universal exceptions list should be defined.
<kevin> No, provision level exceptions. There *might* be a universal exception in future but I can't see one on the list
<AWK> Perhaps we agree to identify the shared exceptions whenever an exception needs to be re-used?
ljoakley: IMO, it's worth having overall exceptions, there needs to also be provision-by-provision exceptions.
<Charles> +1 to defer as we may discover exceptions that are common across provisions
Rachael: People are also suggesting to come back to it later. Since we don't have full consensus, Rachel will put it in GitHub.
GreggVan: Once we close an issue, we try not to open it back up again. If somebody thinks of something new that we haven't thought of before however, it can be brought up to the group again. We can always close it for now and open it up again in the future.
Rachael: Yes, we can have the conversation again with new information, and we can bring it back up here or on GitHub.
<Ben_Tillyer> happy to move to no
Rachael: Remember if you're not comfortable in meetings talking, and we move to asynchronous, GitHub is another place to voice your opinion.
giacomo-petri: Asks for clarification to understand the difference for exception (like logos for brand) and when it is a policy-maker decision.
<Rachael> Key question: Better define the difference between exceptions and policy
<Zakim> GreggVan, you wanted to comment on logos
Rachael: Good question. Capturing that we have a key question we should add into this conversation. What is the limit to what we can decide and what policy makers need to decide.
GreggVan: The reason that logos were made an exception is that it doesn't mean anything, it's just a shape. It doesn't have any particular meaning. It can be seen by differently by different people. It just wasn't important for accessibility.
<kirkwood> sounds like you are describing art ;)
Scope of WCAG 3 https://docs.google.com/presentation/d/1BkgIVS8ODwokDPXJd91ChHfN7-WuaZdGcvK3Ru-hc_Y/edit?usp=sharing
Heather: Branding is a great example for what could be important to WCAG vs company policy.
Rachael: For scope of WCAG 3, there's a specific document itself, and there's a link to the agenda item.
<Rachael> current text https://
Rachael: [Reading slide 2 content, which addresses the differences between WCAG 2 and WCAG 3.]
Rachael: On slide 3, there is proposed changes to start this discussion. Including *digital (replacing web), *kiosks and more, *artificial intelligence, *and AI. WCAG does not address hardware details or other physical aspects of the digital experience.
Rachael: Asks to craft this language during this meeting. Questions to guide this discussion are on Slide 4.
<kirkwood> -1 to Gregg on kiosks
GreggVan: Thank you for highlighting the word 'digital.' Suggests removing the word 'kiosk.' Because the fundamental problem because our guidelines are based not he fact that there is a user agent (a browser). If we decide to broaden it, we have to go back and revisit all of them and write them differently.
GreggVan: AI is fine because it's another way of generating, and you have to be responsible for that. WCAG does not address hardware details or other physical aspects. which means you shouldn't claim to cover it one place and then end up putting an exception.
<Zakim> AWK, you wanted to ask why we are adding kiosks. Closed systems changes things a lot.
AWK: Chiming in about kiosks. Kiosks are an entire environment that are closed systems, most cases, the physical controls, interface ports like the headphone jack. it's such a different experience, and they are more intelligent now. Think about a soda machine or other vending machine. We should be restricting our focus to the content on devices.
I'm wary of saying digital instead of web. I suspect that we will also run into some challenges. Kiosks feels like it's just too much.
<Zakim> joryc, you wanted to ask: why are we singling out AI content? Isn't that covered by the category of content the AI created?
<Makoto_U> +1 to AWK
<giacomo-petri> +steve_faulkner
joryc: Don't know why we are talking about AI, it seems to be talking about types of content and use your agents to consume it, not author it. AI isn't a category of content. Who is the author and taking responsibilities, or what you create with AI? It seems like it's just kind of wedged in here.
<kirkwood> +1 to AI not working here
<AWK> maybe "content management systems and authoring tools (including generative AI), testing tools...
<Zakim> Rachael, you wanted to respond to gregg
<kirkwood> good point
Charles: No opinion about if the kiosks should be removed. There are things to consider in that definition and there are newer and more capable devices. Wants to point out that these two things can't simultaneously be true, where it does include wearable devices, kiosks and more. At the end, it doesn't address other physical aspects.
Rachael: Responding with chair hat on. The question is here for to have this discussion.
<Charles> digital content requires all modalities whereas some hardware limits those
<Zakim> sam-estoesta, you wanted to ask about the use of augmented reality versus using extended realities
Rachael: Chair hat off, I argue that this says digital content, the accessibility of digital content at the beginning, so that clarification is already there. The second to last sentence around physical is more of a clear clarification around the fact that this is just digital content, it is not about the entire object. Kiosks have digital content
and mobile devices present digital content. It's not always the web. Companies and evaluators are looking for guidance on this. different groups apply different standards differently. I think it might be appropriate here.
sam-estoesta: The use of the word digital does open up quite a few things. Wondering why we've limited it for the virtual and augmented reality side. It would make more sense to say extended realities, just because then we can get into a mixed or a variety of different elements within there. Like the digital experience, not just the physicality and
the accessibility of the glass itself.
<joryc> +1 to Wilco. AI is and will be a user agent and an assistive technology
Wilco: Very encouraged that we're having this conversation and the direction that's being proposed. It opens a million questions, including: How can you contain something like this because digital is wide open, huge scope. I'm not sure I disagree is the disconnect between physical and digital. I don't think it makes sense to talk one without
acknowledging the other. I think you need a separate approach to those kinds of products. and I like the inclusion of AI.
Rachael: Impresses me allows how one paragraph in this document can generate as many questions as this is about to.
<shadi> [seems odd to be going ahead with a charter while we're still figuring out the scope of WCAG3]
<SydneyColeman> noting that we have 2 minutes left and a large queue
<SydneyColeman> and some had stops
<SydneyColeman> *hard
<kirkwood> kiosks must have screen reader t(of some sort) o be accessible
GreggVan: Andrew called out if you put kiosks in here, then every place we have we have to re-explian how, and when it's not programmatically determinable. When the thing is closed, you have to do something different. You'd have to consider what is hardware-oriented. Does digital content mean platform? and if so, we need to revisit all the
provisions then too. To me, it means you want to move from being WCAG to being a fully in 301 549, and about the ones that do and don't work and the problems you would be moving outside. For AI agents, there are new and different AI agents built into them. AI agents are getting smarter with new types of AI. We shouldn't pretend like it's brand new.
Ben_Tillyer: Was confused of the word 'digital' because all my content which is shown to me on my laptop, wearable devices is digital. I don't know of any analog content that comes on those devices. I feel like it includes the source files. I feel like we want to get at the user agent to a user. Why do we have desktops, laptops, tablets, mobile
devices, when they are all personal computers of different sizes. We can consolidate that list with a catch-all word.
Rachael: This is a rich discussion, thank you all.
<Ben_Tillyer> Thanks all