W3C

– DRAFT –
WCAG2ICT Task Force Teleconference

30 April 2026

Attendees

Present
_1, bbailey, Daniel, Laura, PhilDay
Regrets
Laura Miller, Loïc Martínez-Normand
Chair
PhilDay
Scribe
PhilDay, Daniel

Meeting minutes

Announcements

<bbailey> https://lists.w3.org/Archives/Public/w3c-wai-gl/2026AprJun/0016.html

AG WG virtual meeting on May 11 and 12 - so we may not get input until after this on WCAG2ICT

bbailey: AGWG's having an extended meeting 11 and 12

<bbailey> https://www.federalregister.gov/documents/2026/04/20/2026-07663/extension-of-compliance-dates-for-nondiscrimination-on-the-basis-of-disability-accessibility-of-web

Daniel: EN 301 549 is discussing wording on 9, 0, and 11.7 around user preferences for documented accessibility features

DOJ - interim final rule - pushing out compliance date

bbailey: DOJ IFR extending deadlines on WCAG application

GreggVan: I think we should watch the space

3.3.9 Accessible Authentication (Enhanced) - update

<bbailey> Rule leaned on WCAG2ICT heavily

2.4.8 Location

<bbailey> Its an opportunity for comment

Link to issue: w3c/wcag2ict#550

PhilDay: Three separate proposals. 1, applies as written. 2, problematic to apply because ... , 3, Gregg's original language

Proposal 1: applies as written with substitutions

Applying SC 2.4.8 Location to non-web documents and non-web software

This applies directly as written, and as described in Intent from Understanding Success Criterion 2.4.8, replacing “set of Web pages” with “set of documents” or "set of software programs".

With these substitutions, it would read:

(for non-web documents)

Information about the user's location within a set of documents is available.

(for software programs)

Information about the user's location within a set of software programs is available.

NOTE 1 (Added)

See set of documents and set of software programs in the Key Terms section to determine when a group of documents or software programs is considered a set for this success criterion. (Sets of software that meet this definition appear to be extremely rare.) Those implementing this document (WCAG2ICT) will need to consider if this success criterion

is appropriate to apply to non-web documents and non-web software. See the Interpretation of Web Terminology in a Non-web Context.

NOTE 2 (Added)

The accessibility barrier this SC addresses for websites is extremely unlikely in the context of non-web documents and non-web software.

Note 2 (Added)

See also the Comments on Closed Functionality.

SC Problematic for Closed Functionality

2.4.8 Location — The WCAG2ICT interpretation of this success criterion replaces "sets of Web pages" with "sets of software programs" which are extremely rare - especially for non-web software on ICT with closed functionality. However, allowing the user to know their location in a complex non-web document or software is generally considered best

practice.

Proposal 2: problematic to apply, explain why

Phil note - I think this one needs more work

Applying SC 2.4.8 Location to non-web documents

This success criterion is problematic to apply directly to non-web documents through simple word substitution because

sets of non-web documents are rare. Instead, sets of web pages would be more equivalent to pages in a non-web document than a set of non-web documents - and page numbers are provided for almost any document viewer by default.

Providing page numbers or some other mechanism for the user to identify their location within a document would address the user needs identified in the Intent from Understanding Success Criterion 2.4.8 and is recommended as best practice.

The following criterion is recommended as a substitute for the WCAG language:

2.4.8 Non-Web Document Location

In non-web documents implemented in a format that supports a programmatically determinable property (such as a page number) that the user can use it identify their location within a document, the non-web document uses such a property to describe the user's location within a non-web document.

Applying SC 2.4.8 Location to non-web software

This success criterion is problematic to apply directly to non-web software through simple word substitution because sets of non-web software are extremely rare. In addition, the title of the software programs in a set would be obvious from window titles or other means; these are already covered by other SCs such as 2.4.2 Page Titled

Proposal 3: does not apply -Gregg's original language

Applying SC 2.4.8 Location to non-web documents and non-web software

This should not be applied as written to non-web documents or non-web software for the following reasons.

Sets of software are so rare and the title of the software programs in a set would be obvious from window titles or other means.

Sets of web pages would be more equivalent to pages in a non-web document than a set of non-web documents - and page numbers are provided for almost any document viewer by default.

Please refer to the Intent from Understanding Success Criterion 2.4.8 for more guidance on how this is interpreted in a web context.

Link to specific point in issue: w3c/wcag2ict#550 (comment)

GreggVan: A webapp is on one url. Set of pages mean to be treated as a thing together, which is similar to a web appin one url
… In non-web documents it couldd be a document or a software program
… It could be within a software program

<bbailey> https://www.w3.org/WAI/WCAG22/Understanding/location#techniques

GreggVan: I wonder if we want to get into details instead of applying generic word substitutions

PhilDay: Pointing to ways you can find your location is helpful

<Zakim> bbailey, you wanted to plus one gregg

bbailey: I read the undersanding documents using "set of documents" and it falls apart
… for PDF techniques are referencing chapters

Daniel: if we are going to explain the details - page shouldn't be the only way - location can be provided through context/sections and other methods as well page numbers

Daniel: Pages is not the only way to indicate location -- chapter and other sections are too

GreggVan: The provisions in web point to a document or a software, because it is unclear what a web of pages is
… Sets of pages should be swapped out for simply document or software

POLL: Which approach do you prefer? Answer 1 for proposal 1 - applies as written, 2 for proposal 2 (problematic to ) and 3 (does not apply)

GreggVan: We should look at all other "sets of" if we are doing this
… They have the same problem and this should solve it for them

POLL: Which approach do you prefer? Answer 1 for proposal 1 - applies as written, 2 for proposal 2 (problematic to ) and 3 (does not apply), 4 for changing language so documents or software (instead of set of documents or set of software)

<bbailey> 4

<GreggVan> 4

Daniel: 4

Consensus: apply to non-web documents and non-web software instead of sets of (non-web documents or non-web software).

PhilDay: I think I'll reword something with the language "problematic to apply"

GreggVan: It wouldn't be problematic if you do that. Problematic is to not have it to be bound to "document" or "software"

ACTION: Phil to write up a proposal that applies to non-web documents and non-web software (not sets of). Then add some notes.

GreggVan: EN 301 549 has followed WCAG2ICT closely. It's now in its final stages, but a second vote is needed. So it's open again

GreggVan: If we are going to make changes to "sets of" we will have to do it now - not in a couple of weeks.

<bbailey> +1 to revisiting other "sets of" SC after we square 2.4.8 up

Daniel: Agree with the approach to fixing it now if we can.

Daniel: First thing - need to be clear if the WCAG2ICT group is happy to work on this. Previously we were concerned that definitions like views were still in a state of flux

GreggVan: There was pressure previously to demonstrate that word substitution can be used - now we have more scope to make changes.

Daniel: We would also need review by AG WG.

POLL: Are you happy for WCAG2ICT to revisit all sets of SCs, and modify the language to say that it applies to non-web documents or non-web software (instead of sets of either)? Answer Yes or No (or Abstain)

bbailey: Do we have a quick list of "sets of"? I think we couldd do it in 10 minutes if we have a list

Set of: 2.4.5, 2.4.8, 3.2.3, 3.2.4, 3.2.6,

GreggVan: These would be 2.4.5, 2.4.8, 3.2.3, 3.2.4, 3.2.6

Set of: 2.4.1, 2.4.5, 2.4.8, 3.2.3, 3.2.4, 3.2.6,

Set of: 2.4.5, 2.4.8, 3.2.3, 3.2.4, 3.2.6,

2.4.5 Multiple ways: latest guidance: https://w3c.github.io/wcag2ict/#applying-sc-2-4-5-multiple-ways-to-non-web-documents-and-non-web-software

<Zakim> bbailey, you wanted to discuss another list from 508...

<bbailey> https://www.access-board.gov/ict/#E207.2

bbailey: In 508 we have a listing of the onesproblematic for non-web software

Section 508 had this list: Non-Web software shall not be required to conform to the following four Success Criteria in WCAG 2.0: 2.4.1 Bypass Blocks; 2.4.5 Multiple Ways; 3.2.3 Consistent Navigation; and 3.2.4 Consistent Identification.

<bbailey> Non-Web software shall not be required to conform to the following four Success Criteria in WCAG 2.0: 2.4.1 Bypass Blocks; 2.4.5 Multiple Ways; 3.2.3 Consistent Navigation; and 3.2.4 Consistent Identification.

PhilDay: Consistent Help is new since 2.0, that's why it's not in the list

3.2.3: consistent navigation: https://w3c.github.io/wcag2ict/#consistent-navigation

3.2.4: consistent identification: https://w3c.github.io/wcag2ict/#consistent-identification

2.4.1: https://w3c.github.io/wcag2ict/#bypass-blocks

<bbailey> https://www.access-board.gov/ict/#E207-software

To apply these "sets of" SCs to non-web software directly, we may have to use the new WCAG3 term "views" to explain

GreggVan: We don't know how to apply to non-web software without using the term "view" - which is still not formally defined. It is still being worked on as part of WCAG3.

GreggVan: We'd have to use the word"view" adopting a definition of view. We have not power to do that in the context of WCAG

<bbailey> FWIW, 508 also excluded those four SC from non-web documents.

<bbailey> https://www.access-board.gov/ict/#E205.4

So unfortunately we cannot easily fix this in the other sets of SCs

So going back to 2.4.8 location

Do we want to apply to sets of non-web documents or non-web software? Or just apply to docs & software?

GreggVan: Wondering if weshould break consistency in 2.4.8

Daniel: This would be a nice segue looking at what we may be able to do in the future with "view"

bbailey: Suggest we make 2.4.8 consistent with 3.2.3, 3.2.4, 3.2.6

bbailey: I'd propose to make this one consistent with what wehave in the others

<bbailey> Make 2.4.8 consistent with phrasing we used for 3.2.3 and 3.2.4

GreggVan: We could do what we did in 3.2.3 and 3.2.4

So copy approach in 3.2.3 and 3.2.4 - applies with word substitutions, and add notes to say it is rare / problematic

Proposal 1: applies as written with substitutions

Applying SC 2.4.8 Location to non-web documents and non-web software

This applies directly as written, and as described in Intent from Understanding Success Criterion 2.4.8, replacing “set of Web pages” with “set of documents” or "set of software programs".

With these substitutions, it would read:

(for non-web documents)

Information about the user's location within a set of documents is available.

(for software programs)

Information about the user's location within a set of software programs is available.

NOTE 1 (Added)

See set of documents and set of software programs in the Key Terms section to determine when a group of documents or software programs is considered a set for this success criterion. (Sets of software that meet this definition appear to be extremely rare.) Those implementing this document (WCAG2ICT) will need to consider if this success criterion

is appropriate to apply to non-web documents and non-web software. See the Interpretation of Web Terminology in a Non-web Context.

NOTE 2 (Added)

The accessibility barrier this SC addresses for websites is extremely unlikely in the context of non-web documents and non-web software.

Note 2 (Added)

See also the Comments on Closed Functionality.

SC Problematic for Closed Functionality

2.4.8 Location — The WCAG2ICT interpretation of this success criterion replaces "sets of Web pages" with "sets of software programs" which are extremely rare - especially for non-web software on ICT with closed functionality. However, allowing the user to know their location in a complex non-web document or software is generally considered best

practice.

PhilDay: I think proposal 1 is the closest we have

bbailey: Is that the same word substitution that we have in 3.2.3 and 3.2.4?

PhilDay: word substitution was taken from 2.4.1

GreggVan: I'd suggest you make adecision here and then you make this one look like the others

DRAFT RESOLUTION: Use proposal 1 as the basis for 2.4.8 Location, but make it consistent with the word substitutions in 3.2.3 and 3.2.4 for consistency. Editors to make final changes to the body of the text.

PhilDay: I'll check how 2.4.1 and 3.2.3/3.2.4 handle this
… 2.4.1 has multiple in it, so that might be the difference

<Daniel> +1

<GreggVan> +_1

<GreggVan> +1

<Laura> +1

<bbailey> -1

<PhilDay> +1

bbailey: I think the word substitution for 2.4.1 works, I think the one on 3.2.3 might also work. I would like to see these side by side

bbailey: would like to see both approaches - how it looks to be consistent with 2.4.1, and how it looks to be consistent with 3.2.3.

ACTION: PhilDay to update 2.4.8 issue with 2 proposals -showing the 2 word substitutions (2.4.1 and 3.2.3).

GreggVan: IF we are doing it off of "sets of" we should be doing it off of 3.2.3/3.2.4

PhilDay: I did the work based on 2.4.1, now I'll do the work based on 3.2.3/3.2.4 so that Bruce and others can double check it

ACTION: PhilDay to then email Bruce to review the 2 different word sub styles on 2.4.8 before then creating the PR

2.4.9 Link Purpose (Link Only)

Link to issue: w3c/wcag2ict#551

Applying SC 2.4.9 Link Purpose (Link Only) to non-web documents and non-web software

This applies directly as written, and as described in Intent from Understanding Success Criterion 2.4.9.

NOTE (added)

In non-web documents or non-web software, a “link” is any user interface control that behaves like a hypertext link.

NOTE (added) (non-web software)

See also the Comments on Closed Functionality.

And in SC problematic for closed:

2.4.9 Link Purpose (Link Only) — This success criterion relies upon text and context being made available in a programmatically determinable form.

PhilDay: Proposing "applies as written" with note defining the link and pointing to comments on closed functionality

<GreggVan> +1

<bbailey> +1

DRAFT RESOLUTION: For 2.4.9 Link Purpose (Link Only) incorporate proposal into the editor’s draft, as is

<Daniel> +1

<Laura> +1

<bbailey> +1

<GreggVan> +1

RESOLUTION: For 2.4.9 Link Purpose (Link Only) incorporate proposal into the editor’s draft, as is

2.4.10 Section Headings

Link to issue: w3c/wcag2ict#552

Applying SC 2.4.10 Section Headings to non-web documents and non-web software

This applies directly as written, and as described in Intent from Understanding Success Criterion 2.4.10.

NOTE 1

(repeating note from SC - may be needed as code that pulls in WCAG SC is only in the comments on A & AA section?)

This success criterion covers sections within writing, not user interface components. User interface components are covered under Success Criterion 4.1.2.

NOTE 2 (ADDED) (FOR NON-WEB SOFTWARE) - derived from 2.4.6

In non-web software, headings and labels are used to describe sections of content and controls respectively. In some cases it may be unclear whether a piece of static text is a heading or a label. But whether treated as a label or a heading, the requirement is the same: that if they are present they describe the topic or purpose of the item(s) they

are associated with.

NOTE 3 (ADDED) (FOR NON-WEB SOFTWARE)

See also the Comments on Closed Functionality.

And for SC problematic for closed functionality:

2.4.10 Section Headings — Requires information in a programmatically determinable form.

And add new glossary term:

section

a self-contained portion of written content that deals with one or more related topics or thoughts

NOTE

A section may consist of one or more paragraphs and include graphics, tables, lists and sub-sections.

PhilDay: Derived this form 2.4.6 andd 4.1.2. Added a single note fro SC pblematic for closed

PhilDay: I thought it might be helpful to repeat the original WCAG note 1

PhilDay: NOTE 1 may not be needed - as it is in the original WCAG text

<Zakim> bbailey, you wanted to ask for reminder about other reference to "section" ?

Daniel: We could add our own note rephrasing the original notes, that's done in other cases I'd say

bbailey: Earlier we found a place where WCAG is using the same word to mean two different things. We flagged this to the group but they decided not to make the correction

PhilDay: I think you're right. We suggested to change "sections" to "regions"

GreggVan: The problem here is it applies to all sorts of things

GreggVan: Suggests not adding a glossary term - and it is complex to be specfiic
… I'd suggest we don't spend the time trying to come up with an adhoc definition

bbailey: Also don't want to add a glossary terms

bbailey: I don't want to add a glossary term

PhilDay: I propose that we just remove it. Do people want to keep note1 in?

GreggVan: We don't need it if it's already in the SC

Remove NOTE 1 - as it will be pulled in automatically

PhilDay: Note 1 is a repetition.

DRAFT RESOLUTION: For 2.4.10 Section Headings incorporate proposal into the editor’s draft, with edits shown in the meeting minutes above (remove note 1, don't add glossary term)

<GreggVan> +1

<bbailey> +1

<PhilDay> +1

<Daniel> +1

bbailey: Just noting that section is already in WCAG 2
… section and region are redundant in WCAG 2

https://github.com/w3c/wcag2ict/issues?q=is%3Aissue%20state%3Aopen%20label%3AAAA%20sort%3Acreated-asc%20no%3Aassignee%20%22Success%20Criterion%22

Summary of action items

  1. Phil to write up a proposal that applies to non-web documents and non-web software (not sets of). Then add some notes.
  2. PhilDay to update 2.4.8 issue with 2 proposals -showing the 2 word substitutions (2.4.1 and 3.2.3).
  3. PhilDay to then email Bruce to review the 2 different word sub styles on 2.4.8 before then creating the PR

Summary of resolutions

  1. For 2.4.9 Link Purpose (Link Only) incorporate proposal into the editor’s draft, as is
Minutes manually created (not a transcript), formatted by scribe.perl version 248 (Mon Oct 27 20:04:16 2025 UTC).

Diagnostics

Succeeded: s/22.4.5/2.4.5

Succeeded: s/for closed functionality/for non-web software/

Succeeded: s/Make 2.2.8 consistent with phrasing we used for 3.2.3 and 3.24/Make 2.4.8 consistent with phrasing we used for 3.2.3 and 3.2.4/

Succeeded: s/realizing/noting/

Maybe present: 2.4.1, 3.2.3, 3.2.4, Consensus, GreggVan, POLL

All speakers: 2.4.1, 3.2.3, 3.2.4, bbailey, Consensus, Daniel, GreggVan, PhilDay, POLL

Active on IRC: bbailey, Daniel, GreggVan, Laura, PhilDay