Meeting minutes
Introductions
Taking volunteers for 2nd half scribe any time :)
Nicki: Joining for first time
One announcement
Editors are working to publish next version of WCAG 3, targeting end of next week or shortly after
Formal CFC will precede the release.
<Adam> https://
Can check it out in advance at above preview link
Adam: last week we talked about User Generated Content
… Section 5.4 from WCAG 2.x was referenced
… some recognition that 2.x did this well and editors sent a survey to ask about this in WCAG 3
… Also asking about the term for what was called "partial conformance"
… or if "partial non-conformance" is better
<Adam> https://
Survey link above
… Survey open rest of today
… 25 responses now
… pasted temp working file of results above
… second question on naming first
… some point out that partial non-conformance is more accurate
… currently 13 in favor of existing term
<Adam> https://
(reviewing results)
… 4 people prefer partial non-conformance
… 3 something else
… 4 with no opinion
<Charles> note: common use does not mean grammatically correct or understood
<Patrick_H_Lauke> random thought: maybe "conformance exemption"? (though this may suggest that it's exempt and "allowed" by WCAG)
<nattarnoff> This is hypotheticals - not tied to any.
<Zakim> AWK, you wanted to ask Gregg/Bruce/others how "partial conformance" got into WCAG 2
AWK: My question is what I had in there. Gregg and Bruce prefer partial non-conformance. How did we end up with "partial conformance" in WCAG 2? We've been using it for 20 years
Matt: After last week's meeting spent time in section 5
… realized that problems like this hinge on one phrase
… "for a web page to conform"
… everthing in section 5 centers on an entire web page conforming, leading us to this discussion
… thought that one of the goals was to go beyond web pages
… what has been done to date for that, e.g., to apps with no URLs
<Zakim> Rachael, you wanted to react to Matt_King
Matt: Think that we need to answer the questions in reverse
Rachael: Seeing if we can get consensus before rewriting Section 5
… don't want to pull in the rest of section 5 yet
Adam: We did change the intro clause to "products and pages/views"
BB: Reply to AWK. Don't recall. Does feel like natural language. Looked through old versions and it came in during 2007.
GV: Also responding to AWK
<bbailey> Early version of "partial conformance": https://
GV: Discussion deals with what we now call UGC
… we added it but it was put in to handle specific cases.
<bbailey> Current version of partial conformance: https://
GV: We are talking about a policy document now so some things can go into there
GV: In WCAG 2 you need to say what doesn't conform.
… we should be using 'progress toward conformance' as the concept for this
<nattarnoff> +1 to GreggVan
<Zakim> Rachael, you wanted to respond to Gregg
Rachael: (chair hat off) Disagree with GV
<bbailey> FWIW, this draft of WCAG 2.0 does NOT mention partial conformance: https://
Rachael: content with UGC may not ever be able to become more conformant, so progress toward conformance concept may not fit well
GV: conformant means meets minimum accessibility standards
… with UGC if it is not possible then it should not be required
<nattarnoff> With User generated content, we are entering ATAG areas. Where is the overlap?
GV: e.g., Microsoft can't be responsible for every word doc being accessible when created
<Laura_Carlson> +1 to Gregg.
GV: If you create an email app the author of the email is responsible, but the app developer needs to make it possible to do so
… we need to make sure that the policy makers are aware of this issue
<Laura_Carlson> Content outside the author's control may justify an accessibility disclosure, but it should not change the meaning of conformance.
<Finnberry> Is the intention to bring ATAG into WCAG 3.0?
Rachael: (Chair hat off) Because we are defining the ruler, we can include how to measure and make a conformance claim products with user generated content in the conformance and expand on that in policy. Maybe rename this "Claiming conformance when your product includes user generated content"
Matt: Agree with GV and Rachael.
<HaTheo> it worth noting Microsoft is somewhat responsible for content created by Word. They are responsible for creating tools to check for accessibility and notify the users, they are also make sure the tools allow it to be accessible. I also think 5.4 is needed to get a company to declare conformance.
<Azlan> +1 to Matt_King
Matt: if we need to bring some ATAG type provisions into WCAG I would support that
<Charles> the survey did specify outside of author control. but i took it literally as a vocabulary question. if Rachael‘s point of scenario limitation to outside of control applies, then i still think ‘conformance of parts’ solves some of this debate.
Adam: hoping to see if we have agreement in this call, but may be more complex
<JamesH> +1 to Charles
Rachael: Would be good to have a resolution if we can
Matt: not sure how to craft a resolution. Doesn't feel like there is support for bringing in the WCAG 2 section 5.4
… people might just scope their conformance claim to views that don't include UGC
GV: Rachael, understand that UGC is important issue but it is still veering off of our remit
… which is to make content accessible not what it is that needs to be accessible
<Finnberry> If an individual country's legislation requires WCAG conformance, is 'partial conformance' legal or not? Vendors tend to assume it's enough but we see it differently. The term causes much friction. AGC is a different issue, even though it kind of overlaps.
<kirkwood> we used to consider Wix website as user-generated content.
<Laura_Carlson> +1 to Gregg. Deciding how to handle the accessibility of user-generated content, like blog comments, forum posts, or shared documents, is a legal and regulatory issue, not a technical one.
GV: number 2. falls into where you need to apply WCAG and this should be in policy guidance
<kirkwood> 1+1 to GreggVan it1’1s policy
<Laura_Carlson> It should be left entirely to policy makers to define safe harbors, liability, or enforcement rules for public contributions within their specific jurisdictions
GP: Who is conformance for?
… people who want to know about the accessibility of a site, site devs, etc?
<kirkwood> who is responsible? who is the publisher? Who is the author? these are legal questions
GP: it is a matter of scoping
… depending on the context something could be in or out of scope
… in my opinion, if I own a CMS I claim conformance with a whole page except a section that I'm not responsible for
… we just need to make it clear
GV: The purpose of conformance in WCAG
… use regs and standards to make websites more accessible
<kirkwood> good point Gregg!
GV: purpose of traffic laws is to encourage better behavior
<Patrick_H_Lauke> rolling stops for bikes... ;)
GP: not saying conformance is not useful
… it is a matter of scope.
… why can't someone say that their carousel is conforming even if the whole site isn't
<kirkwood> i have built 100s of them! but that was in 1996 ;)
Matt: +1000 to GP
<kirkwood> ;)
Matt: this is primarily on the table because of the ambiguous scoping of WCAG today
… some people think that the only thing you should be able to do is claim conformance for an entire page/site
… we need to figure this out to answer these questions
… not a fan of traffic law analogy as it doesn't fit
GV: The traffic laws aren't a perfect parallel
… we need to look at standards that are required by law for a good comparison
… no one has even been taken to court or had any punishment for having a site that was mostly accessible
<nattarnoff> Moscot v Jones - There were a handful of low impact issues, but the investment on accessibility is what got it tossed.
GV: if there are exceptions and they are in the reg they are part of enforcement
<Jon_Avila> Some of us don't drive, don't have a vehicle and haven't broken traffic laws.
<kirkwood> 1However can be sued if a single page on a critical path is inaccessible. but fully agree with GreggVan
<Finnberry> I think a better analogy is what in the UK is called the MOT. It's an annual test of roadworthiness for vehicles. It tests a variety of 'success criteria' such as brakes, tyre tread depth, etc. If your car doesn't pass, you cannot drive it. It is binary. You can't drive a car with dodgy brakes and claim partial conformance.
Ben: doesn't like analogy either
… if you get seen by the police for messing up you get fined.
<Matt_King> +1 Rachale
<HaTheo> +1 Rachael
<HaTheo> let's discuss the real thing... and not spend time talking about how we do or do not obey traffic laws please :)
<bbailey> nattarnoff can you share a link wrt Moscot v Jones ?
Ben: can partially conform to traffic laws and still drive a car
PL: quick on traffic
… nobody who drives doesn't break laws and nobody needs to make public statements about their driving
<Adam> Draft RESOLUTION: Recommendations on how to claim conformance in different situations such as products with aggregated and user generated content will be handled in supplemental documentation and not the main WCAG document.
Adam: hearing general support for not putting in WCAG
<nattarnoff> bbailey https://
<STEVEF> +1
<Patrick_H_Lauke> +1
<Finnberry> +1
GV: if that is the resolution I can step out of line
<Patrick_H_Lauke> (i thought "step out of line" meant you were going to go wild :) )
<kirkwood> Have we defined user generated content?
AWK: This presupposes that we agree to handle things via the policy document
JonA: What does supplemental mean? Informative?
Adam: AFAIK it would be informative
<Zakim> Rachael, you wanted to respond to AWK
Rachael: Believe that it has been made - it is in the proposed charter
<Zakim> Rachael, you wanted to react to AWK
Rachael: +1 to harmonization
… doesn't' think that normative content for policy is possible
… I defer to Kevin but staff has told us a normative policy related document is not in W3c Scope and getting an OK for an informative policy document took a great deal of time.
GV: I thought it was decided at a previous meeting that we were not allowed to do a normative policy doc
<Jon_Avila> What about a modular approach?
Bernardo: Think that WCAG should focus on what is considered to be accessible
… it is up to the regs to review or audit
… WCAG should provide the guidance
<Laura_Carlson> +1 to Bernardo
<Matt_King> Draft resolution: Requirements related to claiming conformance in products containing user generated content or other content where there is little or no author control will be addressed after the WG is aligned on how to scope conformance claims.
Matt: don't know if this is practical resolution
… really think that this is a scoping issue
<bbailey> Proposed change to draft resolution: Recommendations on how to claim conformance in different situations such as products with aggregated and user generated content will be handled in informative guidance and not the normative WCAG guidelines.
<Patrick_H_Lauke> +1 if scoping would allow for sections (like UGC and third-party/aggregated) to be removed from scope, then the whole discussion would fall by the wayside/be obviated
<Patrick_H_Lauke> "this meeting will self-destruct..."
<bbailey> i like Matt's draft resolution better than mine.
<Patrick_H_Lauke> need to drop now
<Finnberry> The ticking sounds like a bomb may go off!
Adam: Matt proposed draft resolution just before break...
… Draft resolution: Requirements related to claiming conformance in products containing user generated content or other content where there is little or no author control will be addressed after the WG is aligned on how to scope conformance claims.
Adam: My concern is that proposed resolution doesn't push group forward enough.
Adam: I am hearing consensus that we don't want conformance to cover partially conforming material...
Proposed change to draft resolution: Recommendations on how to claim compliance in different situations such as products with aggregated and user generated content will be handled in informative guidance and not the normative WCAG guidelines. We will net explore whether scope can be used to exclude user generated content.
Adam: but we could have some informative policy guidance.
Gregg: I am concerned about scoping being anything less than full page/views...
… It sounds good, but if anything short of full processes and pages and try to scope paths, leaves users without ability to follow up, make returns, etc....
<Charles> permitting a conformance claim scope that omits content outside of author control means the author has to admit explicitly what they cannot control. this seems good for us to have a solution for this scenario. but it seems like we need to know how orgs would use that.
<Zakim> Rachael, you wanted to propose some changes
Gregg: scope needs be something very large, clear whole things. No carve outs.
<GreggVan> +1 to rachael' proposed draft resolution wording
Rachael: I proposed a modification to Matt's resolution. We have something of circular problem because can't talk about a part without knowing the whole context....
… We can discuss scope next to try and get a decision point today.
<Ben_Tillyer> +1 to giacomo-petri regulators can easily see that a checkout is missing from a bad scope claim
<HaTheo> +1 Giacomo, I feel like policy makers can prevent abuse... and they are better suited to do that.
giacomo-petri: Its policy maker to decide what is sufficient scoping to claim compliance. But authors should be able to assert conformance of their components.
GreggVan: The counter argument is from the end-users perspective they need accessibility. We've never supported claims for conformance of components.
<Adam> draft RESOLUTION: Recommendations on how to claim compliance in different situations such as products with aggregated and user generated content will be handled in informative guidance and not the normative WCAG guidelines. We will next discuss scope and whether it can be used to exclude user generated content.
Adam: Please defer scoping conversaion.
<Finnberry> +1
Ben_Tillyer: If we are voting for this to be in external document, what will be in normative text? That one has to meet everything all the time?
Adam: Yes, in the main document. But we have a lot of work to do on conformance model.
Rachael: Agree at the high level. We will have a conformance sub group.
GreggVan: Right, conformance means you meet all the requirements.
Matt_King: Can the resolution then just state what the main document will do?
… Are we making a resolution that the main document won't carve out exceptions for user generated and uncontrolled content?
[adam reads proposed resolution]
Matt_King: strike "in different situations"
<Finnberry> Could the issue of UGC be addressed, not in relation to conformance claims, but rather through the assertions. So organisations could, e.g. state that they train their staff on how to create accessible content?
AWK: Gregg has noted that conformance means you meet all the requirements. I would note that we have not settled level...
… So might a certain level include User Generated Content?
Adam: Good point that moving scoping to informative is not the only way to resolve this.
<nattarnoff> I'm not a fan of levels. It always ends up with clients trying to understand what is "required" to meet.
<Adam> Proposed change to draft resolution: The main WCAG conformance section will focus only on conformance. Exceptions such as how to claim regulatory compliance for products with aggregated and user generated content will be handled in informative guidance and not the normative WCAG guidelines. We will next discuss scope and whether it can be used to exclude user generated content.
GreggVan: Rachael has "compliance" but people will misread that as "compliance to wcag". Please add "compliance to regulations'
GreggVan: How does this work with current definition of conformance?
<Adam> https://
<Adam> “conformance”: satisfying all the requirements of the guidelines
<Adam> “conformance scope”: A set of Views and/or Pages selected to be part of a conformance claim. Where a View or Page is part of a Process, all the Views or Pages in the process must be included.
GreggVan: I was hoping conformance for paths and components. How would this work with definition for scope of conformance.
Rachael: I think scope will still end under conformance. (chair hat off)
Adam: Tweak resolution to not only address informative guidance.
<kirkwood> if the burden is too high (undue), compliance to the law may in some cases, actually conflict with conformance to guidelines.
<Adam> Proposed change to draft resolution: The main WCAG conformance section will focus only on conformance (which includes the definition of a scope conformance claim). Exceptions such as how to claim compliance in different situations (Ex: products with aggregated and user generated content) will be handled in informative guidance and not the normative WCAG guidelines. We will next discuss scope and whether it can be used to exclude user generated
<Adam> content.
GreggVan: Careful with the word "scope" it means many different thing. Could have scope of an SC and scope of the guidelines. Term should be qualified.
[Adam reads proposed draft resolution and then next edit]
The main WCAG conformance section will focus only on conformance (which includes defining conformance scope). Exceptions such as how to claim compliance in different situations (Ex: products with aggregated and user generated content) will be handled in informative guidance and not the normative WCAG guidelines. We will next discuss scope and whether it can be used to exclude user generated content.
<Adam> Proposed change to draft resolution: The main WCAG conformance section will focus only on conformance (which includes the definition of a scope conformance claim). Exceptions such as how to claim compliance for products with aggregated and user generated content will be handled in informative guidance and not the normative WCAG guidelines. We will next discuss scope and whether it can be used to exclude user generated content.
Adam: Add "regulation" to above
<Adam> Proposed change to draft resolution: The main WCAG conformance section will focus only on conformance (which includes the definition of a scoped conformance claim). Exceptions such as how to claim regulatory compliance for products with aggregated and user generated content will be handled in informative guidance and not the normative WCAG guidelines. We will next discuss scope and whether it can be used to exclude user generated content.
Matt_King: By describing the where, missing "author controlled" aspect
<kirkwood> -1 Regulatory compliance is outside our remit
<Adam> Proposed change to draft resolution: The main WCAG conformance section will focus only on conformance (which includes the definition of a scoped conformance claim). Exceptions such as how to claim regulatory compliance for products with content that is not fully within the author’s control will be handled in informative guidance and not the normative WCAG guidelines. We will next discuss scope and whether it can be used to exclude user
<Adam> generated content.
Rachael: We are circling back to earlier proposals.
<Adam> Proposed change to draft resolution: The main WCAG conformance section will focus only on conformance (which includes the definition of a scoped conformance claim). Guidance on how to determine regulatory compliance for products with aggregated and user generated content will be handled in informative guidance and not the normative WCAG guidelines. We will next discuss scope and whether it can be used to exclude user generated content.
GreggVan: Guidance regarding exception rather than recommendations
Adam: One more typo...
<Adam> Proposed change to draft resolution: The main WCAG conformance section will focus only on conformance (which includes the definition of a scoped conformance claim). Guidance on how to determine regulatory compliance for products with content that is not fully within the author’s control will be handled in informative guidance and not the normative WCAG guidelines. We will next discuss scope and whether it can be used to exclude user generated
<Adam> content.
Rachael: I disagree as we have changed the intent of where we started.
… Guidance to regulators is different than how to determine compliance.
<Adam> Proposed change to draft resolution: The main WCAG conformance section will focus only on conformance (which includes the definition of a scoped conformance claim). Recommendations for how to determine regulatory compliance for products with aggregated and user generated content will be handled in informative guidance and not the normative WCAG guidelines. We will next discuss scope and whether it can be used to exclude user generated content.
Matt_King: Recommends for how regulators can . . .
GreggVan: Can or should?
… can is permission
[Adam and Rachael and Matt King discuss change to draft resolution]
<GreggVan> Recommendations to regulators on how they should handle exceptions such for products with a content
Matt_King: The word "exceptions" seems problematic.
<Zakim> GreggVan, you wanted to react to Rachael
<GreggVan> Recommendations to regulators on how they should handle exceptions such for products with a ccontent
<Finnberry> In our legislation, exceptions or exemptions are defined. I think guidance for policy/lawmakers on this would be useful.
GreggVan: Just typo, add "content" -- products with content...
<GreggVan> Recommendations to regulators on how they should handle exceptions for products with ontent
GreggVan: use should not can -- not merely giving permission
… could be "how they should handle content not under authors control"
<GreggVan> Recommendations to regulators on how they should handle products with content ...
<kirkwood> How to handle eceptions: bring in front of your lawyers.
Adam: Consider how regulators should handle content not under authors control?
GreggVan: That can be in separate document.
AWK: Saying we're going to next discuss scope is not a good fit for this resolution...
… don't rush this decision.
Adam: If we get to consensus on first chunk, policy document would cover scope.
<Adam> Proposed change to draft resolution: The main WCAG conformance section will focus only on conformance (which includes the definition of a scoped conformance claim). Recommendations to regulators on how they could consider regulatory compliance for content not fully in the authors control will be handled in informative guidance and not the normative WCAG guidelines.
kirkwood: Discussion of exceptions is scary
GreggVan: Agree the last sentence contradicts intent from first sentence...
<kirkwood> is Wix website user-generated? is an ai website user-generated?
<kirkwood> +1 to Gregg
<Charles> ‘that’s complicated. yup.’ sums up this whole discussion.
GreggVan: some user generated content is actually under author controls because some contributors are paid (behind the scenes) it is impossible for auditor to tell difference.
… similar to situation with ATMs and pointing fingers.
<Matt_King> Proposed change to draft resolution: The main WCAG conformance section will focus only on conformance (which includes the definition of a scoped conformance
<Matt_King> claim). Recommendations to regulators on how they could consider regulatory compliance for content not fully in the authors control will be handled in informative guidance and potentially within specific provisions.
Adam: To giacomo-petri we are not pulling out possibility of addressing user generated consented
giacomo-petri: What if remove only the user generated content. Exclude is not the correct term. It is not only UGC.
<Rachael> +1 to keeping we will next discuss scope
giacomo-petri: I want to keep scope in next steps.
Adam: Could scope resolution be handled next and separately ?
Bernardo_Google: I think we are overcomplicating things a bit. The ambiguity of recommendations to regulators can be open ended...
<kirkwood> good point
Bernardo_Google: we don't have to figure out exceptions at this point. We should be providing that guidance and how to adopt guidance.
<Matt_King> Proposed change to draft resolution: The main WCAG conformance section will focus only on conformance, which includes the definition of a scoped conformance claim. Recommendations to regulators on how they could consider regulatory compliance for content not fully in the authors control will be handled in informative guidance and potentially within specific provisions.
Matt_King: I think my proposal addresses Bernardo_Google concern...
… we can address UGC and level is left open.
<Bernardo_Google> "Recommendations on how to adopt conformance... will be..."
<Finnberry> +1
<Adam> Proposed change to draft resolution: The normative WCAG conformance section will focus only on conformance, which includes the definition of a scoped conformance claim. Recommendations to regulators on how they could consider regulatory compliance for content not fully in the authors control will be handled in informative guidance and potentially within specific provisions.
Ben_Tillyer: Should "normative" be in the first part? ...
<kirkwood> “Focus only on conformance to the guidelines”
Ben_Tillyer: To me this reads that conformance will be guidance and informative will be informative.
Adam: Strongest bit is that resolution speaks to content not under authors control
wendyreid: Agree that latest resolution is pretty solid...
… In 3 we should revisit this fresh. Conversation is very WCAG 2.2 centric. The normative parts will be in ATAG, not WCAG anyway.
<GreggVan> skip me
<Charles> wendyreid how would things outside of author control be covered by authoring tools guidance?
Matt_King: When we talk about complete re-think -- could we not have some ATAG-like provision in WCAG?
<Zakim> wendyreid, you wanted to react to Matt_King
Matt_King: Some provisions requiring users be enabled to create accessible content.
wendyreid: See my comment in survey. When building a product, you follow WCAG and ATAG and use WCAG to evaluate end product...
… but as product owner you can't control what the product user actually does. I think were going to end up to ATAG.
Rachael: We'll come back to this.
<Rachael> +1 to Gregg
GreggVan: Someplace we lost that this separated informative document versus informative section of normative conformance.
Rachael: It may be more than a single document. It may be multiple informative sections.
Matt_King: Separate informative guidance documentation.
[adam reads last proposal]
GreggVan: SHOULD consider not could
Rachael: Last phrase should be dropped.
<kirkwood> I’d prefer to see “conformance to guidelines” saw no implying law
Adam: Its open ended.
GreggVan: I'd like it removed, but if there is informative guidance, not Guidelines
Adam: I changed to a May.
GreggVan: should end with "in WCAG"
Adam: To giacomo-petri do you object to address components later, not having scope in this resolution
<GreggVan> put "WCAG" in front of provisions
giacomo-petri: no objection
Adam: Do we need first sentence?
GreggVan: Need first sentence, add "WCAG"
<Rachael> +1
<GreggVan> +1
DRAFT RESOLUTION: The normative WCAG conformance section will focus only on conformance, which includes the definition of a scoped conformance claim. Recommendations to regulators on how they should consider regulatory compliance for content not fully in the authors control will be handled in informative guidance documentation, and potentially within
specific WCAG provisions.
<AWK> -1 as this is a huge decision when we haven't really defined conformance yet.
<Finnberry> +1
<Matt_King> +1
<JamesH> +1
<GreggVan> +1
<kirkwood> +1
<Azlan> +1
<HaTheo> +1
<filippo-zorzi> +1
<jkatherman> +1
<Charles> 0
<wendyreid> +0
<Ben_Tillyer> -0
<Bernardo_Google> +0
<CClaire> +0
<LenB> +1
<Laura_Carlson> +1
RESOLUTION: The normative WCAG conformance section will focus only on conformance, which includes the definition of a scoped conformance claim. Recommendations to regulators on how they should consider regulatory compliance for content not fully in the authors control will be handled in informative guidance documentation, and potentially within
specific WCAG provisions.