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WAI: Strategies, guidelines, resources to make the Web accessible to people with disabilities

W3C Workshop Report:
Referencing and Applying WCAG 2.0 in Different Contexts
W3C Workshop, 23 May 2013, Brussels, Belgium

Workshop Sponsors

This Workshop is organized through the EC-funded WAI-ACT Project
EU FlagSeventh Framework Programme logo

Additional sponsors include:

Executive Summary

W3C Web Accessibility Initiative (WAI) invited policy-makers, users, developers, accessibility experts, researchers, and others with interest in adopting, referencing, and applying WCAG 2.0 to share their experiences in using Web Content Accessibility Guidelines (WCAG) 2.0 and its supporting resources in different policy settings and contexts. The W3C Workshop brought together over 40 participants from Europe and around the world to explore approaches for:

Throughout the workshop, WCAG 2.0 was generally identified as a suitable web accessibility standard for organizations and governments. Its layered approach, which includes the normative technical standard and non-normative supporting resources, provides a robust framework that is forward compatible with newer web technologies such as HTML5 and, as well as in particular contexts such as mobile websites and applications. A number of governments already adopted WCAG 2.0 or are currently in the process of adopting WCAG 2.0 as the standard for web accessibility. However, some governments have chosen to require the use of the non-normative supporting resources thus make them normative, limit the use of certain web technologies, or otherwise add interpretations and constraints to WCAG 2.0. This poses fragmentation concerns despite growing harmonization around the WCAG 2.0 core requirements.

Three key items were frequently raised from different perspectives in discussions throughout the day:

  1. The need for awareness raising and training for everyone involved and responsible throughout the design process. This includes but is not limited to policy and decision makers, designers and developers, website owners and managers, and trainers and educators, as well as end users. In particular, skills and capacity building for designers and developers was seen to be particularly important. There is also a need to integrate accessibility as a natural part of the process and to better communicate its impact on people with disabilities, as well as its broader benefits for all.
  2. The need for authoritative technical guidance on implementing WCAG 2.0 in specific contexts and web technologies. This includes more publicly documented techniques and failures to meet WCAG 2.0 requirements, in particular for newer web technologies such as HTML5 and, and in specific contexts such as mobile websites and applications. Also more clarity and guidance on the level of support for accessibility features provided by web browsers and assistive technologies is needed for more effective and efficient implementation of WCAG 2.0 in practice.
  3. The need for authoritative guidance on website conformance evaluation. This includes additional guidance for evaluating specific WCAG 2.0 requirements, and specifically those that are prone to different interpretations, as well as guidance on approaches for scaled conformance ratings to help measure progress and to accommodate variances among different evaluators. In particular, some participants claimed that absolute conformance at a given level for an entire website is not always practically achievable, and that a scaled conformance rating scheme would be better.

W3C/WAI is actively addressing many of the issues raised, and made adjustments in its priorities according to the input received and observations made during this workshop. W3C/WAI activities include on-going and dedicated efforts to develop more authoritative guidance for the broad range of audiences involved in web accessibility, and to provide technical clarifications to promote international harmonization of web accessibility standards. W3C/WAI welcomes collaboration and contribution to the development of these resources that are developed collaboratively and provided on a royalty-free basis for use by everyone.

Workshop Discussion

The workshop was organized in three main sessions. Each session was moderated by a session chair and initiated by a panel discussion before inviting further discussion with all attendees. The sessions were:

Session I: Implementation Challenges

Session description: This session focused on the key factors that contribute to successful implementation of web accessibility and the challenges in implementation. This includes questions such as:

Session chair: Dominique Burger, Association BrailleNet

Kick-Off Statement: Elin Emsheimer, EC DG Connect


Session Summary:

Throughout the discussion, different participants pointed out that many policy targets for implementing web accessibility were not met within individual EU Member States and across the EU. Some asserted that while there are policy commitments to web accessibility in many EU Member States, these policies are often not enforced in practice. They suggested that more binding EU policies are needed, as well as bodies that are responsible for monitoring and enforcing these policy implementations across the EU.

In other discussion it was suggested that raising awareness and increasing training are critical to help make web accessibility more tangible and easier to understand. This includes policy and decision makers who have significant responsibility in web accessibility implementation. It also includes the designers, developers, and all others involved throughout the design and development process. In particular, web designers and developers require more advanced skills to master the web technologies as they evolve and become increasingly complex. For example, mobile websites and applications, and websites with rich, multimedia, and interactive content offer increased opportunities for many people with and without disabilities. Yet realizing these opportunities requires more advanced skills if one is to create websites with adequate quality. At the same time, many web accessibility barriers are caused by basic design and coding flaws that could be avoided with appropriate awareness raising and increased training.

Several participants identified policies to be a primary contributing factor to drive the implementation of web accessibility. Some argued that policies need to be more focused on the end user experience than on the technical requirements. For example, in a recent MeAC study[12], it was observed that the policies which insert the technical requirements in their text, as opposed to referencing the accessibility standards, tend to get outdated more quickly due to the continual evolution of the technologies and the standards. This creates a tension for developers who are required to meet outdated policy requirements and current end user needs. Participants argued that such policies tend to put more emphasis on meeting the technical requirements than on inclusive design and development processes with broader benefits for everyone.

Generally, participants argued that web accessibility needs to be embedded as a part of the usual design and development processes and accompanied by usability testing that involves people with disabilities. They asserted that organizations and businesses are more likely to benefit from focusing on accessibility as an improvement of the user experience and website quality, with WCAG 2.0 as a tool to achieve this goal, than from focusing on meeting the requirements without adequate understanding of their purpose.

Other factors that participants raised as contributing to successful implementation of web accessibility included: an active presence of engaged disability and advocacy organizations; promotional campaigns and awareness raising; an active market including non-profit and commercial consultancies, assistive technology developers, and other service providers; and the presence of "accessibility champions".

Some of the challenges to the implementation of web accessibility were also raised. These include the difficulty of meeting accessibility requirements that demand high effort to implement in a timely manner, especially for smaller organizations. For instance, providing captions and audio descriptions, and retrofitting large volumes of legacy content – in particular PDF documents – were given as examples.

Some participants argued that it is sometimes not feasible to meet all accessibility requirements for all the content of a website. Some argued that some accessibility requirements have certain subjective elements due to their qualitative nature, so that it is hard to achieve absolute inter-rater reliability. Some asserted that scaled conformance rating schemes would help address these challenges because they would help indicate the level and progress of a website towards conformance with a standard such as WCAG 2.0 in a more granular way, and that they would better accommodate variances in the ratings from different evaluators.

Session II: International Harmonization

Session description: This session focused on the strategies and challenges in pursuing internationally harmonized uptake of web accessibility standards. This includes questions such as:

Session chair: Donal Rice, Centre for Excellence in Universal Design, NDA


Session Summary:

Discussion in this session confirmed that WCAG 2.0 has been adopted by a number of countries around the world, such as by Australia and Canada; by individual EU Member States such as Germany, Ireland, and The Netherlands; and by the European Commission (EC). In the US, the latest ANPRM[11] published by the Access Board for the updated Section 508[10] standards references WCAG 2.0 for web content.

Participants explained the importance of international standards harmonization for a variety of reasons. One reason suggested by the US Access Board is to provide global solutions in an increasingly globalized market. Another reason suggested by Logius of The Netherlands is that, for them, pursuing consensus around accessibility requirements outside the established standards bodies was too difficult, and reusing existing standards and solutions was more efficient than to redevelop them locally. Discussion reaffirmed that WCAG 2.0 provides a robust framework, yet one that provides sufficient flexibility to address the continual evolution of web technologies. Examples that underscore this stability include the continued applicability of WCAG 2.0 to HTML5 and, which did not exist at the time of its publication, and the applicability of WCAG 2.0 to recently and widely deployed mobile websites and applications.

Discussion also suggested that this clarity of the WCAG 2.0 requirements combined with its flexibility to evolving technologies is an important requirement for accessibility policies. For example, due to this robustness and flexibility, WCAG 2.0 is being applied to contexts outside the Web, such as to documents and software in the Section 508 ANPRM[11] and in EN 301 549 (EC Mandate 376)[7]. The non-normative W3C/WAI document on "Applying WCAG 2.0 to Non-Web ICT (WCAG2ICT)"[5] facilitates this uptake.

Discussion also identified challenges in achieving international harmonization. In particular, participants pointed out that accessibility standards need to be compatible with the policy and legal frameworks that are applicable in different countries. The participants explained that accessibility policies can be vertical – applicable to certain sectors and domains, such as the proposed EC Directive on Web Accessibility[8] that is primarily applicable to public sector websites – as well as horizontal – applicable across the different sectors and domains such as the planned EU Accessibility Act[9]. Accessibility standards need to apply to these different types of contexts and are, ideally, separated from policy and regulatory legislation.

Participants also pointed out the continued need for open and freely available web standards to facilitate harmonization and uniform web accessibility implementation, including for assistive technologies. Others pointed out the need for more documentation and guidance on web accessibility implementation in general, and on evaluation in particular, to facilitate more uniform uptake of WCAG 2.0 internationally.

Specifically, some participants claimed that some accessibility requirements have an inherent degree of subjectivity that leads to different evaluation practices. Indeed, there are different evaluation schemes being used in different countries and organizations, which is a source of fragmentation. In particular, some participants argued that absolute conformance at a given level is not always feasible, and that this has led to the development of scaled conformance rating schemes by evaluation service providers.

The discussion reaffirmed the need for an authoritative web accessibility evaluation methodology, and possibly a normative one from W3C, that is closely aligned with WCAG 2.0, to address these issues and to facilitate international harmonization.

Session III: Application of WCAG 2.0

Session description: This session focused on the role of the WCAG 2.0 technical standard, its supporting documents, and accompanying WAI Guidelines. This includes questions such as:

Session chair: Joshue O'Connor, NCBI Centre For Inclusive Technology


Session Summary:

Discussion showed why the international WCAG 2.0 technical standard is a suitable convergence target for local policies. This normative standard is supported by further non-normative resources including:

Discussion indicated that this layered approach makes the technical standard forward compatible for new web technologies that are critical for web accessibility, such as HTML5 and. However, participants pointed out the need for more publicly documented techniques, including common failures. These are essential for developers and evaluators alike, as they document agreed on practices for applying WCAG 2.0 and for avoiding mistakes in specific web technologies.

Discussion also indicated disagreement on the role of these non-normative techniques, including failures, in web accessibility policies. For example, the Government of Canada Web Accessibility Standard[16] normatively requires the use of the techniques and failures provided by W3C/WAI. It was explained that this is primarily done to ensure consistency in applying and evaluating accessibility across the many different government websites and departments. Also the national standard on web accessibility in Spain, UNE 139803[14], normatively recommends the use of techniques and requires the avoidance of failures documented by W3C/WAI for similar reasons. Other participants raised concerns about these practices.

Participants who disagreed with elevating the non-normative techniques and failures to a normative level in local standards and policies were concerned that such normative definition of technology-specific ways for meeting the standard contradicts the intended design of WCAG 2.0 and could constrain developers and evaluators. In particular, they were concerned that the developers might not be able to use new web technologies as they become available but lack publicly documented techniques, even though these new technologies could provide additional support for accessibility. Participants were also concerned that such policies may require developers and evaluators to use techniques and failures that have become outdated due to changes in web technologies because policies have not yet been updated to reflect these changes.

At the time of this workshop, techniques and failures were updated on a yearly basis by the WAI WCAG Working Group. While this frequency has been increased to twice a year since, the Working Group only has a limited amount of resources to address all the technologies and situations to which techniques and failures apply. It is exploring more collaborative ways of working with members of the public, such as through the use of GitHub, to facilitate public contribution. In this context it was also pointed out that the techniques and failures do not need to be centrally maintained by W3C/WAI but could, in theory, also be provided by other organizations, such as the web technology vendors and trusted organizations.

Issues relating to accessibility support, which is a key concept of WCAG 2.0, were also discussed. In many cases, new features in web technologies have the potential to improve accessibility for people with disabilities. However, these features are sometimes not consistently supported across web browsers and, in particular, assistive technologies, so that web developers cannot always rely on them in practice. In some situations, end users may also not know about these features or understand how to use them effectively. Participants pointed out that many end users, in particular users with disabilities, might not easily update their software to the latest versions due to a variety of reasons including the lack of skills and the cost of some assistive technologies. Thus developers are in a constant tension between using new technologies and features that improve accessibility, backward compatibility to accommodate older web browsers and assistive technologies, and working around bugs in the plethora of such web software.

Other discussion highlighted some of the resources to support the application of WCAG 2.0 in practice. These include the open web platform testing activities currently being carried out by W3C[17], which also includes testing for accessibility features and accessibility support for these features[19]. In particular, the open and collaborative Test the Web Forward (TTWF)[18] community events that are carried out around the world are suitable venues for public contribution to accessibility testing. Another resource is the Web Experience Toolkit[20] from the Government of Canada that provides reusable components and code.

Furthermore, participants suggested possible ideas to facilitate more uniform application of WCAG 2.0 in practice. These include (1) a common evaluation methodology and reporting template to help compare the progress towards conformance across different websites; (2) training for developers as well as for end users, preferably using videos; (3) more documentation on applying WCAG 2.0 in specific contexts, such as the mobile context, and mapping WCAG 2.0 to the related standards in these particular contexts; (4) more consideration of usability testing of accessibility features while applying WCAG 2.0; (5) better communication of the real impact of accessibility barriers on people with disabilities; (6) incorporating support for accessibility in developer frameworks and libraries, such as jQuery and DoJo; and (7)  the establishment of a profession for accessibility to increase the availability of knowledgeable developers.

Highlights and Conclusions

During the workshop day participants explored different aspects of referencing and applying WCAG 2.0 from a variety of perspectives, and many different points were raised throughout the discussion. Some of these points were specific to a particular part of the discussion while other points reemerged in different parts of the discussion. Overall the discussion reaffirmed that web accessibility has many facets and that its implementation in practice relies on a broad spectrum of responsibilities and efforts. This includes:

Most of the workshop discussion related to these key points. Some of the particular highlights of the workshop discussion and conclusions that could be drawn from them are summarized in this section.

Progress in Web Accessibility Implementation

Several participants reported overall increase in web accessibility implementation, even though the progress is often slower than is hoped for. In some cases the efforts to drive implementation have been on-going for long periods of time, and utilize strategies that are closely tuned to the environment and context of their specific country. Specifically awareness raising, training, monitoring, and policies were identified by participants as some of the primary drivers to advance web accessibility implementation.

Despite these partial advances, the majority of the discussion indicated the need for more effort to make web accessibility implementation a reality. Several studies were referred to during the discussion, all of which indicated that the level of implementation is below the target set in related policy commitments. For example, results from the MeAC study indicate that the level of web accessibility implementation in most European Member States is below the targets set in the Ministerial Declaration of Riga[21] for 2010.

Web Accessibility Policies and Standards

Discussion implied that the existence of policies and legislation is a primary driver for web accessibility implementation, among several other factors that are needed for successful implementation. Some participants called for binding web accessibility requirements because they feel that non-binding requirements are not being sufficiently implemented. Other participants critiqued current policies and legislation that embed the technical requirements, as opposed to referencing them. Participants noted that such practice puts the focus on checking-off the embedded technical requirements rather than on providing an optimal end user experience. It also causes policies and legislation to be outdated more rapidly, thus constrains developers from utilizing the latest web technologies that provide more accessibility features, such as HTML5.

The W3C/WAI recommends referencing the WAI Guidelines (WCAG[2], ATAG[3], and UAAG[4]) rather than embedding them in policies and legislation. W3C/WAI provides permanent web addresses (URLs) to the individual (non-changing) versions of the WAI Guidelines, to ensure persistent referencing. More information is provided in "Referencing and Linking to WAI Guidelines and Technical Documents"[22]. WCAG 2.0 is also available as ISO/IEC 40500, which can be useful in situations where WCAG 2.0 and other W3C documents cannot be referenced directly (or normatively) from policies and legislation.

International Convergence towards WCAG 2.0

Discussion showed that WCAG 2.0 is a suitable convergence target for organizations and governments. Participants reported that many countries adopted WCAG 2.0 or are currently in the process of adopting WCAG 2.0. In some cases these countries had prior web accessibility requirements that were less clearly harmonized with WCAG 1.0, and consequently there was not as much progress as hoped. While updating these local requirements, some governments are making a more deliberate effort for harmonization with WCAG 2.0 for a variety of reasons; for example, to better address an increasingly globalized market (US Access Board) or to save the costs of redevelopment of existing accessibility requirements (Netherlands).

Discussion also showed an emerging potential for a new form of standards fragmentation related to the use of techniques in WCAG 2.0. While techniques are important and useful resources for web developers and accessibility evaluators, they are, by design, non-exclusive, non-exhaustive, and also non-normative. W3C/WAI provides clarification on following techniques and explains the negative consequences of requiring the exclusive use of techniques published by W3C/WAI. The guidance has been updated since this Workshop, also based on observations made during these discussions.

Authoritative Guidance on Web Accessibility

Throughout the discussion participants pointed out the need for more authoritative guidance on applying WCAG 2.0 in different situations and contexts, to raise the skills of the broad range of people involved in web accessibility. This includes policy and decision makers, designers and developers, website owners and managers, trainers and educators, as well as the end users – people with disabilities. On the one hand participants identified the need to make accessibility more tangible and easier to understand for everyone involved, and on the other hand they identified the need for skills and capacity building. This applies to web designers and developers in particular, to help them learn about the accessibility features in advanced web technologies, and enable them to better meet the accessibility needs of people with disabilities.

Applying WCAG 2.0 in Practice

Participants emphasized the need for more authoritative guidance on applying WCAG 2.0 in specific technologies and contexts. This includes more publicly documented techniques and failures to meet WCAG 2.0 for different web technologies such as HTML5 and, and in particular in contexts such as mobile. This also includes more guidance on the support for accessibility features in web browsers and assistive technologies, so that developers have information about what works in practice.

W3C/WAI has on-going dedicated effort to provide publicly documented techniques through the WCAG Working Group. Since this Workshop the frequency of updating and extending these techniques increased from a yearly basis to twice every year. This work is complemented by the recently launched Mobile Accessibility Task Force and the Cognitive and Learning Disabilities Accessibility Task Force, that are each expected to contribute to the development of techniques. W3C/WAI is currently also developing Web Accessibility Tutorials and an Accessibility Support Database through the EC-funded WAI-ACT Project. W3C/WAI welcomes collaboration and contribution, including opportunities for sponsorships.

Conformance Evaluation

Participants equally emphasized the need for more guidance on website conformance evaluation. Several issues were raised, including differences in interpretation of individual WCAG 2.0 Success Criteria among evaluators that lead to diverging evaluation practices and thus divergent results. Some participants also critiqued that absolute conformance to given levels for an entire website is not always achievable. They claimed that a scaled conformance rating scheme is necessary to help measure and communicate the progress, and to improve inter-rater reliability.

W3C/WAI is developing the Website Accessibility Conformance Evaluation Methodology (WCAG-EM) to complement WCAG 2.0 with additional authoritative guidance for web accessibility evaluators. Other efforts include on-going improvement of the guidance provided around WCAG 2.0 Success Criteria in the complementary WCAG 2.0 resources, Techniques for WCAG 2.0 and Understanding WCAG 2.0. Further work, including research exploration of web accessibility metrics, is being pursued by W3C/WAI.


  1. W3C Web Accessibility Initiative (WAI)
  2. W3C/WAI Web Content Accessibility Guidelines (WCAG)
  3. W3C/WAI Authoring Tool Accessibility Guidelines (ATAG)
  4. W3C/WAI User Agent Accessibility Guidelines (UAAG)
  5. W3C/WAI Guidance on Applying WCAG 2.0 to Non-Web Information and Communication Technologies (WCAG2ICT)
  6. European Accessibility Requirements for Public Procurement of Products and Services in the ICT Domain (EC Mandate 376)
  7. Accessibility requirements suitable for public procurement of ICT products and services in Europe (EN 301 549)
  8. Proposed Directive of the European Parliament and of the Council on the accessibility of public sector bodies’ websites
  9. European Accessibility Act
  10. Section 508 Standards for Electronic and Information Technology
  11. Section 508 Standards Advance Notice of Proposed Rulemaking (ANPRM)
  12. Study on Assessing and Promoting e-Accessibility (MeAC)
  13. Twenty-First Century Communications and Video Accessibility Act (CVAA)
  14. Requisitos de accesibilidad para contenidos en la Web (UNE 139803:2012)
  15. Web Accessibility National Transition Strategy of the Government of Australia
  16. Standard on Web Accessibility of the Government of Canada
  17. W3C Web Testing Activity
  18. Test the Web Forward (TTWF)
  19. W3C/WAI Web Accessibility Evaluation and Testing Activities
  20. Web Experience Toolkit (WET) of the Government of Canada
  21. Ministerial Declaration of Riga
  22. Referencing and Linking to WAI Guidelines and Technical Documents