Challenges with Accessibility Guidelines Conformance and Testing, and Approaches for Mitigating Them

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The Working Draft of Challenges with Accessibility Guidelines Conformance and Testing, and Approaches for Mitigating Them explores challenges that occur in some settings, such as large, highly dynamic websites, including those that aggregate significant amounts of content, when using the page-based conformance of WCAG 2 to verify conformance of websites and web applications.

The purpose of the "Challenges" document is to understand these challenges more holistically, and to explore approaches to mitigating these, so that we can address those challenges more fully in future accessibility guidelines, including WCAG 3.0 now in development. The W3C Accessibility Guidelines Working Group Charter expressly anticipates a new conformance model with WCAG 3.0.

This document also characterizes and catalogs challenges that have arisen with accessibility guidelines conformance during the multi-year research preceding development of the next major revision of W3C accessibility guidelines (WCAG 3.0) , as well as through discussions of conformance taking place in the Silver Task Force subgroup of the W3C Accessibility Guidelines Working Group (AGWG).

A better understanding of the situations in which the WCAG 2 conformance model may be difficult to apply, or to scale, could inform the development of more effective conformance models and testing approaches in the future. We welcome general feedback and feedback on the following questions:

  • Are there additional conformance challenges not described in this document? Examples of challenges that have been suggested, and are not yet discussed in this document, include:
    • Challenges implementing accessibility support in frameworks and design systems that do not support accessibility out of the box
    • Web content authoring tools and content management systems that do not allow users to create accessible pages and sites
    • Limited browser and assistive technology support for making available markup support accessibility
    • Limited W3C markup available to make modern design patterns accessible
    • Decentralization of highly specialized web site production teams
  • Are potentially useful mitigations to these challenges missing from the document?
  • Might any of the proposed mitigation approaches reduce accessibility?
  • Should additional WCAG 2 Success Criteria be listed or clarified in Appendix A?
  • Should additional WCAG 2 Success Criteria be listed in Appendix B with regard to challenges in applying WCAG 2 Success Criteria to non-Web ICT?
  • Given challenges identified in this document, is there a priority order in which you feel they should be addressed, and/or some that you feel are most promising?
  • Do aspects of this document need correction or clarification?
  • Does the document overlook other relevant issues that should be addressed?

To comment, please file a new Issue for each discrete comment in the W3C WCAG GitHub repository. Please put “Challenges:” as the first word of your issue title. It is free to create a GitHub account to file issues. If it’s not feasible to file issues in GitHub, you can send comments in e-mail to (comment archive).

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