What does it mean to be accessible? What determines accessibility compliance for your digital content? Sure, there’s a standard (typically WCAG 2+). But how do you know what level of WCAG conformance is right for you, your organization, and legal expectations?
Accessibility Standards: The Foundation of a Solid Accessibility Strategy
What does it mean for digital content to be accessible? That is, what does it mean for digital content to be usable by those with disabilities?
A strategy to ensure that content like web pages, documents, and other information is accessible to those with disabilities can be complex. Such an effort (as described more fully in a previous commentary, Enabling ADA Compliance at Institutions of Higher Education), generally encompasses several factors, including
- creating a policy for handling electronic and information technology,
- appointing an accessibility coordinator,
- establishing procurement criteria,
- providing a feedback mechanism for concerns,
- performing an audit of existing content,
- remediating content that isn’t accessible, and
- delivering training.
An essential part of an accessibility strategy is establishing how you’re going to determine what it means to be accessible. What will be considered accessible (by both users with disabilities and regulatory entities) will be heavily influenced by the accessibility standard that is used.
Selecting an Accessibility Standard
Multiple standards exist in the United States (the federal government, most individual states, and certain municipalities all have requirements; in addition, institutions of higher education, K-12 schools, and private enterprises have also been held to accessibility standards):
A list of standards that may be applicable include:
- Section 508 of the Rehabilitation Act (a procurement standard for federal agencies that also applies to content created by federal agencies);
- Section 504 of the Rehabilitation Act (which applies to—among others—institutions of higher education that accept federal funds);
- Title II of the American with Disabilities Act (which applies to state and local governments); and
- Title III of the American with Disabilities Act (which applies to public accommodations and commercial facilities).
If you are held to the standards of one of these organizations, the choice is made for you. If you are not, there is a chance that a court will determine the standard for you as part of a court order. OCR Website Accessibility Complaints Hit Schools and Universities and Online Risk Assessment: Does Your Bank Discriminate? are two Microassist accessibility articles that provide good examples of both situations.
To be proactive, choose a reputable standard yourself and begin determining the extent your content meets it, and where you need to improve.
WCAG 2.0: The Most Widely Accepted Accessibility Standard for Digital Environments
Many established standards are aligning themselves with and converging on the World Wide Web Consortium (W3C) international standard for digital content accessibility, Web Content Accessibility Guidelines (WCAG), version 2.0. WCAG 2.0 has also been formalized as standard ISO/IEC 40500:2012.
As of January 2017, WCAG 2.0 has been incorporated into the federal procurement standard Section 508 (For a review of Section 508 and WCAG 2.0, see Section 508 Refresh: How WCAG Impacts Federal Website Accessibility Requirements). It is also the standard to which institutions of higher education are often held in resolution agreements relating to digital accessibility, and courts commonly have held private institutions to WCAG 2.0 when reaching settlements relating to the American with Disabilities Act.
WCAG 2.0 is a robust standard, able to be applied to several different situations, including web pages, documents, electronic presentations, and elearning. It is designed to ensure that content is accessible to those with disabilities relating to vision, hearing, cognition, and mobility.
WCAG 2.0 Conformance Requirements
How do you know if content satisfies the standard? The following five requirements must be met to achieve WCAG 2.0 conformance:
Conformance Level: One of the following levels of conformance is met in full.
- Level A: For Level A conformance (the minimum level of conformance), the Web page satisfies all the Level A Success Criteria, or a conforming alternate version is provided.
- Level AA: For Level AA conformance, the Web page satisfies all the Level A and Level AA Success Criteria, or a Level AA conforming alternate version is provided.
- Level AAA: For Level AAA conformance, the Web page satisfies all the Level A, Level AA and Level AAA Success Criteria, or a Level AAA conforming alternate version is provided.
Full pages: Conformance (and conformance level) is for full Web page(s) only, and cannot be achieved if part of a Web page is excluded.
Complete processes: When a Web page is one of a series of Web pages presenting a process (i.e., a sequence of steps that need to be completed in order to accomplish an activity), all Web pages in the process conform at the specified level or better. (Conformance is not possible at a particular level if any page in the process does not conform at that level or better.)
Only Accessibility-Supported Ways of Using Technologies: Only accessibility-supported ways of using technologies are relied upon to satisfy the success criteria. Any information or functionality that is provided in a way that is not accessibility supported is also available in a way that is accessibility supported. [That is, the methods used to satisfy WCAG requirements are done in such a way that all content is available to people using assistive technology.]
Non-Interference: If technologies are used in a way that is not accessibility supported, or if they are used in a non-conforming way, then they do not block the ability of users to access the rest of the page. In addition, the Web page as a whole continues to meet the conformance requirements under each of the following conditions:
- when any technology that is not relied upon is turned on in a user agent,
- when any technology that is not relied upon is turned off in a user agent, and
- when any technology that is not relied upon is not supported by a user agent
In addition, the following success criteria apply to all content on the page, including content that is not otherwise relied upon to meet conformance, because failure to meet them could interfere with any use of the page:
- 4.2 – Audio Control,
- 1.2 – No Keyboard Trap,
- 3.1 – Three Flashes or Below Threshold, and
- 2.2 – Pause, Stop, Hide.
The first three requirements relate to the level of conformance. (Requirements four and five ensure that technology is able to access the content.) WCAG calls these Level A, Level AA (which encompasses Level A), and Level AAA (which encompasses Levels A and AA).
When WCAG 2.0 is referenced in regulations, resolution agreements, and court orders, the WCAG 2.0 conformance level required is generally Level AA.
WCAG 2.0 Conformance Levels
The different levels of WCAG 2.0 conformance might be summarized this way:
- Level A is the minimum requirements needed for a page to be considered accessible. It includes criteria such as all non-text content (like images) have textual equivalents, that all content is accessible via the keyboard, that all form elements have labels or instructions, and that assistive technologies (like screen readers) can determine what the content is. If a site meets these and other Level A criteria, it will be somewhat accessible to those with disabilities, including people who are using assistive technology, like screen readers.
- Level AA requirements ensure that content achieves a greater degree of accessibility. For example, Level AA criteria require that text and background have a minimum level of contrast, that all content is organized under clear headings and labels, and that navigation is consistent (for example, throughout a website). People with disabilities will have an easier time accessing content that meets Level AA criteria than they would with content that only meets Level A.
- Level AAA includes additional requirements, some of which enhance those established in Level AA criteria (for example, Level AA text must have a contrast ratio of 4.5:1 against the background; level AAA text must have a contrast ratio of 7:1). Other Level AAA criteria add new requirements, such as the need to have a sign language translation for pre-recorded videos, have user data saved when re-authenticating, and have all content at a ninth-grade reading level. Meeting Level AAA requirements creates content that can be used by the greatest number of people with disabilities (at least, as far as WCAG criteria allows).
WCAG 2.0 Success Criteria
The individual requirements in WCAG 2.0 are called success criteria. Each success criterion is assigned to a level. And each success criterion is written to be testable.
As an example, consider WCAG 2.0 Level A success criterion 1.4.1, Use of Color. Use of Color states “color is not used as the only visual means of conveying information, indicating an action, prompting a response, or distinguishing a visual element.” Use of Color is part of the WCAG guideline that content must be “distinguishable,” defined as easier to see and hear.
(The sixty-one success criteria in WCAG 2.0 are grouped under twelve guidelines. The guidelines are organized under four principles—distinguishable is part of the principle Perceivable; the other principles are Operable, Understandable, and Robust. Each principle possesses criteria that are Level A, Level AA, or Level AAA—except Robust, which is so fundamental that its success criteria are both Level A).
It is difficult to test whether it is “easy to see” content. Given an image (for example, a bar chart in which the bars are distinguished from each other using different colors), one person might find it easy to see the distinctions represented by color; another (such as someone who has color blindness) may find it difficult. Two different people, faced with the same question and the same content, and they reach different conclusions. Whether content is “easy to see” cannot be reliably tested.
WCAG breaks down the idea that content needs to be easy to see into several testable “success criteria.” For success criterion 1.4.1, whether or not color is the only visual means of conveying information can be validated without regard to personal opinion. If a green button should be clicked to begin a process, is the button only distinguished by its color? Or does it have something else to differentiate it (such as the word “begin” on the button)? If it only uses color, it fails; if it is using something else in addition to color, it passes.
(It’s important to note that WCAG doesn’t tell you how to satisfy a success criterion. It often provides examples of techniques and sometimes instances of failure. Use of Color might be satisfied by using a text description in addition to color, or other visual cues such as a pattern. By establishing what the outcome needs to be, but not how to get there, WCAG opens itself to new techniques that the original document might not have envisioned.)
The Relationship between WCAG 2.0 Success Criteria and WCAG 2.0 Conformance Levels
Why is a success criterion part of one level and not another?
Factors that determined which criteria are included in which Level include the following:
- Whether the Success Criterion is essential (in other words, if the Success Criterion isn’t met, then even assistive technology can’t make content accessible)
- Whether it is possible to satisfy the Success Criterion for all Web sites and types of content that the Success Criteria would apply to (e.g., different topics, types of content, types of Web technology)
- Whether the Success Criterion requires skills that could reasonably be achieved by the content creators (that is, the knowledge and skill to meet the Success Criteria could be acquired in a week’s training or less)
- Whether the Success Criterion would impose limits on the “look & feel” and/or function of the Web page. (limits on function, presentation, freedom of expression, design or aesthetic that the Success Criteria might place on authors)
- Whether there are no workarounds if the Success Criterion is not met
Level A and Level AA success criteria are achievable with today’s technology, if challenging. For example, one Level A success criterion mandates that videos are captioned. Captioning technology (Level A), for example, is widespread, and even live captioning (Level AA) is regularly used. Minimum contrast requirements, which is a Level AA success criterion, can be checked using numerous tools (WebAIM has a free color contrast checker, as does The Paciello Group). Focus indication, another Level AA success criteria, where the area on a website that has focus is clearly marked, is a routine part of web design.
Other criteria that are part of Level AA, such as consistent navigation and consistent identification apply as much to how a site is conceptualized and organized as they do to the specific programming involved.
Level AAA, on the other hand, can be difficult. Some of the criteria categorized as Level AAA are achievable with reasonable effort. Requirements such as enhanced contrast, low or no background during audio, and no timing on the page may impact design decisions but can be implemented.
Other Level AAA criteria are more challenging. Ensuring that all content on a site doesn’t exceed a ninth-grade reading level can be difficult, depending on the type of content and the audience. Including sign language on all pre-recorded media can be logistically problematic.
Recall that all success criteria for a given level must be met to be able to claim conformance with that level. A site can’t conform to Level AAA unless it meets all applicable success criteria. (In fact, WCAG itself notes that “it is not recommended that Level AAA conformance be required as a general policy for entire sites because it is not possible to satisfy all Level AAA Success Criteria for some content.”)
Choosing the Right Level of WCAG 2.0 Conformance—Should You Aim for ‘A,’ ‘AA,’ or ‘AAA’?
Nine years ago, when WCAG was published as a W3C recommendation, it was difficult to meet Level A success criteria. It was possible, but a challenge. Level A can now be met with little effort.
Level AA can be challenging, but with careful planning and advancements in technology, training, and governance, is also achievable. It is currently the recommended WCAG 2.0 conformance level for most situations.
Fully satisfying all Level AAA criteria is often out of reach. And yet, simply because full WCAG 2.0 conformance isn’t currently required, that doesn’t mean you shouldn’t seek to comply with Level AAA success criteria when you can. This approach can help future-proof your site, both ensuring that the content is more accessible than that which meets Level AA criteria and making it easier to meet Level AAA success criteria, should they be required in the future.
What Next? Learning to Apply WCAG 2.0
Perhaps the best way to learn how to apply WCAG 2.0 is to review the standards themselves. WCAG 2.0 is quite readable, describing what each success criterion is, the intent of the criterion, its benefits, and examples. While WCAG doesn’t prescribe how each criterion must be met, it does provide examples of techniques it considers sufficient to meet the criterion, additional techniques, and occasionally common failures.
Achieve WCAG Level AAA success criteria where you can, but focus on WCAG 2.0 Level AA success criteria (which include Level A criteria), and address the issues needed for your digital content to meet them.
If you would like support in achieving a higher degree of WCAG 2.0 conformance, contact us about our Accessibility Services. From audits to remediation to web and application development to training, we can help.
This article adapted from the March 2018 issue of Mealey’s™ Litigation Report: Cyber Tech & E-Commerce. Mealey’s is a subscription-based information provider and a division of LexisNexis. Copyright © 2018 by Kevin Gumienny. Any commentary or opinions do not reflect the opinions of Microassist or LexisNexis, Mealey’s.
Kevin is Microassist’s Senior Learning Architect. He writes on learning and development topics, including accessible elearning, at our blog, The Learning Dispatch.
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