The Web Content Accessibility Guidelines 2.0 became a W3C Recommendation (code for “finalized specification”) in December 2008. I am proud to have my name listed as a contributor to WCAG 2.0. All of WebAIM’s current clients are working toward WCAG conformance. None of them are seriously considering only the antiquated Section 508, the update of which is perpetually stuck in bureaucratic delay tactics.
While WCAG 2.0 has been used to greatly enhance the accessibility of web content, it is not perfect. Its complexity and rather absurd terminologies, while generally necessary, decrease its approachability (and arguably accessibility) for many people. It is difficult to understand. WebAIM has provided a simplified WCAG checklist to help authors get started and to aid in evaluation of HTML documents. Accessibility and technology continues to evolve, and accessibility guidelines must evolve with them.
After three years of implementing and explaining WCAG 2.0, we have identified areas of the guidelines that could be improved or clarified. For a number of reasons, we are unable to participate formally in W3C processes, and we are unaware of any current plans for a WCAG 2.1 or a WCAG 3.0, so we present here some possible changes and improvements to WCAG 2.0, and items that we hope might help you better understand and implement optimal accessibility.
Remove the CAPTCHA Exception
Success Criterion (SC) 1.1.1 (Non-text Content) allows an exception for CAPTCHA, as long as it is identified as being a CAPTCHA and “alternative forms of CAPTCHA using output modes for different types of sensory perception are provided.” If a site provides both a graphical and an audio CAPTCHA, it passes. This, however, continues to exclude users that are deaf-blind, not to mention the difficulties that all users have with CAPTCHAs.
CAPTCHA has failed. Automated processes can now bypass it faster and more accurately than actual users. WebAIM clients, even those in the highly secure financial services industry, are abandoning CAPTCHA. WCAG should do the same by removing it as an exception, or perhaps allowing graphical and audio CAPTCHA for Level A conformance but prohibiting all CAPTCHA at Level AA.
“Media alternative for text”
Several of WCAG 2.0′s media guidelines include “…except when the media is a media alternative for text and is clearly labeled as such.” This means that text alternatives are not required if the video is an alternative version of the main text content of the same page (for example, a web page with the text of a speech that also presents a video version of that speech). This, however, is often misunderstood to suggest that if a transcript is provided, then captions or audio descriptions are not required. This could perhaps be clarified to indicate that if the main content of the page provides all necessary content of the associated media, then no other requirements (captioning, transcript, etc.) are necessary.
“Alternative for time-based media”
“Alternative for time-based media” is a confusing term for a descriptive transcript – a text transcript of the audio or video that provides all necessary auditory content (such as identifying laughter or an off-screen explosion) and visual content (such as a list of items displayed in the video that are not presented via audio). We simply use “descriptive transcript” instead and have found is much more easily explained and understood. If a user reads the descriptive transcript, they will get all of the necessary content conveyed in the audio or video.
Audio descriptions and transcripts
Synchronized captions are always required for audio/video content at Level A. Additionally, either audio descriptions (auditory presentation of visual content in the video) or a descriptive transcript is required for Level A conformance by Success Criterion (SC) 1.2.3. Either of these meets the needs of users with visual disabilities. If an author provides a descriptive transcript to satisfy SC 1.2.3, then audio descriptions are required in SC 1.2.5 at Level AA. However, if an author provides audio descriptions to satisfy SC 1.2.3, then a descriptive transcript is not required until SC 1.2.8 at Level AAA. This latter case would render the media inaccessible to deaf-blind users at Level AA, because both captions and audio descriptions are inaccessible to these (and many other) users.
This is all compounded by the fact that if the video does not require audio descriptions (meaning all necessary visual content is presented in the audio of the multimedia), then SC 1.2.3 and SC 1.2.5 are satisfied. This means that for such video (e.g., a talking head), the author is not required to provide a descriptive transcript unless they are seeking Level AAA conformance. In other words, if a page contains only audio, it requires a descriptive transcript at Level A. But if you add a talking head video or simply add the audio to some video content, it doesn’t require a descriptive transcript until Level AAA. This surely is a weakness in WCAG 2.0 that should be addressed.
Confusion and limitations of the current guidelines could be addressed by structuring the guidelines as follows based on the media’s characteristics:
- Level A
- Pre-recorded audio only – provide descriptive transcript.
- Pre-recorded video only – provide descriptive transcript or audio description.
- Pre-recorded audio/video:
- Provide synchronized captions.
- If visual content is not presented via audio, provide audio description or a descriptive transcript.
- Level AA
- Pre-recorded audio/video – provide a descriptive transcript.
- Live audio/video – provide synchronized captions.
- Level AAA
- Pre-recorded audio/video – provide audio description, if necessary.
- Pre-recorded audio or audio/video – provide sign language.
- Live audio – provide synchronized captions.
This structuring would require audio descriptions or a transcript at Level A, but only if they are necessary for blind accessibility. At Level AA, all pre-recorded video would require transcripts. At Level AAA, video would require audio descriptions, if they are necessary due to visual-only content.
It is with great hesitation that I recommend moving audio descriptions to Level AAA (in WCAG 1.0, they were Level A). While they are the primary and preferred mechanism for providing multimedia accessibility to users with visual disabilities, one must balance their significant expense and difficultly to generate and the fact that transcripts provide equivalent content and are also accessible to a much broader audience (e.g., deaf-blind). Because a transcript will already have been generated in order to provide captioning, it seems more logical that the emphasis should be placed on providing a nearly universally accessible descriptive transcript, rather than on providing less usable and more burdensome audio descriptions.
Contrast at Level A
White text on a white background is Level A conformant. No contrast requirements are present until SC 1.4.3 at Level AA. Adding a minimal contrast requirement (perhaps 2:1 and 3:1 for large text) at Level A would help address significant readability issues that could be found on Level A conformant sites.
Decrease the 200% Text Resizing Requirement
Users with significant low vision rarely resize text in a browser. If a user requires text that is twice the default size, page zoom or a dedicated screen enlarger is and must be used. Designing modern web interfaces to support 200% text resizing is very difficult. This Level AA success criterion typically poses the most significant burden to our clients (often more so than captioning). We strongly recommend that the text resizing threshold be reduced to 150%, with perhaps a 200% threshold for Level AAA conformance.
UPDATE – 4/27/12
It was pointed out to me that browser zoom is allowable to meet the requirements of this success criteria. This seems very contrary to the normative text which says that “text can be resized…” In short, it’s pretty much impossible to fail this success criteria for HTML content because all major browsers provide adequate zoom functionality. I believe this is a severe deficiency in WCAG 2.0. We know that many users prefer text sizing over page zooming. This adds credence to my recommendation above for a 150% true text resizing requirement.
Clarify Images of Text
Success criterion 1.4.5 requires that if the same visual presentation can be made using text alone, an image is not used to present that text. The possibility of highly stylizing text and page elements with CSS (especially CSS3) begs the question of how one defines “same visual presentation”. For example, a graphical button with rounded corners, a background gradient, and text drop-shadow could be recreated with text and CSS3, but it is not clear if this is required to meet this Level AA success criterion.
While using text is always optimal for accessibility (and for other reasons), Level AA conformance should only require that the graphical text be replaced with true text when readily-available font face styling will suffice. In other words, authors should not be required to implement significant text styling to duplicate the graphical text’s presentation. SC 1.4.9 (Level AAA) already prohibits all presentation of text within images.
Specify Mechanisms to Bypass Blocks
A wide variety of “mechanisms” are available to allow users to bypass blocks of repeated content on web pages. This success criterion would be more meaningful and understandable if it required at least two possible mechanisms, such as:
- a “skip” link
- a consistent heading structure (e.g., main content always begins with an <h1>)
- in-page navigation links
- use of landmark roles
- HTML5 structural elements
“Can Be Programmatically Determined”
WCAG 2.0 uses the phrase “can be programmatically determined” extensively. A wonderful article by Jason Kiss explains this term and its use in WCAG. This term refers to relationships that assistive technologies can make between content and/or markup. WCAG defines it to mean that technologies “can extract and present this information to users in different modalities”, whatever that means.
In most cases, when WCAG 2.0 requires that something “can be programmatically determined”, modern technology can actually do so. But not always.
As an example, if an ambiguous “click here” link is preceded by a descriptive heading, this is allowable at Level A by SC 2.4.4 because the meaning of the link “can be programmatically determined” based on the heading structure. The problem, however, is the word “can”. No modern assistive technology actually implements a method whereby the link is automatically made unambiguous because of this structural relationship. In other words “can be programmatically determined” does not mean “IS programmatically determined”.
This creates a situation where WCAG allows or requires something that does not actually result in any better accessibility. It also presents a situation whereby authors can’t know for sure if their content is actually conformant without knowing if assistive technology CAN do something. And which specific technologies or how many of them must do it before “can” means “can”? This is very akin to WCAG 1.0′s very confusing phrase “until user agents…”.
While supporting documentation attempts to clarify this, it remains a confusing aspect of page conformance. This could perhaps be addressed by more specific details at the success criteria or techniques level that reflect actual assistive technology capabilities, rather than simply suggesting that potential support is sufficient.
Require Keyboard Focus Indicators at Level A
A lack of keyboard focus indicators for navigable page elements – SC 2.4.7 (Level AA) – renders a page nearly entirely inaccessible for the large population of sighted keyboard-only users. This is one of the most significant and pervasive accessibility issues currently on the web (see The Plague of Outline:0). There is no reason why this should not be a Level A requirement.
Remove Parsing Requirement
While the intentions are noble, SC 4.1.1 (Level A), which requires that significant coding validation errors be avoided, has little impact on end-user accessibility and is next to impossible to evaluate. The areas in which coding errors impact accessibility are already sufficiently covered by other success criteria (such as proper form labeling, frame titles, table headers, etc.). I can’t think of a single instance where a significant coding issue would impact assistive technology specifically. The parsing requirement should be removed or perhaps changed to require strict validation at Level AAA.
This is not intended to be a criticism of WCAG 2.0. The web is clearly much more accessible because of these guidelines. As future updates to WCAG are considered, and as authors implement these guidelines today, these recommendations might provide some clarity and guidance, with the hope of making the web more accessible for all users. If you have feedback on these recommendations, or have thoughts of your own on WCAG, please comment below.