WebAIM - Web Accessibility In Mind

WCAG 2.0 Last Call Working Draft

WCAG 2.0 has been recommended for Last Call. While this will be the second last call for the document and (by my count) the 13th formal draft since January 2001, the document is currently shaping up rather nicely. The guidelines are available at http://www.w3.org/TR/WCAG20/. You are invited to provide comments by February 1, 2008.

Having been involved in the guideline development process with the Section 508 advisory committee, I can attest that creating accessibility guidelines is very difficult. No guideline will ever be perfect – which is why we should use them as tools, not as an absolute manifesto of truth. There will always be political motivations, implementation problems, and people that just can’t agree on what the guidelines should do. Despite the inherent problems with the development process, I am encouraged by the current state of the guidelines.

Most of my previous concerns about the May 2007 draft have been addressed. Here are a few specific comments:

Alternate versions

One of the issues with the May draft was how to provide access to an accessible alternative to inaccessible content. If you create an inaccessible Flash movie and an accessible HTML alternative, how does somebody find the accessible alternative if they are directed (via a link or search engine result, for example) to the inaccessible Flash movie?

There really is not a perfect solution to this problem. WCAG 2.0 now requires:

  1. the conforming version can be reached from the non-conforming page via an accessibility supported mechanism, or
  2. the non-conforming version can only be reached from the conforming version, or
  3. the non-conforming version can only be reached from a conforming page that also provides a mechanism to reach the conforming version

If one of these is provided, adequate access to the alternative version should be available.

Link context

WCAG 2.0 now requires at Level A:

2.4.4 – The purpose of each link can be determined from the link text alone, or from the link text together with its programmatically determined link context, except where the purpose of the link would be ambiguous to users in general.

While I’m not on WCAG, I am a bit proud of the fact that they accepted my language recommendation. 🙂

This means that link labels must make sense by themselves or in their programmatically determined context. So links such as “more…” or “click here” are not typically allowed. But if these links were in a table with headings that provided a programmatic context, then they would be allowed.

But what exactly is ‘programmatically determined link context’? Table headers can clearly provide this context. But what about the word before and after? The surrounding sentence? The sentence previous? The title attribute for the link? All of these COULD be determined programmatically (though some would be rather difficult), but the likelihood of them being available to A.T. in a way that would be useful makes this allowance a bit troublesome. It seems that there needs to be some distinction between contexts that could conceivably be determined and those that functionally and logically would actually work.

Of note, at Level AAA (2.4.9) the link must make sense by itself.


I’m still a bit dismayed by the fact that transcripts for multimedia remain at Level AAA. Captions are required at Level A. So are audio descriptions OR textual descriptions for blind users. Captions for live media are required at Level AA. Yet the working group does not seem to understand that transcripts often provide BETTER accessibility than captions for those who are deaf, deaf-blind, have certain cognitive disabilities, or are non-native speakers, in addition to screen reader users and those using print/braille output, etc. Transcripts are the ONLY mechanism by which media can be made accessible to the deaf-blind and some other disabilities.

I voiced this concern with the previous draft and my concern remains. If the working group truly evaluated success criteria levels based upon their own considerations of whether it is essential for access, possible to implement and reasonably achievable (certainly transcripts are much easier to provide than captions, audio description, and sign language), does not impact look, feel, or functionality (again, captions carry a bigger impact than a link to a transcript), and that no alternative is available for providing access (there is none for the deaf-blind), then transcripts MUST be assigned to at least level AA. I fear that with transcripts assigned a AAA level that many users will not be provided reasonable access to multimedia.

Well, these are the things I’ve noticed so far. I imagine there will be other things I’ll discover as I dig deeper into the document. I will post them later. I invite you to post your comments here and if they are relevant, be sure to send them to the working group.


  1. Joe Clark

    does not impact look, feel, or functionality (again, captions carry a bigger impact than a link to a transcript),

    Yeah, because they’re visible (QED). Closed captions can be turned off. Separate open- and uncaptioned streams preserve precious look and feel.

    and that no alternative is available for providing access (there is none for the deaf-blind)

    The use of transcripts as a claimed accessibility method for moving pictures is completely hypothetical and untested, and, if you think about it, ridiculous on its face.

  2. Chad

    Regarding the molti media content.
    I think it’s a tricky area, what about sites such as YouTube that provide user generated content which is mainly video?
    It would be harder to make that accessible.