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Re: WCAG 2.2

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From: Steve Green
Date: May 17, 2023 2:09PM

There have been several rewrites including one published today. If there are no more rewrites, WCAG 2.2 could become a Recommendation in three months. That said, I hope that some of the recent changes are reversed, which would delay this further.

SC 2.4.13 (Focus Appearance) was a welcome and very necessary addition in my view, so I was dismayed that it has just been moved to level AAA. I very much hope it will be moved back to AA where it belongs.

The original wording was almost incomprehensible. I wrote a test procedure that covered all the rules and exceptions, and it filled two A4 pages. Depending on the design, it potentially required 6 or more colour measurements and 4 contrast ratio calculations in addition to measuring numerous lengths and widths and calculating areas. That said, it resulted in sensible pass / fail results for all the focus indicator designs I tested.

The new wording is much simpler, but it has some unfortunate consequences. For instance, if the focus indicator is an underline, it now needs to be at least five pixels thick, whereas three pixels would previously have been sufficient. This means that the focus indicators in some design systems, such as https://design-system.service.gov.uk/, would not be conformant. I can't help wonder if this is why the SC has been dropped to level AAA. The level should be determined by user needs, not difficulty of implementation, and on that basis I can't see an argument for it not being level AA.

SC 2.4.11 (Focus Not Obscured (Minimum)) is another welcome addition at level AA. It's easy to understand and to test. It's relatively easy to fix existing websites and we have helped a client apply it to a dropdown menu already.

SC 2.5.8 (Target Size (Minimum)) is more complicated than you might expect, but it's straightforward once you get your head around it.

I haven't had more than a cursory look at the other level A and AA SCs because they will be relevant far less often, but they all look reasonable.

Steve Green
Managing Director
Test Partners Ltd