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Number of posts in this thread: 11 (In chronological order)

From: Dr Jonathan Hassell
Date: Fri, Dec 21 2012 4:23AM
Subject: A clear EU accessibility law proposed? At what cost?
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Early this month the European Commission issued a proposal for a directive on “Accessibility of Public Sector Bodies’ Websites”.

This will require twelve categories of EU public-sector websites to comply with W3C’s Web Content Accessibility Guidelines 2.0 at the AA level.

The directive could establish a law centred around a clearer definition of ‘the objective set of criteria for determining what an accessible website looks like’ that many accessibility advocates have been wanting for years.

So what does this proposed directive mean for developers, disabled & older people, and website owners in Europe and beyond?

Is it going to get disabled and older people the benefits they want, without burdening website owners with unreasonable costs that prevent them implementing it?

You can find out more by reading my analysis blog at http://www.hassellinclusion.com/2012/12/clear-eu-accessibility-law/

And let me know what you think here on webaim.

Best regards

Jonathan

--

Prof Jonathan Hassell
Director, Hassell Inclusion

Blog: http://hassellinclusion.com
Twitter: http://twitter.com/jonhassell

From: Jukka K. Korpela
Date: Fri, Dec 21 2012 7:16AM
Subject: Re: A clear EU accessibility law proposed? At what cost?
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2012-12-21 13:23, Dr Jonathan Hassell wrote:

> Early this month the European Commission issued a proposal
> for a directive on “Accessibility of Public Sector Bodies’ Websites”.

It is an interesting idea. It may become much more interesting when the
content of the proposal will be disclosed. What I mean is that the
current wording of the proposal just verbosely says that public websites
must be accessible. As such, this means approximately nothing. It might
be the intention that this will later be made much more exact, such as
requirement on WCAG 2.0 AA compliance.

But it’s a positive step forward that the EU is considering measures to
enforce accessibility requirements, not just issue recommendations that
are routinely ignored by everyone, including the EU’s own web site. This
is something that I talked about six years ago in “Breaking the
barriers: digital accessibility”:
http://www.cs.tut.fi/~jkorpela/www/bb.html

While I share the concerns about all the real-world accessibility issues
that are not covered by WCAG 2.0, I think what changes things is rules
that site owners MUST take seriously. It may be trivial and very modest
to require that all img elements must have alt attributes, and it is
trivially easy to fool automated checkers in such issues (just generate
alt="foo", literally). But still moves like that will force site owners,
designers, and implementors to take some accessibility aspects
seriously. This will be a much stronger "awareness raising" action than
all the recommendations combined.

Yucca

From: Birkir R. Gunnarsson
Date: Fri, Dec 21 2012 8:10AM
Subject: Re: A clear EU accessibility law proposed? At what cost?
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I am writing commentary on this directive on behalf of the European
Blind Union, will be finalizing the draft with their Access to
Information Commission and Carine Marcin.
Thanks for an insightful review dr. Hassel, it could come in handy.

My main points so far:
1. there do not seem to be any consequences of non-compliance.
2. the standard does not cover documents and electronic forms that
often are offerred via these websites (no fault of WCAG per se of
course, it is not designed to be a non-web documents standard, but it
could of course be applied as such, plus there are accessibility
guidelines for PDF and other document types),
3. the directive does not address mobile apps.
4. The directive does not directly address the accessibility of social
media presence of the entities whose websites fall under its
definition. It is at least equally impotant that people can follow the
social media channels of public entities.
5. it does not address the accessibility of external hardware or
software security mechanism (talking number generators, CAPTCHA etc.
though of course WCAG addresses CAPTCHA and can easily be applied to
other types of security mechanisms).
I will be watching this thread with interest to see if there are other
things I should bring up, or something I should write up differently.
Cheers
-B

On 12/21/12, Jukka K. Korpela < = EMAIL ADDRESS REMOVED = > wrote:
> 2012-12-21 13:23, Dr Jonathan Hassell wrote:
>
>> Early this month the European Commission issued a proposal
> > for a directive on “Accessibility of Public Sector Bodies’ Websites”.
>
> It is an interesting idea. It may become much more interesting when the
> content of the proposal will be disclosed. What I mean is that the
> current wording of the proposal just verbosely says that public websites
> must be accessible. As such, this means approximately nothing. It might
> be the intention that this will later be made much more exact, such as
> requirement on WCAG 2.0 AA compliance.
>
> But it’s a positive step forward that the EU is considering measures to
> enforce accessibility requirements, not just issue recommendations that
> are routinely ignored by everyone, including the EU’s own web site. This
> is something that I talked about six years ago in “Breaking the
> barriers: digital accessibility”:
> http://www.cs.tut.fi/~jkorpela/www/bb.html
>
> While I share the concerns about all the real-world accessibility issues
> that are not covered by WCAG 2.0, I think what changes things is rules
> that site owners MUST take seriously. It may be trivial and very modest
> to require that all img elements must have alt attributes, and it is
> trivially easy to fool automated checkers in such issues (just generate
> alt="foo", literally). But still moves like that will force site owners,
> designers, and implementors to take some accessibility aspects
> seriously. This will be a much stronger "awareness raising" action than
> all the recommendations combined.
>
> Yucca
>
>
> > > >

From: Ramón Corominas
Date: Sat, Dec 22 2012 7:30AM
Subject: Re: A clear EU accessibility law proposed? At what cost?
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Hi, Birkir and all,

Birkir wrote:

> 2. the standard does not cover documents and electronic forms that
> often are offerred via these websites (no fault of WCAG per se of
> course, it is not designed to be a non-web documents standard, but it
> could of course be applied as such, plus there are accessibility
> guidelines for PDF and other document types),

Why do you think WCAG does not cover these documents? WCAg 2.0 allows
any web content technology, as far as it is used in an
accessibility-supported way.

Regards,
Ramón.

--
Ramón Corominas
Accessibility specialist
Technosite - Fundación ONCE
E: = EMAIL ADDRESS REMOVED =
T: @ramoncorominas
P: +34 91 121 0330
W: http://technosite.es

From: Birkir R. Gunnarsson
Date: Sat, Dec 22 2012 7:49AM
Subject: Re: A clear EU accessibility law proposed? At what cost?
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Hi

I believe that off-line documentation does not fall under the
definition of "web content" even if it is downloaded from a website. I
wonder, with a PDF form with a submit button, whether that is
web-content, though the user can work on it off-line, but my
understanding of WCAG 2.0 (and anyone feel free to correct me if I am
wrong), is that off-line documents are not something coverred natively
by the standard, though the standard could be applied almost in its
entirety to such documents (see the WAI document draft on applying
WCAG to none web-ICTs).
If I am wrong, and WCAG applies to these documents, then we are in
good shape. If not, I'd want it to be explicitly stated in the EU
directive that documents downloaded from websites need to be
accessible as well, ideally applying the principles of WCAG to
evaluating these documents.
I have seen too many WCAG 2.0 AA compliant websites where you can
download untagged PDF forms with no labels, sometimes even PDF
documents that are simply pictures of text and/or Microsoft Word
documents using content controls that are inaccessible to screen
readers, and even mouse-only controls (that even from a social
security administration website).

Cheers
-B

On 12/22/12, Ramón Corominas < = EMAIL ADDRESS REMOVED = > wrote:
> Hi, Birkir and all,
>
> Birkir wrote:
>
>> 2. the standard does not cover documents and electronic forms that
>> often are offerred via these websites (no fault of WCAG per se of
>> course, it is not designed to be a non-web documents standard, but it
>> could of course be applied as such, plus there are accessibility
>> guidelines for PDF and other document types),
>
> Why do you think WCAG does not cover these documents? WCAg 2.0 allows
> any web content technology, as far as it is used in an
> accessibility-supported way.
>
> Regards,
> Ramón.
>
> --
> Ramón Corominas
> Accessibility specialist
> Technosite - Fundación ONCE
> E: = EMAIL ADDRESS REMOVED =
> T: @ramoncorominas
> P: +34 91 121 0330
> W: http://technosite.es
> > > >

From: Ramón Corominas
Date: Sat, Dec 22 2012 9:06AM
Subject: Re: A clear EU accessibility law proposed? At what cost?
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My understanding is that WCAG 2.0 applies to any document that is
offered via web. If not, it would be trivial to force PDF files to
always download (for example, with an HTTP header "content-disposition:
attachment") and thus bypass the need for accessibility.

Regards,
Ramón.

Birkir wrote:

> I believe that off-line documentation does not fall under the
> definition of "web content" even if it is downloaded from a website. I
> wonder, with a PDF form with a submit button, whether that is
> web-content, though the user can work on it off-line, but my
> understanding of WCAG 2.0 (and anyone feel free to correct me if I am
> wrong), is that off-line documents are not something coverred natively
> by the standard, though the standard could be applied almost in its
> entirety to such documents (see the WAI document draft on applying
> WCAG to none web-ICTs).
>
> If I am wrong, and WCAG applies to these documents, then we are in
> good shape. If not, I'd want it to be explicitly stated in the EU
> directive that documents downloaded from websites need to be
> accessible as well, ideally applying the principles of WCAG to
> evaluating these documents.
> I have seen too many WCAG 2.0 AA compliant websites where you can
> download untagged PDF forms with no labels, sometimes even PDF
> documents that are simply pictures of text and/or Microsoft Word
> documents using content controls that are inaccessible to screen
> readers, and even mouse-only controls (that even from a social
> security administration website).

From: Duff Johnson
Date: Sat, Dec 22 2012 10:22AM
Subject: Re: A clear EU accessibility law proposed? At what cost?
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On Dec 22, 2012, at 11:06 AM, Ramón Corominas wrote:

> My understanding is that WCAG 2.0 applies to any document that is
> offered via web.

Why "any document offered via web"?

As I read it, WCAG 2.0 covers "web pages" as normatively defined here:

http://www.w3.org/TR/WCAG/#webpagedef

The Conformance section also make it very clear that "Conformance is defined only for web pages."

http://www.w3.org/TR/WCAG/#conformance-claims

So far as I can tell, WCAG 2.0 intends to cover content that's delivered to the user within a browser. I guess the interesting question is: does WCAG 2.0 cover content that doesn't need a browser?

> If not, it would be trivial to force PDF files to
> always download (for example, with an HTTP header "content-disposition:
> attachment") and thus bypass the need for accessibility.


That's an interesting case. HTTP is still the "protocol of delivery," of course, so purists might argue that real evasion of WCAG 2.0 would require use of an FTP server. ;-)

Duff.

From: Ramón Corominas
Date: Sat, Dec 22 2012 11:50AM
Subject: Re: A clear EU accessibility law proposed? At what cost?
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Since WCAG 2.0 does not define what technology must be used, and
according to the definition you have mentioned:

- Any downloadable PDF will necessarily have a single URI
- HTTP is usually the protocol used to provide PDF files
- PDF documents are intended to be rendered by a user agent

Unless you are considering the strict definition of user agent:

"any software that retrieves and presents Web content for users"

And therefore you could argue that an offline PDF reader is not a user
agent, since it does not "retrieve" web content. But following that
argument screen readers would not be user agents, since they don't
retrieve anything, they simply read what is retrieved by a browser.

Regards,
Ramón.

Duff wrote:

> As I read it, WCAG 2.0 covers "web pages" as normatively defined here:
>
> http://www.w3.org/TR/WCAG/#webpagedef
>
> The Conformance section also make it very clear that "Conformance is defined only for web pages."
>
> http://www.w3.org/TR/WCAG/#conformance-claims
>
> So far as I can tell, WCAG 2.0 intends to cover content that's delivered to the user within a browser. I guess the interesting question is: does WCAG 2.0 cover content that doesn't need a browser?
>
>> If not, it would be trivial to force PDF files to
>> always download (for example, with an HTTP header "content-disposition:
>> attachment") and thus bypass the need for accessibility.
>
>
> That's an interesting case. HTTP is still the "protocol of delivery," of course, so purists might argue that real evasion of WCAG 2.0 would require use of an FTP server. ;-)
>
> Duff.

From: Bryan Garaventa
Date: Sat, Dec 29 2012 9:17PM
Subject: Re: A clear EU accessibility law proposed? At what cost?
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Thank you, this is an excellent article, which reflects my reasoning for
building WhatSock.com as an education and development resource for bridging
Web Content Accessibility Guidelines and practical application with utmost
simplicity.

I've shared your article with the Royal Society of Arts, who should also
find it interesting.

All the best,
Bryan


----- Original Message -----
From: "Dr Jonathan Hassell" < = EMAIL ADDRESS REMOVED = >
To: < = EMAIL ADDRESS REMOVED = >
Sent: Friday, December 21, 2012 3:23 AM
Subject: [WebAIM] A clear EU accessibility law proposed? At what cost?


Early this month the European Commission issued a proposal for a directive
on “Accessibility of Public Sector Bodies’ Websites”.

This will require twelve categories of EU public-sector websites to comply
with W3C’s Web Content Accessibility Guidelines 2.0 at the AA level.

The directive could establish a law centred around a clearer definition of
‘the objective set of criteria for determining what an accessible website
looks like’ that many accessibility advocates have been wanting for years.

So what does this proposed directive mean for developers, disabled & older
people, and website owners in Europe and beyond?

Is it going to get disabled and older people the benefits they want, without
burdening website owners with unreasonable costs that prevent them
implementing it?

You can find out more by reading my analysis blog at
http://www.hassellinclusion.com/2012/12/clear-eu-accessibility-law/

And let me know what you think here on webaim.

Best regards

Jonathan

--

Prof Jonathan Hassell
Director, Hassell Inclusion

Blog: http://hassellinclusion.com
Twitter: http://twitter.com/jonhassell

From: Jake Joehl
Date: Thu, Jan 10 2013 3:44PM
Subject: Re: A clear EU accessibility law proposed? At what cost?
← Previous message | Next message →

I really enjoy the article too, and I like the whole website! I'm
going to pass it along to my colleagues.
Jake

On 12/29/12, Bryan Garaventa < = EMAIL ADDRESS REMOVED = > wrote:
> Thank you, this is an excellent article, which reflects my reasoning for
> building WhatSock.com as an education and development resource for bridging
>
> Web Content Accessibility Guidelines and practical application with utmost
> simplicity.
>
> I've shared your article with the Royal Society of Arts, who should also
> find it interesting.
>
> All the best,
> Bryan
>
>
> ----- Original Message -----
> From: "Dr Jonathan Hassell" < = EMAIL ADDRESS REMOVED = >
> To: < = EMAIL ADDRESS REMOVED = >
> Sent: Friday, December 21, 2012 3:23 AM
> Subject: [WebAIM] A clear EU accessibility law proposed? At what cost?
>
>
> Early this month the European Commission issued a proposal for a directive
> on “Accessibility of Public Sector Bodies’ Websites”.
>
> This will require twelve categories of EU public-sector websites to comply
> with W3C’s Web Content Accessibility Guidelines 2.0 at the AA level.
>
> The directive could establish a law centred around a clearer definition of
> ‘the objective set of criteria for determining what an accessible website
> looks like’ that many accessibility advocates have been wanting for years.
>
> So what does this proposed directive mean for developers, disabled & older
> people, and website owners in Europe and beyond?
>
> Is it going to get disabled and older people the benefits they want, without
>
> burdening website owners with unreasonable costs that prevent them
> implementing it?
>
> You can find out more by reading my analysis blog at
> http://www.hassellinclusion.com/2012/12/clear-eu-accessibility-law/
>
> And let me know what you think here on webaim.
>
> Best regards
>
> Jonathan
>
> --
>
> Prof Jonathan Hassell
> Director, Hassell Inclusion
>
> Blog: http://hassellinclusion.com
> Twitter: http://twitter.com/jonhassell
>
> > > >
> > > >


--
Jake Joehl
Social Media Assistant, JJ's List

Email: = EMAIL ADDRESS REMOVED =
Web: http://www.jjslist.com

From: Wyant, Jay (OET)
Date: Mon, Jan 14 2013 12:21PM
Subject: Re: A clear EU accessibility law proposed? At what cost?
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Jonathan,

Apparently the BS 8878 document is only available for purchase from BSI for 50 pounds. And I had to hunt to find that link. Why isn't it published online like the WCAG 2.0 for most effective dissemination and reference? Or am I missing something obvious?

Jay