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From: Karin Carlson
Date: Wed, Dec 13 2017 12:06AM
Subject: Proof of compliance?
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Hi everyone. Is there a certification or official designation when a site or product passes testing? Im looking for something official/formal for compliance to WCAG 2 level AA.
Thanks
Karin 


Sent from my Samsung Galaxy smartphone.

From: Srinivasu Chakravarthula
Date: Wed, Dec 13 2017 1:37AM
Subject: Re: Proof of compliance?
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As far as I know, there is "none". Even whoever provides certification,
typically the certification is valid just at the minute it certifies. What
is the guarantee that there is no new code gets in after site is certified?

Regards,

Srinivasu Chakravarthula - Twitter: http://twitter.com/CSrinivasu/
Website: http://www.srinivasu.org | http://serveominclusion.com

Let's create an inclusive web!

Lead Accessibility Consultant, Informatica


On Wed, Dec 13, 2017 at 12:36 PM, Karin Carlson < = EMAIL ADDRESS REMOVED = >
wrote:

> Hi everyone. Is there a certification or official designation when a site
> or product passes testing? Im looking for something official/formal for
> compliance to WCAG 2 level AA.
> Thanks
> Karin
>
>
> Sent from my Samsung Galaxy smartphone.
> > > > >

From: Steve Green
Date: Wed, Dec 13 2017 4:54AM
Subject: Re: Proof of compliance?
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The nearest thing I know of is a VPAT. Although these are only intended for the US market we use them for any client who wants some sort of certificate. There is no official format so we created our from a variety of sources such as:

https://www.state.gov/m/irm/impact/126343.htm (only Section 1194.22 is relevant for websites)
https://www.itic.org/policy/accessibility

The ITIC version has recently been updated so it can be used for reporting under EN 301 549. This will be required under the EU Accessibility Directive from 2019 although the precise certification method is not yet defined.

Steve Green
Managing Director
Test Partners Ltd

-----Original Message-----
From: WebAIM-Forum [mailto: = EMAIL ADDRESS REMOVED = ] On Behalf Of Srinivasu Chakravarthula
Sent: 13 December 2017 08:38
To: WebAIM Discussion List < = EMAIL ADDRESS REMOVED = >
Subject: Re: [WebAIM] Proof of compliance?

As far as I know, there is "none". Even whoever provides certification, typically the certification is valid just at the minute it certifies. What is the guarantee that there is no new code gets in after site is certified?

Regards,

Srinivasu Chakravarthula - Twitter: http://twitter.com/CSrinivasu/
Website: http://www.srinivasu.org | http://serveominclusion.com

Let's create an inclusive web!

Lead Accessibility Consultant, Informatica


On Wed, Dec 13, 2017 at 12:36 PM, Karin Carlson < = EMAIL ADDRESS REMOVED = >
wrote:

> Hi everyone. Is there a certification or official designation when a
> site or product passes testing? Im looking for something
> official/formal for compliance to WCAG 2 level AA.
> Thanks
> Karin
>
>
> Sent from my Samsung Galaxy smartphone.
> > > archives at http://webaim.org/discussion/archives
> >

From: Duff Johnson
Date: Wed, Dec 13 2017 7:55AM
Subject: Re: Proof of compliance?
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Hi Karin,

What would a “proof” of compliance even mean? Web content isn’t static… if the site managers change the site’s CSS, for example, it could trash accessibility across the site, irrespective of any previously-issued “proof”.

The nearest WCAG 2.0 comes to this concept is the notion of a “conformance claim” which is (very unfortunately) NOT defined in machine-readable terms (unlike PDF/UA). See:

https://www.w3.org/TR/WCAG20/#conformance-claims

For whatever reason (perhaps someone more involved can comment?) the draft of WCAG 2.1 also fails to specify a machine-readable means of claiming conformance...

Duff.


> On Dec 13, 2017, at 02:06, Karin Carlson < = EMAIL ADDRESS REMOVED = > wrote:
>
> Hi everyone. Is there a certification or official designation when a site or product passes testing? Im looking for something official/formal for compliance to WCAG 2 level AA.
> Thanks
> Karin
>
>
> Sent from my Samsung Galaxy smartphone.
> > > >

From: John Foliot
Date: Wed, Dec 13 2017 8:39AM
Subject: Re: Proof of compliance?
← Previous message | Next message →

Hi Duff,

> For whatever reason (perhaps someone more involved can comment?) the
draft of WCAG 2.1 also fails to specify a machine-readable means of
claiming conformance...


You've answered your own question: due to the non-static nature of web
content today, it's kind of hard to have a static, machine-readable
"conformance claim" that would always be accurate. And while a 'dynamic'
claim could certainly be crafted using things like mechanical testing tools
and change-log parsing, the value of a claim such as that would likely also
be diminished from a "legal-defensiveness" position, which is often the
root of these types of claims and requirements, due to its malleability
​ and ever-changing reporting values​
.

That said, a machine-*referenceable* conformance claim could be addressed
using metadata (perhaps something like Schema.org's "Claim Review" -
http://schema.org/ClaimReview), but the conformance claim would still be
based upon a "snapshot" and date of review. This is not unlike a CPA's
stamp, where the Chartered Accountant claims that what was reviewed on a
specific date met the claim's assertions, but beyond that date, all bets
are off.

​Or were you thinking of something different?

JF​



On Wed, Dec 13, 2017 at 8:55 AM, Duff Johnson < = EMAIL ADDRESS REMOVED = > wrote:
>
> Hi Karin,
>
> What would a “proof” of compliance even mean? Web content isn’t static…
if the site managers change the site’s CSS, for example, it could trash
accessibility across the site, irrespective of any previously-issued
“proof”.
>
> The nearest WCAG 2.0 comes to this concept is the notion of a
“conformance claim” which is (very unfortunately) NOT defined in
machine-readable terms (unlike PDF/UA). See:
>
> https://www.w3.org/TR/WCAG20/#conformance-claims
>
> For whatever reason (perhaps someone more involved can comment?) the
draft of WCAG 2.1 also fails to specify a machine-readable means of
claiming conformance...
>
> Duff.
>
>
> > On Dec 13, 2017, at 02:06, Karin Carlson < = EMAIL ADDRESS REMOVED = >
wrote:
> >
> > Hi everyone. Is there a certification or official designation when a
site or product passes testing? Im looking for something official/formal
for compliance to WCAG 2 level AA.
> > Thanks
> > Karin
> >
> >
> > Sent from my Samsung Galaxy smartphone.
> > > > > > > > >
> > > > --
John Foliot
Principal Accessibility Strategist
Deque Systems Inc.
= EMAIL ADDRESS REMOVED =

Advancing the mission of digital accessibility and inclusion

From: Jonathan Avila
Date: Wed, Dec 13 2017 8:52AM
Subject: Re: Proof of compliance?
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Duff, et al.

The WAI Tools project indicates that they plan to create an open project/standard for accessibility statements.
https://www.w3.org/WAI/Tools/ that may extend the WCAG-EM report Tool https://www.w3.org/WAI/eval/report-tool/#/

A sharable form/machine readable form of a VPAT is also something people have been discussing in the US.

Jonathan

Jonathan Avila
Chief Accessibility Officer
Level Access, inc. (formerly SSB BART Group, inc.)
(703) 637-8957
= EMAIL ADDRESS REMOVED =
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-----Original Message-----
From: WebAIM-Forum [mailto: = EMAIL ADDRESS REMOVED = ] On Behalf Of Duff Johnson
Sent: Wednesday, December 13, 2017 9:55 AM
To: WebAIM Discussion List < = EMAIL ADDRESS REMOVED = >
Subject: Re: [WebAIM] Proof of compliance?

Hi Karin,

What would a “proof” of compliance even mean? Web content isn’t static… if the site managers change the site’s CSS, for example, it could trash accessibility across the site, irrespective of any previously-issued “proof”.

The nearest WCAG 2.0 comes to this concept is the notion of a “conformance claim” which is (very unfortunately) NOT defined in machine-readable terms (unlike PDF/UA). See:

https://www.w3.org/TR/WCAG20/#conformance-claims

For whatever reason (perhaps someone more involved can comment?) the draft of WCAG 2.1 also fails to specify a machine-readable means of claiming conformance...

Duff.


> On Dec 13, 2017, at 02:06, Karin Carlson < = EMAIL ADDRESS REMOVED = > wrote:
>
> Hi everyone. Is there a certification or official designation when a site or product passes testing? Im looking for something official/formal for compliance to WCAG 2 level AA.
> Thanks
> Karin
>
>
> Sent from my Samsung Galaxy smartphone.
> > > archives at http://webaim.org/discussion/archives
>

From: Duff Johnson
Date: Wed, Dec 13 2017 9:36AM
Subject: Re: Proof of compliance?
← Previous message | Next message →

> You've answered your own question: due to the non-static nature of web
> content today, it's kind of hard to have a static, machine-readable
> "conformance claim" that would always be accurate.

I didn’t mean to imply that it would always be accurate. Clearly, any change to the site would require some sort of validation protocol to justify the continued use of the conformance claim.

> And while a 'dynamic'
> claim could certainly be crafted using things like mechanical testing tools
> and change-log parsing, the value of a claim such as that would likely also
> be diminished from a "legal-defensiveness" position, which is often the
> root of these types of claims and requirements, due to its malleability
> ​ and ever-changing reporting values​

I take this point entirely.

<shameless PDF plug>
One of PDF’s useful qualities is that it IS entirely self-contained in this regard, which makes the conformance claim problem that much easier to solve.
</shameless PDF plug>

> That said, a machine-*referenceable* conformance claim could be addressed
> using metadata (perhaps something like Schema.org's "Claim Review" -
> http://schema.org/ClaimReview), but the conformance claim would still be
> based upon a "snapshot" and date of review. This is not unlike a CPA's
> stamp, where the Chartidanered Accountant claims that what was reviewed on a
> specific date met the claim's assertions, but beyond that date, all bets
> are off.
>
> ​Or were you thinking of something different?

I was thinking of precisely what you’ve outlined above. It’s too bad that WCAG 2.0 (and 2.1, it seems) provide so little guidance on this.

Duff.

From: John Foliot
Date: Wed, Dec 13 2017 10:07AM
Subject: Re: Proof of compliance?
← Previous message | Next message →

> It’s too bad that WCAG 2.0 (and 2.1, it seems) provide so little guidance
on this.

​I think that is in part due to the fact that the W3C is not a "compliance"
organization, but rather a consortium of companies that work on voluntary
technical standards. None of the numerous standards at the W3C have the
same legal 'echo-effect' like WCAG does however, and so it is something of
an outlier in that regard​. (Additionally, the W3C does not have an
'enforcement' mechanism either, so everything that comes from the W3C is
voluntary by nature. The fact is that for most W3C Recommendations,
interested parties benefit from the

In fact, WCAG 2.0 (and 2.1) both state:


Conformance claims are *not required*. Authors can conform to WCAG 2.1
without making a claim.

Because of this, WCAG
​appears
less interested in conformance claims as a practical outcome; instead it
is legal entities and governmental organizations that are more interested
in claims of this nature, for reasons often outside of the direct "it
benefits the end user" justification (yes, achieving and maintaining
compliance *does* benefit the end user, but reporting that fact has less
value to said end-user)
​.

It seems to me that to see a standardized mechanism for compliance
reporting emerge, a specific proposal needs to come forward to the WCAG
Working Group (and even then, there is no guarantee that they will take up
this particular piece)​. Alternatively, a government organization could
enact a requirement for conformance claims, and that org could (should?)
also provide the reporting mechanism specifics. I'm fairly certain that the
easiest way of doing so is to use metadata, but there are multiple schemas
out there (our EDU friends are likely already aware of Dublin Core) and so
deciding on which schema would need to be articulated by the org requesting
the compliance document.


Duff, if you have a more fleshed out proposal however, please bring it to
the attention of the WCAG WG. For while this 'problem' may not be addressed
in the short-term, the Task Force working on Project Silver (see:
https://www.24a11y.com/2017/wcag-2-1-silver-ag-next-accessibility-guidelines/
)

Cheers!

JF

On Wed, Dec 13, 2017 at 10:36 AM, Duff Johnson < = EMAIL ADDRESS REMOVED = >
wrote:

> > You've answered your own question: due to the non-static nature of web
> > content today, it's kind of hard to have a static, machine-readable
> > "conformance claim" that would always be accurate.
>
> I didn’t mean to imply that it would always be accurate. Clearly, any
> change to the site would require some sort of validation protocol to
> justify the continued use of the conformance claim.
>
> > And while a 'dynamic'
> > claim could certainly be crafted using things like mechanical testing
> tools
> > and change-log parsing, the value of a claim such as that would likely
> also
> > be diminished from a "legal-defensiveness" position, which is often the
> > root of these types of claims and requirements, due to its malleability
> > ​ and ever-changing reporting values​
>
> I take this point entirely.
>
> <shameless PDF plug>
> One of PDF’s useful qualities is that it IS entirely self-contained in
> this regard, which makes the conformance claim problem that much easier to
> solve.
> </shameless PDF plug>
>
> > That said, a machine-*referenceable* conformance claim could be addressed
> > using metadata (perhaps something like Schema.org's "Claim Review" -
> > http://schema.org/ClaimReview), but the conformance claim would still be
> > based upon a "snapshot" and date of review. This is not unlike a CPA's
> > stamp, where the Chartidanered Accountant claims that what was reviewed
> on a
> > specific date met the claim's assertions, but beyond that date, all bets
> > are off.
> >
> > ​Or were you thinking of something different?
>
> I was thinking of precisely what you’ve outlined above. It’s too bad that
> WCAG 2.0 (and 2.1, it seems) provide so little guidance on this.
>
> Duff.
> > > > >



--
John Foliot
Principal Accessibility Strategist
Deque Systems Inc.
= EMAIL ADDRESS REMOVED =

Advancing the mission of digital accessibility and inclusion

From: Duff Johnson
Date: Wed, Dec 13 2017 2:55PM
Subject: Re: Proof of compliance?
← Previous message | Next message →

> The WAI Tools project indicates that they plan to create an open project/standard for accessibility statements.
> https://www.w3.org/WAI/Tools/ that may extend the WCAG-EM report Tool https://www.w3.org/WAI/eval/report-tool/#/

I’ve been studying the Rules format and I like, in general, what I see.

https://www.w3.org/TR/act-rules-format-1.0/

I am thinking about how this model could be implemented with respect to PDF/UA.

Just informationally… (I’m not necessarily recommending this approach):

PDF/UA makes a couple of crucial moves that differ from WCAG 2.0. Key to the distinction (beyond being machine-readable, which is simply workflow-enablement) is the recognition that our objective in PDF/UA is to provide a means of asserting a useful conformance *claim*. A claim is not a conformance *fact*. It’s more like an assertion of intent (to make stuff accessible), an assertion of awareness of what the “right thing to do” is, and a stated willingness to correct problems when reported. It is a means of generating accountability for the accessibility of specific units of content in a lasting manner.

To take this road, PDF/UA conformance claims *require* PDF/UA metadata. Of course, a PDF may be perfectly accessible in the absence of the metadata, but that misses the point. Claiming PDF/UA conformance represents a willingness to be accountable for one’s document. It provides managers (and regulators) with a clean-cut means of managing their content for accessibility.

Fanciful supposition...

If this model were implemented in the HTML world for WCAG 2.0 purposes, I imagine that one’s content-management and/or accessibility-management software would remove the WCAG 2.0 conformance metadata flag (and its associated expression on the affected page(s)) whenever a change to a given page (whether the change was site-wide or page-specific) caused that assertion to be in question. Restoring the conformance claim metadata to the page would be based on some sort of testing; automated or (if necessary) manual.

The accessibility flag would then have a specific - and useful - purpose.

…and why not? This is more-or-less the sort of content-management practice we want to promote, right?

Duff.

< awaits schooling on web technology shibboleths :-) >

From: Shadi Abou-Zahra
Date: Thu, Dec 14 2017 1:53AM
Subject: Re: clarification on related W3C work (was: Proof of compliance?)
← Previous message | No next message

Hello,

Apologies for a slightly longer response to clarify work of the cited
WAI-Tools Project and related efforts currently going on at W3C:


On 13/12/2017 22:55, Duff Johnson wrote:
>
>> The WAI Tools project indicates that they plan to create an open project/standard for accessibility statements.

Guidance on providing accessibility statements is a deliverable of the
W3C Education and Outreach Working Group (EOWG). It will be developed
with support of the EC-funded WAI-Tools Project. It is not expected to
be a standard but rather informative guidance. It will build on the
definitions of "conformance claims" and "evaluation statements", which
are provided by WCAG 2.x and WCAG-EM respectively:
- https://www.w3.org/TR/WCAG20/#conformance-claims
- https://www.w3.org/TR/WCAG-EM/#step5c

An accessibility statement could describe which parts of a website or
product are expected to be accessible or have accessibility barriers,
who to contact when barriers are encountered, and what improvements
plans there are. The exact details will be discussed in EOWG under the
W3C consensus process. This work is expected to start in spring 2018,
and work will be carried out in public as usual. Comments are welcome.


>> https://www.w3.org/WAI/Tools/ that may extend the WCAG-EM report Tool https://www.w3.org/WAI/eval/report-tool/#/

WAI-Tools Project intends to extend the WCAG-EM Report Tool in several
ways, including:

- Allow importing of test results from evaluation tools. This will be
based on the (machine-readable) Evaluation and Report Language (EARL)
https://www.w3.org/WAI/intro/earl

- Include machine-readable metadata (possibly using micro-formats of
EARL) in the human-readable reports generated by WCAG-EM Report Tool.
Currently machine-readable formats are only provided as JSON (of EARL).

- A tool that helps people to generate accessibility statements, which
will possibly be an extension to this WCAG-EM Report Tool. This will
also be developed through EOWG.


> I’ve been studying the Rules format and I like, in general, what I see.
>
> https://www.w3.org/TR/act-rules-format-1.0/

The W3C work on Accessibility Conformance Testing (ACT) is related but
slightly separated. ACT is intended to document known ways of testing
content for accessibility, following WCAG 2.x:
-
https://www.w3.org/WAI/GL/task-forces/conformance-testing/wiki/ACT_Overview_-_What_is_ACT

The ACT Rules Format 1.0 defines how to write "test rules" for such
documentation. Having such a common format allows different people to
share their own test rules. Examples of such test rules are currently
being developed by the W3C Auto-WCAG Community Group:
- https://auto-wcag.github.io/auto-wcag/pages/rules.html

WAI-Tools Project will also develop such test rules, and support the
completion of the ACT Rules Format 1.0 and related deliverables of the
W3C ACT Task Force. Participation in these efforts is welcome too.

Regards,
Shadi

--
Shadi Abou-Zahra - http://www.w3.org/People/shadi/
Accessibility Strategy and Technology Specialist
Web Accessibility Initiative (WAI)
World Wide Web Consortium (W3C)