At our agency, we try to do our part to help make the web a more accessible place. But there are aspects of the ADA-dependent, litigation-fueled environment that has shaped U.S. web accessibility that we take issue with. We tend to shy away from public policy punditry, so we don’t usually write on this topic. That said, we are pleased to see the first public working draft for the Web Content Accessibility Guidelines (WCAG) 3.0, which addresses some of the issues we have noticed (as well as a few that we hadn’t yet considered), and we wanted to share some of our preliminary thoughts.
What is WCAG 3.0?
WCAG has served as the most widely accepted set of standards for web accessibility for over 20 years. The most recent major version (2.1) has been adopted as authoritative by many other bodies and has been encoded into law as the bottom line standard for accessibility requirements in many countries. While U.S. federal law is silent on the need for web accessibility, many federal courts have interpreted the ADA as requiring web accessibility and have referenced the WCAG 2.x A.A. as the governing rule.
WCAG 3.0 is an ambitious rewrite of digital accessibility standards that does not limit itself to the web. It aims to reorient towards a wider audience and better educate non-technical users about how different disabilities can impact user experience and which methods can be used to address them.
When Will WCAG 3.0 Be Released?
WCAG 3.0 is expected to be completed in early 2023. It is worth noting that the Web Consortium (W3C) has indicated that this new set of standards will not be backward compatible with 2.x but that it also does not supersede earlier versions. What this means practically for site owners is not clear, but it is reasonable to assume that compliance with the WCAG 2.1 (or 2.2) standards will be acceptable for some time, even after 3.0 has been released. While WCAG 3.0 will probably eventually be adopted by legal bodies as the authoritative standard, this is not something that you need to worry about any time soon.
The Web is One of Many Mediums on the Internet
When WCAG 2.0 came out in 2008, the first iPhone model was barely a year old, and the mobile web was in its infancy. Since then, we have seen the rise of mobile apps, OTT television apps, virtual reality, augmented reality, and other new content mediums. WCAG 3.0 attempts to address the fact that the internet is a lot more than just websites and that a significant portion of digital content is not consumed in a web browser.
Some of these mediums, like Augmented Reality, are still too niche to have generated much demand for accessibility compliance services, but as one of a small number of agencies providing mobile app ADA audits, NP Group is quite aware that the current WCAG 2.1 guidelines are a poor fit. Many web-centric success criteria translate easily into apps, while others are not applicable or translated awkwardly.
WCAG 3.0 aims to consolidate current disparate sets of standards for the web, electronic publications, and PDFs into a single set of technology platform agnostic standards. While the guidelines do make room for technology-specific methods, there are also fallback methods that can generally describe how newer technologies should behave. This should encourage a more holistic approach to accessibility that allows developers and users of new technologies to implement these requirements.
Accessibility Is Not Binary
In the United States, lawsuits alleging violations of the ADA have been among the strongest drivers of accessibility adoption. This encourages meeting a bare minimum but does not create any incentives to try to improve further. We have always believed that accessibility is a spectrum. Even for sites that cannot yet meet the minimum thresholds for complying, it is better to become more accessible. Our website accessibility audits try to measure the impact of particular accessibility violations on the user experience; for instance, it’s common sense that an accessibility issue that prevents a customer from making a purchase is worse than an image being improperly tagged in a blog post. A pass/fail standard cannot truly measure how accessible a site is.
WCAG 3.0 introduces some exciting updates that address this dynamic. There are three levels of conformance that can be claimed: bronze, silver, and gold. And achieving the minimum compliance level (bronze) does not require perfection. Tests of various accessibility methods are scored on a rating scale; some are binary, with others measured as percentages or even based on qualitative assessments. The “passing” thresholds are still to be determined, but the consortium has indicated that many methods will have a bit of slack (allowing sub-100% scores to pass) as long as critical processes are not impeded and certain critical errors are avoided.
This more detailed scoring method should also provide language for sites to document their compliance level (whether or not it is passing). After all, if you can bring up a rating from 30% to 70%, that is a considerable improvement. And even among passing sites, wouldn’t you want to show that you are at 95% (rather than a passing 80%)? This should also open up the possibility of claiming conformance to specific processes or even for particular sections or pages of a site, even if full compliance has not yet been achieved.
Finally, the WCAG 3.0 drafters have announced that the next version of the guidelines will include far more non-normative information. While those motivated solely by compliance pressures will likely ignore these sections of WCAG, we hope that this will encourage more thoughtfulness on the part of organizations that wish to embrace an accessibility mindset.
Scaling Accessibility is Hard
Making a single page site accessible is relatively easy. As you start adding more pages and custom or complex functionality, it gets a little more challenging. But the more extensive a site gets, the harder it becomes to keep it accessible. Large sites depend on many content writers and editors, each of whom can potentially introduce violations. And sites that update automatically and frequently (including those whose layout is not static) do not have a shared artifact to test against. Even if no accessibility violations are ever introduced, it is difficult for the site owner to claim that this is the case with any certainty.
Scaled rating values should help address this issue somewhat. But the drafters of WCAG 3.0 have also said that they are investigating other testing modalities such as holistic testing or sampling that could be used for larger sites to claim and demonstrate accessibility compliance. Currently, many sites that are an order of magnitude smaller already rely on some forms of sampling to intelligently audit for accessibility issues. From a legal perspective, having WCAG explicitly give its blessing to these testing modes and verification would be a game-changer.
More Scientific Color Standards
In our experience, minimum color contrast ratios are often the most challenging accessibility standard for many organizations to adapt. Completely updating a company’s brand is rarely part of the brief when we are hired for an accessibility audit, but it is often the case that longstanding brands have insufficient color contrast to pass WCAG 2.1.
We are intrigued by the consortium’s announcement that the new visual contrast standards will introduce a paradigm shift from evaluating colors to embracing new research on “perception of light intensity”. While many brands may still fail the new standards, we expect that this model will open up more color combinations (at least under certain circumstances) for designers.
This change is personal for us. We have had to cut back on our use of orange because (in combination with white), it technically violates the 1.4.3 WCAG standard. We have reason to believe that the color combinations we use are actually accessible, but in a focused compliance environment, it is difficult to argue against the consensus standard.
Making Accessibility More Accessible
We can’t help but notice that accessibility is often left to the experts. Most site owners, designers, and we would venture to say even developers don’t know or understand much about what makes a website accessible. This has hampered the incorporation of accessibility from becoming an expected and universal part of the web.
For this reason, it is crucial to point out that WCAG 3.0 is taking giant steps towards producing accessibility guidelines and documentation that non-specialists can use and understand. The drafters plan to include plain language how-tos and conceptual framing of accessibility that should serve as a more straightforward entry into the topic than a list of requirements. The guidelines will consist of functional needs for users with disabilities (e.g., “Use without vision”) and categories of disabilities and only then pivot to specific methods and outcomes that address these concerns.
What This All Means
While many people will still want to (and probably should) engage experts for help, it is helpful that the W3C is making an effort to document accessibility universally. However, only time will tell if the digital community accepts adaptation more and if accessibility becomes a priority for a broader range of organizations.
