These aren't the SCs you're looking for ... (mis)adventures in WCAG 2.x interpretation and audits / a11y Camp / 9-11 November 2021

WCAG is supposed to give us a reasonably objective way of saying whether or not the sites we are building/auditing are "accessible" (to a particular baseline). However, they are only as useful as our understanding and interpretation of the actual guidelines' normative text. And of course they're not perfect - with some omissions, handwaving, and straight up loopholes. So where does this leave developers and auditors? In this talk, Patrick may not have all the answers, but he'll have a good rant around the subject anyway...

Transcript

1. These aren't the SCs you're looking for... (mis)adventures in WCAG 2.x interpretation and audits Patrick H. Lauke / A11y Camp 2021
2. about me... ▪  principal accessibility specialist at TetraLogical ▪  previously at The Paciello Group (now TPGi) ▪  occasional W3C AGWG member ▪  WCAG trash panda
3. what really grinds my gears... ▪  doing accessibility audits ▪  advising and reviewing the work of other engineers doing audits ▪  being active on accessibility mailing lists (WebAIM, W3C, ...), twitter, Slack ...and far too often, the same question always bubbles up
4. “which success criterion can I fail this under?”
6. far too often, auditors clearly dislike something, and look for a justification to fail it ...
7. overstep the boundaries of WCAG SCs claim something has to be fixed/changed "to pass WCAG" when it normatively doesn't
9. we are not lawyers (or judges) but our audits and evaluations often have some legal dimension to them. ▪  evaluations should be as objective as possible ▪  evaluations should be consistent ...of course, this is easier said than done
10. WCAG is built on the idea that success criteria can be evaluated clearly, unambiguously and consistently... ...but that's not always the case
11. only a few cherry-picked examples ... otherwise we'd be here a few more hours
12. WCAG success criteria are often misunderstood and/or misinterpreted leads to wrong, or at least inconsistent, error reporting
14. 2.4.6 Headings and Labels (AA) Headings and labels describe topic or purpose. this doesn't mandate the use of headings and labels ... only that if a page uses headings and labels, they must be descriptive. it also doesn't mandate that headings and labels be correctly marked-up - that's the job of 1.3.1 Info and Relationships and (where it affects "accessible name" of controls) 4.1.2 Name, Role, Value . lastly, if labels aren't there, it's a 3.3.2 Labels or Instructions problem. “
15. 3.3.2 Labels or Instructions (A) Labels or instructions are provided when content requires user input. again, this doesn't mandate that labels be marked-up as <label> and properly associated with form controls - that's covered by 1.3.1 Info and Relationships and (where it affects "accessible name" of controls) 4.1.2 Name, Role, Value . “
16. <p class="heading1">More information</p> ▪   passes 2.4.6 Headings and Labels ▪   fails 1.3.1 Info and Relationships
17. <input type="text"> ▪   passes 2.4.6 Headings and Labels ▪   fails 3.3.2 Labels or Instructions ▪   fails 4.1.2 Name, Role, Value
18. <p>First name</p> <input type="text"> ▪   passes 2.4.6 Headings and Labels ▪   passes 3.3.2 Labels or Instructions ▪   fails 1.3.1 Info and Relationships ▪   fails 2.5.3 Label in Name ▪   fails 4.1.2 Name, Role, Value
19. <p>First name</p> <input type="text" aria-label="First name" > ▪   passes 2.4.6 Headings and Labels ▪   passes 3.3.2 Labels or Instructions ▪   passes 2.5.3 Label in Name ▪   passes 4.1.2 Name, Role, Value ▪   passes (arguably) 1.3.1 Info and Relationships
20. 2.1.1 Keyboard (A) All functionality of the content is operable through a keyboard interface [...] doesn't say anything about which keys are needed to operate controls/functionality “
21. <a href="#" onclick="..." role="button">fake button</a> ▪   passes 2.1.1 Keyboard even though it doesn't respond to SPACE like real button would
22. <a href="#" role="button">Activate using 'b'</a> .addEventListener('keypress', function(e) { if (e.key == 'b') { /* do something */ } }) ▪   passes 2.1.1 Keyboard even though it can only be triggered using the letter b
23. 3.2.3 Consistent Navigation (AA) Navigational mechanisms that are repeated on multiple Web pages within a set of Web pages occur in the same relative order each time they are repeated, unless a change is initiated by the user. this only normatively requires the relative order of navigation (in relation to other page components) to be consistent - nothing more. doesn't mandate that navigation should be same, work the same, etc across pages “
24. 1.3.3 Sensory Characteristics (A) Instructions provided for understanding and operating content do not rely solely on sensory characteristics of components such as shape, color, size, visual location, orientation, or sound. this only relates specifically to instructions ... and not whether or not sensory characteristics are used - this is covered by other SCs, like 1.4.1 Use of Color or even 1.1.1 Non-Text Content . Fixes for Understanding 1.3.3 Sensory Characteristics #767 “
25. SCs that are interpreted as their opposites
26. 1.4.1 Use of Color (A) Color is not used as the only visual means of conveying information, indicating an action, prompting a response, or distinguishing a visual element. both lines contain a link. but only in the first line is colour used. the first cases fails 1.4.1 Use of Color, but the second passes yes, it's rubbish, but no, can't argue that "color is used to convey..." “
27. WCAG success criteria and cascades of fail ...
28. cascade of fail <a href="..."> <img src="..."> </a> fails multiple criteria , in sequence: ▪  the image itself fails 1.1.1 Non-text content ▪  as a result, link lacks accessible name and fails 4.1.2 Name, Role, Value ▪  arguably, link also fails 2.4.4 Link Purpose (In Context) need consistency in how this is reported
29. auditor education / consistency problems... internal training and resources can help
30. more problematic are issues caused by WCAG SCs that are vague , incomplete or otherwise lacking
31. WCAG 2.x is not perfect written by well-meaning, but fallible humans...
32. WCAG success criteria can be subjective ...
33. subjective interpretation? ▪   1.1.1 All non-text content [...] has a text alternative that serves the equivalent purpose - but what's the purpose? ▪   1.3.1 Information, structure, and relationships conveyed through presentation [...] - where do you draw the line? ▪   2.4.6 Headings and labels describe topic or purpose - what's "descriptive" exactly?
34. <div class="footer"> ... </div> do you fail 1.3.1 Info and Relationships because they don't use <footer> or role="contentinfo" ? the footer may be styled differently from the rest of the page, but is its purpose not clear from context?
35. <a href="/">home</a> <a href="...">products</a> <a href="...">contact</a> do you fail 1.3.1 Info and Relationships because they didn't wrap this in a <ul> , even if this isn't conveyed through presentation ?
36. WCAG has a few strange omissions ...
37. 2.4.4 Link Purpose (In Context) (AA) 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 [...] but what about buttons or similar? is perhaps covered by 4.1.2 Name, Role, Value ? “
38. 4.1.2 Name, Role, Value (A) For all user interface components [...] the name and role can be programmatically determined [...] buttons need to have a programmatically exposed accessible name, but doesn't mandate that the name needs to make sense / convey purpose “
39. <p>...my amazing article...</p> <p><a href="...">Read more</a></p> ▪   fails 2.4.4 Link Purpose (In Context) <p>...my amazing product...</p> <p><button>Add to cart</button></p> ▪   passes 4.1.2 Name, Role, Value and arguably fails no other criterion, unless you want to drag out 2.4.6 Headings and Labels because the label is not "descriptive"? or 1.3.1 Info and Relationships ?
40. "I think what the founding fathers/mothers of WCAG meant to say..."
42. understanding documents and techniques try to clarify... normative versus non-normative
43. understanding / techniques can't provide examples of all possible scenarios
44. beyond the need for subjective interpretation WCAG success criteria can have odd loopholes ...
45. 2.4.7 Focus Visible (AA) Any keyboard operable user interface has a mode of operation where the keyboard focus indicator is visible. but what does visible mean? it's not normatively defined... “
46. a single extra pixel shown on focus is arguably visible
47. WCAG 2.1 decided not to modify 2.0 SCs, patched loopholes with more SCs but these new SCs also ended up having some loopholes
48. 1.4.11 Non-text Contrast (AA) The visual presentation of the following have a contrast ratio of at least 3:1 against adjacent color(s): ▪  User Interface Components: Visual information required to identify user interface components and states [...] ▪  Graphical Objects: [...] “
49. much better...that pixel has a 3:1 contrast ratio now
50. 1.4.11 Non-text Contrast (AA) The visual presentation of the following have a contrast ratio of at least 3:1 against adjacent color(s): [...] note that this only applies normatively to adjacent colors ... doesn't apply to contrast between different colors used for states of the same control “
51. fails 1.4.11 Non-text Contrast
52. passes 1.4.11 Non-text Contrast
53. passes 1.4.11 Non-text Contrast. but wait, does it fail 1.4.1 Use of Color ?
54. 1.4.1 Use of Color (A) Color is not used as the only visual means of conveying information, indicating an action, prompting a response, or distinguishing a visual element. but there's an escape clause in the non-normative F73 failure technique that tries to redefine, by the backdoor, what "color" means... “
55. F73: Failure of Success Criterion 1.4.1 due to creating links that are not visually evident without color vision Note 1: Red and Pink are the same color (hue) but they have different lightness (which is not color). So red and pink would pass the requirement for "not distinguished by color (hue) alone" since they differ by lightness (which is not color) - as long as the difference in lightness (contrast) is 3:1 or greater a note buried in a non-normative technique redefining what "color" means? ...at least now added to WCAG 2.2 understanding for 1.4.1 (see #1500) “
57. ...but we'll fix focus WCAG 2.2 2.4.11 Focus Appearance (Minimum) (Level AA) 2.4.12 Focus Appearance (Enhanced) (Level AAA)
58. SCs that are overly specific... and then end up only applying to very specific cases
59. 1.4.10 Reflow (AA) Content can be presented without loss of information or functionality, and without requiring scrolling in two dimensions for: ▪  Vertical scrolling content at a width equivalent to 320 CSS pixels ▪  Horizontal scrolling content at a height equivalent to 256 CSS pixels [...] meant to help low vision users that require up to 400% zoom, but ended up too specific - only normatively applies at those exact values “
60. @media ( width: 320px ) { ... } codepen.io/patrickhlauke/pen/ZZqzaB
61. 1.4.12 Text Spacing (AA) In content implemented using markup languages that support the following text style properties, no loss of content or functionality occurs by setting all of the following and by changing no other style property: ▪  Line height (line spacing) to at least 1.5 times the font size ▪  Spacing following paragraphs to at least 2 times the font size ▪  Letter spacing (tracking) to at least 0.12 times the font size ▪  Word spacing to at least 0.16 times the font size [...] only those exact values and over - if content breaks/stops working at line height of 1.4 instead of 1.5, not a failure... “
62. use JavaScript to detect line height and fix only if 1.5 or higher codepen.io/patrickhlauke/pen/jgVGOp
63. even after years of auditing, I sometimes have weird moments of realisation seeing SCs, and what they say/apply to, in a new light
65. same discussions about applicability and interpretation even happen within the AGWG
66. WCAG success criteria need to be testable ... but this doesn't allow for nuance
67. WCAG SCs are binary you either pass or fail
68. sometimes the values/thresholds are just arbitrary lines in the sand ...
69. no weighting given to impact or frequency of a particular fail, or how bad a failure is off the mark sometime, you just want to say something's a minor or soft fail , but distinction doesn't exist
70. fail a single SC and you can't really claim to be conformant
71. loopholes , omissions and subjective requirements can and will be exploited auditors aren't the only ones who try to find these gaps...
73. ...so what do we do about this?
75. join the open debate/discussion github.com/w3c/wcag/issues also a good place to look if there's pending clarifications
76. frustration: most efforts going towards new WCAG 2.2 SCs rather than fixing what's broken in 2.0/2.1
77. more consistent Accessibility Compliance Testing (ACT) w3.org/community/act-r
78. act-rules.github.io/rules
79. github.com/canaxess/wcag-tests
80. less dense/technical than ACT Rules, but early days same risk of "boiling the ocean"?
81. w3.org/TR/wcag-3.0 but note that it's still very early days on this and it will be quite some time before legislation references 3.0 once it's actually a ratified recommendation...
82. but in the meantime ...
83. don't creatively reinterpret what an SC says to fit your agenda whether you're a developer or an auditor doing an evaluation
84. "but unless it's reported as a WCAG failure the client won't change it" then you have more fundamental problem...
85. as auditor, you do your client a disservice by not making clear what is and isn't a normative failure ...what happens when a clued-up client rightly challenges your claim? all your other results lose credibility!
86. be conservative in your pass / fail assessments document your hesitation, clearly state when something's "more of a suggestion" than a hard failure
87. further reading...
88. join my WCAG Trash Panda Webring : ▪  Fixes to WCAG 2.1 Understanding 2.4.6 and 3.3.2 #612 ▪  Edits to 135 failure #890 ▪  Proposal for color and contrast (1.3.1, 1.4.1, 1.4.3., 1.4.6, 1.4.11) #901 ▪  Should role button and input button be a WCAG fail if cannot be activated using space? #857 ▪  Does SC 1.4.11 require comparing focused and non-focused states #541 ▪  Ambiguity in understanding for 1.3.3 sensory characteristics #750 ▪  Bad/incomplete example for Understanding 3.3.2 #755
89. ▪  "at least" should be "at most" in WCAG 2.1 SC 1.4.12 #635 ▪  Expand 1.4.10 to apply 'down to' instead of 'at' #698 ▪  2.4.7 Focus Visible - what counts as "visible"? #302 ▪  Must the tooltip of icons match the accessible name? (for "Label in Name", SC 2.5.3) #891 ▪  Keyboard operation with assistive technology: 2.1.1 or 4.1.2? #878 ▪  Can title on links (e.g. linked icon) as sole source of accName ever pass 1.1.1? #867 (side discussion about high contrast mode and responsibility of user agents) ▪  Error of the User Agents part of WCAG or not #866
90. ▪  1.4.5 / 1.4.9 Image of Text and <text> inside SVGs #773 ▪  Revisiting imbalance between 1.2.4 Captions (Live) (AA) and 1.2.9 Audio- only (Live) (AAA) #795 ▪  ARIA in HTML conformance to conform WCAG ? #717 ▪  Failure technique F94 (1.4.4 resize text): remove "1280 pixels wide" step in test procedure #704 ▪  Contrast Ratio Math and Related Visual Issues #695 ▪  Include font weight for color contrast tests #665 ▪   Accessible P Tag Usage (WebAim)
91. ▪  Must the tooltip of icons match the accessible name? (for "Label in Name", SC 2.5.3) #891 ▪  Are Reflow, Text Size and Orientation cumulative? #391 ▪  What does "support the following text style properties" mean (1.4.12)? #884 ▪  Does using the placeholder with a value alone pass 3.3.2 Labels or Instructions? #864 ▪  Using color ALONE as focus indicator #757 ▪  New SC for keyboard operation? #872 ▪  Does 3.3.2 mandate forms that have required/optional fields indicate this visually? #923
92. ▪  2.5.3: Must the visible label of site logos linking to the start page be included in the accName? #722 ▪  Exception for use of symbols as visible label in regard to 2.5.3 Label in Name #598 ▪  Understanding Label in Name #352 ▪  @stevefaulkner: "<button aria-label="close">X</button> pass or fail WCAG 2.1 label in name?"
93. ▪  Overlap between 3.3.1 and 4.1.2? #696 ▪  Problems with WCAG 2.0 Flash Definition #553 ▪  WCAG 2.1 Understanding 2.3.1 - missing/vague dimension definitions #585 ▪  1.4.5 / 1.4.9 Image of Text and inside SVGs #773 ▪  Clarity on 1.4.11 as it applies to "Cards" #856 ▪  Can ENTER on seach field be accepted as conforming alternative to inaccessible control (loupe icon)? #2069
94. ▪  Cursor as sole focus indicator of inputs sufficient to meet 1.4.11? #680 ▪  Looking for definitive clarification regarding 1.4.1 #1467 ▪  1.4.10: If original page must be scrolled and unchanged at 320px - is that a violation of "Reflow"? #2063 ▪  1.4.11 Understanding: Additional focus indication of text inputs (default caret visible) #1014 ▪  Errata/clarification of 2.2.1 Timing Adjustable extension #1040 ▪  Does the adjacent color clause of SC 1.4.11 apply when focus changes swap colors but also are adjacent to the background ? #1775
95. @patrick_h_lauke github.com/patrickhlauke/ tetralogical.com splintered.co.uk