WCAG 2.0 and Accessibility Supported

Web accessibility is at the cross-roads. The WCAG of 1999 is not able to meet the needs of the web today, with its enhanced interactivity, greater community engagement and the proliferation of new technologies. WCAG 2.0 is supposed to address this problem by looking not at the technologies used to generate web content, but at how they are used. However, I am fearful that WCAG 2.0 and the concept of “accessibility supported” are not fully understood and this could put at risk the whole move to improve the accessibility of the web.

Many countries, including Australia are currently considering when and how to adopt WCAG 2.0 as the benchmark for accessibility. This issue was briefly canvassed in an earlier post, Adopting WCAG 2.0, and the comments it attracted.

Central to WCAG 2.0 is the notion of technological neutrality, since this will allow the guidelines to be applied to all current and future web technologies. In conjunction with this approach, the WCAG Working Group introduced the concept of “accessibility-supported” and the associated requirement that only accessibility supported ways of using technologies can be relied upon to satisfy the Success Criteria.

While I support the idea of WCAG 2.0 being technology neutral, I am concerned that there maybe a general misunderstanding in the web community about what is meant by “accessibility supported”. In particular, I am worried that regulators in Australia and other countries may be reluctant to fully embrace the notion of technological neutrality and continue to view web content accessibility from an exclusively HTML perspective. This appears to be basically the approach adopted by New Zealand.

It should be noted, when a technology is considered “accessibility supported” it doesn’t automatically mean all uses of that technology will be acceptable. PDF, JavaScript or Flash, for example, can all be used to make content that is either accessible or inaccessible as is also the case with HTML. For more information see the W3C Working Group note Understanding Accessibility Support.

If the authorities in different countries, who set the rules and regulations relating to the accessibility of web content, decide that only W3C formats like HTML and CSS can be considered accessible, then alternatives will have to be provided for all content that relies on other technologies. This is basically how we have operated for the ten years of WCAG 1.0 and I believe to continue with this approach risks jeopardising the overall accessibility of the web. A failure to accept new technologies will in my opinion:

  • Provide little incentive for website developers to improve the accessibility of web content that uses non-W3C technologies like JavaScript and PDF.
  • Reduce pressure on the producers of current and future non-W3C technologies to improve the accessibility of their technologies and associated authoring systems.
  • Reduce the incentive for the manufacturers of assistive technologies to improve the ability of their technologies to render non-W3C formats.
  • Undermine the overall community perception of the importance of web content accessibility as interactive non-W3C technologies are increasingly used on high traffic websites often without appropriate alternatives.
  • Result in an increasing number of sites being technically in breach of web accessibility regulations, and since the vast majority of these breaches are not likely to be prosecuted this will further undermine the credibility of accessibility-related rules and regulations.

But, what about all the inaccessible non-W3C content now on the web?

We all know that the web now contains a large amount of PDF and Flash material that is inaccessible. There is also poor JavaScript that prevents users who depend on assistive technologies from accessing the content and functionality of some sites. And, from my experience, nearly all of this inaccessible non-W3C content on Australian websites is not being corrected. A few site proprietors, who are committed to improving the accessibility of their sites, are progressively addressing the problem caused by old inaccessible content, but most just don’t think it is worth the time or money.

In addition to allowing a wide range of technologies to be considered “accessibility supported”, I believe the regulators in Australia (and elsewhere) should consider providing a moratorium or exemption for all existing non-W3C content, such as Flash or PDF, which does not comply with WCAG 1.0. The providers of this content should however be required to supply a description of what the content contains, but not a full equivalent alternative that is accessible.

I recognise that in effect this approach will give tacit approval to a potentially large amount of inaccessible content on Australian websites. However, I think it is unlikely an alternative, more punitive, approach will result in any significant improvements in the accessibility of the non-W3C content that is currently available.

With regard to JavaScript, in my opinion no alternative should be required for JavaScript that is accessible to versions of commonly used assistive technologies, which have been released in the last three years. An alternative that does not rely on JavaScript support however, should be provided for all Script that is inaccessible.

In my view, we need to look forward, not back. Rather than putting a lot of effort into correcting the accessibility failures of the last ten years, we should put in place a process that embraces the diversity of technologies, which are now available, so long as they are used in a way that is accessible. The regulators and the web community as a whole should then take a more active role in ensuring web content meet the requirements of WCAG 2.0.

I am keen to read the opinion of others on this issue as I suspect the approach outlined above will not be acceptable to some people.


  1. So I don’t work on selling these evil formats… and in part I agree and in part I don’t.

    The idea of a “moratorium” on old content isn’t something I support at all. The way that the basic legal requirements are framed, there is an effective moratorium on anything unless it causes an actual problem to an actual person (so problems like the fact that we are losing our history by collecting it in digital formats that we may or may not be able to read don’t get a look in – although that’s better than the huge amounts of thermal paper in the Public Records Office where it is no longer possible to read the critical documents from the 1970s).

    Recognising that HTML and CSS aren’t the only things that can be accessible (and that they can be as bad as anything else) was actually a preoccupation of WCAG 1.0, and a careful look at it shows that while it is clearly focused on W3C technology, it can easily be applied to PDF and it isn’t too difficult for an experienced professional to apply it even to a flash application. I welcome the fact that WCAG 2.0 extends that understanding by making it more explicit.

    There are other reasons for choosing open and freely implementable standards-based technology. I think that accessibility benefits from a preference for such technology, but with the reality being that Peter seems to be doing a good job selling his products to the people, I clearly agree that we need to think well beyond “HTML and CSS are the only way”, and particularly in the accessibility community.

    Flash started to get its accessibility story straighter almost a decade ago. The open equivalents (SVG, javascript and ARIA) also started at that time, but the state of http://www.w3.org/TR/svg-access (written way back then) and the fact that it is still ahead of the state of the art in implementations shows that open standards often develop slowly. There is a clear argument that using these technologies can be a *more accessible* approach to some tasks, just as there is a clear argument that in other cases they are simply a bad idea.

    So, interesting post. I hope it makes people think harder about the devilish details, not just sweeping statements…

  2. Interesting article. I commend your optimism. However, having just tried to tag a hundred page PDF document (and failed) I think there is a long way to go before technologies such as PDF and Flash really support accessibility.

  3. Roger, I wonder if the New Zealand government took the approach it did because of a lack of information about technologies that are accessibility supported, and an unwillingness to let the new standard sit in limbo?

    While I think the idea of being technology neutral is appropriate in a medium that is moving very fast, it doesn’t help that
    a) there isn’t a list of technologies that are accessibility supported (or not)
    b) a lot of work needs to be done to decide was is/isn’t accessibility supported
    c) the definition in WCAG 2.0 has some vagueness in it – what level of AT support qualifies as ‘supported’?

    At least AGIMO is coordinating some work on this. I’m sure everyone in Australia who cares about accessibility will be monitoring this activity closely.

  4. I’m a firm believer in open standards getting the job done and broad accessibility. I ue braille and speechtechnologies from the small to the large in my daily life and have found barriers which transcend the web. I however believe that good standardization will only be achieved when we use the w3c as a subset of it.

  5. I don’t think the issue is whether we ignore new tech or not – we really can’t.

    To me the problem is how to ensure that accessibility can be incorporated into the new tech. More importantly, how can we help the “amateur” user (instructors, teens, grandma) create accessible content without attending a week-long seminar?

    For instance, you can create a tagged PDF, but only if you invest in the full-featured Adobe Acrobat Professional. Using the daefulat Print as PDF doesn’t cut it (at least not on a Mac), even if you begin with a Word file with Heading 1/Heading 2 within it. To make it worse, accessibility is buried under an “Advanced” option.

    If you’re NOT a Web Professional (and most generators of PDF files are not Web professionals), it sounds like a rip off and a major pain. No wonder most PDF files are in accessible. It won’t improve until Adobe or a competitor builds in default options for accessibility in a PDF like in Dreamweaver…and makes it cheap.

    So…since most HTML editors like Dreamweaver, now enhance accessibility, I do recommend using HTML whenever possible at the moment to anyone creating content.

    P.S. Flash requires a LOT of Actionscript know-how and fiddling to implement key items like keyboard functionality. I don’t see that many accessible Flash objects will be created until Adobe implements the kind of easy accessibility checks that are in Dreamweaver.

  6. Roger well done. I agree with you about the moratorium on previously published material, although there will be exceptions where material, which is needed and is current, should be made fully accessible. I manage online services for a federal government agency and the requirements for accessibility and useability are mandatory, but due to the amount of material generated and published looking backwards is not possible. One can only do the best one can within the parameters of their operating environment.

  7. Standards don’t make anyone design accessible sites; social pressure does. In the US, companies care about Section 508, a worthless, 11-years-outdated set of guidelines, not because they care about accessibility (and certainly not because these guidelines promote modern-day accessibility in any way) but because Section 508 compliance is the law (for anyone dealing with the government or accepting government money) and breaking the law is viewed by society to be unacceptable. Society determines if it’s acceptable to hit a pregnant woman in the stomach, hang a black man, kill a lesbian, or torment a guide dog. Standards just don’t have gravity; they’re “good ideas.” Until society decides that nothing short of universal access is acceptable, writes it into law, and stands by those laws in court (meaning organizations like the National Federation of the Blind continue to win cases), accessibility will remain a buzzword.

Leave a Reply

Your email address will not be published. Required fields are marked *