New Advice on WCAG for Software and Documents: Part 1

Update: On October 8, 2024, the W3C published updated guidance on Applying WCAG 2 to Non-Web Information and Communications Technologies (WCAG2ICT). The final version has very minor changes from the update described in the two blog posts in this series.

WCAG2ICT is referenced by the ADA Title II Regulations on Web Content and Mobile Accessibility and is likely to influence updates to the EN 301549 standard. This resource can be a valuable reference for creating accessible documents, mobile apps, kiosk software interfaces and other software.

In September 2013, the W3C published a Working Group Note titled Guidance on Applying WCAG 2.0 to Non-Web Information and Communications Technologies (WCAG2ICT).

The aim was to describe how the Web Content Accessibility Guidelines (WCAG) 2.0 and its principles, guidelines, and success criteria could be applied to non-web Information and Communications Technologies (ICT), specifically to non-web documents and software.

It set out to provide “informative guidance”, which means the guidance is not normative (required for conformance) and doesn’t set requirements.

Since then, WCAG has been updated to version 2.1 and then 2.2, so the WCAG2ICT Task Force put a considerable amount of time and effort into drafting an updated Note taking into account the changes in WCAG.

Now, after a year representing TPGi on the WCAG2ICT Task Force, I’m happy to report our new draft is ready for broad public review.

The Draft Note was published on July 2 this year as Guidance on Applying WCAG 2 to Non-Web Information and Communications Technologies (WCAG2ICT).

Wait: Non-Web what?

This is all about using WCAG for “non-web ICT” — documents and software that aren’t running straight from a URL in a browser. 

Examples of non-web software: 

  • Apps for mobile or tablet
  • Apps and games for smart TVs, gaming consoles, or wearables
  • Applications for desktop computers
  • Interactive software that’s built into any of those devices, including the user interface of the operating system or home screen
  • Interactive content on the screens of appliances, office equipment, payment terminals, or self-service kiosks

Examples of non-web documents (where they can appear outside of web pages): 

  • Office documents
  • PDF documents
  • Email messages
  • Video or audio files

Non-web ICT

How can WCAG apply to all of those things?

Back in 2013, the guidance was, in a nutshell: applies directly as written. 

Unveiling the new guidance (drumroll): mostly applies directly as written. 

Naturally, there’s a bit more to it than that. 

From the beginning, WCAG has been technology-neutral as much as possible. Nevertheless, if you try to apply all 55 WCAG 2.2 level A and AA Success Criteria (SC) to all those kinds of software and documents, there are some head scratchers.

This is where the new draft of WCAG2ICT aims to help.  For example, how can SC 1.4.12 Text Spacing apply beyond web pages? 

1.4.12 Text Spacing: In content implemented using markup languages that support the following text style properties, no loss of content or functionality

Surprise! Despite the mention of “markup languages”, this one applies as written. WCAG2ICT explains how this is possible by adding notes to SC 1.4.12

Note 1 

This success criterion only applies to non-web documents and software that are implemented using markup languages and allow the user to modify these text spacing properties. 

Note 2 

“Content implemented using markup languages” includes parts of software that use markup internally to define a user interface. Examples of markup languages that are used internally to define a software user interface include but are not limited to: HTML (e.g., in Electron applications or iOS application Web views), XAML, XML (e.g., in Android application layouts), and XUL. 

Note 3 

There are several mechanisms that allow users to modify text spacing properties of content implemented in markup languages. For example, an eBook technology may have an available user agent that allows users to override document text styles, or a software application may provide a “user style sheet” facility to modify the appearance of the software’s own user interface. This success criterion does not mean that documents and software need to implement their own mechanisms to allow users to set text spacing; however, when such a mechanism is available, the success criterion requires that content respond appropriately to it. 

This example demonstrates a couple of patterns you can expect throughout WCAG2ICT. 

  • WCAG2ICT sticks closely to the normative text of WCAG. It doesn’t add requirements —SC 1.4.12 starts with “In content implemented using markup languages,” so WCAG2ICT does not expand it to other kinds of text.
  • Likewise, WCAG2ICT doesn’t remove requirements — compared with the web, there will be fewer cases where SC 1.4.12 is helpful for software and documents, but they still exist, and the SC applies to them. 
  • Listing a few examples is as close as WCAG2ICT will come to technology-specific guidance. The W3C doesn’t want to play favorites, and they do want to remain as applicable as possible to the world’s future technology innovations. 

Some things haven’t changed (much)

The overall structure and approach are the same as the 2013 version: 

  • Quote the WCAG Level A or AA SC
  • Provide word substitutions without changing the intent of the SC
  • Add Notes explaining how the SC can apply to non-web information and communication technology (ICT)

Some of the word substitutions state the obvious, while some of them provide crucial guidance. For example, where WCAG mentions a “page” or “web page,” keeping the same intent of the SC for non-web ICT can mean different things in different contexts. 

  • In some SCs, a phrase like “on a web page” has the same intent as “anywhere in the content.” WCAG2ICT’s substitution for the phrase is a trivial editorial annotation. For example, in SC 2.4.3 Focus Order, “If a Web page can be navigated …” becomes “If non-web documents or software can be navigated …”
  • In other SCs, a phrase like “of each web page” says something about the whole page as a discrete unit. In such cases, we decided that the equivalent for non-web ICT is the entire document or software program. This is an important distinction, not always obvious. Example: SC 2.4.2 Page Titled

As in 2013, we couldn’t find a way “to unambiguously carve up non-web software into discrete pieces.” So, despite some kinds of applications being organized into screens, which would benefit users by providing things like screen-specific titles and consistent navigation, we could only equate a “web page” to a whole “software program.”

As a consequence, the following four WCAG criteria continue to apply only to a “set of software programs”.

  • SC 2.4.1 Bypass Blocks
  • SC 2.4.5 Multiple Ways
  • SC 3.2.3 Consistent Navigation
  • SC 3.2.4 Consistent Identification

Exactly what constitutes a “set of software programs” and how these SCs could be applied remains the subject of considerable discussion.

For WCAG2ICT’s own summary of what’s changed since 2013, see Comparison with the 2013 WCAG2ICT Note

In my next post, I’ll dive a little deeper and highlight some important differences between WCAG2ICT and WCAG alone, whether they are new since 2013, or the same as before. 

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Categories: Technical

About Mitchell Evan

I’ve served on the WCAG2ICT Task Force since 2023. I enjoy figuring out standards and regulations, user needs, and technical solutions, all converging on great user experience for everybody including people with disabilities. I’m neurodivergent. Steve Faulkner calls me “Laird of the VPAT,” whatever that means.