Re: Costs of testing with Silver

I wonder if we can restart this conversation with a mission or goal in mind.

Instead of discussing cost of procurement, cost of testing, cost of remediation or any other associated cost generally associated with a business, can we acknowledge the cost to people without access?
Accessibility guidelines are a method to aid in ensuring people can access the web.

The entire and only two reasons that any public policy or legislation (anywhere in the world) has ever specifically cited the WCAG x.x is because it was the most comprehensive guidance currently available at the time the legislation was considered AND that guidance was published by the W3C as a recommendation which is considered a web standard.

The only reason that any said legislation cites a compliance or conformance requirement is because a strict and explicit conformance is part of WCAG.

Any new guidance that is also comprehensive and a recommendation (standard) would supersede the previous guidance when drafting any new policy or legislation. The only constant is change.

Supporting legislation and policy is not the purpose of accessibility guidelines. People are.

If starting from scratch, but using everything we have collectively learned from research and experience:

Can we create new guidelines that support (more) people and solve all (or most of) the problems that research revealed within the current guidelines?

Can we create a conformance model that is not strict and explicit to technical details, but is to human factors?

Can we do that while also considering the impact on (all) stakeholders?


Charles Hall // UX Architect, Technology

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From: Mark Tanner <mktanner@btinternet.com>
Date: Wednesday, September 5, 2018 at 7:49 AM
To: Silver Task Force <public-silver@w3.org>
Subject: Re: [EXTERNAL] Costs of testing with Silver
Resent-From: Silver Task Force <public-silver@w3.org>
Resent-Date: Wednesday, September 5, 2018 at 7:48 AM

I am writing to support and slightly expand upon the points made by John. WCAG 2.0 is currently referenced throughout the EU as a key component of digital accessibility legislation.
As John pointed out, the EU standard EN 301 549 lays out "Accessibility requirements suitable for public procurement of ICT products and services in Europe" http://mandate376.standards.eu/standard

This standard not only references WCAG 2.0 as normative, but specifically  details all the WCAG 2.0 success criteria at reasonable length http://mandate376.standards.eu/standard/technical-requirements/#9

However, as from 23 September, 2018, the standard has a wider application beyond procurement.  EU DIRECTIVE  2016/2102 on digital accessibility https://eur-lex.europa.eu/eli/dir/2016/2102/oj , which comes into legal effect in all EU countries (including the UK) requires that:

•       Public sector websites created after 23 September 2018 need to comply with the accessibility requirements from 23 September 2019

•       Public sector websites created before 23 September 2018 need to comply with the accessibility requirements from 23 September 2020

•       Public sector mobile applications  need to comply with the accessibility  requirements from 23 June 2021.
Paragraphs 36 and 37 of EU DIRECTIVE  2016/2102 are clear:
“36. The accessibility requirements set out in this Directive … describe what must be achieved in order for the user to be able to perceive, operate, interpret and understand a website, a mobile application and related content …
“37 … Those principles of accessibility are translated into testable success criteria, such as those forming the basis of the European standard EN 301 549 V1.1.2  ….Pending publication of the references to harmonised standards, or of parts thereof, in the Official Journal of the European Union, the relevant clauses of European standard EN 301 549 V1.1.2 (2015-04) should be considered as the minimum means of putting those principles into practice.”
As EN 301 549 currently uses WCAG 2.0 as its normative reference for all public sector websites this means that all public sector websites and applications throughout all EU countries will need to meet WCAG 2.0.
It is also important to note that EN 301 549 is currently being updated to map to WCAG 2.1 to level AA). See Explanatory Memorandum To The Public Sector Bodies (Websites And Mobile Applications) Accessibility Regulations 2018 No. 852 http://www.legislation.gov.uk/uksi/2018/852/pdfs/uksiem_20180852_en.pdf

All this clearly has important implications for any shift in the future from WCAG to Silver.
Mark Tanner
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