Input on Changes in Level Grouping

Hello and thank you for your work on WCAG!
I was looking at the "What We're Working On<https://www.w3.org/WAI/update/>" page which led me to the WCAG 2.2 Draft<https://www.w3.org/WAI/standards-guidelines/wcag/new-in-22/#changes-to-the-22-draft>. I noticed that in the recent draft that 2.4.7 Focus Visible was moved back to Level AA and that 2..4.13 Focus Appearance was moved to Level AAA. Since I do a lot of web accessibility reviews for conformance with WCAG, I wanted to express my concern on those changes.

  *   2.4.7 Focus Visible. During my testing, I ALWAYS come across issues where there is no indication of the visible focus for keyboard. Even on sites that do a pretty good job on this, I can usually find areas where they fail this criterion. In most cases, the problem is persistent enough that a keyboard-only user would have difficulty interacting with the page content. Moving this criterion to Level A seemed like the right decision especially since most automated scanners never check for this. I am curious as to why it was moved back to Level A as that would seem to minimize the importance of this criterion.
  *   2.4.13 Focus Appearance. I thought this criterion was way overdue. During my testing, even when sites provide a visual indication of focus, it is often difficult to discern that visual indicator. Providing a specific criterion that addresses this is important in my opinion and is important enough that is shouldn't be moved Level AAA. Looking through what the success criterion expects, it should not be difficult to apply. Which is why I am also curious as to why this criterion was moved from Level AA to Levell AAA.
Changing these criteria to Level AA and Level AAA seems like a backwards step considering how important the visual indication of focus is keyboard-only users. We often are asked to review issues that are alleged in web accessibility legal complaints, and the lack of a visual indication of focus is often included in those complaints. Reducing the importance of these will not help site owners understand the importance of this aspect of accessibility. Please consider moving these back to Level A and Level AA, respectively, for the released version of WCAG 2.2.
Thank you!
--Jeff
Jeff Singleton
Principal
jeffrey.singleton@convergeaccessibility.com<mailto:jeffrey.singleton@convergeaccessibility.com>
+1 (425) 390-4605
+1 (425) 306-3123 mobile
Let's chat! Book a time here<https://convergeaccessibility.com/schedule-a-call/>
[Converge Accessibility. Narrowing the Digital Divide.]<https://convergeaccessibility.com/>