ATAG 2.0

Dear ATAG working group,

First of all, thank you for making the ATAG 2.0 last call working draft available. I have read the document on and I really liked it.

However, I do have one comment.
Currently, ATAG 2.0 does not address the subject that is related to transparency, compliance management and accountability. The importance of accountability in online information and service delivery is growing. Authoring tools can play a key role here, since checking assistance - and helping authors decide on potential web content accessibility problems – is not only valuable on an operational level, but also on the managerial level.
Technically, it is easy to offer a mechanism to capture and store the results of checks performed by authors[1]. By doing so, authoring tools become key instruments in providing input for compliance management systems. Such systems help website owners to better organise their accountability, resulting is more transparency. Not only regarding the level of conformance to the web accessibility specification, but also regarding the performance of website owners on the issue of web accessibility.

[1]: The Evaluation and Report Language (EARL) is W3C's specification to capture and store evaluation results

The following success criteria in ATAG 2.0 are related:
•  Part B: Support the production of accessible content
    •  Principle B.3. Authors are supported in improving the accessibility of existing content
        •  Guideline B.3.1. Assist authors in checking for accessibility problems
            •  B.3.1.1 Checking Assistance (WCAG)
            •  B.3.1.2 Help Authors Decide
            •  B.3.1.4 Status Report

I am not sure whether the subject can be successfully addressed in the context of above success criteria.
Therefore, I have not tried to fit my proposal into Part A or Part B.
I a aware that adding a Part C to ATAG 2.0 is an unlikely suggestion; please consider it just a placeholder for the concretization of what is described in above paragraphs.


Part C: Enhance transparency, compliance management and accountability

Principle C.1: Authoring tools offer capturing of evaluation results

Guideline C.1.1: Authors are able to re-use the results of evaluations against WCAG 2.0

Rationale: The results of accessibility testing are not only valuable during the process of  creating and editing content, but also for accountability purposes. Especially in situations where web accessibility is required by law, website owners are expected to be able to show proof that their content is successfully checked against W3C's web content accessibility guidelines.

Capturing the results of accessibility evaluation performed by authors has several advantages, including:
    • enabling the re-use of self-evaluation results to substantiate WCAG 2.0 conformance claims;
    • enabling auditing as a credible alternative to product inspections;
    • enabling aggregation of evaluation results (for research purposes, monitoring and ranking);
    • enhancement of the scope of large-scale monitoring of web accessibility, which at present often is limited to a subset of WCAG 2.0 (i.e. what can be reliably programmatically determined);
    • supporting the transition of web content accessibility management from a product-based approach to a process-based approach. This will especially help integrating the subject of web accessibility into complex and/or multi-stakeholder environments.

C.1.1.1 Capture of checking assistance results:
If the authoring tool provides authors with the ability to check against success criteria, the author can export the evaluation results, including the decisions that were made by the author during checking.



Please let me know if there is a need for clarification.

With kind regards,

Raph de Rooij
Logius, the Netherlands


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Received on Friday, 27 September 2013 13:48:53 UTC