Re: Costs of testing with Silver

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