RE: possible text to use or start from for applying TITLE SC to non-web documents

Hi Gregg and all.

 

Thanks for sharing your proposal.

 

Here are my follow-up comments.

 

I don’t think “in general” would be needed as a qualifier here. I am not sure if we have research to sufficiently judge whether the cases you are bringing up where “page titled” may not be applied to non-web documents are generalized or are edge cases. And if there is such research, we should carefully analyze it in order to be able to put this in.

 

Points 1 and 3 -- If “not all document formats support title attributes or metadata” and/or “not all storage formats support adding a title that would be attached when document is served/exported” then we should go on and explain that in these cases the SC is problematic to apply. Similarly, we should provide clear guidance for when the SC can indeed be applied as written when the document format supports titles, hence my attempt to make the group think about an alternative language to the SC that makes the latter clear.

 

Point 2 -- I am not sure which WCAG requirements you are referring to with “existing requirements in accessibility standards that you shall not lose accessibility information in document conversions”. I couldn’t find anything in WCAG that sets requirements about document conversion. And if we are talking about requirements that are in other standards, I don’t think WCAG2ICT can or should include them, because WCAG2ICT is informative and does not set requirements. To your point on violating either one or the other, WCAG doesn’t require titles to be “programmatically determinable” so even if you have a txt document whose title is the text from the beginning to the first two consecutive line break characters, you could still argue that this would pass WCAG because you’re not required to make this programmatically determinable.

 

More anecdotal, but to your point 4 I would argue that “untitled” would pass the SC because the title only needs to describe topic or purpose, WCAG normative language doesn’t say It needs to be meaningful or self-contained as to explain the whole piece of art. I would say this would pass because “untitled” is indeed describing the purpose of the document, which is to entitle the movie. So, after all, this example would be demonstrating how 2.4.2 Page titled can be applied to non-web documents, which is the kind of guidance I am missing if we do want to introduce and explain the problematic cases.

 

--

Daniel Montalvo Charameli

Principal Accessibility Specialist

W3C/WAI

 

From: Gregg Vanderheiden RTF <gregg@raisingthefloor.org> 
Sent: Thursday, October 9, 2025 7:13 PM
To: WCAG2ICT <public-wcag2ict-tf@w3.org>
Subject: possible text to use or start from for applying TITLE SC to non-web documents

 

This SC is problemmatic to apply to non-web documents in general for a number of reasons including but not limited to 1) not all documents formats support title attributes or metadata including txt files  2) if you combine (1) with the existing requirements in accessibility standards that you shall not lose accessibility information in document conversions, it would mean that one could not convert any document to txt format without violating one or the other provision  3) not all storage formats support adding a title that would be attached when document is served/exported  4) non-web documents includes movies and art -- and there may be copyright issues in providing a meaninful name other than one provided by the author  (e.g. a piece of art named “untitled’ should not be given a meaningful title).