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Proposed WG answer for issue https://github.com/w3c/wcag/issues/538 (Do modals fail 3.2.1 On Focus)

From: Detlev Fischer <detlev.fischer@testkreis.de>
Date: Thu, 17 Jan 2019 07:12:55 +0100
Message-Id: <4FD8C878-CF23-4AE6-A0DD-469C0631683C@testkreis.de>
To: WCAG group <w3c-wai-gl@w3.org>
Proposed WG answer for issue 538, Clarify if modal dialog on page load is a failure of SC 3.2.1 + 3.2.5

We apologize for not yet having addressed this issue in our work for WCAG 2.1 as we had intended according to issue https://github.com/w3c/wcag/issues/170.

Reviewing the situation, the problem seems to be that there is broad consensus that the opening of new windows as a result of loading a page is a significant accessibility issue that should be covered by WCAG. The absence of obvious other SC to tie this Failure to explains the reluctance to remove the reference to AA SC 3.2.1 On Focus, because without that, it would only be tied to a AAA SC, 3.2.5 Change on Request. The rationale of keeping this reference has been challenged since SC 3.2.1 is scoped to situations where context changes as a result of focus being set to a user interface element. Opening a new window does not do that, but instead sets focus to the page (which is not a user interface component).

In terms of the effect on the user, the opening of a custom dialog as a result of  loading a page can be as much a disorienting event as the opening of a new browser window . However, in the discussion of this issue, it has been pointed out that there may be valid use cases for opening a custom dialog and setting focus to it which should not be considered a Failure. As it stands, a custom dialog is not technically a new window so it seems reasonable for now to apply a narrow interpretation to F52 and not include custom dialogs. The Working group will need to discuss the option of extending the text of F52 to bring automatically loading custom elements (and possibly new elements lke the native dialog element) into scope.

One way forward might be to modify F52 to narrow its scope to situations where after opening a new window, focus is set to user interface components on that new window. This change would then justify its reference to 3.2.1 On Focus. Another option is define a new Success Criterion that would be a better home for F51. These substantive changes will need more Working Group discussion before agreement can be reached. In the meantime, the working group shall again discuss, and this time decide, on the removal of the reference to 3.2.1 On Focus to end the current uncertainty over this issue.

Detlev Fischer PhD
DIAS GmbH - Daten, Informationssysteme und Analysen im Sozialen
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