Reasons we voted against 2.4.11 Focus Visible (RE: CFC Move WCAG 2.2 to Candidate Recommendation (Revised))

Hello AG WG,

We would like to provide some additional information about why we continue to press for cleaner and clearer language for 2.4.11 Focus Appearance.

Note that we are completely onboard and support this SC conceptually. We support providing additional clarity and expectations for the Visual Focus Indicator (VFI). At the same time, we are committed to Guidelines being clear, understandable, and implementable. We feel 2.4.11 in its current state does not meet this bar and therefore cannot support it.

Here is some information we provided to the Chairs previously and feel it may be helpful for the wider AG WG to understand our position.

  1.  2.4.11 is not written clearly.
     *   We sent out a couple of surveys to our internal team (included roles were front end developers, UX designers, UX researchers, project managers, and a11y specialists) to gather data about how understandable 2.4.11 is.

                                                         i.      Question: Do you understand how you would incorporate this criterion in your daily work?

           *   Yes: 16 (59%)
           *   No: 3 (11%)
           *   Maybe: 8 (30%)

                                                       ii.      Question: Do you have any comments on this criterion? (small sample of comments)

           *   “The minimum area calculations are extremely complicated - so much so that I feel like it will be very difficult to tell if the criterion is met or not.”
           *   “While the minimum area can be determined by digging in to the document its wording is confusing, particularly for less technical readers, and it will be difficult to determine conformance.“
           *   “I struggle to understand the language of the requirement, specifically, the language describing the minimum area. I only get it when I see the examples.”

Because slightly more than half of our team, with our training and resources, understand this particular SC, we feel strongly that the normative language of 2.4.11 is not sufficiently clear.

  1.  It is not uncommon for AGWG to mention being mindful of the needs of regulators/legislators. However, in the US at least, that means statutes and regulations need to be “clear on their face.” Without being clear, the legislation or regulation risks being either unenforceable or subject to the interpretation by lawyers, judges, and expert witnesses. Note that for our purposes, the statutory or regulatory language is essentially what we identify as the normative text. It is the normative text, standing alone, that needs to be clear to be statute/regulation-friendly.

Unclear language has the unfortunate effect of weakening the statute/regulation.

Primarily for the reasons above, we do not support including 2.4.11 in 2.2 with the current language.


From: Dirks, Kim (TR Product) <>
Sent: Tuesday, August 9, 2022 12:11 PM
To: Bradley-Montgomery, Rachael <>; WCAG <>
Subject: RE: CFC Move WCAG 2.2 to Candidate Recommendation (Revised)


As raised multiple times, we cannot live with 2.4.11 (Focus Appearance) and unfortunately our concerns have not been addressed.


From: Bradley-Montgomery, Rachael <<>>
Sent: Tuesday, August 2, 2022 9:03 AM
To: WCAG <<>>
Subject: [EXT] Re: CFC Move WCAG 2.2 to Candidate Recommendation (Revised)

External Email: Use caution with links and attachments.

My apologies, I used the incorrect URI. Please review<;!!GFN0sa3rsbfR8OLyAw!bnI-dulrpiL6uG8PyHlqjTIjnZoeg4sD2nDwCRoe4K-lrEbgKnCOChyA6Sm6gFUoezn-FvghJJ8lh4GTwGklUjmUWsX8SVQJ$>

The revised CFC is below.

Call for Consensus – ends Thursday August 11th at 23:59pm Boston time.
The Working Group has approved CFCs for all new normative content in WCAG 2.2 and it is ready to move to Candidate Recommendation.
The draft is at<;!!GFN0sa3rsbfR8OLyAw!bnI-dulrpiL6uG8PyHlqjTIjnZoeg4sD2nDwCRoe4K-lrEbgKnCOChyA6Sm6gFUoezn-FvghJJ8lh4GTwGklUjmUWsX8SVQJ$>
If you have concerns about this proposed consensus position that have not been discussed already and feel that those concerns result in you “not being able to live with” this decision, please let the group know before the CFC deadline.

Received on Saturday, 13 August 2022 19:23:03 UTC