Thoughts about WCAG 3.0 Requirement Levels

With reference to Proposed Conformance Level Slides:

https://docs.google.com/presentation/d/1DlDxp8MCYXj3RWnFCCz13zsmM2fV4Wf8NbECKogdul8/edit?slide=id.g39fd5db5083_2_0#slide=id.g39fd5db5083_2_0


Views about Requirement Levels

Prerequisite: Reconsider using the term for requirements. It implies,
"before doing anything, ..." That cannot be a conformance level.

Mandatory: please reconsider using the term  as part of formal WCAG 3.0 in
the context of requirement levels - it is alright to use internally to
conceptualize what foundational level requirements should include.



Foundational Level and Supplemental should be the only two requirement
types to keep it simple.

Foundational can borrow from existing Level a and Level AA of WCAG 2.2 plus
other requirements to be deemed as the floor.

There could be optional requirements (like Level AAA in WCAG 2.X) and / or
be included in the Best Practices group.

Content owners should state which level they have met as part of their
accessibility statement / conformance claim - bronze /silver /gold.

Assertions should not be part of this statement.

There could be an accessibility policy document that contains an elaborate
set of practices followed internally that covers design, dev and internal
QA / testing posted publicly if warranted.

When someone doing an evaluation of a digital asset cannot do a 100%
assessment due to time /cost constraints or simply because the asset is too
vast, they might adopt a sampling technique or limit their reporting to the
scope actually evaluated.

At such times they might ask for specific representations from the content
owner about practices followed and they may choose to rely on such
assertions and reference them in their evaluation report. These assertions
could be part of the policy statement but are explicitly re-affirmed for
the purpose of a specific evaluation report.

The onus should be on the content owner to defend specific assertions
provided to the evaluator / auditor as true and correct.


About percentages for Bronze / Silver /Gold:

Is there a mapping between requirements (foundational, supplemental) and
functional needs? The counts against the functional needs will be helpful
to determine appropriateness of percentage based metric for bronze / silver
/ gold with due regard to how many supplemental requirements will commonly
pass based on N/A.



Humbly and Thanks,


Sailesh Panchang
Principal Accessibility Consultant

Email: sailesh.panchang@deque.com
Deque Systems Inc | - Accessibility for Good | www.deque.com

Received on Wednesday, 5 November 2025 15:08:27 UTC