SC 1.3.1 Info and Relationships - does it require grouping of links?

Are groups of links required to be grouped structurally to conform to WCAG
2 Level A?



One of the sufficient techniques for SC 1.3.1 is “H48: Using ol, ul and dl
for lists or groups of links (HTML)”.  The presence of a sufficient
technique does not mean it is required.  SC 1.3.1 states  “Information,
structure, and relationships conveyed through presentation can be
programmatically determined or are available in text. (Level A)”



The mentioned sufficient techniques also applies to SC 2.4.1 Bypass Blocks,
however, there are other methods to bypass blocks of information.  Thus, my
question is aimed at SC 1.3.1.



Placing related links in a grouping container such as DIV could meet the
requirements although no real semantic benefit is provided to users of
assistive technology using this type of grouping element.  There are a
number of other possible structures that could meet the requirements such
as nav, map, and ARIA roles such as grouping and ARIA landmarks like
role=navigation.  Text could also meet the requirements as well as perhaps
placing headings before or after the group.    It may be helpful to have
some clear examples of failures for this particular concept.



One example of user impact is that users of screen readers may have
difficulty understanding where a group of links ends and another starts.
In particular a group of links that also contain non-link text with the
links can be an issue.



Best Regards,



Jonathan