Introduction
This section covers the basics – what you need to know about the update and how to provide feedback. Read the full article for more interesting details.
The Accessibility Guidelines Working Group (AG) has updated the W3C Content Accessibility Guidelines (WCAG) 3 Working Draft. This post presents an overview of this update as well as AG co-chairs thoughts on the standard’s direction.
The December 2024 update includes three guidelines that were used to explore how WCAG 3 might be structured:
These guidelines are still developing and need a lot more work before they are ready to use. The AG would like feedback from you on whether the content organization and the labels (guidelines, foundational requirements, supplemental requirements, and assertions) make sense.
Key questions for you to consider when reading the 3 developing guidelines:
- Does this overall approach help you understand what needs to be done to make content accessible?
- How can it be improved?
The update also includes changes to the conformance section such as the overall approach to conformance and Section 3.1.1 Only accessibility-supported ways of using technologies. You may notice that explanatory content from previous versions is no longer in WCAG 3. This content has been moved to the Explainer for WCAG 3, which was also updated.
Key question for you to consider when reading the conformance section:
- Do you have concerns about the direction conformance is moving?
We publish twice a year to give you visibility into the working group progress and an opportunity to give feedback. We welcome constructive comments on the direction conformance is developing. We recommend reading this post, the conformance section, and the explainer before sending feedback.
Should you wish to provide feedback after reading, please file a GitHub issue or send an email to public-agwg-comments@w3.org (comment archive). Please create 1 GitHub issue or send 1 email per topic – it makes our work much easier which leads to faster standards creation.
Caveats
These may seem dull but these pointers are really important to remember.
The majority of this draft is still Exploratory. Even the most mature portions have only just moved into the Developing stage of our content maturity process. We expect them to remain in Developing for a while.
What does that mean? It means this draft content will change.
The Accessibility Guidelines Working Group wants public feedback on WCAG 3 early and often.
Remember:
- This WCAG 3 draft doesn’t replace WCAG 2. WCAG 2 is used around the world and will still be required by different countries for a long time to come.
- Public feedback is an important part of the W3C process and the Accessibility Guidelines Working Group (AG) takes the comments we receive seriously.
- If you want to learn more about WCAG 3, please read the WCAG 3 Introduction.
Do not use this draft content as a standard or revise your accessibility program and goals to meet the contents written in this draft. We are not there yet! If anyone tells you otherwise, they are uninformed or lying.
WCAG 3 Structure
From here on, the content reflects the co-chairs thoughts about the direction this draft is taking. Not all AG members may agree but we hope it gives insight into the general direction and progress made.
The proposed structure relies on Guidelines broken out into Requirements and Assertions. AG will be discussing including Recommendations.
Guidelines
Guidelines are written as user-centered outcome statements to make them easy to understand. These had been called Outcomes before and these were at various levels of detail. This draft clarifies the structure of Guidelines and Requirements.
Guidelines are organized into groups based on what is typically tested by that guideline. POUR (perceivable, operable, understandable, and robust) is an excellent way to teach guidelines but many people reorganize WCAG 2 Success Criteria (SC) to facilitate testing. The Web Accessibility Initiative (WAI) plans on building a tool that tags WCAG 3 requirements and allows users to reorganize them by POUR or other tags.
Requirements
Requirements are comparable to Success Criteria. AG changed the name so they are easily distinguishable as the required portion of this standard. Requirements can be tested with repeatable results, though just like in WCAG 2, the requirements may need manual testing and educated judgement.
Requirements are further divided into:
- Foundational Requirements – These requirements present core needs that must be met to support people with disabilities. These may be met by authors, operating systems, browsers, or assistive technology but they must be met. AG expects the list of Foundational Requirements will be similar to A & AA WCAG 2.2 with additional support for disabilities not included there. For example, AG is exploring requirements that only apply to specific languages or writing systems. These requirements would include conditions and a plan for internationalization.
- Supplemental Requirements – These requirements may include meeting a higher threshold than the Foundational requirements (think enhanced color contrast in WCAG 2) or they may best apply in specific situations.
Assertions
Assertions have been discussed in previous drafts and continue to be an important part of WCAG 3. When making a conformance claim, assertions would allow the writer to state that they used a process to improve or verify accessibility such as using an accessible design system, assistive technology testing, usability testing, or plain language testing.
We are still working out how assertions will fit. For this draft they are included under Guidelines but they may be moved into their own section as we are finding that the same assertion covers multiple guidelines. You can read more about Assertions in Section 5.3 of the WCAG Explainer.
Recommendations
The group will be discussing adding in recommendations. Recommendations are best practices that improve accessibility but are not reliably testable. These have some overlap with Assertions and the group will need to spend time discussing this option and and trying these out before making a decision. You can also join the discussion about recommendations on GitHub.
The Goldilocks Organization Problem
One of the complexities in WCAG 2 is that a single sentence SC includes layers and layers of complexity. That makes the SC hard to write and hard to understand. We are attempting to break the complexity out into separate parts and create a structure that helps readers understand when to use each part. The challenge is finding the best balance between testability and complexity.
As we worked through this, decision trees became very helpful for the group. We have included some decision trees in this draft to get public feedback.
From a chair perspective, we don’t think the current organization is quite right though we do think it is on the right track. Some items we think need more work include:
- Moving the details that support testing out of the How To documents and Methods and back into the normative document.
- Refining decision trees by writing more examples.
- Trying out decision trees that include all the Requirements, Assertions and Recommendations that could support the guideline. In the current draft the decision trees only include the Foundational Requirements.
WCAG 3 Conformance
The AG has decided that:
“The most basic level of conformance will require meeting all of the Foundational Requirements. This set will be somewhat comparable to WCAG 2.2 Level AA.
Higher levels of conformance will be defined and met using Supplemental Requirements and Assertions. AG will be exploring whether meeting the higher levels would work best based on points, percentages, or predefined sets of provisions (modules).”
This short statement reflects a lot of research and testing to narrow down the approach. As a reminder, this is still in draft. The AG will spend the first half of next year working on the guidelines. The AG may, after testing, decide against this approach but this is the direction we will be moving until we prove it doesn’t work.
Like WCAG 2, WCAG 3 will have a set of core requirements and an extra set of requirements. Unlike WCAG 2, conformance levels won’t map directly to those sets. The most basic level of conformance to the standard will be the Foundational Requirements plus some subset of the Supplemental Requirements and Assertions.
AG will be exploring whether the author should select which Requirements and Assertions to meet in order to reach a certain number based on points or percentages OR whether AG will create modules of related content for authors to meet based on certain criteria. For example, a module about plain language may be more important for educational materials than for other types of materials.
As an example of how this might work, the most basic level of conformance (Bronze perhaps) might ask that content meets all the Foundational Requirements and 10% of the Supplemental Requirements OR all the Foundational Requirements and a plain language module. It is worth noting that many plain language requirements are being worked on as Foundational, rather than Supplemental requirements or assertions. However, some will likely fall into the optional grouping.
WCAG 3 can only recommend conformance to its own technical specification. It will be up to governments to write that conformance into law. One of the biggest risks of the proposed approach is that the legal standard will simply point to the Foundational Requirements, mimicking WCAG 2. However, the AG deemed that risk less severe than the risk that entire groups of people with disabilities would be left out if the conformance model gave authors the ability to choose which requirements to meet without constraints.
Accessibility Supported
WCAG 2 includes the concept of accessibility supported and conforming alternate versions but in our experience they rarely comes up in conversation outside the working group.
In WCAG 3, we are working to make these ideas much more visible. WCAG provides guidance for authors, not operating systems, browsers, or assistive technology. That said, whenever publicly available user agents like these are able to support accessibility requirements it reduces the burden on the author.
In WCAG 2, the AG does not write guidance that user agents already support. There is no criteria for visible pointers because pointers are typically visible. The challenge with this gap is that when new technologies are developed, there is no complete list of criteria for new technology to meet. We are exploring the idea of using the decision trees in part to allow WCAG 3 to age gracefully by providing a list of criteria that user agents and new technologies can use to support accessibility. If user agents meet WCAG 3 guidance, authors could then focus on not breaking that support rather than building it in.
Next Steps
AG will spend the next 6 months focusing on moving all the guidance to the developing stage. This will include removing some guidance that needs additional research and looking for research partners willing to conduct that research. At the same time, we will be working to refine the structure in this draft and continue to address difficult topics such as third party content and complex, rapidly updating content.
Rachael, Alastair, & Chuck
