Add a Disclaimer

One option to address the possibility that a publisher might have missed some minor issues during an accessibility evaluation is to include a disclaimer in the EPUB Package Document metadata.

To enable the embedding of these types of disclaimers, this document proposes a new disclaimer property in the EPUB accessibility properties namespace [[EPUB-A11Y-11]]. The full definition of this property is provided in .

No changes are necessary to the EPUB specifications or epubcheck to use this property. Publishers interested in this approach are encouraged to experiment with its use and report on its utility to the Task Force.

This property would be optional to include in the metadata but would allow the publisher to provide a clarifying statement that they have checked the EPUB Publication for conformance to the best of their abilities. The Accessibility Task Force is not proposing a boilerplate statement for all publishers to use with this property. Rather, publishers who want to make disclaimers are expected to craft the statements in consultation with their legal departments.

Although the exact wording of the statement is at the publisher's discretion, the Task Force recommends publishers provide contact information for reporting failures to make it easier for users to provide feedback. The objective of a disclaimer is not to absolve the publisher of responsibility for issues that do slip through.

The potential drawbacks of this approach are: 1) it may give the appearance that all publications that claim conformance contain errors; and 2) it may be abused by unscrupulous actors to claim conformance while not performing any detailed analysis of their content.

The Task Force expects publishers to only use this property after performing thorough evaluation of their content or going through a thorough process of certifying the production processes, but there is no way to control how the metadata gets used. In environments where there are contractual and/or legal obligations to provide WCAG-conformant content, abuse of disclaimers will not provide cover for those misusing the property, so market forces will help curb some excesses.

Avoid Conformance Claims

Another potential approach to the problem is to not make a claim of conformance to the EPUB Accessibility specification [[EPUB-A11Y-11]] in an EPUB Publication. This would avoid the publisher having to state a specific level of WCAG conformance.

Since that specification would no longer be followed, the author can omit adding a dcterms:conformsTo property. In its place, authors are recommended use the a11y:certifierReport property to link to a detailed report such as a VPAT. That report could detail the conformance, or lack thereof, with more context than would be possible in the EPUB Publication.

This approach offers no more certainty that errors have not have slipped through, but the author could make unofficial claims such as "substantively" conforming to [[WCAG2]] in their reports.

Some potential drawbacks to this approach include:

1. Without a conformance claim, the publication may not register as accessible in vendor ingestion systems or in reading system processing. Users, in turn, would not be able to easily search for the publication.
2. Users may not be able to access the information in a linked report, especially if the publication does not register as having been accessibility checked. Links to external web sites are not generally trustworthy, so vendors and reading systems may not provide access. Similarly displaying an embedded report is a potential security risk.

Add a New Discoverability Conformance Level

This option is similar to the preceding approach, but adds a new conformance identifier to the EPUB Accessibility specification [[EPUB-A11Y-11]] that indicates the publisher has only met the discovery metadata requirements.

This approach would also rely on the publisher providing a link to a report to explain their actual conformance, or lack of, so has the same drawbacks as above. Its only advantage relative to that approach is that it disambiguates publications publishers have checked against the EPUB Accessibility specification from those they have not.

Wait for WCAG 3

The final option is to not try to solve this problem for [[WCAG2]] and wait on the development of WCAG 3, the next major version. It is expected that WCAG 3 will provide a scoring model for publications that will allow for some tolerance of minor issues. In this model, if issues are found after the fact, they would not necessarily invalidate the conformance claim if they are minor in nature.

The obvious drawback of this approach is that relies on the current status quo being palatable to publishers until development of WCAG 3 is complete and its adoption widespread. The assumption here is that there is already a level of tolerance in the market for minor issues in content that claims conformance to [[WCAG2]] so publishers should not be overly concerned about their content being perfect.