Copyright © 2018-2021 the Contributors to the Silver Conformance Prototype Specification, published by the Silver Task Force and Community Group under the W3C Community Contributor License Agreement (CLA). A human-readable summary is available.
A new conformance structure is integral to Silver meeting the needs of people with disabilities, rapidly evolving technology, and the needs of regulators for clear compliance measurement. This editors' draft of a prototype of a conformance structure is based on the Silver research of 2017-2018, the results of the Silver Design Sprint of March 2018, and input from the AccessU Prototyping session of May 2018. This prototype is divided into three areas: Compliance, Measurement, and Accessibility Supported.
This is still a rough draft. Please comment on the general direction. Specific examples would be helpful.
This specification was published by the Silver Task Force and Community Group. It is not a W3C Standard nor is it on the W3C Standards Track. Please note that under the W3C Community Contributor License Agreement (CLA) there is a limited opt-out and other conditions apply. Learn more about W3C Community and Business Groups.
Silver Conformance Prototype is published as a joint effort of the Silver Task Force of the Accessibility Guidelines Working Group and of the W3C Silver Community Group. It is a work in progress, and comments are welcome as Github Issues or by email.
This is the first draft of the prototype. It is a combination of suggestions from the Silver Design Sprint final report, public input from the Silver meeting at AccessU, and discussion in the Silver meetings. See the changelog for specific changes.
The research done in 2017-2018 by the Silver Task Force, the Silver Community Group, and the research partners was used to identify the key problem statements in the area of conformance. See the Silver Research Summary slides for more detailed information.
The Problem Statements related to conformance are summarized below. See the Silver Problem Statements wiki page for the complete problem statements.
Constraints on What is Strictly Testable. The requirement for strict testability for WCAG success criteria presents a structural barrier to including the needs of people with disabilities whose needs are not strictly testable. Guidance that WCAG working group members would like to include cannot be included. The needs of people with disabilities – especially intellectual and cognitive disabilities – are not being met.
Human Testable. Success criteria are measured by different standards and by people who often make subjective observations. Because there's so much room for human error, an individual may believe they've met a specific conformance model when, in reality, that's not the case. The ultimate impact is on an end user with a disability who cannot complete a given task, because the success criteria wasn't properly identified, tested and understood.
Accessibility Supported. This is poorly understood, even by experts. Users experience difficulty understanding what qualifies as a content technology or an assistive technology; difficulty quantifying assistive technologies or features of user agents; claiming conformance with inadequate assistive technology; and difficulty claiming conformance.
Evolving Technology. Consider a more general approach that is not explicit and is flexible to the differences in technologies as they evolve.
The Silver Design Sprint was a two-day face-to-face meeting of 30 experts in various areas of accessibility, including:
The Report of the Silver Design Sprint contains suggestions from the groups that address the Problem Statements. The suggestions related to conformance can be summarized as:
Conformance relates to the ways of measuring whether or not accessibility guidance has been implemented correctly. For the purposes of this prototype, the conformance suggestions are grouped into three areas.
While Overall Conformance was not directly addressed as part of the Silver Design Sprint, a number of suggestions related to overall conformance were discussed. A key suggestion originated from Eve ??, a lawyer formerly a part of the Office of Civil Rights. She suggested that Silver members study the LEED Certification for green buildings for inspiration for a more flexible method to measure overall Silver Conformance. The LEED program uses a point system, that can varies by the type of building (Homes, Commercial, Neighborhoods, etc) and within each type, assigns a level: bronze, silver, gold, platinum. Advantages of this system include:
Silver could look have a conformance model where individual guidance is evaluated by different types of measures, like:
The individual guidance could use the type of test most appropriate for the guidance. The results of the measures are scored by a point scoring system that could be different for different types of sites or apps. The score is then used to determine the level: Bronze, Silver or Gold. Sites that currently meet WCAG 2.x AA could be grandfathered in at Bronze level. Sites that also meet the new content could be Silver level. Sites that go beyond (example: user testing with people with disabilities) could be gold level.
Any site, application or product that currently meets WCAG AA would be grandfathered in at Bronze level. Most accessibility testing that can be performed with automated tests would probably fall under bronze level. Existing pass/fail tests associated with WCAG 2.0 success criteria would apply to points under Bronze level.
Silver level sites, apps, or products would meet the requirements of Bronze level plus additional points. It was suggested that the Silver level include the new guidance that would be included to address the needs of people with cognitive disabilities, low vision, and other disabilities that are not easily measured with a pass fail test.
WCAG 2.0 and 2.1 use success criteria as the basis for determining conformance. That choice of structure has been very successful for 10 years and has resulted in WCAG 2.0 being accepted as a basis of accessibility regulation around the world. The unintended consequence of that decision became apparent during the development of WCAG 2.1. Task Forces who had worked for years identifying user needs and proposing success criteria found that their user needs could not be tested with a pass fail test, and therefore could not be included in WCAG 2.1. These proposals for success criteria were postponed to be addressed in Silver.
One subgroup of the Silver Design Sprint, Table 5, chose to focus on more flexible measurement of individual guidance.
A suggestion from the Silver Design Sprint which was also discussed at AccessU was the concept of "substantially meets". This would allow an organization to claim conformance to individual guidance where they have clearly put effort into meeting, but not fail because of a small number of bugs. For example, an e-commerce site with alternative text on thousands of product images would not fail because of one or two products where there was no alternative text. This needs thought to unintended consequences and organizations "gaming" the system to claim conformance without providing accessibility. Many people representing their companies accessibility departments were very interested in including this concept.
Sample of an individual test:
Accessibility Supported is a poorly understood part of WCAG 2 conformance. Although there are many interpretations of the meaning of Accessibility Supported, for this purpose, we are taking the meaning that Accessibility Supported requires the author who wishes to claim conformance to WCAG to demonstrate that their site, app, or product meets the success criteria for the assistive technology and user agent in the language of the user. When the assistive technology or user agent fails to provide the necessary feature in the language of the user, then the author is required to make up that lack to claim conformance. While this was a good idea, in practice, the unintended result was a proliferation of javascript code to solve accessibility supported problems that in many cases reduced usability for people with disabilities.
One subgroup of the Silver Design Sprint, Table 2, chose to focus on accessibility supported. This information needs to be summarized and developed for this prototype. The Overview of Table 2 provides a summary of their work and links to the photos of their prototypes.
One suggestion from AccessU prototyping meeting was that the W3C webplatform.org tests be augmented with accessibility tests to measure the implementation of the accessibility support features of the major browsers.
The following people participated in the Design Sprint of 2018 held in San Diego, California prior to the CSUN AT 2018 conference. We thank them for the generous gift of time that they donated to the Silver project.
These researchers selected a Silver research question, did the research, and graciously allowed us to use the results.