Accessibility, Conformance, & Regulation (Compliance)

1

Goals for this conversation

• Understand some of the assumptions that we use individually and as a group in conformance conversations
• Develop a shared understanding or at least identify where we differ and acknowledge individual positions
• Begin the process of identifying what pieces of the accessibility remediation process fall within each category

2

Accessibility

• Whether people with disabilities can use content
• Accessibility exists on a continuum
• Content can be accessible (in principle) without:
• Any specific effort,
• Testing,
• Conformance claims, or
• Regulatory requirements
• Accessibility guidelines provide a list of criteria to measure accessibility but it is possible for:
• A site that is accessible to many people may not meet the accessibility guidelines entirely.
• A site that meets the accessibility guidelines may be inaccessible to some users
• Accessibility - independent of guidelines
• Guideline based accessibility - Dependent on guidelines (may overlap or be the same as conformance)

3

Testing and evaluation

• Checking whether, in the best judgement of the evaluator or user, the content is in fact accessible.
• You can have accessibility without testing or evaluation.
• Testing and evaluation can occur without making a conformance claim or being subject to regulatory requirements.

4

Conformance

• Adhering to technical standards
• In accessibility this is typically WCAG
• Practically this is following a set of steps that lead to a valid conformance claim as defined by W3C
• Conformance is defined by W3C, not regulators
• Standards conformance and regulation serve two different (though overlapping) needs and come from two different (though sometimes overlapping) groups. Those groups work in partnership to support each other in our respective spaces toward our goals which should ideally align perfectly, with neither sacrificing their own goal to support the other. [note we may need to add this to requirements]
• In the US many use VPATs as conformance claims

5

Policy / Regulation

• Policy includes regulation, self-regulation, and contracts
• Regulation (in this context) is a legal requirement by a governing body to follow an accessibility standard
• Compliance is adhering to regulation and other types of policies
• Includes who and what must comply and how they must comply
• May refer to conformance but is separate
• It is important that we coordinate
• W3C does not write policy for other organizations
• W3C can advise on technical aspects of policies when appropriate
• W3C could write an informative document recommending how regulation could use the conformance model but can’t dictate
• Regulation will be used for the rest of this presentation for these activities

6

Vision 1: Accessibility and Conformance largely overlap, Policy is mostly separate

7

Vision 2: Conformance and Policy overlap, Accessibility is mostly separate

8

Question:

• Does policy drive conformance?
• Does conformance drive policy?

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What falls in each category?

• Conformance options began a similar exercise
• Substantial Conformance/Example Scenarios
• https://www.w3.org/WAI/GL/task-forces/silver/wiki/Substantial_Conformance/Example_Scenarios
• Used different divisions
• Technical standards: Accessibility and Conformance
• Guidance: Informative documentation
• Policy: Regulators

9

WORKING AREA BEYOND THIS POINT

Nothing official!

10

Vision 1a: WCAG maximizes guidance to address accessibility coverage.

11

Vision 2a: WCAG limits guidance to current policy expectations

12

Desired end state? Regulators (grudgingly?) implement an expanded set of WCAG requirements

13

Vision XI: something something II

14

Sketch: Wishful vs realistic end state?

Note: this became too hard to try to convey intention

15

Accessibility

WCAG b

Accessibility

Accessibility

WCAG

Policy/�Regulation

WCAG a

Policy/�Regulation

Policy / Regulation

Sketch: Wishful vs realistic end state?

Note: this became too hard to try to convey intention

16

Accessibility

WCAG b

Accessibility

WCAG

Policy/�Regulation

WCAG a

Policy/�Regulation

Policy / Regulation (almost covering Guidelines)

WCAG Guidelines (almost covering all user needs)

User needs (largest area)