We are often asked what level of conformance a website needs to reach to be digitally accessible. Although guidelines exist, such as the Web Content Accessibility Guidelines 2.0 (WCAG 2.0), laws such as the Americans with Disabilities Act (ADA) do not specify standards such as WCAG 2.0 as requirements for web content.
When Level Access tests a website for accessibility, we consider three main areas of compliance: technical, functional, and documentation/support requirements.
For technical requirements, the WCAG 2.0 standards are the international voluntary consensus standards that are often adopted by organizations and governments to measure accessibility conformance of web content. In order to claim a certain level of WCAG 2.0 conformance, all web pages within a claim would need to fully conform at that level and meet the conformance requirements. A partial claim of conformance is not a fully-conformant site. Most organizations – and many regulations – target WCAG 2.0 Level AA conformance, which means all success criteria are met at the Level A and AA benchmarks. However, often times organizations find that specific pages may not fully conform with the guidelines, yet they generally support the success criteria. Conformance to the standards is a process that organizations are often working towards over time. A natural question is – if you are not making a formal claim and your site has some minor accessibility issues – how do you know when/if the site is sufficiently conformant in way that supports users with disabilities?
WCAG 2.0 doesn’t require that a formal conformance claim be made. In addition, as mentioned above, WCAG 2.0 Level A and AA conformance is not specifically mandated by the ADA. In the past, WCAG 2.0 has been used by the Department of Justice (DOJ) as a measurement, and is likely to be cited for those seeking accessible content. WCAG 2.0 is also referenced in the Revised Section 508 standards under the Rehabilitation Act used by the Federal Government. The revised standard indicates that when information and communication technology (ICT) must conform to the technical standards – when the technical standard cannot be met or when a technical standard doesn’t apply – Section 508 allows for equivalent facilitation through functional access by people with disabilities.
Section 508 also requires that U.S. Federal agencies buy the most accessible product that meets the business needs of the agency, but this might not always be a fully-conformant product. Other standards such as Accessibility for Ontarians with Disabilities Act (AODA) have allowed a phased-in approved for different WCAG conformance levels, and have made exceptions for certain success criteria that have been deemed more difficult to implement, such as live captions and audio description.
At Level Access, our audit results are automatically mapped to the accessibility standards, and a compliance score is calculated for each standard. This is based on the percentage of pages in the site that have one or more violations for that standard. We weigh each accessibility standard – such as WCAG A, AA, etc. – and calculate an overall compliance score. Compliance scores are not indicated or prescribed by the standards, and there is no industry wide measurement for the scoring of standard compliance. We provide the compliance number to assist organizations in a broad understanding of the conformance level in a metric that can be applied across a site and sites over a period of time to track conformance to the standards.
Using our compliance calculation, we generally recommend the following metrics as indicating that a site conforms with the standards, although anything less than 100% is not a fully-conforming site:
- Conformance to the Technical/Functional Standards
- 98%+ technical conformance inclusive of automatic and manual testing
- All high- and medium-severity violations addressed for all core site workflows
- Conformance to Functional outcome-based goals
- All core use-case tasks pass with a passing score of 4 (out of 5) or above
- Use-case tests are completed by users with disabilities – not an organization’s QA group
- Information, Documentation and Support
- Accessibility statement
- Ability to effectively handle inbound accessibility support cases (feedback, etc.)
- Any documentation requirements are completed per applicable regulations (e.g. AODA requirements in Ontario require posting of an accessibility plan, etc.)
Functional access is measured as an outcome-based goal. For example, can a person with limited vision use the site? The Federal Government is obligated to procure the most compliant product that meets the business needs of the agency. Most products are not 100% conformant, and the end goal of civil rights legislation such as the ADA and the Rehabilitation Act is that people with disabilities are not discriminated against because of their disability. In a similar vein, fully conforming to WCAG 2.0 standards does not mean that all users with disabilities will be able to access web content: some users may still need alternative ways of accessing the information and communication technology.
The process of conformance is an iterative process that takes time, and is most effective when accessibility is part of an organization’s culture. Accessibility is not a one-time thing, but an ongoing commitment across all parts of an organization. That is, accessibility is not just about development, but also about contracting, procurement and use of third-party tools, training, customer services, and requires support through to the C-Level.
Next week, I’ll address how best to reduce your risk with an accessible website.
This post is not legal advice and if you have legal questions about your level of compliance for accessibility please seek legal counsel.