Proposed Public Sector Web Accessibility Guidelines

Thursday, September 20, 2007 6:55 | Filed in Accessibility, Articles, Disability, Public Sector, Standards

Firstly, what gives me the right to propound my proposed public sector guidelines to you all? What makes me think I know more about accessibility than the WAI or the UK Cabinet Office?


What I do have is considerable experience and knowledge in the field of accessibility, and considerable experience and knowledge of working in the public sector in the UK, having not only worked for my public sector employer, but also having discussed common accessibility issues with other public (and private) sector webbies from around the world.

I’m not claiming this lot of guidelines is going to be perfect: I’ll state right now that they aren’t. They are intended to be a bodge job: something practical, achievable and where possible measurable that will bring benefit to users with disabilities. They are intended to be suitable for the UK Public Sector as a whole, whom I don’t expect to have a great deal of specific knowledge about accessibility.

They are also intended to be a first draft, to be kicked around and updated by other people taking part in the PSWMG as I proposed earlier, so I’m expecting that they will evolve, not to become the perfect set of accessibility guidelines, but to become more appropriate to the UK public sector. That’s all I’m pitching them at.

Right. That’s the why, now let’s get down to the what.

The Reasoning Behind The Guidelines

The guidelines are a mix of stuff from WCAG versions 1 and 2, with a couple of my own ideas thrown in too. One of the key things about these guidelines is that I would expect them to be regularly reviewed and either re-approved or revised by the PSWMG to avoid the farcical situation we have now where WCAG 1.0 is the set of officially sanctioned guidelines that we are expected to adhere to but they are somewhat dated, and sites are being told that because they fail the mandatory guidelines, they are inaccessible, simply for using a deprecated attribute such as valign which, while not being good practice, is not going to suddenly mean that someone with a disability can’t use the site.

I’m proposing to stick with three accessibility ‘levels’, with a similar plan to what there is now, except that I’m simply going to call the levels ‘Critical’, ‘Important’ and ‘Desirable’. Obviously the target is for everyone to be able to achieve all of the ‘Critical’ and ‘Important’ levels. I’m focusing primarily on ‘what affects users with disabilities’. Stuff that is good practice but won’t directly affect users with disabilities may be found in the ‘Desirable’ category.

I don’t expect everyone to agree with my selections. I don’t expect everyone to agree with the importance I’ve associated with them. That’s why I said that this was a first draft, and why I’m proposing that the other members of the PSWMG kick around with it and that between us we arrive at a set of standards we can all endorse.

The other thing (and this may be controversial, but I’m trying to strike a balance between the people who reject accessibility because they perceive it as difficult or onerous, and the people they perceive as accessibility zealots) is that I have deliberately reduced the number of criteria. WCAG 1 has 65 ‘checkpoints’. WCAG 2 has 56 ‘success criteria’. I want to deliberately reduce that number further, so to simplify things I have tried to stick to 15 checkpoints at each level, or 45 in total.

Critical Guidelines

  1. Provide a text equivalent for every non-text element (null if decorative); note that an equivalent to a visual CAPTCHA would be an audio CAPTCHA
  2. Ensure that all information conveyed with colour is also available without colour
  3. For data tables, identify row and column headers
  4. Ensure that pages are usable when scripting and other programmatic objects are unavailable or that the scripting/programmatic objects used work with assistive technologies
  5. Do not cause pop-ups or other windows to appear, and do not change the current window except when initiated by the user
  6. Clearly identify the target of each link from the link with surrounding context
  7. Associate labels explicitly with their controls
  8. Ensure that text (and images of text) have a luminosity contrast ratio of at least 5:1 (or 3:1 if larger than 14 point)
  9. Ensure that text size can be adjusted up or down two size increments (approximately 50% up and 40% down) without loss of content or functionality
  10. Ensure that if the sequence in which information is presented affects the meaning (e.g. in a series of instructions), that the correct reading sequence can be programmatically determined and that keyboard/tab navigation is consistent with that sequence
  11. Audio description of video, or a full text alternative for multimedia, is provided for pre-recorded multimedia
  12. For any time-based multimedia presentation (e.g. a movie or animation), syncronize equivalent alternatives (e.g. captions or audio description) with the presentation
  13. Captions are provided for pre-recorded multimedia except where that multimedia is itself provided as an alternative to text
  14. All functionality of the content is operable through a keyboard
  15. Content does not contain anything that flashes more than three times in any one second period, or the flash is below the general and red flash thresholds

Important Guidelines

  1. Information and relationships conveyed through presentation can be programmatically determined through the correct use of appropriate elements (e.g. headings and list markup used correctly)
  2. Navigation mechanisms are used in a consistent manner
  3. More than one way is available to locate content (i.e. more than one of site map, search page, table of contents, in-page links, navigation mechanisms)
  4. Do not use tables for layout unless the table makes sense when linearized
  5. Identify the primary natural language of the document
  6. If any audio plays for more than 3 seconds, provide a mechanism to pause or switch off the audio
  7. Any audio content that contains foreground speech does not contain background sounds that make it difficult to hear the foreground speech
  8. Web pages have meaningful titles
  9. A mechanism (glossary, in-page definition or link to an explanation) is available for identifying specific definitions of words or phrases that are used in an unusual or restricted way, including idioms and jargon
  10. The clearest and simplest language appropriate to the content is used (reading ability required should be no more than that expected for age 14)
  11. For forms that cause transactions to occur, either the transactions must be reversible or the user must be presented with the details to check and confirm before the transaction takes place
  12. If an input error is detected, the item in error is identified and described to the user along with suggestions for correction if known and appropriate (e.g. “this field should be numeric” is fine; “the password for this user is actually ’9Shearer9′” is not)
  13. A mechanism is available to bypass blocks of content that are repeated on multiple web pages (e.g. allow headers and navigation sections to be skipped)
  14. A mechanism for finding the expanded form of abbreviations (including acronyms and initialisms) is available — by use of the appropriate element with title, by an inline expansion, by a link to a glossary etc.
  15. Documents made available in PDF format must either also be available in a text format (HTML or plain text) or must be tagged and structured so that they are accessible to users of assistive technology

Desirable Guidelines

  1. Identify changes in the natural language of a document’s text
  2. Ensure that pages are usable when scripting and other programmatic objects are unavailable (strengthens guideline C4)
  3. Do not use tables for layout
  4. Provide different types of searches for different skill levels and preferences
  5. Create a style of presentation that is consistent across the site
  6. Ensure that timing is not an essential part of the activity of the content, except for non-interactive multimedia, time-based testing or real-time events
  7. Clearly identify the target of each link from the link alone (strengthens guideline C6)
  8. Information about the user’s location within a set of web pages is available (e.g. via the navigation mechanisms or a breadcrumb trail)
  9. Deprecated attributes or elements are not used
  10. Pages validate to the specifications used
  11. Documents can be read without style sheets
  12. Text is not right-justified
  13. Sign-language interpretation is provided for pre-recorded multimedia
  14. Ensure that text (and images of text) have a luminosity contrast ratio of at least 7:1 — or 5:1 if larger than 14 point (strengthens guideline C8)
  15. Text size can be adjusted to anywhere between 50% and 200% of the original size without loss of content or function, and up or down three size increments without requiring the user to scroll horizontally (strengthens guideline C9)


Comments are open but if you work in the UK public sector, I would rather you made comment on the appropriate discussion thread. The reason for this is that comments made there will be drawn together to help form a consensus of opinion from within the UK public sector on what accessibility standards they think they need. Comments made here will be noted by me, but won’t be used officially for this purpose.

Also, please remember that if you want to offer the sort of criticism that just tells me that these guidelines are rubbish, or that I am rubbish (or variations on that theme), I won’t bother listening to you. If you want to offer constructive comments that tell me how I can improve these guidelines so that they are more applicable to the UK public sector, then I’ll be very willing to listen.

You can leave a response, or trackback from your own site.

9 Comments to Proposed Public Sector Web Accessibility Guidelines

  1. Ian Dunmore says:

    September 21st, 2007 at 10:01 pm

    Jack, superb first stab and a fantastic starting place. Could I re-distribute these:

    a) via psf (& newsletter etc) and
    b) draw them to attention of the PSWMG list?

    What thoughts do you have about how/where people contribute/add etc should they wish to?

    Oh for a wiki of some sort for this one!

  2. JackP says:

    September 22nd, 2007 at 10:07 am

    Ian, not a problem, since I’ve written the guidelines for the PSWMG! – I’ve sent you an email.

  3. Ian Dunmore says:

    September 23rd, 2007 at 9:58 am

    Thanks Jack.

    Everyone else…..


  4. Seb says:

    September 24th, 2007 at 3:27 pm

    Wow – great start Jack.

    I have signed up for the forum, but don’t have posting rights yet. So, I’m posting this here now, but will copy over once I have been approved. Hope that’s OK.

    I have a few comments for your consideration… all references to Cx Ix and Dx are your guidelines/checkpoints and WCAG-x are for WCAG 1.0 x checkpoint.

    C2 – not sure about the wording; to me it implies that I have to create a black and white version of the site if I use colours. What I think you mean is that users should be able to apply there own CSS colour scheme (although this would not work for images, so not sure whether the are included in this cp or not).

    C3 – (as appropriate in the output code)?

    C4 – I assume that this is derived from WCAG-6.2 However, I don’t know whether this adequately covers the problem of AJAX replacing/inserting new content into the existing page and how that works with screen readers. What spec of assistive tech? some screen-reader version implementation is really bad, I understand. Also, would a screen-reader user (especially of one of those that doesn’t play nicely with scripting) have it disabled by default and therefore may not get the functionality the developer is expecting ‘because it works’ anyway?

    C5 – warnings no longer adequate? I would demote this to Important and/or keep with warnings in Critical

    C6 – I need more explanation on this – does it mean lots of links ‘more…’ are OK as each is identifiable when with the context of the preceding text? If so, I’m not sure I agree – I thought one of the common screen-reader features used was the list of links read out. See D7 comment.

    C8 – This implies that images of text is acceptable even though it wouldn’t be resizeable… I think more guidance/caveat along the lines of ‘if you really have to…’ is needed for images of text.

    C11/12/13 – I’m sure these can be combined. The caveat from C13 surely applies to C11 too?

    I6 – I would strengthen this to say that audio content is not auto-started.

    I12 – should this be at the top of the page or in context of the input?

    I15 – should this be broadened to all proprietary content? This implies MS Word/Excel/Visio files are all fine and dandy

    D7 – I personally think this should be Important, if not Critical (see C6 comment).

    D12 – or both justified? Although if right to left reading language this needs to be reversed.

    You haven’t covered image-maps explicitly – are you assuming coverage by C14, etc. If so, then I would cite as an example.

    Auto-refresh (as in WCAG-7.4) is not covered as far as I can see. I think it should be Critical.

    I think it would be useful to incorporate some more AJAX specific warnings, e.g. about not using ‘hidden’ property to not display content (ignored by assistive tech)

  5. Julian says:

    September 25th, 2007 at 9:56 am

    originally posted on public sector web managers forum – moved to here for completion


    an ambitious and worthy project and sure to create discussion. here’s my initial tuppence :

    1) no mention of the validity of code (wcag1 3.2) I always thought this was perhaps *the* most important checkpoint of them all. If code doesn’t validate to specified dtd how can we be sure that it will work as intended ->should be critical.

    2) no mention of table summaries. (Desirable?)

    3)no mention of how to handle frames (maybe add to I 8)

    4) re I 11: how exactly would you allow a form submission to be reversed? I’m not being intentionally antagonistic, I really don’t know.

    5) re D12: should this be justified per se or right-aligned (both are poor practice [unless of course you happen to be writing in a R to L language!])


  6. Julian says:

    September 25th, 2007 at 9:58 am

    sorry, my point 3 should read I8 at the end. Seems that 8 followed by a closing parenthesis is converted to some sort of smug-looking face which obviously was not my intention.


  7. Julian says:

    November 21st, 2007 at 12:09 pm

    Well, bloody hell, I really thought this would get more attention/feedback….

    Jack, can I raise C4 again… Do you know of a definitive list of AT that postback (and other javascript) works with (or that it doesn’t work with!)? Unless that is available then C4 cannot realistically have the ‘OR’ clause.

  8. JackP says:

    November 22nd, 2007 at 10:28 pm

    Julian -
    I haven’t got a definitive list of either what AT works with or without postbacks. I don’t particularly have access to AT; I’m not disabled — but you’re right, it really would be worthwhile knowing.

    But it’s as pointless banning all javascript for no good reason as it is allowing javascript that discriminates against users. I don’t have access to the tech myself, but it is a set of tests that needs doing.

    And regarding the whole “proposed public sector web guidelines”, I think we’re more waiting to see what the COI comes back with (of which more later)…

  9. Stretch says:

    September 3rd, 2012 at 12:40 am

    Smart thinking – a celver way of looking at it.

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