UK Web Focus (Brian Kelly)

Innovation and best practices for the Web

All UK Government Web Sites Must Be WCAG AA Compliant

Posted by Brian Kelly on 14 Oct 2007

The UK Government has published a Public consultation on Delivering Inclusive Websites document (TG102). This document (available in MS Word and PDF formats) states that all government Web sites must comply with the WCAG AA guidelines by December 2008. And failure to comply will result in the withdrawal of the domain.

Great, you may think. At last the Government is doing something positive for people with disabilities.

I would disagree – I think this is a flawed approach for several reasons:

  • The WCAG 1.0 guidelines are widely acknowledged to be out-of-date and inappropriate for the technical environment and ways in which the Web is used today. And this is not just what I think. Michael Cooper, who works for WAI (who produce the WCAG guidelines) admitted this is a paper he presented at the W4A 2007 conference. As I described in my report on the conference Michael write:

However, we recognize that standards are slow, and technology evolves quickly in the commercial marketplace. Innovation brings new customers and solidifies relationships with existing customers; Web 2.0 innovations also bring new types of professionals to the field, ones who care about the new dynamic medium. As technologies prove themselves, standardizing brings in the universality of the benefit, but necessarily follows this innovation. Therefore, this paper acknowledges and respects Web 2.0, discussing the issues and real world solutions.

  • The WCAG 1.0 guidelines are flawed and ambiguous, as described in a paper on “Forcing Standardization or Accommodating Diversity? A Framework for Applying the WCAG in the Real World“. For example a strict interpretation of the priority 2 guideline which states “… use the latest versions [of W3C technologies] when supported” would mean that a WCAG AA conformant HTML 4 Web site would be degraded to WCAG A conformance overnight when XHTML 1.0 was officially released! There are similar flaws when one considers use of GIF (a widely used, but proprietary graphical format) and PNG (an open and rich, but comparatively rarely-used W3C graphical format). Use of a closed graphical format such as GIF would appear to break the WCAG priority 2 guideline which requires Web developers to “Use W3C technologies when they are available and appropriate for a task“. But is there any evidence that use of GIF rather than PNG is a significant accessibility barrier?
  • It is unclear whether proprietary file formats such as MS Word and PowerPoint and Adobe PDF can be hosted on a government Web site. The document implies they can, provided the file formats are used in an accessible way. But doesn’t this conflict with the WCAG guideline given above? And if Word, PowerPoint and PDF formats can be used, what other proprietary formats can be used? Would a Flash-only Web site be permitted, provided accessible Flash was used?
  • Although the document supports use of both automated testing tools and manual testing, I fear that time pressures will result in priority being given to automated testing, perhaps based on the EU-funded automated accessibility checking tool, the limitations of which I wrote about recently.
  • The conservatism often found in the public sector will stifle initiative and innovation, even when this could provide more accessible services to people with disabilities.
  • The difficulties of ensuring that user-generated content complies with WCAG AA guidelines (e.g. ensuring the abbreviations and acronyms are marked up when first used in a page) will discourage government bodies from providing services which seek to actively engage UK citizens.
  • The requirement seems to ignore the benefits that can be provided within a particular context. A Web site featuring an anti-drugs campaign aimed at youths in the inner city may be more effective if it uses language likely to be understood by the target audience. But the danger is that such an approach would not be allowed, as the language would not be universally accessible.
  • The failure to address change control in the policy. When, for example, the WCAG 2.0 guidelines are released which, based on the current draft, are more tolerant of proprietary formats, JavaScript and invalid HTML pages, how are Web site owners supposed to respond?

I fear the underlying rationale to this approach is based on the checklist approach which the government seems over-enamoured with. Sadly the requirements to comply with benchmark targets seems inevitably to lead to a fixation with addressing the targets themselves, and a failure to address the underlying issues. As I write the broadsheets are arguing that failures in hygiene standards are due to the NHS’s requirements to satisfy (and monitor) benchmark figures rather tackling the hygiene issues.

After a series of useful government services are withdrawn because of the concerns that they may break dated guidelines, I predict a government minister will face the wrath of Jeremy Paxman – and Jeremy will be able to make use of an anti-EU argument, as the consultation document does admit that “In 2002, the European Parliament set the minimum level of accessibility for all public sector websites at Level Double-A“. A good question for Jeremy will be “Do you have any evidence that compliance with these dated guidelines brings any benefits to people with disabilities?

It seems that political expediency (a Brown government seeking to make a statement, perhaps) has failed to acknowledge the limitations of the checklist approach. And this despite participation from the COI at the “Accessibility Summit II: A User-Focussed Approach to Web Accessibility” in November 2007. As described in a report on the event Kevin Carey, Vice-Chair of the Royal National Institute of the Blind and director of digital inclusion charity HumanITy argued that “At the moment the government is following highly specific [WCAG] points. Some work, some don’t“.

Sadly it seems that the recommendations of this group have been ignored. At least we’re not the only ones concerned about this new. In a comment on a post on New UK government web accessibility consultation on the Blether blog, Karls states that:

I’ve been reading this document today and I agree with Jack – it needs to lose the checklist mentality, extend the deadline (I understand that the author probably had to put some date there) and get every website tested by our friends at RNIB / AbilityNet / Shaw Trust / Nomensa using some kind of joined-up (consistent) testing scheme. I might have missed a few other big players out there but the point I really want to make is I don’t want to see sites get sucked in by snake-oil salesmen.

Your thoughts?

13 Responses to “All UK Government Web Sites Must Be WCAG AA Compliant”

  1. Mike said

    Brian, as you know, I’m 100% with the “holisitic accessibility” approach that you suggest. Too often in my sector (museums) there has been a box-ticking approach: “run it through Bobby, tweak until it works..”. As you say, this accessibility “easy way out” occurs across most sectors who have funding – direct or indirect – from government.

    The net result is the horrible, generic wash of government and council websites.

    Most often these sites look terrible – yes, they tick every accessibility box but when 90%(?) of the population is able-bodied, visual language and usability are as important (waaaaay MORE important..) than making sure image X has an alt tag. What is REALLY sad is that it’s not any longer like we have to compromise – you really can produce sites now which are easy and intuitive to navigate AND visually beautiful. But where in the guidelines is anything about visual appeal or usability…?

    Accessibility guidelines provide a useful backdrop to holistic accessibility. Without them, we’d probably be in a pretty dark place. But reading them as-is without looking at the wider picture is just plain foolish. And leads to a really, really dull web.

  2. Brian, as you know I broadly agree with what you are saying here. The dilution of the WCAG guidelines into a checkbox approach has been terrible. I meet too many people in the public and private sector who want those ticks or want to “legitimise” their by-passing by scrutinising them for some loophole. Really accessibility is sadly the last thing on their mind.

    Personally I think web developers and designers ultimately need a better (not necessarily expert) understanding of disability and user needs. An appreciation of how user wants to interact with a web service will lead to a better experience irrespective of their abilities.

  3. Joe Clark said

    PDF is not a “proprietary” format. The standard is published under copyright, but freely downloadable. In those respects there is no difference between PDF and HTML.

    Once PDF finishes ISO ratification, it will be impossible to claim PDF is a proprietary format. At present it is merely false to make that claim.

  4. Hi Joe
    I’m using the term open standard in line with the EU’s definition, as cited by Ivan Herman, W3C, in a talk at the Workshop on E-Government: Barriers and Opportunities held at WWW 2006. In my talk at the workshop I asked which of HTML, PDF, Java, MS Word and RSS were open standards. Everyone agreed that only HTML was definitaly an open standard, and there was some uncertainty over RSS.
    It should be noted that openness covers owenership of futuyre developments to the standard, and not just making a published specification free for reuse – it that were the case, MS Word and RTF could be regarded as open standards.
    It is true that PDF has been submitted to ISO for standardisation and, if this is ratified, it would then be compliant with a strict interpretation of WCAG guidelines – however that has not yet happened.

  5. Hi Joe
    I’ve just read Wikipedia’s definition of an open standard.
    It begines “An open standard is a standard that is publicly available and has various rights to use associated with it.” This doesn’t cover the ownership of the standard. It would appear that PDF is an open standard according to this definition.
    However Wikipedia goes on to cite the EU’s difinition:

    “The standard is adopted and will be maintained by a not-for-profit organisation, and its ongoing development occurs on the basis of an open decision-making procedure available to all interested parties (consensus or majority decision etc.).”

    According to this, PDF is not an open standard!

    As I was referring to UK government proposals, I think I am correct in my interpretation, but your comments were also correct from your Canadian perspective.

    I think we need to standard definition of an open standard :-)

  6. David Sloan said

    The problem as I see it is this: accessibility is generally recognised as being a process rather than a product. But current systems that measure web accessibility are weak because they focus on accessibility as a product (a web page or ‘unit’ or whatever) and not a process. In other words they look at something in isolation (such as a web page) and report on its accessibility as an interpretation of its performance against some standard, instead of looking at the real world task(s) the web page is there to help enable. This leads to the design approaches to accessibility rightly condemned by Brian and comments above.

    So what we need is a more enlightened approach to web accessibility – one that:

    measures the accessibility of a real world task – like finding out when the next refuse collection takes place or paying a library fine. This will include assessment of the web site but presents results in relationship to the availability and accessibility of other (web or non-web) solutions currently available.
    measures how well the organisation behind the web site has fared in using the web to make that task as accessible as possible.

    This goes way beyond WCAG conformance to look at the wider picture, and rewarding creativity in providing accessible solutions, for example by considering:

    Who did the design team speak to beforehand about accessibility?
    How did they assess how tasks are currently supported (whether through the Web or other means)
    What was the accessibility evaluation process undertaken?
    What evidence do they have to show that the site can be used for the intended purpose by people with sensory, physical and hearing impairments?
    How do they justify the existence of accessibility issues (i.e. breaches of checkpoints)?

    Sadly, I can see this is likely to be seen as idealistic…it’s much easier just to stick a site address into a checking tool and report the results as a nice table of Pass/Fail stats.

  7. D Cook said

    I believe the solution is very simple. The government should set up a team (could be contracted out one or more third parties) of accessibility testers who test all the sites. This should be comprehensive, ‘real world’ testing, not just automated tests or testing against outdated WCAG checkpoints. After testing each site, the team should provide a report to the site owners telling them where the problems are and how to fix them. The performance of the sites would also be made public, both to honour the most accessible sites and to name and shame the least accessible, and of course you could add to that additional motivations such as rewards/fines.

  8. AlastairC said

    Unfortunately ‘real world’ testing will not give you comparable results. There can and should be differences between the task you perform on local authority sites, let alone central government sites.

    On the other extreme, purely automated testing does not necessarily (often?) pick up problems that affect people.

    I agree with Mike that general usability is more important to the success of a website, but those issues affect everyone, they are not discriminatory.

    There are two styles of testing relevant here:

    1. Manual testing of accessibility (with tools) to compare the technical accessibility across sites.
    2. Usability style testing that helps the site owner improve the usability and ‘practical accessibility’ of the site.

    The first helps from the point of view of preventing accessibility issues and tends to apply across a whole site better.

    The second will provide insights into the usability for particular people doing particular things. This will improve the site for all in a general way, but it is not necessarily generalisable across the whole site (or even to other audiences sometimes).

    If you are going to legislate about it, or ban sites, there is not a good way of doing that with usability testing, unless you spend huge amounts, as is it very difficult to create comparable results.

    There’s a large European project that has tried to do something along those lines (

    We’ve had a great deal of success with our testing method, not a single web site owner has taken umbrage with the publicly published results, despite them being quite damning. (Considering that includes FTSE 100, central & local UK Gov, and 100 sites across the world for the UN, that’s a lot of people that would like to!)
    The only issue I have is that it’s not as granular as I would like:

    Essentially we use manual testing with a set of criteria based on WCAG 1, but updated with modern practices, and tested by usability-aware developers. You might consider a set of WCAG 1 Errata quite useful for the basis of the criteria. ;)

    Until WCAG 2 ‘ships’, that has to be the best basis for comparison. For all round improvement, combine it with usability testing.

  9. […] of companies such as Google and Yahoo!Sadly political changes in the UK led to the release of a government mandate which banned such technologies, in an effort by a socialist government to prevent the decline in use of public services. The lead […]

  10. […] by Brian Kelly (UK Web Focus) on 13 December 2007 In a post on All UK Government Web Sites Must Be WCAG AA Compliant I recently warned of the dangers that the UK Government’s blunt instrument of mandating that […]

  11. […] by Brian Kelly (UK Web Focus) on 25 June 2008 I commented previously on the Public consultation on Delivering Inclusive Websites (TG102) which proposed that “all […]

  12. […] I wish WAI had been much more vocal in making this point since many public sector organisations (including the UK Government) have stated (or, indeed, mandated) conformance with WCAG guidelines without giving any […]

  13. […] have, for example, see how a well-intentioned government policy, such as the one which stated that All government Web sites must be WCAG compliant could lead to undesirable side-effects if it were to be implemented in a simplistic fashion. In […]

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