Meeting WCAG 2.2

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Intro to WCAG 2.2

This guide is subject to change, as the specification may still undergo some changes, but we will update this guide as soon when and where necessary

WCAG 2.2 is currently at the "Candidate Release" stage and it has been there for quite some time, this is the final stage before it becomes "Recommendation" or the new standard. It is anticipated by those working for or with the W3C that WCAG 2.2 will achieve Recommendation in 2023, the latest whisperings are "by April 30th".

WCAG currently has 9 additional success criteria (SC) or requirements to meet, in order to "conform to the new 2.2 standard", which are:

In addition, one of the previous requirements is being removed, which is SC 4.1.1 Parsing (Level A), as the working group felt this requirement did not accurately explain the intent and has been the source of much confusion. Whilst the requirement is being removed, it does not remove the requirements to have certain valid HTML nesting etc, as these are typically recorded against both SC 1.3.1 Info and Relationships (Level A) and SC 4.1.2 Name, Role, Value (Level A), as well as other existing requirements. Finally, one SC is being reclassified from Level AA down to Level A, which is 2.4.7 Focus Visible.

How does this affect the UK public sector?

This may come as complete bombshell, but this change can only be a good thing for our users. On Friday 9th December 2022, Cabinet Office of the UK Government released updated guidance regarding the PSBAR regulations on the site.

The key takeaways from Cabinet Office's amendments to the regulations are:

That gives those of us affected by the regulation change a year or so to be WCAG 2.2 Level AA compliant, which definitely won't be as much work as when the initial regulations came into law back in 2018. There are a few of reasons I think this will be a relatively straightforward transition from WCAG 2.1:

OK, so what is new?

As discussed, there are 9 new requirements, but as we typically aim for AA compliance, only 7 of those are required for meeting the regulations, although as always, viewing accessibility through a legal lens, as opposed to through a people lens means we should at the very least consider those AAA criteria, as they often contain hidden gems of best practice, which typically make interfaces easier to use for everybody, but especially disabled people.

Let's look at the 2 new Level A requirements first

3.2.6 Consistent Help (A)

This can be met by having any contact details you already have on your sites consistently placed across pages. So, if for example your company address and contact details are in the site footer and they appear on multiple pages, they appear in the "same relative order" and use the same labelling. Which basically means all of the links and text remains in the same order on every page it is included on. There doesn't appear to be a requirement that contact details or help is available, just that when it is, it is consistent. Help could be in the main navigation or anywhere else, as long as it is consistently placed and labelled. I view footers as static elements, their content typically remains unchanged across all pages, as we would simply include or require the footer component in our site template and call it good. It feels a like a quick win to have contact details in there, which would by convention be easy to discover for everybody.

Obviously it would be widely beneficial to provide contact details that have enough alternatives to cater for everybody, for example don't rely solely on social media contact, not everybody has Twitter of Facebook and they'd need to create an account to be able to contact you on those platforms, and there are plenty of reasons for people not wanting to join those platforms.

Arguably, the most robust contact method of all is an email address, generally people who use computers have one, we need one to set up a phone, computer or tablet and of course shop online. Giving people choices on how to contact you would be the best practice here, don't restrict users to chatbots, phones or social media, add an email address to your existing contact methods, so everybody has choice and nobody is excluded from contacting you.

3.3.9 Redundant Entry (A)

This applies to forms where users may be required to enter the same data, at more than one step of a process. As an example, a user is filling out an application form to enrol in a programme of education, at Step 1, they provide their name, email, address and phone number etc, at Step 5, we ask them for their address again for correspondence, instead of the user having to type those details again, either:

This new requirement appears like there will be a little extra development in capturing user data and ensuring users can either select previously entered data or edit a pre-populated input, but as we'd be storing this information somewhere, on each step, it won't too be difficult to achieve where our developers have full access to the code, it may be harder to get suppliers to accommodate this requirement in Customer Relationship Management (CRM) software or third party payment tools etc, so I assume some tricky questions will be asked, going forward.

Now let's look at the 5 new Level AA requirements

2.4.11 Focus Appearance (AA)

This new requirement somewhat of combines 2 existing requirements, 2.4.7 Focus Visible (AA) and 1.4.11 Non-text Contrast (AA) and enhances them slightly, to provide users with more perceivable focus indicators. It's worth noting that this particular requirement is "At risk", as there doesn't appear to be general consensus over the wording of the requirement. So this requirement may not make it to Recommendation stage, which would be a shame, as it certainly enhances the visibility of focus indicators. As this is "At risk", I'm not going to go into any depth right now, but if the W3C can agree on the wording and get this requirement out the door, I'll add some CodePen examples for a wide variety of use cases. But essentially, it requires a minimum threshold for author created focus indicators, in that at least part of them must be of a minimum size and (depending on whether it encompasses the component, or whether it runs along its vertical or horizontal axis) and part of that indicator (it must meet a surface area requirement) must have a minimum contrast ratio of 3:1, against the "unfocused state".

But if you'd still like to understand it better and have it explained in human language, along with some examples, this article by the excellent Sara Soueidan gives an awesome overview.

2.4.12 Focus not Obscured (Minimum) (AA)

This particular requirement requires that interactive elements on webpages do not become wholly obscured by author-created components when they receive keyboard focus. The usual suspects that cause this behaviour are sticky headers and footers, overlay type 'drawer' menus or navigations, 'toast' messages, chat widgets, non-modal dialogs and other disclosure patterns that obscure content. This is one of the new requirements that I believe we would hopefully hit by accident, as my mindset is people rely on focus indicators to move around webpages, they need to see that focus indicator at all times when they tab between interactive elements, so I always recommend fixes when focus is obscured by something.

Interestingly the requirement only requires that "some part of the component (and as result, normally part of its focus indicator as well) not be obscured by other author-created content". How much constitutes "some part" is anybody's guess, half, a quarter, a couple of pixels, who knows? There is a AAA enhanced requirement that builds on this, and does not allow any part of the component or its focus indicator to be obscured by author created content (Author created content is essentially our code, content and components etc, not the browser's). This doesn't apply to modal dialogs as, the underlying content page content should not be reachable, as modal is a state that renders the content below inert. In correctly coded modal dialogs focus would advance to a suitable place within the dialog when it is opened and naturally, focus would be trapped within.

One example I can see being a huge problem is chat widgets, you know those ones that usually start with a small control at the bottom right of a page, but after a short while they expand automatically to show the full chat widget? As these are typically absolutely positioned (taken out of the main document's flow and positioned on a new layer above) you can pretty much guarantee that at some viewport, orientation or zoom level that it will wholly obscure a focused element, which will be an instant fail. This would of course apply to those intrusive dialogs that pop up for cookies, subscriptions, notifications and anything else somebody erroneously thought would be a great idea to interrupt users with.

Going back to the chat widget, if it displays as the full message panel, we'd want to be requesting it doesn't do that until a user clicks the chat button, we'd likely want that to act as a modal dialog, clicking the trigger expands the full widget, focus is moved to a suitable place within and when a user closes the widget, focus returns to the point of origin. But then if your chat widget pushes other content down, as opposed to overlaying it, this won't be a problem at all.

2.5.7 Dragging Movements (AA)

This one requires an alternative way to complete those actions that require a user to drag something from point A to Point B in an interface, using a pointing device. An example of this could be a Kanban board, a user may drag something from the 'In development' column to the 'On test' column, there must be a mechanism for users who are not keyboard users, to achieve the same goal (Keyboard alternatives must exist already in 2.1.1 Keyboard (A) and 2.5.1 Pointer Gestures (A) applies where dragging paths must follow a specific route).

This is aimed at non-keyboard users who may have limited dexterity or are not able to control a mouse or other pointing device with the same level of precision as non-disabled users. Whilst they have a disability, that doesn't mean they are a keyboard user, they may be able to manage to touch or click targets, but the act of dragging could be quite problematic for them. Perhaps an easy way of achieving this would be to have 2 arrow buttons on the moveable component, clicking on say an arrow that points left, will move the component into the previous column. Alternatively, there could be a menu on the component, "Move to", where the options would be the column names, that is assuming we're still using the Kanban example, but this could apply to sortable vertical lists or anything else where a dragging action can be completed to change orders, meaning or other important operations.

It's important to consider all dimensions here, if a mouse user can drag a ticket from one column to the next, but also position it at a specific position in that column, say the top, as this is a priority ticket, then this must also be achievable with single point activation, so in a Kanban example, maybe an option to move to a specific column and then up and down arrow buttons which can move the item up or down the stack of tickets.

This will be especially beneficial for pointing-device users, who may have difficulties holding a mouse button down (or finger) and then dragging said component from point A to point B, because let's face it, not everybody knows how to navigate using a keyboard, just think of a user on an iPad, with no keyboard, they know how to move the component, but maybe they have tremors and each time they attempt to move the component, a tremor results in their finger momentarily leaving the capacitive surface of the tablet, so the component automatically moves back to its point of origin, that would be hugely frustrating.

2.5.8 Target Size (Minimum) (AA)

Users who have difficulty interacting with small interactive elements rejoice, you now have something that prevents teeny tiny touch targets being on "compliant sites", well, sort of. This one has seemingly undergone some changes since its initial proposal and I'm not convinced what we have ended up with is what users needed. Interactive targets must be at least 24px by 24px unless (this is where it gets a bit flaky):

This doesn't apply to colour pickers and other controls that may require granular input. given that most Human interface guidelines recommend 44px or 48px for target sizes, 24px seemed like a very small starting point for Level AA, but better than nothing. I am concerned about the fact that if it's 24px away from any other interactive element, it does not apply. Maybe this is something that will be easier to flag when resizing the viewport, maybe our 1px by 1px Twitter icon will cosy up to something else if we squish the screen down to 320px?

In essence, if there are controls tightly grouped together, with no spacing between, they must be a minimum of 24px by 24px (unless some obscure law forbids 24px icons or whatever).

If the controls are smaller than 24px by 24px, then we must calculate the target offset, which is an interesting concept. Assume we have 2 square social links, adjacent to each other, with just 2px of space between them. The 'hit area' of each is 22px by 22px, which at first glance seems like an instant failure, but it's actually not. Here's why:

I think we'll still have those difficult discussions about target sizes, as this doesn't appear to do a great deal to address that.

3.3.7 Accessible Authentication (AA)

This requirement applies to when users login to sites or applications, as in order to be logged in, they must be authenticated. The idea with this requirement is reduce the cognitive burden of remembering login credentials and to a lesser extent, other cognitive function tests. This unfortunately doesn't do away with the dreaded reCAPTCHA and other similar riddles, so we'll all likely still be asking ourselves whether part of the pedestrian crossing is in a specific square or not or even which way a horse is facing (yes, really).

The W3C's interpretation of a cognitive function test is a puzzle (that could be a sum, reCAPTCHA, identifying characters and all the other ridiculous things we must endure to prove to a machine, that we are in fact, not a machine). There is a AAA requirement for this too, which goes further and seemingly does away with reCAPTCHAS's altogether, but at AA, it's not so clear cut.

"A cognitive function test (such as remembering a password or solving a puzzle) is not required for any step in an authentication process unless that step provides at least one of the following:"

Back to the direction the horse is facing riddle, that's my only encounter of having to identify any animal-based puzzles and yep, one of them was looking kind of head on, but I winged my way through it. A horse isn't an object, I understand objects to be inanimate things that are tangible, which would also exclude patterns and shapes, right? Let's see what the dictionary says:

Object (noun) A thing that you can see or touch but that is not usually a living animal, plant, or person: Cambridge dictionary

Wording matters, as when words say one thing, but mean something else, we end up in situations where there's no other choice but to remove the criterion altogether, subtle nod to 4.1.1 Parsing there.

Also we have those puzzles where we may be required to identify characters or words, which are typically displayed as a graphic, are they objects or shapes and patterns? I'm no lexicologist, but I'd say the latter.

Having to remember certain characters from a memorable word, based upon their position, would also fail this requirement.

So, in a nutshell, reCAPTCHA is still allowable (sigh), but there are certain requirements that must be met with authenticating:

A user must not be required to remember their username or password as these typically change between sites. We can rely on password managers, browser autofill and simply fields that allow users to paste credentials into them. If a field prevents you from pasting into it or doesn't auto-fill etc, this would fail the new requirement.

Other acceptable ways of logging in are: biometrics (your face or fingerprint etc), 2-factor authentication where that secondary factor is confirming your identity on your trusted device (maybe TouchID etc), QR codes, third-party providers (Oauth etc), email links with login tokens.

There's quite a lot to unpack in this one, there seem to be an almost infinite amount permissible alternatives, so at it's base level, if a user is required to manually type their password and/or username, then that site fails this requirement.

I believe we would would typically pass this by accident, if we have inputs with correctly associated clear labels and even autocomplete attributes, and nobody thought it would be user friendly to block copy and pasting into those fields, then that's all that is required, but if you can get people to do away with those awful reCAPTCHA, please do.

Let's take a quick look at the 2 new AAA requirements

Just the 2 to look at and both of these are the enhanced versions of 2 of the new AA requirements.

2.4.13 Focus not Obscured (Enhanced) (AAA)

This one builds on 2.4.12 Focus not Obscured (Minimum) (AA), in that no part of the focused element or by extension, its focus indicator becomes obscured by any author created content. This does away with the vagueness of "Some part" of the component is not hidden and explicitly states none of it should be. I think this is the standard we should be pushing for, remember conformance is the floor, not the ceiling.

3.3.8 Accessible Authentication (No Exception) (AAA)

Building upon 3.3.7 Accessible Authentication (AA), this removes the exceptions in the aforementioned requirement, in that if a site does have a puzzle of some sort, then there is an alternative which a user may choose, that does not rely on a cognitive function test. So, assuming the website wants us to prove beyond all doubt that we are not a robot by having us help them improve the artificial intelligence for self-driving cars, there must be another way to authenticate that doesn't require recognition of objects or presumably non-objects, so, hasta la vista, reCAPTCHA (sorry).

Goodbye to 4.1.1 Parsing

Ahh, 4.1.1 Parsing is due to be removed from 2.2, as the wording many of us followed was not what we were supposed to be doing, because those words, in the context they were written, were only understandable in their true context, by the folks that wrote them. I'm not going into any detail here, as Adrian Roselli does a fine job (as always) with his 411 on 4.1.1 article

In essence, the same failures are still failures, but not against the criterion we were lead to believe they were, by reading the actual guidelines.

Focus Visible to be reclassified at Level A

So, did you ever wonder why Focus Visible was a AA? Something so basic, so essential, something that likely had to be intentionally removed by a developer in the first instance, only needed to be present at Level AA? Well, 2.4.7 Focus Visible is being reclassified as a Level A requirement. In the UK, we don't typically test for Level A, so other than writing the level, this has no affect on us. As an aside, I've always wondered why most of the colour requirements are Level AA too.

Wrapping up

WCAG 2.2 is essentially a minor revision, whilst it seemingly adds 7 new criteria that we need to meet at Level AA, effort required to test or remediate isn't huge, as much of what is new are what were previously considered best practices and these are things I'd ordinarily put in an advisory or if there were other issues on a specific component, my recommendation would include those best practices. Whilst at this moment I haven't gone into depth on Focus Appearance, due to its 'At risk' nature, I don't see this as being problematic, as when I discover something without a focus indicator, my recommendation would always be a highly visible focus indicator, but we can dig deeper there when and if it makes the cut.

I'll update this guide, as and when things change and also as and when my own understanding changes, should I come across chatter that explains things better than the official standard, which is typically how most of us learn how to interpret WCAG anyway, read it several times, scratch one's head and Google the life out of it (other search engines are available).

As the standard has been delayed a few times, we're probably super close to the actual release, the most recent discussions I read stated December or January. With that in mind, it would be worth making preparations now, we've created our new audit template in preparation for this change and as soon as the standard is canon, we're going to start testing against 2.2, so we don't create an additional backlog of sites to retest at a later date. It may be worth taking a similar approach at your organisation, it seems like the most efficient way of being ready for the upcoming regulation change, but as always, every barrier we remove, no matter how small, opens up participation to more people and that's always the goal.

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