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Expanding from a digital accessibility focus to include the whole library experience.

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Expanding from a digital accessibility focus to include the whole library experience.

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How do you get your priorities on the radar of stakeholders with decision-making or budgeting power?

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How do you get your priorities on the radar of stakeholders with decision-making or budgeting power?

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How do you measure progress towards accessible platforms with your vendors?

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How do you measure progress towards accessible platforms with your vendors?

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How do you measure progress towards your own accessibility goals?

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How do you measure progress towards your own accessibility goals?

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How do you address immediate accessibility needs?

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How do you address immediate accessibility needs?

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How do you keep momentum in your accessibility work?

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How do you keep momentum in your accessibility work?

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How do you staff your accessibility team? 

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How do you staff your accessibility team? 

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Ideas for future ASERL Accessibility Water Coolers

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Ideas for future ASERL Accessibility Water Coolers

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-Schedule Low barrier half-baked lightning talks
-Have a particular theme like PDFs or Signage

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Prime Access Consulting did an evaluation for exhibit spaces in the library. Some things they looked at:

1. contrast between floor and walls

2. site lines looking at exhibition cases

3. making sure tables are the right height for wheelchairs

4. color contrast for displays on the wall

5. fonts and font sizes

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What are people doing to create accessible spaces?

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What are people doing to create accessible spaces?

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Advice/resources for making library instruction one-shot sessions more accessible?

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Advice/resources for making library instruction one-shot sessions more accessible?

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Proposed Department of Justice rule on accessibility of state and local government websites

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Proposed Department of Justice rule on accessibility of state and local government websites

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Is anyone discussing these proposed rules at their library? Any thoughts on how it might change acquisitions?

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The Department of Justice (Department) is publishing a Notice of Proposed Rulemaking (NPRM) explaining how we propose updating the regulations for Title II of the Americans with Disabilities Act (ADA) to add more specific requirements about web and mobile application (app) accessibility.

This NPRM proposes a specific technical standard that state and local governments would have to follow to meet their existing obligations under Title II of the ADA for web and mobile app accessibility. The NPRM asks the public for comments about this proposal.

Purpose of this fact sheet: This fact sheet gives a plain language summary of the NPRM. The summary is designed to provide introductory information about this proposal for people who may not have a legal background. For all of the details about our proposal, please read the NPRM.

What is a Notice of Proposed Rulemaking (NPRM)?

Rulemaking is the process that federal agencies use to write regulations. A regulation (also called a "rule") is a set of requirements issued by a federal agency to implement laws passed by Congress. When Congress passes laws, many details are often left to federal agencies to flesh out in regulations. For example, when Congress passed the ADA, it gave the Department the authority to issue regulations that explain the rights and obligations under Titles II and III of the ADA.

An NPRM is a stage in the rulemaking process that happens before an agency adopts a final regulation. It is like a first draft of a regulation. It lets the public know what the agency is considering and provides an opportunity for feedback.

An NPRM is not a final regulation. So, this proposal is not an enforceable rule right now. This NPRM has been published so that the public can provide us with feedback on our proposal for the rule before we adopt a final rule.

Who would be covered by this proposed rule?

Everyone that has obligations under Title II of the ADA would be covered by the proposed rule. Title II of the ADA applies to all public entities, including state and local governments, and departments, agencies, special purpose districts, special district governments, and other instrumentalities of state or local government. Title II and the NPRM use the term public entities or state and local government entities to describe who they apply to, but in this fact sheet, we call these state and local governments. State and local governments that contract with other entities to provide public services (like non-profit organizations that run drug treatment programs on behalf of a state agency) also have an obligation to ensure that their contractors follow Title II.

Like the rest of Title II, the proposed rule would apply to all state and local government entities. Examples of these include:

State and local government offices that provide benefits and/or social services, like food assistance, health insurance, or employment services

Public schools, community colleges, and public universities

State and local police departments

State and local courts

State and local elections offices

Public hospitals and public healthcare clinics

Public parks and recreation programs

Public libraries

Public transit agencies

Reasons for this Proposed Rule

State and local governments provide many of their services, programs, and activities through websites and mobile applications (apps). When these websites and mobile apps are not accessible, they can create barriers for people with disabilities.

This can also make it more difficult or impossible for people with disabilities to readily access important government services like absentee ballots or tax information that are quickly and easily available to other voters and taxpayers online.

Sometimes, inaccessible websites and mobile apps can keep people with disabilities from joining civic or other community events like town meetings or programs at their child's school, or make it harder for them to join.

This proposed rule is intended to help better ensure access for people with disabilities and provide state and local governments with more clarity on how they can make sure they are complying with the ADA.

You can find more information about why the Department of Justice is proposing this rule in the NPRM in the section called "Need for Department Action."

Highlights of the Proposals in the NPRM

Some of the specific proposed requirements found in the NPRM are highlighted below. Review the full NPRM to get an understanding of the entire proposal.

Proposal: Adopt the Web Content Accessibility Guidelines (WCAG) Version 2.1, Level AA as the technical standard that state and local governments would need to follow.

A technical standard says specifically what is required for something to be accessible. For example, the existing ADA Standards for Accessible Design are technical standards that say what is needed for a building to be physically accessible under the ADA. For instance, the ADA Standards for Accessible Design say how wide a door has to be or how steep a ramp can be.

WCAG, the Web Content Accessibility Guidelines, is a set of guidelines for web accessibility developed by the World Wide Web Consortium.

The NPRM proposes WCAG Version 2.1, Level AA as the technical standard for web content and mobile apps that state and local governments would be required to follow.

You can find more information about why the Department of Justice is proposing WCAG Version 2.1, Level AA as the technical standard in the NPRM in the sections called "Proposed WCAG Version" and "Proposed WCAG Conformance Level."

Proposal: State and local governments' web content and mobile apps would have to comply with the technical standard.

The proposed rule would apply to web content that a state or local government makes available to the public or uses to offer services, programs, and activities to the public.

Proposal: We have proposed some exceptions. When an exception applies, specific kinds of web and mobile app content would not always have to comply with the technical standard.

It is important that state and local governments can prioritize so they can make the most important content-like current or commonly used information-accessible to people with disabilities quickly.

So, we have proposed narrow exceptions for some specific types of content that we do not think are as frequently used or that may be particularly hard for state and local governments to address right now
Example: An exception would likely apply to an old water quality report from 1998 that the state has put in an archived section of its website and has not updated. If the exception applies, the report would not need to comply with the technical standard.

Below, we provide some examples of how the proposed exceptions would work. We also give examples of when each exception would not apply.

What does it mean if an exception applies?

The exceptions would only apply to some kinds of content, when certain facts or circumstances are present. If an exception applies to certain content, it means that particular content is "excepted" from the proposed rule's general requirement that web and mobile app content has to comply with the technical standard. The specific web or mobile app content that is "excepted" usually would not need to comply with the technical standard.

What the proposed exceptions do not change

Proposal: We have proposed limits to some exceptions. When a limit applies, content would have to comply with the technical standard.

Some of the proposed exceptions would have limitations, which we also call limits. The limits mean that the exception would not apply in some situations, if certain facts or circumstances are present.

When there is a limit, the web or mobile app content generally would have to comply with the technical standard, just like any other content that is not excepted.

Below, we provide some examples of how the proposed limits on exceptions would work.

Proposed Exceptions

1. Archived web content:

State and local governments' websites often include a lot of content that is not currently used. This information may be outdated, not needed, or repeated somewhere else. Sometimes, such information is archived on the website.

Web content that meets all three of the following factors would not need to comply with the technical standard:

1. the content is maintained only for research, reference, or recordkeeping; AND

2. the content is kept in a special area for archived content; AND

3. the content has not been changed since being archived.

Example: This exception would likely apply to web content like historical city council meeting minutes stored in the "archives" section of a city's website.

The exception would not apply unless all three factors are present. The content would generally need to comply with the technical standard.

Example: If web content is updated by the state or local government, the exception would not apply even though the content is labeled "archived."

Example: If web content is being used to provide services, programs, and activities, the exception would not apply even though the content is labeled "archived." The content is not maintained only for reference.

What the proposed exception does not change

2. Preexisting conventional electronic documents:

Some state and local governments have a lot of old documents, like PDFs, on their website. It is our understanding that these can sometimes be difficult to make compliant with the technical standard.

Web or mobile app content that meets both of the following factors generally would not need to comply with the technical standard:

1. the documents are in certain file formats specified in the proposed rule, like word processing, presentation, PDF, or spreadsheet files; AND

2. they are available on the state or local government's website or mobile app before the date the state or local government will have to comply with this rule (after the rule is finalized).

Example: This exception would likely apply to a spreadsheet of COVID-19 statistics from 2020 or a Microsoft Word version of a water quality report from 2015.

The exception would not apply unless both factors are present. The content would generally need to comply with the technical standard.

Example: After the date that compliance with the rule is required, a state or local government posts a Microsoft PowerPoint presentation. The presentation would not qualify for the proposed pre-existing content exception because it was posted after the rule's compliance date.

Example: After the date that compliance with the rule is required, a state or local government updates a Microsoft Word document that was on its website before the rule required compliance. The updated document would not qualify for the proposed pre-existing content exception anymore.

Limit on when this exception applies: This exception would not apply if the pre-existing documents are currently being used by members of the public to access or participate in public services, programs, or activities.

Example: A PDF version of a business license application that was posted on a state or local government's website in 2020. If members of the public can still use that PDF to apply for a business license in 2023, the exception would not apply. The application would generally need to comply with the technical standard.

3. Content posted by a third party:

Third parties sometimes post content on state and local governments' websites. Third parties are members of the public or others who are not controlled by state or local governments. The state or local government also may not have control over the content third parties post, and this content may be outdated or not relevant.

This exception would only apply to content posted by a third party. Content that is not posted by a third party would generally need to comply with the technical standard.

1. Third-party content posted by the state or local government.
Example: Many state or local governments post content on their websites that is developed by an outside technology company, like calendars, scheduling tools, maps, reservations systems, and payment systems. This content would not qualify for the third-party exception because it is posted by the state or local government.

2. Content posted by a state or local government's contractor or vendor.
Example: If a state or local government uses a company to design, manage, or update its website, the content the company posts for the government would not qualify for the third-party exception.

3. Tools and platforms that allow third parties to post content.
Example: If the state or local government has a message board platform on its website, that platform would not qualify for the third-party exception because the message board was added to the website by the state or local government.

What the proposed exception does not change

4. Linked third-party content:

Many state and local governments' websites include links to other websites. Clicking on one of these links will take an individual away from the state or local government's website to the website of a third party. Typically, the state or local government has no control over the third party or their web content.

Limit on when this exception applies: This exception would not apply if the state or local government is using the linked web content to offer its service, program, or activity.

Example: A city links to a company's website where people can pay city registration fees or taxes. The city would need to use a third-party payment website that complies with the technical standard.

5. Public schools' password-protected course content

Public elementary schools, middle schools, high schools, colleges, and universities often have a lot of content associated with their classes and courses-like PDFs of required readings for homework-that is only available to students enrolled in a particular class. It might be difficult to make all of this content comply with the technical standard immediately, and there might not be a student or parent with a disability in the class or course who needs access to the content.

This exception would not apply to all of a public school's web content. Many types of public schools' web content would generally need to comply with the technical standard.

1. Content that is not password protected.

2. Password-protected content that is available to all students or parents, not limited to students enrolled in a certain class or course.
Example: school calendars, lunch menus, and information about meal plans or housing

3. Password-protected content for classes or courses that are available to people who are not enrolled in the school. These are sometimes called Massive Open Online Courses (MOOCs).

4. The platforms that schools use to share password-protected content, like learning management systems.

Limit on when this exception applies: This exception would not apply if:

a student with a disability who needs accessible content is enrolled in the class or course;OR

a student is enrolled in an elementary, middle, or high school class or course whose parent needs accessible content because of the parent's disability.

Example: A college student who is blind is enrolled in a literature course. The course content would need to comply with the technical standard.

Example: A student whose parent has low vision is enrolled in a tenth-grade chemistry class. The class content would need to comply with the technical standard.

When did the student enroll in the class or course?

When would the content need to be made accessible?

Before the academic term begins

By the date the academic term begins

After the academic term begins

Within five business days

6. Individualized documents that are password protected

State and local governments sometimes use password-protected websites to share documents that are for specific individuals-like a water or tax bill. It might be difficult to make all of these documents accessible immediately and there might not be a person with a disability who needs access to these documents.

Web content that meets all three of the following factors would not need to comply with the technical standard:

1. the content is in certain file formats, like word processing, presentation, PDF, or spreadsheet files; AND

2. the files are about a specific person, property, or account; AND

3. the files are password protected.

Example: This exception would apply to a PDF version of a water bill for a person's home that is made available in that person's secure account.

The exception would not apply unless all three factors are present. The content would generally need to comply with the technical standard.

Example: If a person's water bill is made available for them to view on a password-protected website as HTML content, the exception would not apply. The content is not in one of the specified document formats.

Example: If the water company posts a PDF document on a password-protected website about an upcoming rate increase for all customers, the exception would not apply. The document is not about one customer's account.

What the proposed exception does not change:

Proposed Time to Comply with the Rule Once It Is Finalized

We are proposing to have state and local governments follow the technical standard in two or three years after the final rule is published, depending on their population.

You can find more information about why the Department of Justice is proposing this timeline in the NPRM in the section called "Requirements by Entity Size."

State or local government entity size

Compliance Date

0 to 49,999 persons

Three years after publication of the final rule

Special district governments

Three years after publication of the final rule

50,000 or more persons

Two years after publication of the final rule

After this time, state and local governments would have to continue to make their web content and mobile apps comply with the technical standard.

What are special district governments?

The NPRM proposes a specific definition of a special district government. Special district governments include, for example, a mosquito abatement district, utility district, transit authority, water and sewer board, zoning district, or other similar state or local government entity that has a specific function.

We Want Your Feedback

This fact sheet gives a high-level summary of the NPRM. For more details about our proposal, you should read the NPRM. The NPRM is also published in the Federal Register.

We have also published an analysis of the costs and benefits of the proposed rule. This is called a Preliminary Regulatory Impact Analysis (PRIA). You can read the PRIA on ADA.gov.

After you've reviewed the NPRM, we'd like to hear your feedback.

Have we made the right proposals about when and how web content and mobile apps should be made accessible?

Do the proposed exceptions and the proposed limits on when those exceptions apply make sense?

Should we change anything about the proposed rule? Why?

You can submit comments through October 3, 2023 by going to Regulations.gov. You can also mail us your comments at Disability Rights Section, Civil Rights Division, U.S. Department of Justice, P.O. Box 440528, Somerville, MA 02144.

If you need information in an alternative format, you can call the ADA Information Line at (800) 514-0301 (voice) or 1-833-610-1264 (TTY).

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Fact Sheet: Notice of Proposed Rulemaking on Accessibility of Web Information and Services of State and Local Government Entities

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The Department of Justice (Department) is publishing a Notice of Proposed Rulemaking (NPRM) explaining how we propose updating the regulations for Title II of the Americans with Disabilities Act (ADA) to add more specific requirements about web and mobile application (app) accessibility.

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Any a11y tools that you finds helpful in your work? Share the details!

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Local discussions of WCAG 2.2 updates at your institution?

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This page lists the new success criteria in WCAG 2.2, with:

A brief introduction of what to do and why it's important

Quotes from personas to help you understand some aspects of the success criteria

Links to Understanding documents that explain the success criteria in detail and provide more examples

Page Contents

Introduction

For an introduction to Web Content Accessibility Guidelines (WCAG) and more about versions 2.0, 2.1, and 2.2, see the WCAG Overview.

WCAG 2.2 was published as a "W3C Recommendation" web standard on 5 October 2023.

Changes from WCAG 2.1 to WCAG 2.2
WCAG 2.2 provides 9 additional success criteria since WCAG 2.1. They are introduced on this page.
The 2.0 and 2.1 success criteria are essentially the same in 2.2, with one exception: 4.1.1 Parsing is obsolete and removed from WCAG 2.2. More information is in WCAG 2 FAQ, 4.1.1 Parsing. WCAG 2.2 includes Notes about different languages; more information is in WCAG 2 FAQ, internationalization.

Provide ways to help users navigate, find content, and determine where they are.

2.4.11 Focus Not Obscured (Minimum) (AA)

WCAG success criteria:

When a user interface component receives keyboard focus, the component is not entirely hidden due to author-created content.

Note: Where content in a configurable interface can be repositioned by the user, then only the initial positions of user-movable content is considered for testing and conformance of this Success Criterion.

Note: Content opened by the user may obscure the component receiving focus. If the user can reveal the focused component without advancing the keyboard focus, the component with focus is not considered hidden due to author-created content.

Understanding Focus Not Obscured (Minimum)
2.4.12 Focus Not Obscured (Enhanced) (AAA)

In brief:
(Persona, problem, and works well same as 2.4.12 above.)

WCAG success criteria:

When a user interface component receives keyboard focus, no part of the component is hidden by author-created content.

Understanding Focus Not Obscured (Enhanced)
2.4.13 Focus Appearance (AAA)

In brief:

Persona example - a reporter with repetitive stress injury who doesn't use a mouse:
and Retiree with low contrast sensitivity:

WCAG success criteria:

When the keyboard focus indicator is visible, an area of the focus indicator meets all the following:

is at least as large as the area of a 2 CSS pixel thick perimeter of the unfocused component or sub-component, and

has a contrast ratio of at least 3:1 between the same pixels in the focused and unfocused states

Exceptions:

The focus indicator is determined by the user agent and cannot be adjusted by the author, or

The focus indicator and the indicator's background color are not modified by the author.

Note: What is perceived as the user interface component or sub-component (to determine enclosure or size) depends on its visual presentation. The visual presentation includes the component's visible content, border, and component-specific background. It does not include shadow and glow effects outside the component's content, background, or border.

Note: Examples of sub-components that may receive a focus indicator are menu items in an opened drop-down menu, or focusable cells in a grid.

Note: Contrast calculations can be based on colors defined within the technology (such as HTML, CSS and SVG). Pixels modified by user agent resolution enhancements and anti-aliasing can be ignored.

Understanding Focus Appearance
Make it easier for users to operate functionality through various inputs beyond keyboard.

2.5.7 Dragging Movements (AA)

WCAG success criteria:

All functionality that uses a dragging movement for operation can be achieved by a single pointer without dragging, unless dragging is essential or the functionality is determined by the user agent and not modified by the author.

Note: This requirement applies to web content that interprets pointer actions (i.e. this does not apply to actions that are required to operate the user agent or assistive technology).

Understanding Dragging Movements
2.5.8 Target Size (Minimum) (AA)

WCAG success criteria:

The size of the target for pointer inputs is at least 24 by 24 CSS pixels, except where:

Spacing: Undersized targets (those less than 24 by 24 CSS pixels) are positioned so that if a 24 CSS pixel diameter circle is centered on the bounding box of each, the circles do not intersect another target or the circle for another undersized target;

Equivalent: The function can be achieved through a different control on the same page that meets this criterion;

Inline: The target is in a sentence or its size is otherwise constrained by the line-height of non-target text;

User agent control: The size of the target is determined by the user agent and is not modified by the author;

Essential: A particular presentation of the target is essential or is legally required for the information being conveyed.

Note: Targets that allow for values to be selected spatially based on position within the target are considered one target for the purpose of the success criterion. Examples include sliders with granular values, color pickers displaying a gradient of colors, or editable areas where you position the cursor.

Note: For inline targets the line-height should be interpreted as perpendicular to the flow of text. For example, in a language displayed top to bottom, the line-height would be horizontal.

Understanding Target Size (Minimum)
Guideline 3.2 Predictable

Make Web pages appear and operate in predictable ways.

3.2.6 Consistent Help (A)

WCAG success criteria:

If a web page contains any of the following help mechanisms, and those mechanisms are repeated on multiple web pages within a set of web pages, they occur in the same relative order to other page content, unless a change is initiated by the user:

Human contact details;

Human contact mechanism;

Self-help option;

A fully automated contact mechanism.

Note: Help mechanisms may be provided directly on the page, or may be provided via a direct link to a different page containing the information.

Note: For this Success Criterion, the same relative order can be thought of as how the content is ordered when the page is serialized. The visual position of a help mechanism is likely to be consistent across pages for the same page variation (e.g., CSS break-point). The user can initiate a change, such as changing the page's zoom or orientation, which may trigger a different page variation. This criterion is concerned with relative order across pages displayed in the same page variation (e.g., same zoom level and orientation).

Understanding Consistent Help
Guideline 3.3 Input Assistance

Help users avoid and correct mistakes.

3.3.7 Redundant Entry (A)

WCAG success criteria:

Information previously entered by or provided to the user that is required to be entered again in the same process is either:

auto-populated, or

available for the user to select.

Except when:

re-entering the information is essential,

the information is required to ensure the security of the content, or

previously entered information is no longer valid.

Understanding Redundant Entry
3.3.8 Accessible Authentication (Minimum) (AA)

WCAG success criteria:

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:

Alternative

Another authentication method that does not rely on a cognitive function test.

Mechanism

A mechanism is available to assist the user in completing the cognitive function test.

Object Recognition

The cognitive function test is to recognize objects.

Personal Content

The cognitive function test is to identify non-text content the user provided to the website.

Note: "Object recognition" and "Personal content" may be represented by images, video, or audio.

Note: Examples of mechanisms that satisfy this criterion include:

1. support for password entry by password managers to reduce memory need, and

2. copy and paste to reduce the cognitive burden of re-typing.

Understanding Accessible Authentication (Minimum)
3.3.9 Accessible Authentication (Enhanced) (AAA)

WCAG success criteria:

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:

Alternative

Another authentication method that does not rely on a cognitive function test.

Mechanism

A mechanism is available to assist the user in completing the cognitive function test.

Understanding Accessible Authentication (Enhanced)
About the Personas

These personas are representations of people with disabilities developed from qualitative data on real people.

The linked persona roles go to the Stories of Web Users. That page has other personas with different disabilities.

Please share your ideas, suggestions, or comments via e-mail to the publicly-archived list wai@w3.org or via GitHub.

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This page lists the new success criteria in Web Content Accessibility Guidelines (WCAG) 2.2. It includes quotes from personas to help you understand some aspects of the success criteria.