When it comes to digital accessibility, few things can rival the Web Content Accessibility Guidelines (WCAG) for impact. For nearly three decades, WCAG has been the definitive global standard, serving as the basis for virtually all meaningful global accessibility regulation.
If WCAG is to help shape the next 30 years of progress and innovation in this field, it needs a partner—a parallel standard for accessibility compliance. The good news is, that standard already exists. It’s called EN 17161: Design for all.
In this post, I’ll cover critical WCAG limitations, explain how EN 17161 can offset those limitations, and outline an approach for embracing both standards equally as a means to building a more accessible future.
Benefits and limitations of WCAG as an output standard
The benefits of WCAG largely stem from the fact that it is an output standard. Put simply, output standards outline what properties something should have. WCAG is a set of guidelines describing the properties that a digital asset should have to be minimally accessible for people with disabilities.
Output standards are generally easy to adopt and test. WCAG is no different. It has traditionally been easy to apply. But there is a downside. Output standards are inherently rigid. In a complex and dynamic environment, that’s a real limitation. For example, many people with disabilities feel their needs aren’t addressed by WCAG. When WCAG is the only legal requirement, their needs go ignored.
It is a known issue that WCAG has gaps. At this year’s Axe-con event, there was a presentation all about this titled The Usability Gap: Why Accessibility does not always mean usable. It focused on the limitations of WCAG compliance in delivering usable experiences for users with diverse needs.
WCAG’s gaps in user needs
An essential requirement of WCAG success criteria is that they must be clear. Government agencies and judges cannot enforce rules if nobody can explain or agree on what the rules really mean or require.
While this makes sense, this need for clear requirements is also a big part of why WCAG has gaps. For example, we can all agree that the content of a page should be understandable to its audience. But deciding who is or isn’t part of that audience, and determining what constitutes “understandable” for that audience, isn’t something that can be codified in clear requirements. Testing if content is understandable requires working directly with the audience through usability studies, user surveys, design walkthroughs, and more. An accessibility tester cannot simply check this with a WCAG success criterion.
Another limitation is that WCAG requirements are universal. The requirements have to apply everywhere equally. For example, a website with educational videos for children would need sign language to ensure that all the students in a classroom can follow along. Ensuring a speaker’s face is visible at all times to enable lip reading might also be necessary. But because these use cases don’t apply to all websites, WCAG isn’t likely to standardize these requirements. They would be too restrictive if applied universally.
The World Wide Web Consortium (W3C), which creates and maintains WCAG, is actively trying to close gaps like these, and WCAG 3.0 is its promised solution. I am skeptical that it will provide everything we need. However, I do believe EN 17161 may help address these gaps.
Benefits of an Integrated Management System (IMS)
In many industries, to get around the limitations associated with output standards, organizations opt for an IMS. Instead of focusing on the outcome itself, an IMS describes how an organization should set up its processes to achieve the outcome.
ISO 9001 is likely the best-known Integrated Management System (IMS) standard—it is “the International Standard for quality management systems.” Other examples include ISO 27001 for information security management systems and ISO 45001 for occupational health and safety management systems.
As defined by AccessibleEU, a European Commission initiative, EN 17161 “specifies requirements and recommendations that enable an organization to:
- Design, develop and provide products, goods and services so that they can be accessed, understood and used by the widest range of users, including persons with disabilities.
- Extend their range of users by identifying diverse needs, characteristics, capabilities, and preferences, by directly or indirectly involving users, and by using knowledge about accessibility in its procedures and processes.
- Meet applicable statutory and regulatory requirements as related to the accessibility of its products, goods and services.”
EN 17161: Design for all
As a management standard that describes how organizations can build and deliver accessible products, goods, and services, EN 17161 does not include WCAG-style requirements such as minimum text contrast or video captions. Instead, it focuses on helping organizations establish processes to ensure user needs are considered throughout planning, design, development, and delivery.
Because EN 17161 uses the same management structure as other ISO management systems—such as those described above—it can be easily integrated into an organization’s existing processes.
EN 17161 requires organizations to:
- Understand the context and the diverse needs, characteristics, capabilities, and preferences of their users.
- Show leadership commitment, with top management owning the “Design for All” policy and providing the resources.
- Involve users (directly or indirectly) and bring accessibility knowledge into procedures and processes.
- Embed accessibility into the full lifecycle: planning, design, development, procurement, delivery, support, and end-of-life.
EN 17161 considers audiences whose needs are least well served. This makes it an ideal partner for organizations already working with WCAG, because it pushes them to focus on gaps in WCAG and on the real-life needs of their users.
Organizations can learn about users through many channels, including customer support, social media, surveys, and more. By considering these alongside WCAG requirements, organizations can cast a much wider net.
As with all IMS standards, EN 17161 requires that efforts be measured, and organizations that adopt it will have a systematic mechanism for identifying and addressing disability needs beyond what’s covered by WCAG.
What’s coming next
The W3C is currently developing a type of requirement called an assertion, which are expected to be a big part of WCAG 3.0. According to the W3C Working Draft for WCAG 3.0, an assertion is a “formal claim of fact, attributed to a person or organization, regarding procedures practiced in the development and maintenance of the content or conformance scope to improve accessibility.” In other words, it is a statement from an organization that certain things were done in the development of content, such as establishing an accessibility policy, conducting usability testing, or consulting a plain-language expert when writing content.
The goal with assertions is to add requirements for disability needs that can’t be expressed in clear and testable requirements. While this is progress, there are still limitations. Asserting you’ve done something doesn’t prove you’ve actually done it, and there is no way to know if any actions taken were actually effective. There are also liability concerns; organizations may not allow public assertions. And best practices often go out of date quickly.
These limitations result from WCAG being an output standard. However, by partnering WCAG 3.0 with EN 17161, these limitations can largely be nullified. EN 17161 requires organizations to document their efforts and measure the effectiveness. The documentation doesn’t need to be public; it can simply be kept for internal or external audits. If the digital accessibility field embraces EN 17161, WCAG 3.0 assertions can be far more impactful.
WCAG and EN 17161: Getting the best of both worlds
As things stand in the field of digital accessibility today, organizations need to look beyond WCAG. With EN 17161, organizations have a systematic way to do this.
Ultimately, WCAG is written to determine if an individual web page meets minimal accessibility requirements. This is essentially an all-or-nothing model. If you create a web page by hand, you may very well be able to ensure that it conforms to all WCAG criteria. However, if you are building a site with dynamic content and millions of pages, problems will inevitably creep in. By integrating EN 17161, organizations set up a robust accessibility program to measure real-world accessibility alongside WCAG success criteria. The end result is a more holistic approach. Accessibility is about more than just ticking compliance checkboxes. It’s about organizational transformation. In my next article on this topic, I’ll dive into what the adoption of EN 17161 could look like in practice, and how it can inform goal-setting, process evaluation, and achieving measurable progress.
