Module 2 - Information and communication technologies: Current conformance with accessibility standards

Accessibility standards

At the moment, there are 3 sets of standards for ICT accessibility that are recognized internationally. These standards could inform the development of future federal regulations for ICT accessibility. They are:

• Web Content Accessibility Guidelines (WCAG)
• Revised Section 508 Standards, and
• Harmonised European Standard accessibility requirements for ICT products and services (EN 301 549) (PDF format, 2.17MB)^{Footnote 1}

Some private and public sector organizations in Canada are already using these standards in the design of their ICT products and services. For example, federal organizations must meet the requirements of WCAG 2.0 for their public facing websites^{Footnote 2}.

Treasury Board of Canada Secretariat (TBS) also strongly encourages federal organizations to follow the Harmonised European Standard accessibility requirements for ICT products and services (EN 301 549) (PDF format, 2.17MB) (European Standard EN 301 549). TBS says federal organizations should apply this standard when buying or developing ICT for use by employees or the public. It also encourages federal organizations to consider accessibility in lifecycle management^{Footnote 3} for existing ICT, including web content^{Footnote 4}.

Various Canadian banks and financial institutions are also increasingly considering ICT accessibility. Online banking and branch transactions are becoming more accessible, especially since the pandemic. In many cases, their web content already meets internationally recognized standards. This includes features like keyboard shortcuts to allow navigation without a mouse or by headings. Some, allow users to change contrast and text size on their web pages, among other features.

ATMs in Canada are becoming more accessible as well. Some now offer audio in English and French. Some ATMs allow audio users to plug headphones into the machine; thereby, the audio direction feature guides users through their transactions. Some ATMs have other accessible design features. These include screens and buttons placed closer to the ground to help wheelchair accessibility. Braille-numbered keypads, large-print and high-contrast keypads and screen text are also common^{Footnote 5}.

ICT vendors and service providers are also taking note of these international standards. More and more, they are designing or buying ICT that meets some or all of the requirements of these standards. As well, it is common practice for governments to ask ICT suppliers and vendors to show how they meet these accessibility standards^{Footnote 6}.

Summary of accessibility standards

Web Content Accessibility Guidelines (WCAG)

WCAG 2.0

• WCAG 2.0 is the single standard for web content across the world
• It includes 12 guidelines grouped under 4 principles, stating that websites must be equally:
• perceivable
• operable
• understandable, and
• robust for all users, regardless of disability or impairment
• Each guideline includes different levels of compliance: A, AA and AAA

WCAG 2.1

• WCAG 2.1 is a newer version of WCAG 2.0 and adds new accessibility criteria (called success criteria) to it
• It adds recommendations for making web content accessible on mobile devices
• It includes additional recommendations to make web content more accessible for persons with:
• blindness and low vision
• deafness and hearing impairment
• limited movement
• speech disabilities
• photosensitivity, and
• combinations of these, as well as some accommodation for learning disabilities and cognitive limitations

Revised Section 508 of the US Rehabilitation Act

• Section 508 is the US standard for ICT accessibility since 1998; it was revised in 2017
• It includes requirements for:
• websites and web applications
• native software applications and operating systems
• telecommunications products
• video and multimedia products
• self-contained, closed products (such as multifunction copiers)
• desktops and portable computers, and
• electronic content, including documents, audio, video and multimedia
• The 2017 update to Section 508 added WCAG 2.0 levels A and AA

The European Standard EN 301 549

• Is the European Standard since 2014
• Is closely harmonized with Revised Section 508
• Includes WCAG 2.1 levels A and AA since 2018, and refers to AAA since 2021
• Applies to all digital technology, including:
• hardware
• websites
• software
• non-web documents
• electronic devices
• ICT built into the environment such as kiosks, and more
• Also touches on the concept of biometrics and support services such as relay service and call centers

Web Content Accessibility Guidelines (WCAG)

The Web Content Accessibility Guidelines are a set of accessibility standards related to web content, non-web documents and software applications when applicable. The WCAG are developed and updated by the World Wide Web Consortium (W3C). This international non-profit organization works with other organizations, persons with disabilities and experts from around the world. Official versions of WCAG 2.0 and 2.1 are available in both English and French^{Footnote 7}.

The WCAG are voluntary in most of the world. Some countries, including the United States, United Kingdom and Ireland include some or all of the WCAG criteria in their accessibility laws. In Canada, federally regulated entities must develop and publish accessibility plans and progress reports. These plans and reports must meet the latest WCAG standards that are available officially in French and English.

Since technology is constantly evolving, WCAG is updated regularly. This ensures its requirements keep up with new developments and innovations in web technologies. These updates are published as different versions, such as WCAG 2.0, WCAG 2.1 and WCAG 2.2.

WCAG 2.0

WCAG 2.0 is the only web accessibility standard to be approved by the International Standards Organization (ISO).

WCAG 2.0 requires that websites meet the following principles for all users, regardless of level of disability or impairment:

• perceivable: information and user tools such as keyboards must be made in a way that users can perceive them through at least 1 of their senses
• Example: ext alternatives for images and captions for audio content
• operable: users can interact with and make full use of websites
• Example: replace complex gestures such as pinching and swiping with simpler gestures such as taps and long presses
• understandable: users should be able to understand information and functions of "user tools"
• Example: make web pages appear and operate in predictable ways
• robust: content and information on the web must work with a wide variety of user tools, such as assistive technologies
• Example: make websites compatible with assistive technologies such screen readers

WCAG 2.0 has 3 levels of conformance (A, AA and AAA). Each level adds new requirements to the previous level to make products more accessible.

• Level A is the minimum level. Without meeting these basic requirements, barriers exist that result in inaccessible content for persons with disabilities. This level provides the largest number of people with the most benefits and is essential
• Example: level A requires that web content does not use colour alone to convey meaning^{Footnote 8}. This means, for instance, that a hyperlink needs to be not only a different colour than other text, but also underlined
• Level AA is used in most accessibility rules and regulations around the world. Meeting Level AA criteria may affect the look of a page or the logic of a website to a greater extent. At this level, content will also work with most assistive technologies
• Example: level AA further specifies that the contrast between the colour of hyperlinked text and the background of the page must be at least 4.5:1 for normal sized text^{Footnote 9}
• Level AAA deals with specific and specialized circumstances. It is not recommended to be adopted as a general policy for entire sites since it is not always possible to meet all Level AAA requirements for some content^{Footnote 10}
• Example: level AAA requires a colour contrast of at least 7:1 for normal sized text, to ensure that users with more severe vision loss can access the website^{Footnote 11}

WCAG 2.1

WCAG 2.1 builds on WCAG 2.0. It has added criteria that aim at making the web content more accessible for^{Footnote 12}:

• users accessing the web via mobile devices (for example, smartphones)
• low vision users
• cognitive and learning impaired users 
• users with motor and visual impairments

For example, 1 of the new criteria in WCAG 2.1 (which is not in 2.0) is regarding additional content that appears and disappears^{Footnote 13}. This requires that content not disappear unless users remove it. This gives people with low vision or learning or cognitive disabilities more time to read the content.

Another new criterion in WCAG 2.1 is about orientation. This means that content must allow portrait and landscape orientations^{Footnote 14}. This is important, for example, for a person with cerebral palsy who uses a wheelchair and has their tablet attached to it. This person must have the option to change display orientation in order to view websites.

Revised Section 508 of the US Rehabilitation Act

Section 508 of the US Rehabilitation Act of 1973 was updated in 2017. The Revised Section 508 requires the US federal government to develop, buy, maintain and use ICT that is accessible to persons with disabilities.

Section 508 is intended to ensure US government websites, services and technology are accessible. Among other benefits, this makes it easier for persons with disabilities to apply for federal jobs, for example.

Section 508 also applies to ICT used by employees of the US federal government. This means US federal employees with disabilities are able to work using accessible computers, phones and office equipment.

Section 508 incorporates the requirements of WCAG 2.0. This means that all US government websites and non-web content and software must meet the Level A and Level AA of WCAG 2.0, with some exceptions^{Footnote 15}.

Section 508 also includes accessibility requirements for:

• software applications and operating systems
• telecommunications products
• desktop and portable computers, as well as products such as copiers, and
• electronic content, including documents, audio, video and multimedia

ICT exceptions under Revised Section 508

US government agencies may claim an exception while buying or developing ICT items. Allowable exemptions include:

1. safe harbour for existing compliant ICT

The safe harbour exemption may apply when unchanged, existing ICT (including electronic content) complies with the original Section 508. If so, the ICT product or service does not have to be modified or upgraded to the Revised Section 508.

2. national security systems

Section 508 requirements might not apply to ICT related to:

• intelligence activities
• command and control of military forces
• equipment integral to a weapon or weapons system, or
• systems critical to the direct fulfillment of military or intelligence missions

Note: Exceptions in these areas do not apply to ICT used for routine administrative functions in the National security systems, such as payroll and finance.

3. maintenance and monitoring spaces

This exemption applies to ICT located in spaces accessed only for maintenance, repair or occasional monitoring by service personnel.

4. non-availability of conforming commercial products and commercial services

There may be times when ICT product or services that meet Revised Section 508 standards is not available. If so, organizations are allowed to buy the ICT that comes closest to meeting the requirements of the Revised Section 508. It should also meet the organizations' business needs.

If an organization uses this exception, it must provide alternative ways for persons with disabilities to access information and data.

Harmonised European Standard accessibility requirements for ICT products and services (EN 301 549)

The European Standard (PDF format, 2.17MB) is the most comprehensive standard. It goes beyond web accessibility to cover all digital accessibility. This includes:

• hardware and software
• non-web documents
• electronic devices
• mobile applications
• biometrics^{Footnote 16} (for example, facial recognition, fingerprint detectors)
• and more^{Footnote 17}

The European Standard currently uses Level A and AA of WCAG 2.1 for accessibility of websites, non-web documents^{Footnote 18} and non-web software^{Footnote 19}. Starting in the 2021 version, the European Standard also references level AAA criteria but doesn't require it.

The European Standard is much wider in scope than the WCAG. For example, it also covers:

• orientation of ICT: items like reusable plastic smart cards (such as key cards, tickets or fare cards) must allow users to determine their orientation by touch. For example, a key card must have a raised area or a notch to indicate which way it goes into the card reader
• biometrics: ICT that uses biometrics to identify a user must not rely on 1 type of biological characteristic, such as fingerprints. Some people may have difficulty using fingers or hands. The ICT must provide alternative biometrics, such as scans for retinal patterns or facial recognition
• hardware: for example, ICT hardware that has speech output must include a way to adjust the volume by at least 18 decibels. This will enable people with mild to moderate hearing impairment to adjust the audio as needed

Sections of the European Standard

The European Standard is updated regularly. The most recent version is V3.2.1 (PDF format, 2.17MB). It was released in March 2021.

Here are some examples of the requirements in the latest version.

1. Functional performance

This section covers the functional performance of ICT. This relates to how the ICT requires users to locate, identify, and operate its functions, and access the information provided.

For example, if the ICT product such as a phone or a computer requires manual actions to use, users with limited hand strength may not be able to perform the action. An alternative that does not require hand strength must be provided.

2. Generic requirements

This section explains generic requirements for ICT accessibility, including biometrics.

For example, the ICT may provide speech output as an option for persons who are blind. If so, it must be in the same language as the displayed content.

3. ICT with two-way voice communication

This section details accessibility criteria for two-way communication systems. This includes landline and mobile phones, etc.

For example, if the ICT provides caller identification, it must be available in text and at least 1 other form, such as voice.

4. ICT with video capabilities

This section covers the requirements for ICT with video capabilities. It focuses on standards for captioning and audio description.

As an example, if the ICT shows video with synchronized audio, it must also be able to display the available captions. If closed captioning is provided, the ICT must allow the user to choose whether or not to show the captions.

5. Hardware

This section covers the accessibility of hardware with speech output, phones and kiosks.

For example, many devices, like ATMs, have a rectangular numeric keypad. The number 5 key in the middle of the keypad must have a way for users to find it by touch.

6. Web content; non-web documents and software

In this area, the European Standard links directly to level AA of WCAG 2.1.

There are also additional requirements for closed systems and operating systems which are not a part of WCAG.

7. Documentation and support services

This section covers the accessibility of product documentation. It also includes accessibility requirements for support services such as help desks and call centers.

As an example, documentation such as manuals that come with the ICT must include a list of its accessibility and compatibility features. It must also describe how to use the accessibility features.

8. ICT providing relay or emergency services

Relay services enable people who use different methods of communication to interact remotely through ICT. This usually involves a human operator. An example would be a service in which a person uses sign language to relay speech from one user to another who has a hearing impairment.

This section of the European Standard spells out the accessibility requirements for the ICT used for these services.
It also sets accessibility standards for the ICT which people use to communicate with emergency services.

What could new ICT accessibility regulations be based on

The new ICT accessibility regulations could set mandatory accessibility requirements for the websites of the federally regulated entities. They could also set mandatory accessibility requirements for other digital technologies developed or purchased by federally regulated entities.

The new ICT accessibility regulations could be based on the requirements of existing accessibility standards, for example, the European Standard (EN 301 549).

This standard-based approach has several advantages. It would provide a more consistent experience for all Canadians, particularly for persons with disabilities.

A standard-based approach would also provide greater certainty and consistency for federally-regulated entities. They would know exactly what is expected of them. As organizations work to meet the standards, businesses that supply and sell ICT would see an increase in demand for accessible ICT. This would encourage development and increased availability of accessible ICT products and services.

The European Standard, for example, has the following advantages:

• the European Standard is flexible. It is easy to update to keep up with advances in technology. For example, the European Standard has been updated 4 times in the last 6 years
• in addition to WCAG for web content, the European Standard covers accessibility of hardware such as printers, digital kiosks, laptops, cellular phones
• as well, compared to WCAG, the European Standard has additional criteria for digital content such as webpages, non-web documents and software. This makes its coverage of digital content more complete than the WCAG
• the European Standard has added requirements to ensure greater equality of access to information for persons with disabilities. For example, it requires proper synchronization of audio and video content. This ensures a product will not interfere with predefined accessibility features
• the European Standard is designed to accommodate existing accessibility standards. For example, it incorporates the requirements of the WCAG. It is also designed to align with the requirements of Revised Section 508. This consistency in rules helps to ensure more efficient development and procurement of ICT products and services

Key questions: We want to hear from you

How to send your feedback

We invite you to submit your responses to the key questions in this module, and any other ideas you might have, via one of the following methods:

• by email to the following email address:
  • accessible.canada.directorate-direction.canada.accessible@hrsdc-rhdcc.gc.ca
• by regular mail to:
• Accessible Canada Directorate
  Employment and Social Development Canada
  1st floor
  105 De l'Hôtel-de-Ville Street
  Gatineau QC  J8X 4H7
• in American Sign Language or Langue des signes québécoise by Video relay service:
• please send an email to the above email address with the subject line "Sign language response". We will contact you to set a date and time for you to provide your comments

Deadline for providing your feedback

The deadline to provide responses is January 31, 2023.

Related information

• Glossary of terms
• Summary version of consultation