Requirements 11.5.2.1 and 11.5.2.2

changed the description

I agree with the proposal with an edit to the pre-condition, as the ICT could include platform software (a smartphone with the included OS) or be platform software (a stand-alone version of Windows 11 that can be purchased to be installed in a computer).

My proposal for the pre-condition would be: "Where the ICT is or contains platform software..."

There is a need throughout EN 301 549 to consider replacing all requirements that say that something "is" something to consider replacing "is" with "is or contains" or "is or includes".

Based on @martineznorm edit to the pre-condition:

11.5.2.1 Platform interoperability with assistive technologies

Where the ICT is or contains platform software, the platform software should provide a set of documented accessibility platform services that will support interoperability between user interface running on the platform software and assistive technology.

NOTE 1: "Documented platform accessibility services" are a subset of the platform's application programming interface (API) that allows application developers to create software that is compatible with assistive technologies. Depending on the platform, these services may be referred to by different names, such as accessibility services or accessibility API. Alternatively, compatibility with assistive technologies may be achieved by using "other documented services" that are not part of the accessibility API, but are part of the platform's user interface services.

NOTE 2: User interface services that provide accessibility support by default are considered to be part of the services provided to conform to this clause (e.g. the service for creating a new user interface element provides role, state, boundary, name and description).

NOTE 3: To comply with this requirement the platform software can provide its own set of services or expose the services provided by its underlying platform layers, if those services conform to this requirement.

NOTE 4: The definition of platform in clause 3.1 applies to software that provides services to other software, including but not limited to, operating systems, web browsers, virtual machines.

11.5.2.2 Minimum platform interoperability with assistive technologies

Where the ICT is or contains platform software, and a user interface concept corresponding to one of the clauses 11.5.2.5 to 11.5.2.17 is supported within the software environment, the platform software shall support that requirement.

EXAMPLE: Selection attributes from clause 11.5.2.14 (Modification of focus and selection attributes) may not exist in environments that do not allow selection, which is most commonly associated with copy and paste.

NOTE 1: "Documented platform accessibility services" are a subset of the platform's application programming interface (API) that allows application developers to create software that is compatible with assistive technologies. Depending on the platform, these services may be referred to by different names, such as accessibility services or accessibility API. Alternatively, compatibility with assistive technologies may be achieved by using "other documented services" that are not part of the accessibility API, but are part of the platform's user interface services.

NOTE 2: User interface services that provide accessibility support by default are considered to be part of the services provided to conform to this clause (e.g. the service for creating a new user interface element provides role, state, boundary, name and description).

NOTE 3: To comply with this requirement the platform software can provide its own set of services or expose the services provided by its underlying platform layers, if those services conform to this requirement.

NOTE 4: The definition of platform in clause 3.1 applies to software that provides services to other software, including but not limited to, operating systems, web browsers, virtual machines.

NOTE 5: Within specific programming environments, the technical attributes associated with the user interface properties described in clauses 11.5.2.5 to 11.5.2.17 might have different names than those used within the clauses.

Clause C.11.5.2.2

Pre-conditions

The software evaluated is or contains platform software.
Any of the user interface concepts corresponding to any of the clauses 11.5.2.5 to 11.5.2.17 is supported within the software environment

Procedure

Check that the platform software documentation includes information about platform accessibility services that enable assistive technology to interoperate with software running on the platform that implements any of the user interface concepts corresponding to the clauses 11.5.2.5 to 11.5.2.17.

Result

Pass: Check 1 is true

Fail: Check 1 is false

Not applicable: Pre-condition 1 is not met.

NOTE: If the ICT complies with clauses 11.5.2.5 to 11.5.2.17, then the ICT complies with clause 11.5.2.2.

Following the comments received from the STF, the new proposal merges contents of previous clauses 11.5.2.1 and 11.5.2.2 into a new clause 11.5.2.1, which is worded as follows:

11.5.2.1 Platform interoperability with assistive technologies

Where the ICT contains platform software

the platform software shall provide a set of documented platform accessibility services, or other documented platform services, that cover any interface concept corresponding to clauses 11.5.2.5 to 11.5.2.17 supported within the platform software.

NOTE 1: "Documented platform accessibility services" are a subset of the platform's application programming interface (API) that support interoperability between user interface running on the platform software and assistive technology. They allow application developers to create software that is compatible with assistive technologies. Alternatively, compatibility with assistive technologies may be achieved by using "other documented services" that are not part of the accessibility API, but are part of the platform's user interface services.

NOTE 2: Depending on the platform, documented platform accessibility services may be referred to by different names, such as accessibility services or accessibility API.

NOTE 3: User interface services that provide accessibility support by default are considered to be part of the services provided to conform to this clause (e.g. the service for creating a new user interface element provides role, state, boundary, name and description).

NOTE 4: To comply with this requirement the platform software can provide its own set of services or expose the services provided by its underlying platform layers, if those services conform to this requirement.

NOTE 5: The definition of platform in clause 3.1 applies to software that provides services to other software, including but not limited to, operating systems, web browsers, virtual machines.

C.11.5.2.1

Type of assessment

Inspection

Pre-conditions

The software evaluated contains platform software.

Procedure

Check that the platform provides a set of documented platform accessibility services.
For each user interface concept corresponding to the clauses 11.5.2.5 to 11.5.2.17 implemented in the platform software.

2.1 Check that the platform software documentation includes information about platform services that enable assistive technology to interoperate with software running on the platform.

Result

Pass: Check 1 and all checks 2.1 are true

Fail: Check 1 is false or any check 2.1 is false

Not applicable: Pre-condition 1 is not met.

NOTE: In case the ICT complies with clauses 11.5.2.5 to 11.5.2.17, then the ICT complies with 11.5.2.1.

I have several comments to the latest proposal by @rodriguezasc:

The precondicion should be "is or contains" (or "is or includes"). The requirement should apply to stand-alone operating systems, or to software distributed as part of a hardware product.
The "duality" between accessibility and non-accessibility services is confusing. I think that it is not necessary, given that the requirement is then specific about meeting 11.5.2.5 to 11.5.2.17. My proposal would be to simplify and only refer to "documented platform services" in the requirement. And then to rewrite Note 1 to explain that these services are commonly called "accessibility services".
Note 3 would include the word "programming", to be more clear what a user interface service is. My proposal would be: "User interface programming services".
In C.11.5.2.1, the note is very confusing. I don't agree with the way it is written. If we take a platform software as a product, then 11.5.2.5 to 11.5.2.17 refer to the user interface of the operating system. But we should not imply that if the UI of the platform meets 11.5.2.5 to 11.5.2.17, then the platform services enable any other software to use these services to provide accessible user interfaces. My proposal would be to delete this note (I could accept a different version of the note, but I cannot think of anything to improve the current version)

Taking this into account, my new proposal is below (changes are highlighted in bold).

11.5.2.1 Platform interoperability with assistive technologies

Where the ICT is or contains platform software

the platform software shall provide a set of documented platform services, that cover any interface concept corresponding to clauses 11.5.2.5 to 11.5.2.17 supported within the platform software.

NOTE 1: These "documented platform services" are normally referred to as "document platform accessibility services". They are a subset of the platform's application programming interface (API) that support interoperability between user interface running on the platform software and assistive technology. They allow application developers to create software that is compatible with assistive technologies. Alternatively, compatibility with assistive technologies may be achieved by using "other documented services" that are not part of the accessibility API, but are part of the platform's user interface services.

NOTE 2: Depending on the platform, documented platform accessibility services may be referred to by different names, such as accessibility services or accessibility API.

NOTE 3: User interface programming services that provide accessibility support by default are considered to be part of the services provided to conform to this clause (e.g. the service for creating a new user interface element provides role, state, boundary, name and description).

NOTE 4: To comply with this requirement the platform software can provide its own set of services or expose the services provided by its underlying platform layers, if those services conform to this requirement.

NOTE 5: The definition of platform in clause 3.1 applies to software that provides services to other software, including but not limited to, operating systems, web browsers, virtual machines.

C.11.5.2.1

Type of assessment

Inspection

Pre-conditions

The software evaluated contains platform software.

Procedure

Check that the platform provides a set of documented platform accessibility services.

For each user interface concept corresponding to the clauses 11.5.2.5 to 11.5.2.17 implemented in the platform software.

2.1 Check that the platform software documentation includes information about platform services that enable assistive technology to interoperate with software running on the platform.

Result

Pass: Check 1 and all checks 2.1 are true

Fail: Check 1 is false or any check 2.1 is false

Not applicable: Pre-condition 1 is not met.

~~NOTE: In case the ICT complies with clauses 11.5.2.5 to 11.5.2.17, then the ICT complies with 11.5.2.1.~~

Regarding the comments by @martineznorm:

The precondicion should be "is or contains" (or "is or includes"). The requirement should apply to stand-alone operating systems, or to software distributed as part of a hardware product.
- Agree, this has been included in the new version of the clause, below.
The "duality" between accessibility and non-accessibility services is confusing. I think that it is not necessary, given that the requirement is then specific about meeting 11.5.2.5 to 11.5.2.17. My proposal would be to simplify and only refer to "documented platform services" in the requirement. And then to rewrite Note 1 to explain that these services are commonly called "accessibility services".
- I agree this "duality" does not help. It was considered here to be consistent with 11.5.2.3, where the expression "documented platform accessibility services" is used but not defined. We will avoid that, and 11.5.2.3 can be mended with a NOTE. Modification of 11.5.2.3 is handled in issue #239 (closed).
- Furthermore, and coherently with the latter, the following text has been dropped in NOTE 1: "Alternatively, compatibility with assistive technologies may be achieved by using "other documented services" that are not part of the accessibility API, but are part of the platform's user interface services." I think it is not needed anymore with the new approach. Also, its spirit is addressed by NOTE 3.
Note 3 would include the word "programming", to be more clear what a user interface service is. My proposal would be: "User interface programming services".
- Agree. The note has been rewritten to make it more understandable.
In C.11.5.2.1, the note is very confusing. I don't agree with the way it is written. If we take a platform software as a product, then 11.5.2.5 to 11.5.2.17 refer to the user interface of the operating system. But we should not imply that if the UI of the platform meets 11.5.2.5 to 11.5.2.17, then the platform services enable any other software to use these services to provide accessible user interfaces. My proposal would be to delete this note (I could accept a different version of the note, but I cannot think of anything to improve the current version)
- I see it differently. Your example of the platform UI that meets 11.5.2.5 to 17 is a good one. It means that, for each clause in that subset, two conditions are met: 1) the specific UI information addressed by each particular clause is programmatically determinable by ATs, 2) the latter is achieved by using the services described in 11.5.2.3. 2) is key in this respect, since compliance of the platform UI with 11.5.2.5 to 17 has been achieved by using documented services. Hence, providing this accessible user interaction is reproducible by any other party. Any other software built on this platform just needs to follow the platform's documentation to meet each of the clauses in that subset. I think that is a merit of how 11.5.2.3 and 11.5.2.5 to 17 are written in the EN.

Below, a new version of 11.5.2.1 where the above comments are considered.

11.5.2.1 Platform interoperability with assistive technologies

Where the ICT is or contains platform software

the platform software shall provide a set of documented platform services that cover any user interface concept corresponding to clauses 11.5.2.5 to 11.5.2.17 supported within the platform software.

NOTE 1: The "documented platform services" addressed by this clause are a subset of the platform's application programming interface (API) that support interoperability between user interface running on the platform software and assistive technology. They allow application developers to create software that is compatible with assistive technologies.

NOTE 2: Depending on the platform, the documented platform services addressed in this clause may be referred to by different names, such as accessibility services or accessibility API.

NOTE 3: Some platforms include services for user interface development that provide accessibility support by default (e.g. the service for creating a new user interface element provides role, state, boundary, name and description). These services are considered to be part of the services provided to conform to this clause.

NOTE 4: To comply with this requirement the platform software can provide its own set of services or expose the services provided by its underlying platform layers, if those services conform to this requirement.

NOTE 5: The definition of platform in clause 3.1 applies to software that provides services to other software, including but not limited to, operating systems, web browsers, virtual machines.

Very constructive thread, thanks @martineznorm, @rodriguezasc and @puskar!

As far as I can see, the proposed changes constitute a significant improvement. But it is quite demanding to read, so there's a risk that some aspect might have gotten accidentally lost or slightly changed in ways not intended. So I hope more people will proofread the final merged version and compare it with what's in EN v3.2.1.

mentioned in issue #274 (closed)

I agree with the latest proposal for 11.5.2.1, with a minor editorial edit of note 4. Instead of "NOTE 4: To comply with this requirement the platform software can", I suggest to add a comma after "this requirement", and to delete the "the".

The resulting note would be:

NOTE 4: To comply with this requirement, platform software can provide its own set of services or expose the services provided by its underlying platform layers, if those services conform to this requirement.

As agreed in the 2024-07-10 STF meeting, here is my proposal for a note for C.11.5.2.1, that provides guidance to use the contents of the requirements 11.5.2.5 to 11.5.2.17 for the inspection procedure:

NOTE: The text of the requirements 11.5.2.5 to 11.5.2.17 provide details on what is required of the platform accessibility services and can be used to prepare detailed checklists for the 2.1 checks.

Thanks, Loïc. I think that the use of the "documented" term (together with the inclusion of its definition in the EN), would allow the NOTE to go further regarding the implications that compliance with 11.5.2.5 to 17 has about compliance with 11.5.2.1.

However, I think the text you are proposing is agreeable, and it is still useful for 3rd party evaluators. Hence, I agree that it is a good solution.

Below I am including how C11.5.2.1 reads when your note (with minor edits) is used,

C.11.5.2.1

Type of assessment

Inspection

Pre-conditions

The software evaluated contains platform software.

Procedure

Check that the platform provides a set of documented platform accessibility services.
For each user interface concept corresponding to the clauses 11.5.2.5 to 11.5.2.17 implemented in the platform software.

2.1 Check that the platform software documentation includes information about platform services that enable assistive technology to interoperate with software running on the platform.

Result

Pass: Check 1 and all checks 2.1 are true

Fail: Check 1 is false or any check 2.1 is false

Not applicable: Pre-condition 1 is not met.

NOTE: The text of requirements 11.5.2.5 to 11.5.2.17 provides details on what is required from the documented platform accessibility services and can be used to prepare detailed checklists for the 2.1 checks.

added Proposed for approval label

added Approved for inclusion in EN label

removed Proposed for approval label

removed Approved for inclusion in EN label

added Included in EN label

Final agreement reached at the 17th July STF614 meeting.

closed

Requirements 11.5.2.1 and 11.5.2.2

Designs

Child items ...

Activity