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11.2.4.2 incorrectly marked as Void

In EN 301 549 v3.2.1, the Page Titled requirement has been marked as Void in chapter 11.2.4.2.

Note 1

NOTE 1: The related web page requirement "Page titled" does not apply to single software programs, but to a specific definition of "sets of software programs" that are extremely rare

This is written in the EN 301 549, but WCAG2ICT (9 July 2024) states:

This applies directly as written, and as described in Intent from Understanding Success Criterion 2.4.2 replacing “Web pages” with “non-web documents or software”.

Which is identical to the version of 5 September 2013:

This applies directly as written, and as described in Intent from Understanding Success Criterion 2.4.2 (also provided below) replacing “Web pages” with “non-web documents or software”.

It looks like Note I in Chapter 11.2.4.2 of the EN 301 549 standard v3.2.1 is incorrect.

The sets of software programs restriction is applied to 2.4.1, 2.4.5, 3.2.3, 3.2.4 and 3.2.6; but not to 2.4.2.

This has been confirmed by Mary Jo Mueller, facilitator of WCAG2ICT Task Force

WCAG2ICT did not interpret 2.4.2 to be applied to "sets of software" as noted by the word substitutions to apply the success criterion to "non-web documents or software".

Related comments:

Note 2

NOTE 2: Although the name of a software product could be a sufficient title if it describes the topic or purpose, software names are trademarked and trademark names cannot by law be descriptive names. It is not practical to make software names both unique and descriptive.

Because web page has been substituted by software program the Page Titled requirement applies to the software program, and not to a screen title.

Note 2 is still accurate, however, you can argue that a trademarked name is still descriptive. I don't know about the legal side of things though.

In Section 508, 2.4.2 does apply to Software: https://www.access-board.gov/ict/#E207.2

Related comment:

Titles

In the EN 301 549, I believe that Software is less broad compared to non-web ICT. I would say almost all kinds of software also have the ability to set a title for individual screens.

For example:

Since Android 1 you are able to set a title for an Activity (= screen). And since iOS 2 you can set a title for a UIViewController (= screen).

Android 1 was released on September 23, 2008 iOS 2 was released on July 11, 2008

Software for Windows, Linux, macOS, etc. also support setting titles of windows, screens, etc.

Therefore I'd like to ask ETSI to consider applying 11.2.4.2 to 'pages' inside the software application instead of the software application itself.

Edited by janjaap