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Clarification of how the WCAG Conformance Requirements are met

As discussed in issue #60 (closed), WCAG Conformance Requirements (i.e., clauses 9.6 (page 51 of EN 301 549 V.3.2.1) and C.9.6 (page 148 of EN 301 549 V.3.2.1)) cause a lot of uncertainty in their current form.

Clauses 9.6 and C.9.6 are necessary to ensure that conforming to EN 301 549 and to WCAG is equivalent. But in the current formulation, these clauses have led to several issues in terms of application and evaluation. Although these clauses differ from other clause 9 requirements (the conformance conditions stated in clause 9.6 are to be applied when checking conformance of all requirements in clauses 9.1 to 9.4), EN 301 549 V.3.2.1 treats these clauses similarly to other clause 9 requirements. It has led to several issues, such as a duplicating or summarising effect (if any requirement from WCAG fails, this requirement must also be violated automatically), ambiguity of C.9.6 in testing methodologies (e.g., how does the evaluator make sure in the testing process that the 4th requirement ("Only accessibility-supported ways of using technologies are relied upon to satisfy the success criteria.") is compliant?), etc.

STF 614 has discussed several ways to deal with the issue:

  • Not having a separate requirement but having all the requirements say “according to WCAG Conformance Requirements”.
  • To reflect WCAG Conformance Requirements similarily to RTT operational scenarios (page 36 of the latest editorial draft of EN 301 549 (could be downloaded in issue #219)), since they are similar in concept to saying what types of RTT connection scenarios need to meet all the clause 6.2 accessibility requirements. 
  • To add several informative notes to clauses 9.6 and C.9.6.

We should attempt to create a solution that is applicable and testable by implementators while also adhering to the principle that conformance to EN 301 549 is equivalent to conformance to WCAG.