Sub-clauses of 11.1-11.4 do not clearly address partially-closed software
Responding to the latest editorial draft (#219) as of 2024-11-21.
Current
Example: 11.1.1.1
Where ICT is or includes non-web software that provides a user interface, and that is not closed to programmatic access of information by assistive technologies,
the software shall satisfy...
Issue: It's unclear how to apply this clause to software where some functionality is closed and some functionality is open. (EN 301 549 version 3.2.1 had a similar issue. The issue is easier to notice now with the recently improved precision of the preconditions.)
A similar issue occurs in several other sub-clauses of 11.1-11.4.
Special case: 11.1.2.1
Where ICT is or includes non-web software that provides a user interface, and that is not closed to programmatic access of information by assistive technologies, and where pre-recorded auditory information is not needed to enable the use of closed functions of the ICT,
the software shall satisfy the...
Issue: The phrase "where pre-recorded auditory information is not needed to enable the use of closed functions" is confusing and redundant. As used elsewhere in the norm, "needed to enable the use of..." means it's part of said functionality, so this is redundant to the "not closed" phrase. The "needed to enable the use of..." phrase might have made sense as a contrast to clause 11.1.2.1.2 in an earlier version, but 11.1.2.1.2 has since been removed.
Proposed
Example: 11.1.1.1
Where ICT is or includes non-web software that provides a user interface, and the software includes functionality that is not closed to programmatic access of information by assistive technologies,
the
softwarefunctionality that is not closed shall satisfy...
Special case: 11.1.2.1
Where ICT is or includes non-web software that provides a user interface, and the software includes functionality that is not closed to programmatic access of information by assistive technologies,
and where pre-recorded auditory information is not needed to enable the use of closed functions of the ICT,the
softwarefunctionality that is not closed shall satisfy the...