Missing EAA non-WCAG requirements for digital instructions

Currently

The current draft of EN 301 549 Table ZB.2 addresses EAA Annex I(III)(b) by reference to clause 12 (Documentation and support services). Clause 12.1.2 includes WCAG success criteria by reference, but WCAG alone does not address these technical requirements of EAA Annex I(III)(b)(iv):

• "fonts of adequate size and suitable shape" — as described in #255
• "adjustable spacing between letters, lines and paragraphs" — WCAG SC 1.4.12 Text Spacing addresses this for instructions in a web page, but does not address instructions that appear embedded in a mobile app.

Similar requirements for "fonts of adequate size and suitable shape" and "adjustable spacing" also appear in the following EAA clauses, which are not addressed in the current draft of EN 301 549:

• EAA Annex I(I)(1)(b): Instructions for use of a product, where not provided on the product itself but made available through the use of the product or through other means such as a website
• EAA Annex I(II)(b): Instructions for the installation and maintenance, storage and disposal of the product not provided on the product itself but made available through other means, such as a website

Note: All three of the above EAA provisions apply to instructions whether they're in a physical or digital format, yet Mandate M/587 says the new "non-digital information" standard will cover them. I'm assuming the Table ZB.2 reference is appropriate because it addresses the digital format; and, in the words of Mandate M/587, EN 301 549 "should be complementary with the new standards."

Proposed

I don't have access to a draft of the new "non-digital information" standard. If, despite its "non-digital" name in the Mandate, it also covers these digital requirements, then maybe EN 301 549 should remove its Table ZB.2 reference to the EAA provision for instructions.

Otherwise, those EAA requirements for digital instructions must be covered somewhere. I suggest:

• Add a new EN 301 549 clause under 12.1.2 (Accessible documentation) addressing adequate size, suitable shape, and adjustable spacing in websites and non-web software.
• Include the three EAA provisions for digital instructions in Annex ZB tables.

It is currently very unclear on the boundary between the new proposed ENs and EN 301 549. I think that Table ZB.2's reference to clause 12 is correct, if will still be requirements in EN 301 549 that are not within the scope of the other ENs.

In general The problem in doing as you suggest is that the EAA requirements are incredibly unclear:

• adequate size - what does "this "adequate" mean? Adequate for what purposes, and for what users, etc?
• suitable shape - what does "suitable" mean? Suitable for what purposes, and for what users, etc?
• adjustable spacing between letters, lines, and paragraphs. Adjustable means that there must be settings and user preferences for these parameters. These are not generally adjustable by users in most mainstream software applications. Such adjustments are only usually available in authoring tools used for creating content. Making such additional adjustments available in more mainstream applications and websites would present a major challenge to the developers of software and websites. The underlying platforms might well not support such adjustments, and the options would be of almost no value to the majority of users and their provision would add further to the perceived complexity of software.

Taking the above issues into account, it is extremely hard to see what requirements could be produced that are both technically feasible for software developers to implement and for users to understand and use.

Any suggestions for how testable and implementable requirements addressing these EAA requirements would be gratefully received!

One interpretation of what the EAA means by "suitable" is where users are able to adjust the settings of available user preferences to a value that "suit" their specific needs. This might be the only logical interpretation of what "suitable" means.

With this approach in mind, w have now redrafted clause 11.7 "User preferences" to read:

Where ICT is, or includes, non-web software that provides a user interface, and is not designed to be isolated from its platform, that user interface shall follow the values of the user preferences that users have set for the documented platform accessibility features.

Where there are user settings related, to things such as font ("suitable shape" and "suitable size") and the spacings referred to in the EAA, are classified under user accessibility settings, then 11.7 will meet what the EAA requires. This also overcomes the need to interpret the word "suitable", as users will choose settings that they believe are "suitable" for their needs. Colour, contrast, font type, font size, and space adjustments for characters, lines and paragraphs are mentioned in a Note as typical examples of accessibility settings that may be available.

The above wording constrains what users can adjust to the set of user preferences that are classified by the platform as related to "Accessibility".

added EAA Alignment label

added Documentation and Support Services label

removed EAA Alignment label

As a result of adopting the proposed changes from Issue #541 (closed), further discussion of this requirement, and all others that concern the content of information about ICT are not appropriate to the scope of EN 301 549. It is the "non-digital" HEN and the "support services" HEN that will need to address all such issues.

closed