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11.1.4.10 Reflow should not apply as written to all closed functionality

Currently

In the 2025-02-07 draft, 11.1.4.10 has this precondition:

Where ICT is, or includes, non-web software that provides a user interface

This causes it to apply to all closed functionality, and does not take into account this guidance in WCAG2ICT, Success Criteria Problematic for Closed Functionality:

  • 1.4.10 Reflow — Some software on ICT with closed functionality does not support scrolling content, or zooming, or changing the size of a viewport or scrollable content area to the specified width/height (examples include, but are not limited to, software for self-service transaction machines or kiosks). Therefore, some other non-WCAG requirements would be needed for products with closed functionality to ensure that content is readable by persons with low vision without scrolling in two dimensions.

    Note 3

    Some ICT with closed functionality does not display large chunks of text and only has UI controls. In such cases, two-dimensional scrolling to access the text and UI controls may be considered essential, thus meeting an exception, and the success criterion would be satisfied.

Proposed

New sub-clauses of 5.1 like the following.

5.1.x Functionality closed to a specific display width

Where ICT includes closed functionality, and any functionality of the ICT is closed to displaying in a viewport or scrollable content area with a width equivalent to 320 CSS pixels, and this functionality includes horizontal line(s) of text,

when displaying in the viewport width nearest to an equivalent of 320 CSS pixels:

  • Content of the closed functionality that meets 5.1.4, in the mode of operation used to meet 5.1.4 shall be presented without loss of information or functionality;
  • Content of the closed functionality that meets 5.1.4, except for parts of the content which require two-dimensional layout for usage or meaning, in the mode of operation used to meet 5.1.4 shall not require horizontal scrolling;
  • Content of the closed functionality that meets 11.1.4.4, except for parts of the content which require two-dimensional layout for usage or meaning, when resized to 200% shall not require horizontal scrolling.

and (with emphasis just to highlight the differences here in the proposal):

5.1.x Functionality closed to a specific display height

Where ICT includes closed functionality, and any functionality of the ICT is closed to displaying in a viewport or scrollable content area with a height equivalent to 256 CSS pixels, and this functionality includes vertical line(s) of text,

when displaying in the viewport height nearest to an equivalent of 256 CSS pixels:

  • Content of the closed functionality that meets 5.1.4, in the mode of operation used to meet 5.1.4 shall be presented without loss of information or functionality;
  • Content of the closed functionality that meets 5.1.4, except for parts of the content which require two-dimensional layout for usage or meaning, in the mode of operation used to meet 5.1.4 shall not require vertical scrolling;
  • Content of the closed functionality that meets 11.1.4.4, except for parts of the content which require two-dimensional layout for usage or meaning, when resized to 200% shall not require vertical scrolling.

The above proposed clauses could potentially be combined into a single clause, but that would require rather complicated language.

The above proposed clauses address all of the cases mentioned in WCAG2ICT as problematic for closed functionality.

  • "Does not support scrolling content" — The tests are written in such a way that they do not assume scrolling support. ICT without scrolling support would simply meet the points that say "shall not require... scrolling".
  • "Does not support... zooming" — Where zooming is supported, then the "meets 11.1.4.4" points are evaluated. (There's no need to test "loss" again, when it's already been tested in 11.1.4.4.) Where zooming is not supported, then the "meets 5.1.4" points are evaluated.
  • "Does not support... changing the size of a viewport or scrollable content area to the specified width/height" — Addressed in the preconditions.

Finally, EN 301 549 will need a new precondition in 11.1.4.10 to exclude the preconditions in the new 5.1.x clauses.