Intentions of "summarizing" criteria (9.6, 11.5.2.3 and 11.8.1)
During drafting a monitoring methodology for compliance tests, training implementers of EN 301 549 and dealing with specific monitoring cases I haven't really understood intentions and rationale of so-called summarizing criteria (9.6, 11.5.2.3 and 11.8.1). Notably confusing is criterion 9.6 because despite detailed description that I have included into the Estonian methodology for compliance tests, implementers of EN 301 549 have frequently asked how to actually implement it.
From the viewpoint of monitoring based on the Commission Implementing Decision (EU) 2018/1524 these criteria will be non-compliant (i.e. results of procedure to check compliance with EN 301 549 will fail) anyway if minimally one criterion of a particular sample (precisely criteria 9.1 to 9.4 in case of criterion 9.6, criteria 11.5.2.5 to 11.5.2.17 in case of criterion 11.5.2.3 and criteria 11.8.2 to 11.8.5 in case of criterion 11.8.1).
There isn't need to repeat non-compliance because at least in Estonia we have to anyway report about every finding regarding non-compliances to participants in proceedings. I guess actually that this is partially the case in all EU members as well, because the 2018/1524 (precisely Annex II) guide to member states report regularly about
the findings regarding frequent or critical non-compliance with the requirements identified in the standards and technical specifications referred to in Article 6 of Directive (EU) 2016/2102.
Thus I am proposing to e-examine appropriateness of 9.6, 11.5.2.3 and 11.8.1 for websites (i.e. Table A1) and mobile applications (i.e. Table A2).