CEN/CLC/ETSI TR 101550:2022
(Main)Documents relevant to EN 301 549 (V1.1.1) "Accessibility requirements suitable for public procurement of ICT products and services in Europe"
Documents relevant to EN 301 549 (V1.1.1) "Accessibility requirements suitable for public procurement of ICT products and services in Europe"
The present document lists the documents used in the creation of EN 301 549 (V1.1.1) on accessibility requirements for public procurement of ICT products and services in Europe and provides a source reference for any other documents needed to implement the test procedures specified in that document.
As well as identifying the sources for the EN content, the present document also provides additional explanation to assist users of the EN with clarifications and supporting information about measurement methods, particularly where no globally agreed test presently exists.
Where there are any test gaps, these are identified and test descriptions and evaluation methodologies are developed. In those exceptional cases where it is not possible to do so, recommendations are given on how the gaps should be filled. The present document does not address additional sources or issues raised during the creation of later versions of the EN.
Relevante Dokumente zu EN 301 549 (V1.1.1) "Barrierefreiheitsanforderungen, geeignet für die öffentliche Beschaffung von IKT-Produkten und -Dienstleistungen in Europa"
Dokumenti v povezavi z EN 301 549 (V1.1.1) "Zahteve za dostopnost pri javnem naročanju izdelkov IKT in storitev v Evropi"
General Information
Standards Content (Sample)
SLOVENSKI STANDARD
kSIST-TS FprCEN/CLC/ETSI TR 101550:2022
01-februar-2022
Dokumenti v povezavi z EN 301 549 (V1.1.1) "Zahteve za dostopnost pri javnem
naročanju izdelkov IKT in storitev v Evropi"
Documents relevant to EN 301 549 (V1.1.1) "Accessibility requirements suitable for
public procurement of ICT products and services in Europe"
Relevante Dokumente zu EN 301 549 (V1.1.1) "Barrierefreiheitsanforderungen, geeignet
für die öffentliche Beschaffung von IKT-Produkten und -Dienstleistungen in Europa"
Ta slovenski standard je istoveten z: FprCEN/CLC/ETSI TR 101550
ICS:
35.020 Informacijska tehnika in Information technology (IT) in
tehnologija na splošno general
kSIST-TS FprCEN/CLC/ETSI TR en,fr,de
101550:2022
2003-01.Slovenski inštitut za standardizacijo. Razmnoževanje celote ali delov tega standarda ni dovoljeno.
kSIST-TS FprCEN/CLC/ETSI TR 101550:2022
kSIST-TS FprCEN/CLC/ETSI TR 101550:2022
TECHNICAL REPORT FINAL DRAFT
FprCEN/CLC/ETSI TR 101
RAPPORT TECHNIQUE
TECHNISCHER BERICHT
December 2021
ICS
Will supersede CEN/CLC/ETSI TR 101550:2014
English version
Documents relevant to EN 301 549 (V1.1.1) "Accessibility
requirements suitable for public procurement of ICT
products and services in Europe"
To be completed Relevante Dokumente zu EN 301 549 (V1.1.1)
"Barrierefreiheitsanforderungen, geeignet für die
öffentliche Beschaffung von IKT-Produkten und -
Dienstleistungen in Europa"
This draft Technical Report is submitted to CEN members for Vote. It has been drawn up by the Technical Committee
CEN/CLC/ETSI/SWG eAcc.
CEN members are the national standards bodies of Austria, Belgium, Bulgaria, Croatia, Cyprus, Czech Republic, Denmark, Estonia,
Finland, France, Germany, Greece, Hungary, Iceland, Ireland, Italy, Latvia, Lithuania, Luxembourg, Malta, Netherlands, Norway,
Poland, Portugal, Republic of North Macedonia, Romania, Serbia, Slovakia, Slovenia, Spain, Sweden, Switzerland, Turkey and
United Kingdom.
Recipients of this draft are invited to submit, with their comments, notification of any relevant patent rights of which they are
aware and to provide supporting documentation.
Warning : This document is not a Technical Report. It is distributed for review and comments. It is subject to change without
notice and shall not be referred to as a Technical Report.
EUROPEAN COMMITTEE FOR STANDARDIZATION
COMITÉ EUROPÉEN DE NORMALISATIO N
EUROPÄISCHES KOMITEE FÜR NORMUN G
CEN-CENELEC Management Centre: Rue de la Science 23, B-1040 Brussels
© 2021 CEN All rights of exploitation in any form and by any means reserved Ref. No. FprCEN/CLC/ETSI TR 101 550 E
worldwide for CEN national Members.
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2 CEN/CLC/ETSI TR 101 550 V1.1.2 5 (2021-12)
Reference
RTR/HF-00301557
Keywords
accessibility, HF, ICT, procurement
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All rights reserved.
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Contents
Intellectual Property Rights . 4
Foreword. 4
Modal verbs terminology . 4
Introduction . 5
1 Scope . 6
2 References . 6
2.1 Normative references . 6
2.2 Informative references . 6
3 Definition of terms, symbols and abbreviations . 8
3.1 Terms . 8
3.2 Symbols . 8
3.3 Abbreviations . 8
4 Overview . 9
5 Preparation of the EN requirements . 9
5.1 General . 9
5.2 Global issues within the EN . 11
5.3 Definitions (clause 3 of the EN) . 12
5.4 Functional performance (clause 4 of the EN) . 13
5.4.1 Functional performance statements . 13
5.4.2 Mapping between requirements and functional performance statements . 14
5.5 Generic requirements (clause 5 of the EN) . 15
5.6 ICT with two-way voice communications (clause 6 of the EN) . 15
5.6.1 Audio bandwidth for speech (informative recommendation) (clause 6.1 of the EN) . 15
5.6.2 Real-Time Text (RTT) functionality (clause 6.2 of the EN) . 15
5.7 Video communication (clause 6.6 of the EN) . 16
5.8 Hardware (clause 8 of the EN) . 16
5.8.1 Hardware products with speech output (clause 8.2 of the EN) . 16
5.8.2 Fixed-line devices (clause 8.2.2.1 of the EN) . 16
5.8.3 Wireless communication devices (clause 8.2.2.2 of the EN) . 16
5.8.4 Physical access to ICT (clause 8.3 of the EN) . 16
5.8.5 Mechanically operable parts (clause 8.4 of the EN) . 18
5.9 Web (clause 9 of the EN) . 18
5.10 Non-web documents (clause 10 of the EN) . 19
5.11 Non-web software (clause 11 of the EN) . 20
5.11.1 Software success criteria (clause 11.2 of the EN) . 20
5.11.2 Interoperability with assistive technologies (clause 11.3 of the EN) . 21
5.11.3 Authoring tools (clause 11.6 of the EN) . 21
5.12 ICT providing relay or emergency service access (clause 13 of the EN) . 21
5.13 Annex B . 21
5.14 Annex C . 22
6 Documents used for the development of test procedures . 22
6.1 Simple tests based on inspection or testing . 22
6.2 Tests with processes defined in other standards . 22
6.3 Selective testing . 22
7 New tests and evaluation methods . 23
7.1 New tests . 23
7.2 Further research . 23
7.2.1 Contrast . 23
7.2.2 Anthropometry . 23
7.2.3 Usage with limited cognition . 24
7.2.4 Real-time text correctness . 24
7.2.5 The physical design of installed and free-standing ICT . 24
History . 25
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Intellectual Property Rights
Essential patents
IPRs essential or potentially essential to normative deliverables may have been declared to ETSI. The declarations
pertaining to these essential IPRs, if any, are publicly available for ETSI members and non-members, and can be
found in ETSI SR 000 314: "Intellectual Property Rights (IPRs); Essential, or potentially Essential, IPRs notified to
ETSI in respect of ETSI standards", which is available from the ETSI Secretariat. Latest updates are available on the
ETSI Web server (https://ipr.etsi.org/).
Pursuant to the ETSI Directives including the ETSI IPR Policy, no investigation regarding the essentiality of IPRs,
including IPR searches, has been carried out by ETSI. No guarantee can be given as to the existence of other IPRs not
referenced in ETSI SR 000 314 (or the updates on the ETSI Web server) which are, or may be, or may become,
essential to the present document.
Trademarks
The present document may include trademarks and/or tradenames which are asserted and/or registered by their owners.
ETSI claims no ownership of these except for any which are indicated as being the property of ETSI, and conveys no
right to use or reproduce any trademark and/or tradename. Mention of those trademarks in the present document does
not constitute an endorsement by ETSI of products, services or organizations associated with those trademarks.
DECT™, PLUGTESTS™, UMTS™ and the ETSI logo are trademarks of ETSI registered for the benefit of its
Members. 3GPP™ and LTE™ are trademarks of ETSI registered for the benefit of its Members and of the 3GPP
Organizational Partners. oneM2M™ logo is a trademark of ETSI registered for the benefit of its Members and of the ®
oneM2M Partners. GSM and the GSM logo are trademarks registered and owned by the GSM Association.
Foreword
This Technical Report (TR) has been produced by ETSI Technical Committee Human Factors (HF).
Modal verbs terminology
In the present document "should", "should not", "may", "need not", "will", "will not", "can" and "cannot" are to be
interpreted as described in clause 3.2 of the ETSI Drafting Rules (Verbal forms for the expression of provisions).
"must" and "must not" are NOT allowed in ETSI deliverables except when used in direct citation.
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Introduction
The present document was prepared in response to Phase 2 of Mandate M 376 [i.9] from the European Commission to
CEN, CENELEC and ETSI.
The primary objective of Mandate M 376 was to produce a European Standard (EN 301 549 (V1.1.1) [i.3]), hereafter,
for the purpose of the present document, called "the EN", that sets out in a single source, detailed, practical and
quantifiable functional accessibility requirements which: take note of global initiatives in that field, are applicable to all
ICT products and services identified in Phase I, and are usable in public procurement.
The present document is one of two Technical Reports that support the EN. The present document lists the standards
and technical specifications used in the creation of the compliance requirements for accessibility set out in EN 301 549
(V1.1.1) [i.3]. It also provides a source reference for other documents needed to implement the test procedures required
by the EN.
The present document also notes new test methods developed during the work on the EN and identifies exceptional
cases where further research was found to be necessary. It does not address additional sources or issues raised during
the creation of later versions of the EN.
A second Technical Report (CEN/CLC/ETSI TR 101 551 [i.7]) gives guidance to procurers on the award criteria
relevant to each area of user needs in the products and services under consideration.
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1 Scope
The present document lists the documents used in the creation of EN 301 549 (V1.1.1) [i.3] on accessibility
requirements for public procurement of ICT products and services in Europe and provides a source reference for any
other documents needed to implement the test procedures specified in that document.
As well as identifying the sources for the EN content, the present document also provides additional explanation to
assist users of the EN with clarifications and supporting information about measurement methods, particularly where no
globally agreed test presently exists.
Where there are any test gaps, these are identified and test descriptions and evaluation methodologies are developed. In
those exceptional cases where it is not possible to do so, recommendations are given on how the gaps should be filled.
The present document does not address additional sources or issues raised during the creation of later versions of the
EN.
2 References
2.1 Normative references
Normative references are not applicable in the present document.
2.2 Informative references
References are either specific (identified by date of publication and/or edition number or version number) or
non-specific. For specific references, only the cited version applies. For non-specific references, the latest version of the
referenced document (including any amendments) applies.
NOTE: While any hyperlinks included in this clause were valid at the time of publication, ETSI cannot guarantee
their long term validity.
The following referenced documents are not necessary for the application of the present document but they assist the
user with regard to a particular subject area.
[i.1] ANSI C63.19 (2011): "Methods of Measurement of Compatibility between Wireless
Communications Devices and Hearing Aids".
[i.2] ETSI EG 201 013: "Human Factors (HF); Definitions, abbreviations and symbols".
[i.3] EN 301 549 (V1.1.1): "Accessibility requirements suitable for public procurement of ICT products
and services in Europe".
[i.4] ETSI ES 200 381-1: "Telephony for hearing impaired people; Inductive coupling of telephone
earphones to hearing aids Part 1: Fixed-line speech terminals".
[i.5] ETSI ES 200 381-2: "Telephony for hearing impaired people; Inductive coupling of telephone
earphones to hearing aids; Part 2: Cellular speech terminals".
[i.6] ETSI ETS 300 381: "Telephony for hearing impaired people; Inductive coupling of telephone
earphones to hearing aids".
[i.7] CEN/CLC/ETSI TR 101 551: "Guidelines on the use of accessibility award criteria suitable for
public procurement of ICT products and services in Europe".
[i.8] ETSI TR 102 612: "Human Factors (HF); European accessibility requirements for public
procurement of products and services in the ICT domain (European Commission Mandate M 376,
Phase 1)".
[i.9] European Commission M 376: "Standardisation Mandate to CEN, CENELEC and ETSI in support
of European accessibility requirements for public procurement of products and services in the ICT
domain".
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[i.10] European Commission M 420: "Standardisation Mandate to CEN CENELEC and ETSI in support
of European Accessibility Requirements for Public Procurement in the Built Environment".
[i.11] ISO 9241-171:2008: "Ergonomics of human-system interaction-Part 171: Guidance on software
accessibility".
[i.12] ISO 21542:2011: "Building construction -- Accessibility and usability of the built environment".
[i.13] ISO 26800: 2011: "Ergonomics -- General approach, principles and concepts".
[i.14] ISO/IEC 17007:2009: "Conformity assessment -- Guidance for drafting normative documents
suitable for use in conformity assessment".
[i.15] ISO/IEC 13066-1:2011: "Information technology -- Interoperability with assistive technology
(AT) -- Part 1: Requirements and recommendations for interoperability".
[i.16] ISO/IEC 40500:2012: "Information technology -- W3C Web Content Accessibility Guidelines
(WCAG) 2.0".
[i.17] ISO/IEC TR 29138-1 "Information Technology -- Accessibility considerations for people with
disabilities - User needs summary.
[i.18] Supplement 1 to ITU-T H-Series Recommendations: "Application profile - sign language and lip-
reading real time conversation using low bit rate video communication".
[i.19] Telecommunications and Electronic and Information Technology Advisory Committee (TEITAC):
"Report to the Access Board: Refreshed Accessibility Standards and Guidelines in
Telecommunications and Electronic and Information Technology", April 2008.
[i.20] TIA-825-A: 2003: "A Frequency Shift Keyed Modem for Use on the Public Switched Telephone
Network".
[i.21] TIA-1083-A (2010): "Telecommunications; Telephone Terminal equipment; Handset magnetic
measurement procedures and performance requirements" - Telecommunications Industry
Association.
[i.22] US Access Board: "Draft Information and Communication Technology (ICT) Standards and
Guidelines" March 2010 (ANPRM 2010).
[i.23] US Access Board: "Draft Information and Communication Technology (ICT) Standards and
Guidelines", December 2011 (ANPRM 2011).
[i.24] US Department of Justice: "2010 ADA Standards for Accessible Design". ®
[i.25] W3C Recommendation (11 December 2008)/ISO/IEC 40500 (2012): "Web Content Accessibility
Guidelines (WCAG) 2.0".
NOTE: Available at http://www.w3.org/TR/WCAG20/. ®
[i.26] W3C Working Group Note (5 September 2013): "Guidance on Applying WCAG 2.0 to Non-Web
Information and Communications Technologies (WCAG2ICT)".
NOTE: Available at http://www.w3.org/TR/wcag2ict/.
[i.27] Recommendation ITU-T F.700: "Framework Recommendation for multimedia services".
[i.28] Recommendation ITU-T F.703: "Multimedia conversational services".
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3 Definition of terms, symbols and abbreviations
3.1 Terms
For the purposes of the present document, the terms given in ETSI EG 201 013 [i.2] and the following apply:
accessibility: extent to which products, systems, services, environments and facilities can be used by people from a
population with the widest range of characteristics and capabilities, to achieve a specified goal in a specified context of
use
NOTE 1: This definition of term is from ISO 26800 [i.13].
NOTE 2: Context of use includes direct use or use supported by assistive technologies.
assistive technology: hardware or software added to, connected to, or incorporated within, a system that increases
accessibility for an individual
NOTE 1: This definition of term is from ISO 9241-171 [i.11].
NOTE 2: Examples are braille display, screen reader, screen magnification software, eye tracking devices.
NOTE 3: Where ICT does not support directly connected assistive technology, but can be operated by a system
connected over a network or other remote connection, such a separate system (with any included assistive
technology) can also be considered assistive technology.
electronic content: information and sensory experience to be communicated to the user by means of ICT
real-time text: form of text conversation in point to point situations or in multipoint conferencing where the text being
entered is displayed on all terminals in such a way that the communication is perceived by the user as being continuous
3.2 Symbols
Void
3.3 Abbreviations
For the purposes of the present document, the following abbreviations apply:
ADA Americans with Disabilities Act
ANPRM Advance Notice of Proposed Rule Making
ANSI American National Standards Institute
ATAG Authoring Tool Accessibility Guidelines
FPC Functional Performance Criteria
FPS Functional Performance Statement
GSM Global System for Mobile communications
ICT Information and Communication Technologies
IEC International Electrotechnical Commission
IMS IP Multimedia Subsystem
IP Internet Protocol
ISO International Organisation for Standardization
JWG Joint Working Group
PSTN Public Switched Telephone Network
RTT Real-Time Text
SI Système International (International System of Units)
TEITAC Telecommunications and Electronic and Information Technology Advisory Committee
W3C World Wide Web Consortium
WCAG Web Content Accessibility Guidelines (of W3C)
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4 Overview
When writing EN 301 549 (V1.1.1) [i.3], hereafter, for the purpose of the present document, called "the EN", there were
a number of key requirements that had to be taken into account.
It was important to build on the significant work undertaken during Phase 1 of Mandate M 376 [i.9] which resulted in
ETSI TR 102 612 [i.8]. Phase 1 was the preparatory work that preceded the Phase 2 activity of preparing a European
Standard (Norm) (EN) containing in one volume all the necessary functional accessibility requirements for public
procurement of products and services in the ICT domain. This EN, EN 301 549 (V1.1.1) [i.3], was intended to contain
these requirements in a fully demonstrable and testable form, compliant with ISO/IEC 17007 [i.14], the standard which
gives guidance for drafting normative documents suitable for use in conformity assessment.
It was important that the document should achieve global acceptability, originally by taking into account the
requirements of the US Telecommunications and Electronic and Information Technology Advisory Committee
(TEITAC) Report published in April 2008 [i.19] on which the Phase 1 work was based. Unfortunately, before work
started on Phase 2 of the Mandate [i.9], the US Access Board set out in an Advance Notice of Proposed Rulemaking
(ANPRM) of their "Information and Communication Technology (ICT) Standards and Guidelines" [i.23].
In order to maintain the aim to reduce the burden on manufacturers by providing a common set of public procurement
requirements for accessibility which as far as possible could apply to markets both in Europe and in the rest of the world
it was necessary to change the work to meet the new US ANPRM [i.23]. This has been achieved whilst meeting the
requirements mandated by the European Commission.
Whilst trying to achieve a globally acceptable standard it was important to ensure that the requirements of the EN took
account of the European public procurement needs, particularly in those areas affected by European legislation. It was
also necessary to take note of some areas where aspects of performance are controlled by different legislative
requirements, such as telephone transmission.
Where websites are concerned, it was important to achieve global status for the accessibility requirements by referring
to the well-established process of conformance to the internationally accepted web content accessibility guidelines
(WCAG) produced by the World Wide Web Consortium (W3C), an international community that develops
recommendations. These recommendations are currently at version WCAG 2.0 [i.25], which was adopted in December
2008.
5 Preparation of the EN requirements
5.1 General
For each potential requirement identified in Phase 1 of the work on Mandate M 376 [i.9], the sources identified in the
report were checked to see if they were appropriate to be a potential source of wording for the requirement (i.e. whether
it was a widely accepted global standard) and, where appropriate, to identify whether the specific text in the standard
could be taken into account when wording the requirement. A full listing of the sources that relate to each requirement
can be found in ETSI TR 102 612 [i.8] produced at the end of Phase 1.
The original Terms of Reference for the work on the EN were based on the output of Phase 1 of the mandate.
Subsequent to the publication of the Phase 1 reports there were considerable developments in relevant international
regulations and standards. The publication by the US Access Board of an Advance Notice of Proposed Rulemaking
(ANPRM) [i.22] in March 2010 was particularly significant.
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When writing the EN an attempt was made to maximize alignment with the updating of the American accessibility
requirements that are foreseen by the American Architectural and Transportation Barriers compliance board's (Access
Board) document entitled "Telecommunications Act Accessibility Guidelines: Electronic and Information Technology
nd
Accessibility Standards". This was published as an advance notice of proposed rulemaking (ANPRM) on the 22
March 2010 [i.22]. This document led to the writing of the US Access Board's draft "Information and Communication
Technology (ICT) Standards and Guidelines" [i.22] (henceforward described here as the first 508/255 ANPRM), and
th
was followed by a second version of the standards and guidelines that was published on the 8 December 2011 [i.23].
This second 508/255 ANPRM was significantly different from the first one, replacing many of the previous
requirements by global references to WCAG 2.0 [i.25]. At the time of writing it is not known what requirements will be
included in the final Notice of Proposed Rule Making (NPRM) which will lead to the formal revision of Section 508 of
the Rehabilitation Act.
Initially, the first 508/255 ANPRM text, together with the official comments on the proposed requirements, were
considered as the basis of candidate text. Following this study, in some cases the same text was able to be used, but in
many cases the wording was changed by the experts writing the new requirements in order to address the issues raised
by the official comments and to address points found in the other standards that were consulted.
In some cases the concepts and wording from widely accepted International Standards were used as a basis for the
drafting or re-drafting of those requirements.
A new requirement was introduced into the EN to provide a clear point of separation between those areas that are Web
content, and hence within the scope of WCAG 2.0 [i.25], and those that are not. The intent was that for Web content,
the requirements of the EN would be identical to those of WCAG 2.0. This was to be achieved by making WCAG 2.0 a
part of the EN as a PDF attachment.
Major re-writing or expanding of the requirements beyond that of the 508/255 ANPRM had to be undertaken for areas
where the performance requirements of European networks or legislation demanded different or more precisely defined
specifications of services, for example when defining requirements for magnetic coupling of ICT to hearing aids and
also for Real Time Text.
In summary, the net result of taking all of these factors into account was that, for the majority of the individual
requirements (for ICT not within the scope of WCAG 2.0), the wording was closely based on the wording of the
508/255 ANPRM with changes being made to reflect the concerns expressed in the official comments on that document
and also the concerns of the experts drafting the European requirements. Where a requirement that was identified in
Phase 1 did not appear in the 508/255 ANPRM, but was still seen as being important to be included in EN 301 549
(V1.1.1) [i.3], the initial source chosen to look for appropriate wording was the TEITAC report [i.19].
The structure of some requirements in the 508/255 ANPRM was found to be incompatible with the rules adopted and
considered essential by the ESOs and official International Standards Bodies. It was therefore necessary to alter the way
in which these groups of requirements were structured and to amend the wording of requirements to match the revised
structuring logic. In making these changes, care was taken to avoid altering the intended meaning of the individual
requirements and the intended relationships between them.
th
On 8 December 2011, a second 508/255 ANPRM was issued with a completely new set of standards and guidelines
[i.23]. The approach taken in the second 508/255 ANPRM was radically different from that taken in the first 508/255
ANPRM. The number of requirements and the overall size of the document was greatly reduced in this second 508/255
ANPRM by proposing that the WCAG 2.0 Success Criteria could be applied to "User interface components and content
of platforms and applications" as well as to web pages. This approach met with initial scepticism from some
commentators in the US, as well as from those drafting EN 301 549 (V1.1.1) [i.3]. In particular the US Access Board's
suggestion that applying WCAG 2.0 Success Criteria to these other areas was "straightforward" was widely questioned.
There was also concern that some requirements appeared to have been lost.
After considering the implications of the changes proposed in the second 508/255 ANPRM it was decided that it was
possible to move significantly in the proposed direction. The result of this re-evaluation was that many of the
requirements that had been developed in the earlier drafts of EN 301 549 (V1.1.1) [i.3] were removed, with their place
being taken by equivalent Success Criteria in WCAG 2.0. This change was somewhat less dramatic than it might at first
appear as many of the requirements in the first 508/255 ANPRM started as minor redrafts of WCAG 2.0 Success
Criteria.
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Detailed consultation also took place with experts in the US who were actively involved in commenting on and
contributing to the 508/255 ANPRM. The result of this consultation was that a level of mutual agreement was reached
about certain proposals in the second 508/255 ANPRM that could not be fully accepted. Acceptable alternatives were
then drafted jointly and some of these have been carried forward into the revised versions of EN 301 549 (V1.1.1) [i.3]
in parallel to being submitted as proposals for potential revisions to the content of the 508/255 ANPRM. US regulations
meant that it was not possible to negotiate directly with the Access Board.
Further initiatives were undertaken to maximize alignment between the requirements in EN 301 549 (V1.1.1) [i.3] and
the equivalent requirements in future updates to Section 508. These initiatives, which relate to the application of WCAG
2.0 to non-Web ICT, are described in more detail in clause 5.10 of the present document.
An issue that will affect the degree of alignment between European and US accessibility requirements for ICT public
procurement is that the final changes in Section 508 of the US Rehabilitation Act will not have occurred before
EN 301 549 (V1.1.1) [i.3] enters its approval process. Attempts were made to judge where changes were likely to occur
between the second ANPRM and the final update to Section 508 in an attempt to maximize alignment between the two
sets of accessibility standards.
5.2 Global issues within the EN
A point of significant confusion throughout the development of the EN is the fundamental difference in status between
the EN and the equivalent standards in Section 508, both in its current form and in the subsequent ANPRMs [i.23].
Although the Section 508 documents are called "standards and guidelines" they are an integral part of U.S. law. In
contrast, EN 301 549 (V1.1.1) [i.3] is a voluntary standard that has no direct legal status. The first parts of Section 508
specify issues of "application and administration" and "scoping requirements", whereas the subsequent parts of Section
508 and the ANPRMs contain requirements that are similar to those normally found in a voluntary standard.
The expectation of those who are familiar with Section 508 was that the EN should contain the important policy issues
such as "equivalent facilitation" and "best meets" as well as a list of exemptions for certain categories of ICT or certain
contexts of use of the ICT. Such policy-related issues are not permitted in a voluntary standard such as an EN. These
factors are expected to be dealt with by any legislative instruments that use the EN as the technical basis for the
legislation.
There were also requests that whole categories of ICT should be exempted from meeting some or all of the
requirements of the EN. It is not possible to include such exemptions in the EN. Any exclusion of specific types of ICT
would need to be agreed at a policy level within Europe.
In the later phases of the development of the EN additions were made to the text, or proposed by commenters, to try to
ensure that the EN could not be mistakenly used in situations that could be against the interest of any or all direct or
indirect users of the standard (i.e. users of the ICT, procuring authorities and suppliers). Unfortunately, the wording that
was designed to prevent such unintentional misuse almost always fell into the category of policy-based language and
had to be removed.
As a consequence of the above issues and others, significant effort was made to ensure that the title and scope of the EN
correctly reflected its role and purpose. An adjustment was made to the title to ensure that its suitability for use in public
procurement was clear, whilst not implying that it could only be used in public procurement. The finally agreed title for
the EN was agreed to be:
• "Accessibility requirements suitable for public procurement of ICT products and services in Europe".
The scope was carefully adjusted to ensure that any exclusion to the scope of applicability of the standard were not
policy-based but related to technical issues only. The relevant text in the scope that was agreed was:
• "-- the requirements in the present document are not applicable:
- when the product is in a failure, repair or maintenance state where the ordinary set of input or output
functions are not available;
- during those parts of start-up, shutdown, and other state transitions that can be completed without user
interaction.
NOTE 1: Even in the above situations, it is best practice to apply requirements in the present document
wherever it is feasible and safe to do so.
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NOTE 2: Compliance issues are covered in normative clause C.1."
At the outset of the work on the EN, consideration was given to the possibility of defining requirements:
• that could each be me met at different levels (e.g. a minimum level, a typical level or a superior level);
• that were part of a scheme that supported different levels of conformance (i.e. similar to the levels of
conformance of WCAG 2.0 [i.25].
The experts responsible for drafting the requirements soon recognized that there was no way to decide how the different
levels referred to above could be assigned to accessibility requirements for ICT in general. It was fairly obvious that
many requirements would be very important for some users, if they met their specific accessibility needs, but those
same requirements might offer no benefits to other users with different accessibility needs.
W3C spent significant time deciding how to allocate their success criteria to the different conformance levels. These
levels are now well established and accepted in the field of web accessibility. However, the W3C WCAG2ICT Task
Force also recognized that these same levels might not be applicable when the WCAG 2.0 success criteria were applied
to non-web ICT. This was reflected in the EN by the removal of the conformance level designators (i.e. A and AA) in
clauses 10 and 11 of the EN.
There are two very fundamental related principles underlying the way that the requirements and tests have been drafted.
The first principle is that a description of the scope of application of a requirement should be written as the first part of
the requirement text. The implication of this principle is that it should be possible to read a requirement from the EN in
isolation and know whether it is applicable to the item of ICT under consideration. Formulating requirements in this
way should also be beneficial when the requirements are used outside of the direct context of the EN itself (e.g. when
they are used in the M 376 toolkit).
The second principle builds upon the one described above. This principle is that the tests in Annex C of the EN should
be a direct rewrite of the requirements in the main body of the EN. The requirements are written in a consistent way so
that the scoping text that starts the requirement becomes the pre-condition for the test. The wording of the rest of the
requirement can be decomposed into a series of checks to be performed during testing and a pass/fail evaluation for the
test that is based upon which checks are true or false. In the last processing of the EN, a thorough re-examination and
adjustment of the self-scoping text in the requirements and updating of the tests was undertaken. A note was added to
clause C.1 of the EN to highlight these principles:
"NOTE 3: All clauses apart from those in clause 12 are self-scoping. This means they are introduced with the
phrase 'Where ICT '. Compliance is achieved either when the pre-condition is true and
the corresponding test (in annex C) is passed, or when the pre-condition is false (i.e. the pre-condition is
not met or not valid)."
The following clauses identify specific instances where the above general appro
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