EN 301 549 Accessibility requirements for ICT products and services - 10. Non-web documents

10.0 General (informative)

Requirements in clause 10 apply to:

  • documents that are not web pages;
  • documents that are not embedded in web pages; and
  • documents that are provided with web pages but are neither embedded nor rendered together with the web page from which they are provided (i.e. the present clause applies to downloadable documents).

Clause 9 provides requirements for documents that are in web pages or that are embedded in web pages and that are used in the rendering or that are intended to be rendered together with the web page in which they are embedded.

NOTE 1:  Some examples of documents are letters, spreadsheets, emails, books, pictures, presentations, and movies that have an associated user agent such as a document reader, editor or media player.

NOTE 2:  A single document may be composed of multiple files such as the video content and closed caption text. This fact is not usually apparent to the end-user consuming the document/content.

NOTE 3:  Documents require a user agent in order for the content to be presented to users. The requirements for user agents can be found in clause 11.

NOTE 4:  The requirements for content that is part of software, can be found in clause 11.

NOTE 5:  The success criteria set out in clause 10 are intended to harmonize with the Working Group Note [i.26] produced by the W3C's WCAG2ICT Task Force.

NOTE 6:  "Void" clauses have been inserted in order to maintain alignment of the numbering in clauses 9, 10 and 11.

NOTE 7:  Requirements in clause 10 also apply to documents that are protected using mechanisms such as digital signatures, encryption, password protection, and watermarks when they are presented to the user.

NOTE 8:  It is best practice to provide meta data on the accessibility of the document within or separate to the document using WebSchemas/Accessibility 2.0 [i.38].

10.1 Perceivable

10.1.1 Text alternatives

10.1.1.1 Non-text content

Where ICT is a non-web document, it shall satisfy the WCAG 2.1 Success Criterion 1.1.1 Non-text Content.

NOTE:      CAPTCHAs do not currently appear outside of the Web. However, if they do appear, this guidance is accurate.

10.1.2 Time-based media

10.1.2.1 Audio-only and video-only (pre-recorded)

Where ICT is a non-web document, it shall satisfy WCAG 2.1 Success Criterion 1.2.1 Audio-only and Video-only (Prerecorded).

NOTE:      The alternative can be provided directly in the document - or provided in an alternate version that meets the success criterion.

10.1.2.2 Captions (pre-recorded)

Where ICT is a non-web document, it shall satisfy the WCAG 2.1 Success Criterion 1.2.2 Captions (Prerecorded).

NOTE:      The WCAG 2.1 definition of "captions" notes that "in some countries, captions are called subtitles". They are also sometimes referred to as "subtitles for the hearing impaired". Per the definition in WCAG 2.1, to meet this success criterion, whether called captions or subtitles, they would have to provide "synchronized visual and / or text alternative for both speech and non-speech audio information needed to understand the media content" where non-speech information includes "sound effects, music, laughter, speaker identification and location".

10.1.2.3 Audio description or media alternative (pre-recorded)

Where ICT is a non-web document, it shall satisfy the WCAG 2.1 Success Criterion 1.2.3 Audio Description or Media Alternative (Prerecorded).

NOTE 1:  The WCAG 2.1 definition of "audio description" says that "audio description" is "Also called 'video description' and 'descriptive narration'".

NOTE 2:  Secondary or alternate audio tracks are commonly used for this purpose.

10.1.2.4 Captions (live)

Where ICT is a non-web document, it shall satisfy the WCAG 2.1 Success Criterion 1.2.4 Captions (Live).

NOTE:      The WCAG 2.1 definition of "captions" notes that "in some countries, captions are called subtitles". They are also sometimes referred to as "subtitles for the hearing impaired". Per the definition in WCAG 2.1, to meet this success criterion, whether called captions or subtitles, they would have to provide "synchronized visual and / or text alternative for both speech and non-speech audio information needed to understand the media content" where non-speech information includes "sound effects, music, laughter, speaker identification and location".

10.1.2.5 Audio description (pre-recorded)

Where ICT is a non-web document, it shall satisfy the WCAG 2.1 Success Criterion 1.2.5 Audio Description (Prerecorded).

NOTE 1:  The WCAG 2.1 definition of "audio description" says that audio description is "Also called 'video description' and 'descriptive narration'".

NOTE 2:  Secondary or alternate audio tracks are commonly used for this purpose.

10.1.3 Adaptable

10.1.3.1 Info and relationships

Where ICT is a non-web document, it shall satisfy the WCAG 2.1 Success Criterion 1.3.1 Info and Relationships.

NOTE:      Where documents contain non-standard structure types (roles), it is best practice to map them to a standard structure type as a fall-back solution for the reader.

10.1.3.2 Meaningful sequence

Where ICT is a non-web document, it shall satisfy the WCAG 2.1 Success Criterion 1.3.2 Meaningful Sequence.

10.1.3.3 Sensory characteristics

Where ICT is a non-web document, it shall satisfy the WCAG 2.1 Success Criterion 1.3.3 Sensory Characteristics.

10.1.3.4 Orientation

Where ICT is a non-web document, it shall satisfy the WCAG 2.1 Success Criterion 1.3.4 Orientation.

10.1.3.5 Identify input purpose

Where ICT is a non-web document, it shall satisfy the WCAG 2.1 Success Criterion 1.3.5 Identify Input Purpose.

10.1.4 Distinguishable

10.1.4.1 Use of colour

Where ICT is a non-web document, it shall satisfy the WCAG 2.1 Success Criterion 1.4.1 Use of Color.

10.1.4.2 Audio control

Where ICT is a non-web document, it shall satisfy the success criterion in Table 10.1.

Table 10.1: Document success criterion: Audio control

If any audio in a document plays automatically for more than 3 seconds, either a mechanism is available to pause or stop the audio, or a mechanism is available to control audio volume independently from the overall system volume level.

NOTE 1:   Since any part of a document that does not meet this success criterion can interfere with a user's ability to use the whole document, all content in the document (whether or not it is used to meet other success criteria) shall meet this success criterion.

NOTE 2:   This success criterion is identical to the WCAG 2.1 Success Criterion 1.4.2 Audio Control, replacing "on a Web page" with "in a document", "any content" with "any part of a document", "whole page" with "whole document", "on the Web page" with "in the document", removing "See Conformance Requirement 5: Non‑Interference" and adding note 1.

10.1.4.3 Contrast (minimum)

Where ICT is a non-web document, it shall satisfy the WCAG 2.1 Success Criterion 1.4.3 Contrast (Minimum).

10.1.4.4 Resize text

Where ICT is a non-web document, it shall satisfy the WCAG 2.1 Success Criterion 1.4.4 Resize Text.

NOTE 1:  Content for which there are software players, viewers or editors with a 200 percent zoom feature would automatically meet this success criterion when used with such players, unless the content will not work with zoom.

NOTE 2:  This success criterion is about the ability to allow users to enlarge the text on screen at least up to 200 % without needing to use assistive technologies. This means that the application provides some means for enlarging the text 200 % (zoom or otherwise) without loss of content or functionality or that the application works with the platform features that meet this requirement.

NOTE 3:  It is best practice to use only fonts that allow for scaling without loss of quality (e.g. pixelized presentation). This applies in particular to embedded fonts.

10.1.4.5 Images of text

Where ICT is a non-web document, it shall satisfy the WCAG 2.1 Success Criterion 1.4.5 Images of Text.

10.1.4.6 Void

10.1.4.7 Void

10.1.4.8 Void

10.1.4.9 Void

10.1.4.10 Reflow

Where ICT is a non-web document, it shall satisfy the success criterion in Table 10.2.

Table 10.2: Document success criterion: Reflow

Content can be presented without loss of information or functionality, and without requiring scrolling in two dimensions for:

  • Vertical scrolling content at a width equivalent to 320 CSS pixels.
  • Horizontal scrolling content at a height equivalent to 256 CSS pixels.

Except for parts of the content which require two-dimensional layout for usage or meaning.

NOTE 1:   320 CSS pixels is equivalent to a starting viewport width of 1 280 CSS pixels wide at 400 % zoom. For documents which are designed to scroll horizontally (e.g. with vertical text), the 256 CSS pixels is equivalent to a starting viewport height of 1 024 pixels at 400 % zoom.

NOTE 2:   Examples of content which require two-dimensional layout are images, maps, diagrams, video, games, presentations, data tables, and interfaces where it is necessary to keep toolbars in view while manipulating content.

NOTE 3:   This success criterion is identical to the WCAG 2.1 Success Criterion 1.4.10 Reflow replacing the original WCAG 2.1 notes with notes 1 and 2, above.

10.1.4.11 Non-text contrast

Where ICT is a non-web document, it shall satisfy WCAG 2.1 Success Criterion 1.4.11 Non-text Contrast.

10.1.4.12 Text spacing

Where ICT is a non-web document that does not have a fixed size content layout area that is essential to the information being conveyed, it shall satisfy WCAG 2.1 Success Criterion 1.4.12 Text spacing.

10.1.4.13 Content on hover or focus

Where ICT is a non-web document, it shall satisfy WCAG 2.1 Success Criterion 1.4.13 Content on Hover or Focus.

10.2 Operable

10.2.1 Keyboard accessible

10.2.1.1 Keyboard

Where ICT is a non-web document, it shall satisfy the WCAG 2.1 Success Criterion 2.1.1 Keyboard.

10.2.1.2 No keyboard trap

Where ICT is a non-web document, it shall satisfy the success criterion in Table 10.3.

Table 10.3: Document success criterion: No keyboard trap

If keyboard focus can be moved to a component of the document using a keyboard interface, then focus can be moved away from that component using only a keyboard interface, and, if it requires more than unmodified arrow or tab keys or other standard exit methods, the user is advised of the method for moving focus away.

NOTE 1:   Since any part of a document that does not meet this success criterion can interfere with a user's ability to use the whole document, it is necessary for all content in the document (whether or not it is used to meet other success criteria) to meet this success criterion.

NOTE 2:   Standard exit methods may vary by platform. For example, on many desktop platforms, the Escape key is a standard method for exiting.

NOTE 3:   This success criterion is identical to the WCAG 2.1 Success Criterion 2.1.2 No Keyboard Trap replacing "page" and "Web page" with "document", removing "See Conformance Requirement 5: Non-Interference" and with the addition of note 2 above and with note 1 above re-drafted to avoid the use of the word "must".

10.2.1.3 Void

10.2.1.4 Character key shortcuts

Where ICT is a non-web document, it shall satisfy WCAG 2.1 Success Criterion 2.1.4 Character Key Shortcuts.

10.2.2 Enough time

10.2.2.1 Timing adjustable

Where ICT is a non-web document, it shall satisfy the success criterion in Table 10.4.

Table 10.4: Document success criterion: Timing adjustable

For each time limit that is set by the document, at least one of the following is true:

  • Turn off: The user is allowed to turn off the time limit before encountering it; or
  • Adjust: The user is allowed to adjust the time limit before encountering it over a wide range that is at least ten times the length of the default setting; or
  • Extend: The user is warned before time expires and given at least 20 seconds to extend the time limit with a simple action (for example, "press the space bar"), and the user is allowed to extend the time limit at least ten times; or
  • Real-time Exception: The time limit is a required part of a real-time event (for example, an auction), and no alternative to the time limit is possible; or
  • Essential Exception: The time limit is essential and extending it would invalidate the activity; or
  • 20 Hour Exception: The time limit is longer than 20 hours.

NOTE 1:   This success criterion helps ensure that users can complete tasks without unexpected changes in content or context that are a result of a time limit. This success criterion should be considered in conjunction with WCAG 2.1 Success Criterion 3.2.1, which puts limits on changes of content or context as a result of user action.

NOTE 2:   This success criterion is identical to the WCAG 2.1 Success Criterion 2.2.1 Timing Adjustable replacing "the content" with "documents" and with the words "WCAG 2.1" added before the word "Success Criterion" in note 1 above.

10.2.2.2  Pause, stop, hide

Where ICT is a non-web document, it shall satisfy the success criterion in Table 10.5.

Table 10.5: Document success criterion: Pause, stop, hide

For moving, blinking, scrolling, or auto-updating information, all of the following are true:

  • Moving, blinking, scrolling: For any moving, blinking or scrolling information that (1) starts automatically, (2) lasts more than five seconds, and (3) is presented in parallel with other content, there is a mechanism for the user to pause, stop, or hide it unless the movement, blinking, or scrolling is part of an activity where it is essential; and
  • Auto-updating: For any auto-updating information that (1) starts automatically and (2) is presented in parallel with other content, there is a mechanism for the user to pause, stop, or hide it or to control the frequency of the update unless the auto-updating is part of an activity where it is essential.

NOTE 1:   For requirements related to flickering or flashing content, refer to WCAG 2.1 Guideline 2.3.

NOTE 2:   Since any part of a document that does not meet this success criterion can interfere with a user's ability to use the whole document, it is necessary for all content in the document (whether it is used to meet other success criteria or not) to meet this success criterion.

NOTE 3:   Content that is updated periodically by software or that is streamed to the user agent is not required to preserve or present information that is generated or received between the initiation of the pause and resuming presentation, as this may not be technically possible, and in many situations could be misleading to do so.

NOTE 4:   An animation that occurs as part of a preload phase or similar situation can be considered essential if interaction cannot occur during that phase for all users and if not indicating progress could confuse users or cause them to think that content was frozen or broken.

NOTE 5:   This success criterion is identical to the WCAG 2.1 Success Criterion 2.2.2 Pause, Stop, Hide replacing "page" and "Web page" with "document", removing "See Conformance Requirement 5: Non-Interference" in note 2 of the success criterion, with the words "WCAG 2.1" added before the word "Guideline" in note 1 above and with note 2 above re-drafted to avoid the use of the word "must".

10.2.3 Seizures and physical reactions

10.2.3.1 Three flashes or below threshold

Where ICT is a non-web document, it shall satisfy the success criterion in Table 10.6.

Table 10.6: Document success criterion: Three flashes or below threshold

Documents do not contain anything that flashes more than three times in any one second period, or the flash is below the general flash and red flash thresholds.

NOTE 1:   Since any part of a document that does not meet this success criterion can interfere with a user's ability to use the whole document, it is necessary for all content in the document (whether it is used to meet other success criteria or not) to meet this success criterion.

NOTE 2:   This success criterion is identical to the WCAG 2.1 Success Criterion 2.3.1 Three Flashes or Below Threshold replacing "Web pages" with "documents", "the whole page" with "the whole document", "the Web page" with "the document" and removing "See Conformance Requirement 5: Non-Interference" and with note 1 above re-drafted to avoid the use of the word "must".

10.2.4 Navigable

10.2.4.1 Void

NOTE 1:  The related web page requirement "Bypass blocks" does not apply to single documents, but to a specific definition of "sets of documents" that are rare.

NOTE 2:  Although not a requirement, the ability to bypass blocks of content that are repeated within documents is generally considered best practice and addresses user needs.

10.2.4.2 Document titled

Where ICT is a non-web document, it shall satisfy the success criterion in Table 10.7.

Table 10.7: Document success criterion: Document titled

Documents have titles that describe topic or purpose.

NOTE 1:   The name of a document (e.g. document, media file) is a sufficient title if it describes the topic or purpose.

NOTE 2:   This success criterion is identical to the WCAG 2.1 Success Criterion 2.4.2 Page Titled replacing "Web pages" with "documents" and with the addition of note 1 above.

10.2.4.3 Focus Order

Where ICT is a non-web document, it shall satisfy the success criterion in Table 10.8.

Table 10.8: Document success criterion: Focus order

If a document can be navigated sequentially and the navigation sequences affect meaning or operation, focusable components receive focus in an order that preserves meaning and operability.

NOTE:      This success criterion is identical to the WCAG 2.1 Success Criterion 2.4.3 Focus Order replacing "Web page" with "document".

10.2.4.4 Link purpose (in context)

Where ICT is a non-web document, it shall satisfy the WCAG 2.1 Success Criterion 2.4.4 Link Purpose (In Context).

10.2.4.5 Void

NOTE:      The related web page requirement "Multiple ways" does not apply to single documents, but to a specific definition of "sets of documents" that are rare.

10.2.4.6 Headings and labels

Where ICT is a non-web document, it shall satisfy the WCAG 2.1 Success Criterion 2.4.6 Headings and Labels.

10.2.4.7 Focus visible

Where ICT is a non-web document, it shall satisfy the WCAG 2.1 Success Criterion 2.4.7 Focus Visible.

10.2.5 Input modalities

10.2.5.1 Pointer gestures

Where ICT is a non-web document, it shall satisfy the success criterion in Table 10.9.

Table 10.9: Document success criterion: Pointer gestures

All functionality that uses multipoint or path-based gestures for operation can be operated with a single pointer without a path-based gesture, unless a multipoint or path-based gesture is essential.

NOTE 1:   This requirement applies to documents that interpret pointer actions (i.e. this does not apply to actions that are required to operate the user agent or assistive technology).

NOTE 2:   This success criterion is identical to the WCAG 2.1 Success Criterion 2.5.1 Pointer Gestures replacing the original WCAG 2.1 note with note 1 above.

10.2.5.2 Pointer cancellation

Where ICT is a non-web document, it shall satisfy the success criterion in Table 10.10.

Table 10.10: Document success criterion: Pointer cancellation

For functionality that can be operated using a single pointer, at least one of the following is true:

  • No Down-Event: The down-event of the pointer is not used to execute any part of the function;
  • Abort or Undo: Completion of the function is on the up-event, and a mechanism is available to abort the function before completion or to undo the function after completion;
  • Up Reversal: The up-event reverses any outcome of the preceding down-event;
  • Essential: Completing the function on the down-event is essential.

NOTE 1:   Functions that emulate a keyboard or numeric keypad key press are considered essential.

NOTE 2:   This requirement applies to a document that interprets pointer actions (i.e. this does not apply to actions that are required to operate the user agent or assistive technology).

NOTE 3:   This success criterion is identical to the WCAG 2.1 Success Criterion 2.5.2 Pointer Cancellation replacing the original WCAG 2.1 note with notes 1 and 2 above.

10.2.5.3 Label in name

Where ICT is a non-web document, it shall satisfy WCAG 2.1 Success Criterion 2.5.3 Label in Name.

10.2.5.4 Motion actuation

Where ICT is a non-web document, it shall satisfy WCAG 2.1 Success Criterion 2.5.4 Motion Actuation.

10.3 Understandable

10.3.1 Readable

10.3.1.1 Language of document

Where ICT is a non-web document, it shall satisfy the success criterion in Table 10.11.

Table 10.11: Document success criterion: Language of document

The default human language of each document can be programmatically determined.

NOTE:   This success criterion is identical to the WCAG 2.1 Success Criterion 3.1.1 Language of Page replacing "web page" with "document".

10.3.1.2 Language of parts

Where ICT is a non-web document, it shall satisfy the success criterion in Table 10.12.

Table 10.12: Document success criterion: Language of parts

The human language of each passage or phrase in the document can be programmatically determined except for proper names, technical terms, words of indeterminate language, and words or phrases that have become part of the vernacular of the immediately surrounding text.

NOTE 1:   There are some document technologies where there is no assistive technology supported method for marking the language for the different passages or phrases in the document, and it would not be possible to meet this success criterion with those technologies.

NOTE 2:   Inheritance is one common method. For example a document provides the language that it is using and it can be assumed that all of the text or user interface elements within that document will be using the same language unless it is indicated.

NOTE 3:   This success criterion is identical to the WCAG 2.1 Success Criterion 3.1.2 Language of Parts replacing "content" with "document" and with the addition of notes 1 and 2 above.

10.3.2 Predictable

10.3.2.1 On focus

Where ICT is a non-web document, it shall satisfy the WCAG 2.1 Success Criterion 3.2.1 On Focus.

NOTE:      Some compound documents and their user agents are designed to provide significantly different viewing and editing functionality depending upon what portion of the compound document is being interacted with (e.g. a presentation that contains an embedded spreadsheet, where the menus and toolbars of the user agent change depending upon whether the user is interacting with the presentation content, or the embedded spreadsheet content). If the user uses a mechanism other than putting focus on that portion of the compound document with which they mean to interact (e.g. by a menu choice or special keyboard gesture), any resulting change of context would not be subject to this success criterion because it was not caused by a change of focus.

10.3.2.2 On input

Where ICT is a non-web document, it shall satisfy the WCAG 2.1 Success Criterion 3.2.2 On Input.

10.3.2.3 Void

NOTE:      The related web page requirement "Consistent navigation" does not apply to single documents, but to a specific definition of "sets of documents" that are rare.

10.3.2.4 Void

NOTE:      The related web page requirement "Consistent identification" does not apply to single documents, but to a specific definition of "sets of documents" that are rare.

10.3.3 Input assistance

10.3.3.1 Error identification

Where ICT is a non-web document, it shall satisfy the WCAG 2.1 Success Criterion 3.3.1 Error Identification.

10.3.3.2 Labels or instructions

Where ICT is a non-web document, it shall satisfy the WCAG 2.1 Success Criterion 3.3.2 Labels or Instructions.

10.3.3.3 Error suggestion

Where ICT is a non-web document, it shall satisfy the WCAG 2.1 Success Criterion 3.3.3 Error Suggestion.

10.3.3.4 Error prevention (legal, financial, data)

Where ICT is a non-web document, it shall satisfy the success criterion in Table 10.13.

Table 10.13: Document success criterion: Error prevention (legal, financial, data)

For documents that cause legal commitments or financial transactions for the user to occur, that modify or delete user-controllable data in data storage systems, or that submit user test responses, at least one of the following is true:

  1. Reversible: Submissions are reversible.
  2. Checked: Data entered by the user is checked for input errors and the user is provided an opportunity to correct them.
  3. Confirmed: A mechanism is available for reviewing, confirming, and correcting information before finalizing the submission.

NOTE:  This success criterion is identical to the WCAG 2.1 Success Criterion 3.3.4 Error Prevention (Legal, Financial, Data) replacing "web pages" with "documents".

10.4 Robust

10.4.1 Compatible

10.4.1.1 Parsing

Where ICT is a non-web document, it shall satisfy the success criterion in Table 10.14.

Table 10.14: Document success criterion: Parsing

For documents that use markup languages, in such a way that the markup is separately exposed and available to assistive technologies and accessibility features of software or to a user-selectable user agent, elements have complete start and end tags, elements are nested according to their specifications, elements do not contain duplicate attributes, and any IDs are unique, except where the specifications allow these features.

NOTE 1:   Start and end tags that are missing a critical character in their formation, such as a closing angle bracket or a mismatched attribute value quotation mark are not complete.

NOTE 2:   Markup is not always available to assistive technology or to user selectable user agents such as browsers. In such cases, conformance to this [requirement] would have no impact on accessibility as it can for web content where it is exposed.

NOTE 3:   Examples of markup that is separately exposed and available to assistive technologies and to user agents include but are not limited to: documents encoded in HTML, ODF, and OOXML. In these examples, the markup can be parsed entirely in two ways: (a) by assistive technologies which may directly open the document, (b) by assistive technologies using DOM APIs of user agents for these document formats.

NOTE 4:   This success criterion is identical to the WCAG 2.1 Success Criterion 4.1.1 Parsing replacing "In content implemented using markup languages" with "For documents that use markup languages, in such a way that the markup is separately exposed and available to assistive technologies and accessibility features of software or to a user-selectable user agent" with the addition of notes 2 and 3 above.

10.4.1.2 Name, role, value

Where ICT is a non-web document, it shall satisfy the success criterion in Table 10.15.

Table 10.15: Document success criterion: Name, role, value

For all user interface components (including but not limited to: form elements, links and components generated by scripts), the name and role can be programmatically determined; states, properties, and values that can be set by the user can be programmatically set; and notification of changes to these items is available to user agents, including assistive technologies.

NOTE 1:   This success criterion is primarily for software developers who develop or use custom user interface components. Standard user interface components on most accessibility-supported platforms already meet this success criterion when used according to specification.

NOTE 2:   For document formats that support interoperability with assistive technology, standard user interface components often meet this success criterion when used according to the general design and accessibility guidance for the document format.

NOTE 3:   This success criterion is identical to the WCAG 2.1 Success Criterion 4.1.2 Name, Role, Value replacing the original WCAG 2.1 note with: "This success criterion is primarily for software developers who develop or use custom user interface components. For example, standard user interface components on most accessibility-supported platforms already meet this success criterion when used according to specification." and with the addition of note 2 above.

10.4.1.3 Status messages

Where ICT is a non-web document, it shall satisfy WCAG 2.1 Success Criterion 4.1.3 Status Messages.

10.5 Caption positioning

Where ICT is a non-web document that contains synchronized media with captions, the captions should not obscure relevant information in the synchronized media.

10.6 Audio description timing

Where ICT is a non-web document that contains synchronized media with audio description, the audio description should not interfere with relevant audio information in the synchronized media.