WCAG 2.2 misses mark on defining visible focus


About two weeks ago, the WCAG WG released a new version of the Candidate Recommendation for WCAG 2.2. After it had been in the Editor’s Draft for quite some while, it changed the requirements for the Focus Appearance Success Criterion (SC).

The SC was deemed to not be AA-worthy. With the W3C process, however, items marked as at risk, which this SC was, can only be removed before publication of the standard, not altered. So changing it to a AAA criterion meant that there had to be a new Candidate Recommendation anyway.

The WG took that opportunity to change the order of the SC, too, as new AAA success criteria have always been inserted after AA success criteria. I’m not fond of the last-minute SC number change (it is now 2.4.13 instead of 2.4.11) but it can always happen. It’s one reason why I never refer to SC numbers when talking about proposed criteria in Editor’s or Working Drafts. I am not sure that this has ever happened during Candidate Recommendation phase, however. 1

First, the good thing about the changed 2.4.13 Focus Appearance criterion: It reads really simple, and that is a good thing. To meet AAA, your focus indicator needs to be at least as large as a 2px thick around the perimeter of the focused element and have a 3∶1 contrast ratio.

Now, the bad thing about the change: The previous proposal of moving 2.4.7 Focus Visible to A level has been completely reverted. A basic, in any way visible focus is essential for keyboard users who do not use assistive technologies that create their own focus ring. It is such a basic accessibility affordance like having good page titles or having a consistent focus order, both SCs are A-level SCs.

It makes little sense to say that the order of the focused elements must be logical, but it does not matter to be able to perceive where you are in those elements.

This SC should have been an A-level SC from WCAG 2.0 back in 2008. That the Working Group has reverted a change that would not affect most people (as the general baseline is AA in laws and policies) but sent a signal on its importance is baffling to me.

But, the most outrageous issue is that what a “visible focus” stays undefined at AA level. Arguably, changing one pixel from white to just off-white satisfies that there is a visible change on focus.

This is the only place where, in an AA SC, the term visible is not defined. 1.4.3 Contrast Minimum (AA) defines is as 3∶1 for large/bold text and 4.5∶1 for normal size text. 1.4.11 Non-text Contrast (AA) defines it as 3:1 against adjacent colors.

Anything that is stronger than “visible” on an AA level would have been welcome. I proposed simplifications to the initial AA Focus Appearance SC, which were deemed as not strict enough (and at the same time overly strict) by the group last November.

The Group could have added an SC that defines what visible is: “At least a part of the focus indicator has a 3∶1 contrast ratio between the same pixels in the focused and unfocused states.”

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Why is this important?

Good focus styles make the lives better of many disabled people and are generally a usability win. Many who do not think of themselves as disabled use the keyboard to navigate web pages. A visible focus is an essential affordance.

The other reason is that WCAG 2.2 is planned to be the final update for WCAG 2. The proposed new Charter for the Working Group puts WCAG 3 at the front, with WCAG 2 going into maintenance mode. And considering that the WG refuses to publish updates in the case of typos, I expect little maintenance on the actual specification.

As for WCAG 3, the Charter has an “expected completion date” of Q2, 2026. But the previous/current charter stated WCAG 2.2 would be done by Q4 2020 and WCAG 3 done by Q2 2023.

I don’t blame the Group for having deadlines slip in the midst of a global pandemic. But I take the expected dates with a grain of salt, especially as we are staring at a WCAG 3 Working Draft that has seen no updates over the past year. And it tries to re-invent accessibility conformance completely. I’ll not repeat that I think an evolution of WCAG 2 – a generally good standard that would need more frequent updates – would be a simpler approach. You can read about it here or watch my 75-minute presentation here2 .

But I don’t expect WCAG 3 to be ready before the end of the decade. And that means, gaps in conformance that have a real impact on users will be at least be unsolved for another decade, as it will take time for WCAG 3 practices to get developed. That is a lot of time during which we are basically OK with the rules of accessibility as they are. Maybe we should aim for better.

  1. Hence I used the SC numbers in the headings of a recent blog post.
  2. Feel free to skip to the WCAG chapter directly.

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