Update to the EPUB Accessibility - EU Accessibility Act Mapping

[gregoriopellegrino]

We have updated the document in these parts:

• reSpec metadata: reference working group
• Abstract: information with respect to implementation
• How EPUB conforming to EPUB accessibility guidelines cover European Accessibility Act requirements:
  • improvement of references to specifications
  • addition of a paragraph on Fixed Layouts (based on the wording of the Act)
• Mappings:
  • 2.1.1.2.5 (v): addition of success criterion 1.4.12 Text Spacing and note on Fixed Layouts (based on the wording of the Act)
  • 2.1.1.2.6 (vi): addition of success criterion 1.2.1 Audio-only and Video-only (Prerecorded) and 1.2.2 Captions (Prerecorded)
  • 2.1.2.1.3 (iii): addition of success criterion 1.4.10 Reflow and note regarding Fixed Layouts (based on the wording of the Act)
• Metadata to describe possible exemptions: added section to introduce metadata to describe possible exceptions to the law

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See:

• For EPUB Accessibility - EU Accessibility Act Mapping:
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[iherman]

The text of the added notes usually say something like:

NOTE
Specific features (like flexibility and choice in the presentation of the content) of Fixed Layout EPUBs should be considered in the light of all applicable accessibility requirements.

I must admit I do not understand this sentence. Do you mean that these requirements should be "eased" for FXL? Or that the FXL authors should be specifically careful about these requirements?

I think we should try to find a better formulation...

[iherman]

I do not know about the politics here, but from a usual W3C style perspective it may be better to put here a formal reference to the exemption note, so that it would also appear in the references' section below.

[mattgarrish]

em dashes might also help the sentence here, as the references to onix and epub don't flow with the rest: "Metadata standards for digital publishing — ... — provide specific codes..."

The specific standards might also be better written into a note after the paragraph. For example: "NOTE: Refer to ONIX Code List 196 [onix] and The EPUB Accessibility exemption property [epub-a11y-exemption] for more information on expressing these codes."

[iherman]

I have left some comments that are mostly editorial.

[shiestyle]

Note for Fixed Layout should be improved for easy to understand.

[mattgarrish]

Suggested change

	<p>The EAA has been approved on 27 June 2019 and will come into force from 28 June 2025. The directive has already been implemented at national level in many member states and is being implemented in the remaining.</p>
	<p>The EAA was approved on 27 June 2019 and will come into force from 28 June 2025. Many member states have already implemented the directive at the national level, with the remaining states currently in the process of implementing it.</p>

"has been" suggests a continuous state from the past (e.g., "has been approved since..." but I don't think that's what you want here). The second sentence doesn't need to be passive.

[mattgarrish]

Does this paragraph belong in this document? It also comes from the Accessibility standard's intro.

[mattgarrish]

This paragraph also looks like a copy. It's talking about "this document" establishing the requirements for the EPUB Accessibility standard.

I think this whole section needs some rewriting to focus more on how the EPUB Accessibility standard matches the requirements of the EAA. Otherwise, maybe the title needs changing as I don't get a connection from this text to the EAA.

[mattgarrish]

This is a long sentence. Maybe break it up like this (also offering a possible rewrite for the last sentence, but not sure if that's exactly what you're after, or if it should be in a note, so feel free to ignore!):

Suggested change

	<p>The EPUB format provides the ability to create reflowable publications (whose content adapts to the user's viewport,
	depending also on the user's chosen graphical characteristics, such as font size, line spacing, etc.), but it also
	allows the creation of EPUB Fixed Layout in which each element is positioned absolutely on the page (mainly used
	for publications such as comics, illustrated children’s books and art books). Specific features of Fixed Layout EPUBs
	should be considered in the light of all applicable accessibility requirements.</p>
	<p>The EPUB format provides the ability to create reflowable publications whose content adapts to the user's viewport, including the user's chosen graphical characteristics, such as font size, line spacing, etc. It also
	allows the creation of fixed layout content in which each element is positioned absolutely on the page (mainly used
	for publications such as comics, illustrated children’s books and art books). Specific features of fixed layouts (e.g., zooming of text) present challenges for accessibility, however. Authors need to consider these challenges and how best they can mitigate them before employing fixed layouts. Refer to the EPUB Fixed Layout Guidelines for more information.</p>

[mattgarrish]

These references are kind of confusing. Principles contain all levels of success criteria. Do you mean only the level A requirements of Robust principle here? Or can the level reference just be deleted as unnecessary?

[mattgarrish]

Suggested change

	<p>The European Accessibility Act foresee three possible exemptions to meeting its requirements:</p>
	<p>The European Accessibility Act foresees three possible exemptions to meeting its requirements:</p>

[wareid]

Approved (as long as the already suggested changes are applied!).

[gregoriopellegrino]

Thank you for all the feedback received.

We have done a major revision of the document and present you with the new draft. We have tried to make the introduction part more explicit and clear and we have tried to make the mapping section more readable.

We look forward to your further comments to finalize it.

For EPUB Accessibility - EU Accessibility Act Mapping:

• Preview
• Diff

[iherman]

For some reasons the 'diff' does not work. Note that the preview shows a respec error, which may explain why the diff fails.

[iherman]

All my comments are strictly editorial

[mattgarrish]

Note that the preview shows a respec error

The error says that the status section must contain at least one custom paragraph. When did that become a requirement and what are we supposed to make up to satisfy it?

[iherman]

At the moment

<section id="sotd"></section>

has been removed. (See #2590 (comment)). I would expect the error will go away if that is put back...

[mattgarrish]

I would expect the error will go away if that is put back...

Ah, right, I was looking at a different version locally that still had the section. I thought this was a new requirement to pad the sotd.

[mattgarrish]

Looking better. Just some editorial comments.

[mattgarrish]

You need to use two square brackets for citations: [[epub-a11y-11]]

[mattgarrish]

You're referring to WCAG here, at least by using caps, so there should be a reference.

[gregoriopellegrino]

Sorry, what does it mean?

[mattgarrish]

Suggested change

	<p>The EPUB Accessibility defines requirements for accessibility metadata. In this way consumers can examine the accessibility characteristics of the content and make well-informed decisions on whether an EPUB publication is appropriate for each need before buying, borrowing or downloading it.
	<p>The EPUB Accessibility specification also defines requirements for accessibility metadata. In this way consumers can examine the accessibility characteristics of the content and make well-informed decisions on whether an EPUB publication is appropriate for each need before buying, borrowing or downloading it.

[mattgarrish]

"The EPUB" is confusing. This should probably be "EPUB 3", or a specific reference to 3.3 with a citation.

[mattgarrish]

Also, "Fixed Layout" shouldn't be capitalized (here and elsewhere). We don't use capitalized terms in the specification anymore.

[mattgarrish]

Suggested change

	<p>EPUB Fixed Layout are mainly used for publications in which the meaning is layout-driven such as comics, illustrated children’s books and art books.</p>
	<p>Fixed layouts are mainly used for EPUB publications in which the meaning is layout-driven such as comics, illustrated children’s books and art books.</p>

[mattgarrish]

WCAG should be cited here.

[gregoriopellegrino]

Sorry, what does it mean?