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The A11y Path

This blog aims to cover: W3C Guidelines, Assistive Technologies (AT), European Accessibility (EN 301 549), and more.

EN 301 549 Clause 10 Overview

Published

#was #en301549 #journal

Clause 10: Non-web documents

Clause 10 ensures that documents not rendered as web pages are still accessible. This includes:

  • PDFs, DOCXs, PPTs, ePubs, spreadsheets, videos, etc.
  • Content not embedded directly in web pages (e.g., downloadable resources)
  • Files that require a user agent (like a PDF reader, document viewer, or media player)

Clause 10 mirrors WCAG 2.1 SCs but interprets them through the WCAG2ICT lens, i.e., it adapts web-specific terminology to fit documents that need a user agent (like Acrobat, Word, PowerPoint) for access.

Many WCAG SCs are kept exactly as they are (e.g., 1.1.1 Non-text Content), but others have customized explanations, particularly where WCAG speaks to "pages" or "sites".

Adaptations for Document-Specific Behaviors

Non-web documents have:

  • No DOM (in the same sense)
  • No live navigation tree or URL structure
  • Interaction managed via document viewers/editors, not browsers

So EN 301 549 introduces tweaks to maintain meaning and functionality in this different environment.

Unique Characteristics of Clause 10

  • Some SCs, it uses tables to define equivalent document-specific behavior.
  • Best practice notes and exceptions: Adds informative guidance where WCAG didn't cover documents in detail.
  • No WCAG 2.1 Conformance Requirement 5: You'll see this removed in SCs like Keyboard Trap, Audio Control, etc. because documents don't have the same layered structure as web pages.

Example of Clause 10 Tweaks:

  • 1.4.2 Audio Control becomes "If audio in a document plays automatically for more than 3 seconds..."
  • 2.1.2 No Keyboard Trap
  • 2.4.2 Page Titled becomes "Documents have titles that describe topic or purpose.."
  • 2.4.1 Bypass Blocks is void as it doesn't apply to single documents

Some Takeaways

  • Clause 10 relies on WCAG2ICT interpretations. For example, a single PDF doesn't need "multiple ways to navigate" like a site, so SC 2.4.5 is skipped (marked void).
  • Emphasis is placed on non-interference, any part of a document that interferes with usage (e.g. autoplaying audio, flashing elements) invalidates conformance.
  • "Best practice" notes encourage things like accessibility metadata to be included.

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