Clarifying and Enhancing Requirements for Sign Language and Subtitles in WCAG 3.0

[InfoGapBuster]

Title: Clarifying and Enhancing Requirements for Sign Language and Subtitles in WCAG 3.0

Summary of Proposal:

We propose that WCAG 3.0 more clearly define and strengthen the roles of sign language and subtitles as part of its accessibility framework. The current draft lacks specific provisions for sign language and does not distinguish between types of sign language delivery. Subtitles are addressed, but more emphasis is needed on their quality and multilingual support. Our proposals are as follows:

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🔹 Background and Rationale

Users who are Deaf and use sign language as their first or primary language often encounter accessibility barriers when content is provided only in written form. Captions are essential, but they are not always sufficient. Automatically generated subtitles may be inaccurate or fail to convey tone and nuance.

WCAG 2.0 included sign language as a AAA criterion, which led to limited implementation. In practice, many public-facing web videos lack sign language support entirely. WCAG 3.0 presents an opportunity to change this by elevating both sign language and high-quality subtitles as core accessibility features.

Additionally, current guidelines do not distinguish between:

• Sign language interpretation: real-time signing used in live contexts.
• Sign language translation: carefully prepared signing created in advance, with attention to clarity, accuracy, and viewer accessibility.

We strongly recommend that WCAG 3.0 encourage sign language translation for pre-recorded videos intended for repeated viewing by a wide audience, as it offers greater precision and quality.

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🔹 Proposed Enhancements

1. Explicit inclusion as Outcomes

   • Clearly define "Provision of videos with sign language translation" and "Provision of subtitles synchronized with audio content" as distinct Outcomes in WCAG 3.0.

2. Integration into Supplemental Requirements

   • Position sign language (translation and interpretation) and subtitles as essential elements that supplement basic accessibility for Deaf and hard-of-hearing users.

3. Specific reflection in Conformance Levels

   • Bronze: Basic subtitling (e.g., auto-generated or simple captions).
   • Silver: Accurate, descriptive subtitles and sign language (context-appropriate: interpretation or translation).
   • Gold: Comprehensive support, including culturally appropriate sign language and multilingual subtitle options.

4. Recognition of Language Preferences

   • Align with “Preferred Language” principles by supporting signed and written language alternatives based on users’ native or preferred languages (e.g., JSL, ASL, English, etc.).

5. Guidance on Quality Standards

   • Include best practices or minimum quality recommendations for subtitles and sign language content (e.g., accuracy, speaker identification, emotional tone, cultural context).

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We believe these additions will strengthen WCAG 3.0 and help ensure that accessibility guidelines meet the needs of sign language users worldwide. We would be happy to assist further in drafting or reviewing guideline language related to these topics.

Thank you for your consideration.