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Written by Annabeth Williams-Gilchrist, Digital Accessibility Consultant.

Here at Digital Access, we've been working tirelessly for years to help our clients bring their sites and apps into compliance with the WCAG standards. Part of providing the best guidance we can is continuing to study the WCAG Success Criteria, to test our solutions and see how they work for real users, to keep up with the ongoing conversations among other accessibility experts about how best to interpret those criteria, and to continually iterate on our own approach to meeting those standards. That is why, after much deliberation, we are adjusting our interpretation of the minimum functionality required to comply with WCAG 2.4.1 A – Bypass Blocks to bring our recommendations more in line with user needs and the broader consensus within the digital accessibility community.

2.4.1 A – Bypass Blocks requires that users have a mechanism to bypass blocks of content that repeat across multiple pages of a site. Most commonly, this refers to the contents of the sitewide header, which often include many interactable components for navigating the site. These repetitive blocks are often arduous and annoying for keyboard and screen reader users, who must navigate through them each time they move to a new page in order to reach the page's unique main content.

Historically, we and others within the accessibility community have considered the presence of a robust heading or region structure sufficient to meet this criterion. Screen reader users can navigate freely between the regions and headings of a page without needing to manually tab through the intervening contents. We have also strongly encouraged the use of a skip link at the top of the page as a quicker, more convenient way for users to skip past the sitewide header specifically, but we did not consider this necessary for conformance.

However, an unfortunate flaw of relying solely on a heading or region structure to fulfil this criterion is that non-screen-reader-using keyboard users do not have the ability to navigate between headings and regions in the same way. They are limited to navigating linearly through the keyboard focus order using the Tab key. As 2.4.1 A – Bypass Blocks does not only require that screen reader users be able to skip recurring blocks of text but rather that all users be able to, we have concluded that a skip link is, in fact, required to achieve conformance.

As we move to adopt and incorporate this new understanding of the success criterion into our audits, Digital Access will undertake the following action: From 1 May 2024, failure to provide a functioning skip link will be included in our Audit Reports and Verification Testing as an accessibility issue and a failure to conform with 2.4.1 A – Bypass Blocks. As with all other issues, we will not be able to provide clients with a Statement of Accessibility for their site or app until this issue is resolved.

This does mean that if a skip link is absent from a site that has previously had an accessibility audit and this was not flagged as an issue at the time, it will be flagged during any Verification Testing after 1 May. Please note, however, that this is unlikely to affect any client who commissioned their initial audit within the last six months, as we have made a concerted effort to flag this issue in advance of our official announcement to avoid blindsiding anyone.

However, if we have previously issued a Statement of Accessibility for a website or app that lacks a skip link, we will uphold the validity of that Statement and will not retroactively invalidate it. Our Statements of Accessibility represent a certification of compliance with WCAG as it was understood at the time the statement was issued. The fact that our understanding of WCAG has evolved does not invalidate the efforts our clients have previously made to make their sites as accessible as possible. For any clients who last received a Statement of Accessibility several years ago, or who have added substantial new content since their Statement, we encourage you – skip link or not – to submit your site for a new audit to receive a more current Statement. Accessibility as a field is always evolving, and new strides forward in assistive technology, as well as new editions of the WCAG Success Criteria, have only expanded the possibilities for making websites and apps that work for everyone, and we would be delighted to help you bring yours into 2024.

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