Centre for Internet & Society

The Centre for Internet & Society (CIS) submitted its comments on mobile accessibility guidelines to the Ministry of Electronics & IT, Govt. of India.

Consolidated comments on mobile application guidelines:

  • Overall, this document is very difficult to review and comprehend. It needs to be more structured. If the mobile accessibility practices had provided earlier can be directly adopted that adds more value
  • Avoid adopting WCAG POUR structure. If it is used use it wisely.
  • Certain checkpoints do not have appropriate headings. E.g. D, E, G, H must be under perceivable but currently are under Operable. Similarly, I must be under Understandable but currently under Operable.
  • Some checkpoints are difficult to understand. E.g. Grouping operable elements that perform the same action.
  • Provide WCAG 2.0 reference with techniques and tools to test wherever appropriate
  • If any of the checkpoints are differentiated as Mandatory, advisory and voluntary specifically mention them against each checkpoint.
  • Section specific comments:
  1. In section 1.A, The requirement that since screen size is small we should only use native applications does not make sense.
  2. Section 2.d, 2.e, 2.g and 2.i should go in first section i.e. perceivable.
  3. Section 2.F suggests that buttons should be placed where they are easy to access. But there is no criteria to decide what is easy to access? For example, in iOS, back button is at top left and often important buttons such as end call, ok etc. are placed at the bottom of the screen. Similarly, there are conventions for Android. Please check Android conventions and refer to the same in this document. We could require that app developers should follow conventions for the platform that they are building for
  4. Section 3.a would go in part 2 i.e. operability
  5. Section 4.a and 4.b would go in operability.
  6. Section 4d onwards do not belong in robust, they should be in additional section
  7. Include Mobile Practice 10 from Mobile practices v1.0 that deals with custom actions. Custom actions behave like context menus and help screen reader users.
  8. We also recommend that Mobile Practice 2,3,4 and 5 from Mobile practices v1.0 could be included under principle 4 i.e. robust.

A lot of reflection and deliberations happened during development of Mobile Practices so taking those practices would improve the guidelines. For example, practice 2 has a lot more details about why it is important and how to add labels.

Download the full submission here

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