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WCAG Conformance and Third-Party Web Content

Jun 6, 2024

If you operate a website, you have a legal and ethical responsibility to provide accessible content for users with disabilities — and if you care about the user experience, you’ve got good reasons to test your content regularly for potential accessibility issues. 

But logically, you can only control the content that you create or maintain. Many websites host a large amount of third-party and user-generated content: aggregated news, user-created forum posts, social media feeds, plugins, widgets, and so on. 

How can you ensure that third-party content is accessible? And if the content is completely out of your control, could you face potential digital compliance issues?  

Below, we’ll answer a few common questions about how third-party web content impacts conformance with the Web Content Accessibility Guidelines (WCAG). For help with a specific accessibility issue, send us a message to connect with an expert. 

Does third-party content prevent my website from conforming with WCAG?

Third-party content may partially prevent conformance with WCAG, which may be important if you’re writing an accessibility statement for your website. The World Wide Web Consortium (W3C)’s Working Group writes

When an author makes a decision to use a third party implementation, they should choose products that meet WCAG requirements. If all content on a page, including third party content, meets all WCAG success criteria then the page conforms to WCAG. 

However, if the rest of your website meets WCAG, you can still make a claim of partial conformance. A partial conformance claim shows your commitment to accessibility while identifying any content or elements that cannot be monitored or made accessible.
We should note here that you are not required to make any WCAG conformance claim, and if your content isn’t regularly audited, you probably shouldn’t make such a claim. 

Additionally, if you cannot monitor third-party content, you should identify the non-conforming parts of your website (i.e., the third-party content) for your users. Learn about the best practices of writing a website accessibility statement.

Could third-party web content content violate the ADA or other non-discrimination laws?

First, a quick disclaimer: This article is not legal advice, and the Bureau of Internet Accessibility is not a law firm.

As accessibility experts, we regularly help our clients address barriers that impact users with disabilities, and we’ve written extensively about web accessibility and the Americans with Disabilities Act (ADA).

Recently, the Department of Justice (DOJ) introduced a new rule establishing WCAG 2.1 Level AA as the technical standards for Title II ADA compliance. The DOJ also recommends using WCAG to test for Title III compliance. 

Since third-party content prevents complete conformance with WCAG, third-party content could technically violate digital accessibility laws. However, ADA lawsuits target businesses that ignore WCAG — not businesses that embrace the guidelines.

The bottom line: Third-party content usually isn’t a major issue from a compliance standpoint, although the scope and amount of third-party content matters.

Related: Are Fraudulent ADA Website Lawsuits Common?

If my website hosts third-party content, what should I do to make that content as accessible as possible?

As always, accessibility is easier when it’s an ongoing priority. Get into the habit of thinking about users with disabilities when adding elements to your website that could qualify as third-party content.

Some quick tips:

  • Before adding third-party content, do your research. If you’re adding media content (for example, social media feeds or financial tickers), determine whether the publisher has considered accessibility — and whether they’ve tested their products against WCAG. 
  • If working directly with a third-party service provider, communicate the importance of accessibility. Ask about accessibility features and set clear requirements for testing.
  • Test services and media content before publishing. In particular, you should make sure that the new content doesn’t “break" your website by impacting keyboard accessibility, changing the focus order, or altering operability in another unexpected way.
  • Check the settings of third-party tools and make accessible choices. Follow WCAG’s requirements for color contrast, provide accurate text alternatives, and avoid any elements with flashing content or autoplay.
  • For user-generated content, think of ways to enforce the best practices of accessibility. For example, require users to add alternative text when submitting images. 
  • If possible, provide accessible alternatives for any content that cannot be made accessible. 

Of course, the best course of action is to create content yourself — but that’s not always realistic, particularly if you’re introducing a feature that you couldn’t reasonably recreate on your own (for example, a social media feed or a user authentication system).

However, you still have a responsibility to do your best. You want to avoid decisions that will lock people out of the conversation; just as importantly, you want to show that you care about inclusivity. By thinking about accessibility from day one — and testing your content regularly — you can maintain conformance while delivering the best possible experience for users.

Use our free Website Accessibility Checker to scan your site for ADA and WCAG compliance.

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