In general, SSB views the placement of disabled components and instructive text in the tab order as a hindrance to accessibility and a barrier to compliance with Section 508. Guidance from the Access Board, the standards making body for Section 508 requirements, other US Federal Government agencies, operating system control paradigms, the World Wide Web Consortium (W3C) and user feedback support this stance. SSB’s validation process explicitly includes a test to ensure that inactive components are not in the tab order of an application.
This opinion does not impact the placement of read only edit fields in the tab order. There are many legitimate reasons to place read only fields in the tab order and SSB recommends that organizations place read only edit fields in the tab order if they contain information required in the current form, provide dynamically changing text, or provide critical text such as license or warning statements.
Client Specific Policies
A variety of specific federal government agencies including Veteran’s Affairs and the Social Security Administration require that applications provide keyboard access to instructive text and / or disabled fields within a page. In this situation the client may require the following:
- Utilize the tabindex attribute in portions of instructive text in the application include form text and headers in the application. To place the fields in the appropriate tab order without adding the tabIndex to all form fields on the page, set the tabIndex to 0 (“zero”). Organizations should note that this enhancement is explicitly not in compliance with W3C document specifications form HTML and XHTML documents and is a browser specific feature.
- Replace all “disabled” edit/text and text area fields with “read only” edit/text textarea fields. Other form fields do not support the “read only” property, thus replace all other disabled fields with equivalent display text. The tabIndex attribute must then be set on the display text to place it in the tab order. These fields should be included in the tab order of the application. As part of the conversion of the fields – from the standard html attribute of “disabled” to the modified read only fields – descriptive text should be added that clarifies the difference between read-only and disabled fields. This can be achieved by creating a title attribute for each field that includes the field label and the word “unavailable”. In addition, a mechanism should be provided to indicate current keyboard focus when this disabled fields receive focus. This will ensure that disabled form fields are read at least somewhat properly in assistive technology and conform to the relevant assistive technology paradigms.
SSB maintains that these requirements are not part of the Section 508 requirements and are not required for Section 508 compliance. On a case-by-case basis individuals should determine to what degree it is reasonable and cost effective to try and change the agency’s opinion about the specific requirements of Section 508. As possible, however, incremental requirements that appear to go above and beyond the scope of Section 508 should be clarified as additional “accessibility enhancements” in the contracts with agencies rather then Section 508 compliance requirements. This ensures that any “compliance” challenges that may arise can clearly be adjudicated outside the scope of Section 508.