Drupal Accessibility Conformance Report

Based on VPAT® 2.4 Revised Section 508 Edition

# Name of Product/Version

Drupal 9.1

# Report Date

8/31/2021

# Product Description

Content Management System

# Contact Information

# Author Information

• Name: Mike Gifford
• Company: CivicActions
• Address: 3527 Mt Diablo Blvd, Unit 269, Lafayette, CA 94549
• Email: mike.gifford@civicactions.com
• Phone: (510) 408-7510
• Website: https://civicactions.com/

# Notes

Links to the issues identified are included where possible to ensure that this is a living document where outstanding issues are regularly reviewed for compliance. The Authoring tool is evaluated against ATAG 2.0, Part A and B. Incorporating feedback from the Drupal community.

# Evaluation Methods Used

Use of automated tools like WAVE and Accessibility Insights. Manual keyboard only testing. Some testing with JAWS, NVDA and VoiceOver. The evaluation process also includes a review of the Drupal Core accessibility issue queue.

# Applicable Standards/Guidelines

This report covers the degree of conformance for the following accessibility standard/guidelines:

Standard/Guideline	Included In Report
Web Content Accessibility Guidelines 2.0	Table 1: Success Criteria, Level A Table 2: Success Criteria, Level AA Table 3: Success Criteria, Level AAA
Revised Section 508 standards published January 18, 2017 and corrected January 22, 2018	Chapter 3: Functional Performance Criteria (FPC) Chapter 4: Hardware Chapter 5: Software Chapter 6: Support Documentation and Services

# Terms

The terms used in the Conformance Level information are defined as follows:

• Supports: The functionality of the product has at least one method that meets the criterion without known defects or meets with equivalent facilitation.
• Partially Supports: Some functionality of the product does not meet the criterion.
• Does Not Support: The majority of product functionality does not meet the criterion.
• Not Applicable: The criterion is not relevant to the product.
• Not Evaluated: The product has not been evaluated against the criterion. This can be used only in WCAG 2.0 Level AAA.

# WCAG 2.0 Report

# Table 1: Success Criteria, Level A

Notes: Drupal doesn't make a strong distinction between the front-end & back-end accessibility. Many administration interfaces can be exposed to users in a more interactive site. Generally this report focuses the Conformance Level / Remarks and Explainations so that Web comments are about elements that are typically public, while Authoring Tool is typically for authors and administrators. The goal of the authoring interface is to support ATAG 2.0 AA (Part A and B). The Drupal community strives to beek up with the latest WCAG recommendation.

Criteria	Conformance Level	Remarks and Explanations
1.1.1 Non-text Content	Web: Supports Electronic Documents: Supports Software: Not Applicable Authoring Tool: Supports	Web: Drupal 8 requires alt text for images by default. Electronic Documents: Some non-textual content in the documentation does not provide a textual alternative. Authoring Tool: The back end of Drupal Core was built to be WCAG 2.0 AA compliant and non-text content in the administration interface has a textual equivalent. Audio and video can be added to the media library, but Core does not provide tools to manage transcripts and captions/subtitles for local video and audio - Drupal issue 3002770.
1.2.1 Audio-only and Video-only (Prerecorded)	Web: Supports Electronic Documents: Supports Software: Not Applicable Authoring Tool: Supports	Web: Authors can satisfy 1.2.1 Audio-only and Video-only (Prerecorded) by using text on the same page. Electronic Documents: This is not explicitly defined in the documentation. Authoring Tool: There is no additional support for authors within the authoring interface to explain how this can be done.
1.2.2 Captions (Prerecorded)	Web: Does Not Support Electronic Documents: Not Applicable Software: Not Applicable Authoring Tool: Does Not Support	Web: The file module in Core lets authors upload audio and video content, and output <audio> and <video> elements and does not support captions. Authoring Tool: Drupal does not support, let alone require users to include captions. Hard coding open captions is presently the only way to satisfy this in Core.
1.2.3 Audio Description or Media Alternative (Prerecorded)	Web: Does Not Support Electronic Documents: Does Not Support Software: Not Applicable Authoring Tool: Does Not Support	Web: Audio files can be uploaded, but there is no way to associate captions in Core. Electronic Documents: There is no documentation on how to properly convey pre-recorded audio descriptions. Authoring Tool: There is no audio in the authoring interface of Drupal Core, but there is no support for authors to upload accessible audio files.
1.3.1 Info and Relationships	Web: Partially Supports Electronic Documents: Supports Software: Not Applicable Authoring Tool: Supports	Web: Information is structured into logical relationships. Navigational lists are well used to group information. Forms have a visual and semantic representation for required fields. Message windows have ARIA role defined incorrectly as role=contentinfo which impacts content relationships - Drupal issue 2942404. aria-live announcement is not contained in a landmark - Drupal issue 3098857. Electronic Documents: Information is structured into logical relationships. Navigational lists are well used to group information. Authoring Tool: The authoring environment was constructed to support ATAG 2.0 AA (Part A and B).
1.3.2 Meaningful Sequence	Web: Supports Electronic Documents: Supports Software: Not Applicable Authoring Tool: Supports	Web: Drupal Core has been extensively tested with keyboard only users. As a proudly multilingual CMS, Drupal provides support for bidirectional navigation. Authoring Tool: The authoring environment was constructed to support ATAG 2.0 AA (Part A and B).
1.3.3 Sensory Characteristics	Web: Supports Electronic Documents: Supports Software: Not Applicable Authoring Tool: Supports	Web: Where possible Drupal Core uses combinations of text and symbols for the user interface. Authoring Tool: The authoring interface has been developed to not rely on symbols alone to convey information to the user.
1.4.1 Use of Color	Web: Supports Electronic Documents: Supports Software: Not Applicable Authoring Tool: Supports	Web: Color is not used without text and often symbols to convey meaning. Authoring Tool: In general, the admin theme is very accessible. The Claro Administration Theme shortcut start needs improvement - Drupal issue 3171726.
1.4.2 Audio Control	Web: Not Applicable Electronic Documents: Not Applicable Software: Not Applicable Authoring Tool: Not Applicable
2.1.1 Keyboard	Web: Supports Electronic Documents: Supports Software: Not Applicable Authoring Tool: Partially Supports	Web: Users can interact with Drupal Core with the keyboard and without specific timings for individual keystrokes. Authoring Tool: Authors are largely able to engage with Drupal Core with the keyboard and without specific timings for individual keystrokes. Tooltips not displayed for keyboard navigation - Drupal issue 2933984. There are reported issues with IE11 and JAWS - Drupal issue 2852702. It is worth noting that Drupal's admin is powerful and complex, and there are other accessibility reports in the issue queue.
2.1.2 No Keyboard Trap	Web: Supports Electronic Documents: Supports Software: Not Applicable Authoring Tool: Supports	Web: Focus can be moved away from that component using only a keyboard interface. Authoring Tool: Focus can be moved away from that component using only a keyboard interface.
2.2.1 Pause, Stop, Hide	Web: Supports Electronic Documents: Supports Software: Not Applicable Authoring Tool: Supports	Web: The time limit is longer than 20 hours. Authoring Tool: The time limit is longer than 20 hours.
2.2.2 Timing Adjustable	Web: Not Applicable Electronic Documents: Not Applicable Software: Not Applicable Authoring Tool: Not Applicable
2.3.1 Three Flashes or Below Threshold	Web: Supports Electronic Documents: Not Applicable Software: Not Applicable Authoring Tool: Supports	Web: There are no flashing elements in Drupal Core. Authoring Tool: There are no flashing elements in Drupal Core.
2.4.1 Bypass Blocks	Web: Supports Electronic Documents: Supports Software: Not Applicable Authoring Tool: Supports	Web: Skip links are provided. Electronic Documents: Skip links are provided. Authoring Tool: Skip links are provided.
2.4.2 Page Titled	Web: Supports Electronic Documents: Supports Software: Not Applicable Authoring Tool: Supports	Web: Pages have titles, but in the case of multi-page events, the page number is not included - Drupal issue 2509716. Authoring Tool: Pages have titles, but in the case of multi-page events, the page number is not included - Drupal issue 2509716.
2.4.3 Focus Order	Web: Supports Electronic Documents: Supports Software: Not Applicable Authoring Tool: Supports	Web: Focusable components receive focus in an order that preserves meaning and operability. Electronic Documents: Focusable components receive focus in an order that preserves meaning and operability. Authoring Tool: Focusable components receive focus in an order that preserves meaning and operability.
2.4.4 Link Purpose (In Context)	Web: Supports Electronic Documents: Not Applicable Software: Not Applicable Authoring Tool: Supports	Web: Careful attention has been paid to ensure that automated "Read More" links are available in a way that is available with contextual information for screen readers. Authoring Tool: Careful attention has been paid to ensure that automated "Read More" links are available in a way that is available with contextual information for screen readers.
3.1.1 Language of Page	Web: Supports Electronic Documents: Supports Software: Not Applicable Authoring Tool: Supports	Web: Page language is defined semantically on every page. Electronic Documents: Page language is defined semantically on every page. Authoring Tool: Page language is defined semantically on every page.
3.2.1 On Focus	Web: Supports Electronic Documents: Supports Software: Not Applicable Authoring Tool: Supports	Web: Change in the focus state does not initiate a change of context for the user. Electronic Documents: Change in the focus state does not initiate a change of context for the user. Authoring Tool: Change in the focus state does not initiate a change of context for the user.
3.2.2 On Input	Web: Supports Electronic Documents: Supports Software: Not Applicable Authoring Tool: Supports	Web: Engaging with the interactive sites does not unexpectedly take control from the users. Electronic Documents: Engaging with the interactive sites does not unexpectedly take control from the users. Authoring Tool: Engaging with the interactive sites does not unexpectedly take control from the users.
3.3.1 Error Identification	Web: Supports Electronic Documents: Supports Software: Not Applicable Authoring Tool: Supports	Web: The Inline Form Error module was added in Drupal 8. This needs to be enabled site-wide on installation. Authoring Tool: The Inline Form Error module was added in Drupal 8. This needs to be enabled site-wide on installation.
3.3.2 Labels or Instructions	Web: Supports Electronic Documents: Supports Software: Not Applicable Authoring Tool: Partially Supports	Web: Default forms all include labels. Authoring Tool: There are a few places where there are problems with labels, but these are odd exceptions - Drupal issue 3015494.
4.1.1 Parsing	Web: Supports Electronic Documents: Supports Software: Not Applicable Authoring Tool: Supports	Web: There are no HTML5 errors or warnings that are known to impact assistive technology users. Electronic Documents: There are no HTML5 errors or warnings that are known to impact assistive technology users. Authoring Tool: Generally parsing is very well supported, but there are a few places where this needs to be improved - Drupal issue 1852090 and 3144948.
4.1.2 Name, Role, Value	Web: Supports Electronic Documents: Supports Software: Not Applicable Authoring Tool: Supports	Web: Public pages support this criterion. Electronic Documents: Public pages support this criterion. Authoring Tool: This is generally well supported, but there are places where it has been overlooked. Drupal issue 3144948, 3019487, and 3085545.

# Table 2: Success Criteria, Level AA

Criteria	Conformance Level	Remarks and Explanations
1.2.4 Captions (Live)	Web: Not Applicable Electronic Documents: Not Applicable Software: Not Applicable
1.2.5 Audio Description (Prerecorded)	Web: Does Not Support Electronic Documents: Does Not Support Software: Not Applicable Authoring Tool: Does Not Support	Web: Audio files can be uploaded, but there is no way to associate captions in Core. Electronic Documents: There is no documentation on how to properly convey pre-recorded audio descriptions. Authoring Tool: There is no audio in the authoring interface of Drupal Core, but there is no support for authors to upload accessible audio files.
1.4.3 Contrast (Minimum)	Web: Partially Supports Electronic Documents: Supports Software: Not Applicable Authoring Tool: Supports	Web: Generally meets. Some contrast failures around grey backgrounds - Drupal issue 3040673. Electronic Documents: The docs have sufficient contrast. Authoring Tool: Generally meets requirements. Some challenges with Core admin themes - Drupal issue 930508 and 3080100.
1.4.4 Resize text	Web: Partially Supports Electronic Documents: Supports Software: Not Applicable Authoring Tool: Partially Supports	Web: Generally support with some minor exceptions - Drupal issue 3129257. Electronic Documents: The docs are accessible up to 200%. Authoring Tool: Generally good with some exceptions - Drupal issue 3164587.
1.4.5 Images of Text	Web: Not Applicable Electronic Documents: Supports Software: Not Applicable Authoring Tool: Supports	Authoring Tool: Text is generally styled with CSS in the authoring tool. Should images of text be uploaded by the user, they will be required to add alternative text.
2.4.5 Multiple Ways	Web: Supports Electronic Documents: Supports Authoring Tool: Supports	Web: There is more than one way to locate a Web page within the CMS. Electronic Documents: There is more than one way to locate a Web page within the CMS. Authoring Tool: There is more than one way to locate a Web page within the CMS.
2.4.6 Headings and Labels	Web: Partially Supports Electronic Documents: Not Applicable Software: Not Applicable Authoring Tool: Partially Supports	Web: Generally there is very good support. Some heading levels may be missed in some unique contexts - Drupal issue 1768732. Better support could be provided for threaded comments - Drupal issue 2290043. Authoring Tool: Generally good, but for dynamic elements like the Layout Builder need a plan for a dynamic heading structure - Drupal issue 3007978.
2.4.7 Focus Visible	Web: Partially Supports Electronic Documents: Supports Software: Not Applicable Authoring Tool: Partially Supports	Web: Focus elements are well established for the front-end. Further enhancements are being developed to make it more obvious for keyboard only users. Authoring Tool: An IE specific bug where there are focus issues for authors and administrators in the Claro theme - Drupal issue 3048785.
3.1.2 Language of Parts	Web: Partially Supports Electronic Documents: Not Applicable Software: Not Applicable Authoring Tool: Supports	Web: Multilingual sites have language switchers with proper semantics. Unfotunately support is lacking for multi-lingual search 2992894 as well as both the Filesystem 3163915 & Views components 2496223. Authoring Tool: Drupal has good support for multilingual content and accessibility. To support the Language of Parts for authors, a button can be added to simplify the process of adding language specific phrases.
3.2.3 Consistent Navigation	Web: Supports Electronic Documents: Supports Authoring Tool: Supports	Web: Drupal's menu structure allows for consistent navigation across the site. Electronic Documents: Drupal's menu structure allows for consistent navigation across the site. Authoring Tool: Drupal's menu structure allows for consistent navigation across the site.
3.2.4 Consistent Identification	Web: Supports Electronic Documents: Supports Authoring Tool: Supports	Web: Components in Drupal that have the same functionality are identified consistently. Electronic Documents: Components in Drupal that have the same functionality are identified consistently. Authoring Tool: Components in Drupal that have the same functionality are identified consistently.
3.3.3 Error Suggestion	Web: Supports Electronic Documents: Not Applicable Software: Not Applicable Authoring Tool: Supports	Web: The Inline Form Error Module is provided in Core and needs to be enabled to allow for this functionality. Authoring Tool: The Inline Form Error Module is provided in Core and needs to be enabled to allow for this functionality.
3.3.4 Error Prevention (Legal, Financial, Data)	Web: Supports Electronic Documents: Supports Software: Not Applicable Authoring Tool: Partially Supports	Web: By default users can editing content which they own. Electronic Documents: Documentation could be improved. Authoring Tool: There is nothing to differentiate editing financial or legal data from any other data managed by Drupal.

# Table 3: Success Criteria, Level AAA

Notes: Where possible the Drupal community strives to exceed AA compliance.

Criteria	Conformance Level	Remarks and Explanations
1.2.6 Sign Language (Prerecorded)	Web: Not Applicable
1.2.7 Extended Audio Description (Prerecorded)	Web: Not Applicable
1.2.8 Media Alternative (Prerecorded)	Web: Not Applicable
1.2.9 Audio-only (Live)	Web: Not Applicable
1.4.6 Contrast (Enhanced)	Web: Supports	Web: A front-end and back-end theme could be configured to allow this to comply.
1.4.7 Low or No Background Audio	Web: Not Applicable
1.4.8 Visual Presentation	Web: Not Evaluated	Web: Stable Core themes leave much of the presentation of text to user agents, so aside from line spacing this generally works.
1.4.9 Images of Text (No Exception)	Web: Supports	Web: Text images are all supplied by the author.
2.1.3 Keyboard (No Exception)	Web: Supports	Web: The web front-end is not a barrier to keyboard only users.
2.2.3 No Timing	Web: Supports	Web: There are no timeouts in Drupal Core that would affect people with disabilities.
2.2.4 Interruptions	Web: Not Applicable
2.2.5 Re-authenticating	Web: Not Applicable
2.3.2 Three Flashes	Web: Supports	Web: There is no flashing content.
2.4.8 Location	Web: Supports	Web: Breadcrumbs are available and sitemap modules can be added to provide additional means for navigation.
2.4.9 Link Purpose (Link Only)	Web: Partially Supports	Web: There is a mechanism to support automated links with semantic descriptive titles.
2.4.10 Section Headings	Web: Supports	Web: Drupal provides heading elements at the beginning of each section of content.
3.1.3 Unusual Words	Web: Not Applicable
3.1.4 Abbreviations	Web: Not Applicable
3.1.5 Reading Level	Web: Not Applicable
3.1.6 Pronunciation	Web: Not Applicable
3.2.5 Change on Request	Web: Not Applicable
3.3.5 Help	Web: Not Applicable
3.3.6 Error Prevention (All)	Web: Not Applicable

# Revised Section 508 Report

# Chapter 3: Functional Performance Criteria (FPC)

Notes: Not applicable.

Criteria	Conformance Level	Remarks and Explanations
302.1 Without Vision	Supports	Testing has been done with JAWS, NVDA and VoiceOver.
302.2 With Limited Vision	Supports	Testing has been done with browser zoom and ZoomText.
302.3 Without Perception of Color	Supports	The interface has been reviewed for use of color.
302.4 Without Hearing	Not Applicable
302.5 With Limited Hearing	Not Applicable
302.6 Without Speech	Not Applicable
302.7 With Limited Manipulation	Supports	Drupal's interface does not restrict users with limited manipulation.
302.8 With Limited Reach and Strength	Supports	Drupal's interface does not restrict users with limited reach or strength.
302.9 With Limited Language, Cognitive, and Learning Abilities	Not Applicable

# Chapter 4: Hardware

Notes: Drupal is a web application. Hardware accessibility criteria is not applicable.

# Chapter 5: Software

Notes: Drupal is a web application. Software accessibility criteria is not applicable.

# Chapter 6: Support Documentation and Services

Notes: Drupal is a web application and all support documentation is delivered through the web. Additional documentation and services are not available.

Criteria	Conformance Level	Remarks and Explanations
602.2 Accessibility and Compatibility Features	Not Applicable
602.4 Alternate Formats for Non-Electronic Support Documentation	Not Applicable
603.2 Information on Accessibility and Compatibility Features	Not Applicable
603.3 Accommodation of Communication Needs	Not Applicable

# Legal Disclaimer

The information herein is provided in good faith based on the analysis of the web application at the time of the review and does not represent a legally-binding claim. Please contact us to report any accessibility errors or conformance claim errors for re-evaluation and correction, if necessary.

# Repository

https://github.com/GSA/openacr/blob/main/openacr/drupal-9.yaml

# Feedback

https://www.drupal.org/project/issues/drupal

# Related OpenACRs

• https://ckeditor.com/docs/ckeditor4/latest/guide/dev_section508.html (secondary)