Table 3 - Comparison of the Functional Performance Criteria in the NPRM and Existing 508 Standards and 255 Guidelines
| Proposed Sections E207.2 and C205.2 (incorporating WCAG 2.0 by reference) and 302 | Existing 508 Standards | Existing 255 Guidelines |
| 302.1 Without Vision. Where a visual mode of operation is provided, ICT shall provide at least one mode of operation that does not require user vision. | § 1194.31 (a) At least one mode of operation and information retrieval that does not require user vision shall be provided, or support for assistive technology used by people who or blind or visually impaired shall be provided. | § 1193.41 (a) Operable without vision. Provide at least one mode that does not require user vision. |
| 302.2 With Limited Vision. Where a visual mode of operation is provided, ICT shall provide at least one mode of operation that magnifies, one mode that that reduces the field of vision required, and one mode that allows user control of contrast. | § 1194.31 (b) At least one mode of operation and information retrieval that does not require visual acuity greater than 20/70 shall be provided in audio and enlarged print output working together or independently, or support for assistive technology used by people who or visually impaired shall be provided | § 1193.41 (b) Operable with low vision and limited or no hearing. Provide at least one mode that permits operation by users with visual acuity between 20/70 and 20/200, without relying on audio output. |
| 302.3 Without Perception of Color. Where a visual mode of operation is provided, ICT shall provide at least one mode of operation that does not require user perception of color. | No criteria for users without perception of color. | § 1193.41 (c) Operable with little or no color perception. Provide at least one mode that does not require user color perception. |
| 302.4 Without Hearing. Where an auditory mode of operation is provided, ICT shall provide at least one mode of operation that does not require user hearing. | § 1194.31 (c) At least one mode of operation and information retrieval that does not require user hearing shall be provided, or support for assistive technology used by people who are deaf or hard of hearing shall be provided. | § 1193.41 (d) Operable without hearing. Provide at least one mode that does not require user auditory perception. |
| 302.5 With Limited Hearing. Where an auditory mode of operation is provided, ICT shall provide at least one mode of operation that improves clarity, one mode that reduces background noise, and one mode that allows user control of volume. | § 1194.31 (d) Where audio information is important for the use of a product, at least one mode of operation and information retrieval shall be provided in an enhanced auditory fashion, or support for assistive hearing devices shall be provided. | Operable with low vision and limited or no hearing. Provide at least one mode that permits operation by users with visual acuity between 20/70 and 20/200, without relying on audio output. |
| 302.6 Without Speech. Where a spoken mode of operation is provided, ICT shall provide at least one mode of operation that does not require user speech. | § 1194.31 (e) At least one mode of operation and information retrieval that does not require user speech shall be provided, or support for assistive technology used by people with disabilities shall be provided. | § 1193.41 (h) Operable without speech. Provide at least one mode that does not require user speech |
| 302.7 With Limited Manipulation. Where a manual mode of operation is provided, ICT shall provide at least one mode of operation that does not require fine motor control or operation of more than one control at the same time. | § 1194.31 (f) At least one mode of operation and information retrieval that does not require fine motor control or simultaneous actions and that is operable with limited reach and strength shall be provided. | § 1193.41 (e) Operable with limited manual dexterity. Provide at least one mode that does not require user fine motor control or simultaneous actions. |
| 302.8 With Limited Reach or Strength. Where a manual mode of operation is provided, ICT shall provide at least one mode of operation that is operable with limited reach and limited strength. | § 1194.31 (f) At least one mode of operation and information retrieval that does not require fine motor control or simultaneous actions and that is operable with limited reach and strength shall be provided. | § 1193.41 (f) Operable with limited reach and strength. Provide at least one mode that is operable with user limited reach and strength |
| WCAG 2.2.1 Timing Adjustable: For each time limit that is set by the content, at least one of the following is true: (Level A) •Turn off: The user is allowed to turn off the time limit before encountering it; or •Adjust: The user is allowed to adjust the time limit before encountering it over a wide range that is at least ten times the length of the default setting; or •Extend: The user is warned before time expires and given at least 20 seconds to extend the time limit with a simple action (for example, “press the space bar”), and the user is allowed to extend the time limit at least ten times; or •Real-time Exception: The time limit is a required part of a real-time event (for example, an auction), and no alternative to the time limit is possible; or •Essential Exception: The time limit is essential and extending it would invalidate the activity; or •20 Hour Exception: The time limit is longer than 20 hours. |
§ 1194.22 (p) When a timed response is required, the user shall be alerted and given sufficient time to indicate more time is required. | § 1193.41 (g) Operable without time-dependent controls. Provide at least one mode that does not require a response time. Alternatively, a response time may be required if it can be by-passed or adjusted by the user over a wide range. |
| WCAG 2.2.2 Pause, Stop, Hide: For moving, blinking, scrolling, or auto-updating information, all of the following are true: (Level A) •Moving, blinking, scrolling: For any moving, blinking or scrolling information that (1) starts automatically, (2) lasts more than five seconds, and (3) is presented in parallel with other content, there is a mechanism for the user to pause, stop, or hide it unless the movement, blinking, or scrolling is part of an activity where it is essential; and •Auto-updating: For any auto-updating information that (1) starts automatically and (2) is presented in parallel with other content, there is a mechanism for the user to pause, stop, or hide it or to control the frequency of the update unless the auto-updating is part of an activity where it is essential. |
§ 1194.22 (h) When animation is displayed, the information shall be displayable in at least one non-animated presentation mode at the option of the user. | § 1193.43 (c) Access to moving text. Provide moving text in at least one static presentation mode at the option of the user. |
| No corresponding provisions. | No corresponding provisions. | § 1193.41 (i) Operable with limited cognitive skills. Provide at least one mode that minimizes the cognitive, memory, language, and learning skills required of the user. |