SC 1.3.4 is problematic for some content appearing only on stationary hardware

[mitchellevan]

Issue

WCAG2ICT over-stretches the "essential" exception, to give a pass to software that runs only on devices such as TVs or kiosks. I agree it makes sense to give such software a pass for SC 1.3.4, but I believe the normative meaning of the "essential" exception is not quite up to this task.

As @GreggVan wrote in EN 301 549 GitLab issue 660, comment 2025-09-30:

An essential exemption means that if you did this requirement - you product would no longer work. That is is ESSENTIAL that this requirement NOT be followed. In this case -- making software reorient would not be a problem. Just useless extra work - for no benefit.

Consider these use cases:

1. Content is designed for a projector or TV, but also appears on other devices.
2. Software is designed for the specific hardware of a handheld calculator, with closed functionality and no support for orientation changes.
3. A kiosk app is designed to be run on a platform capable of orientation changes, such as an Android tablet, but in practice the integrated kiosk will only be deployed with a single orientation in a fixed mounting.

I can accept applying the essential exception to use case #2, because rotating the calculator software would make it not understandable in relation to the non-rotatable physical keypad.

It's in use case #3 that the "essential" exception becomes most over-stretched. We're currently saying this: if the restriction to a specific display orientation were removed, it would fundamentally change the information or functionality of the content. But that's not true in use case #3. In the unlikely event that somebody did physically rotate the kiosk, allowing the kiosk app to change orientation would have no negative impact on its function.

Quoting our current texts

WCAG Success Criterion 1.3.4 Orientation:

Content does not restrict its view and operation to a single display orientation, such as portrait or landscape, unless a specific display orientation is essential.

Note
Examples where a particular display orientation may be essential are a bank check, a piano application, slides for a projector or television, or virtual reality content where content is not necessarily restricted to landscape or portrait display orientation.

WCAG definition of 'essential':

if removed, would fundamentally change the information or functionality of the content, and information and functionality cannot be achieved in another way that would conform

WCAG Understanding SC 1.3.4:

The exception for things considered essential is aimed at situations where the content would only be understood in a particular orientation, or where the technology restricts the possible orientations. If content is aimed at a specific environment which is only available in one orientation (such as a television) then the content can restrict the orientation. Technologies such as virtual reality use screens within goggles that cannot change orientation relative to the user's eyes.

WCAG2ICT, Applying SC 1.3.4 Orientation to Non-Web Documents and Software:

This applies directly as written, and as described in Intent from Understanding Success Criterion 1.3.4.

Note 1 (Added)
Content that is only used on hardware with a fixed display orientation or that has no sensor to detect or change the orientation is covered under the essential exception and does not need to provide support for orientation changes.

Note 2 (Added) (for non-web software)
See also the Comments on Closed Functionality.

WCAG2ICT, Success Criteria Problematic for Closed Functionality:

1.3.4 Orientation — ICT with closed functionality that has fixed-in-place displays or other limitations that prevent modifying the physical display orientation should be considered as examples that are covered under the essential exception. See the note in the section Applying SC 1.3.4 Orientation to Non-Web Documents and Software.

Proposed

Update the WCAG2ICT "problematic" section to address use case #3 above. The update could be similar to Gregg's proposal in EN 301 549 GitLab issue 660, comment 2025-09-29.

Consider also editing the WCAG Understanding.

[GreggVan]

I think this problem was solved by adding the precondition. So we are not relying on essential at all. It is in the precondition.

or are you trying to say something else?

[maryjom]

We have been working on the appropriate language for the EN first and then will decide what to do with this in WCAG2ICT. PR #780 is where we're working on the changes.

[maryjom]

I think that this is resolved in the text proposed by Gregg in an email from 28 September that I incorporated into PR #780 which the WCAG2ICT TF will review and discuss in the 2 October meeting.

[maryjom]

PR 780 has been updated with the latest text from the EN 301 549 V20 draft. The TF discussed it today as well, though we didn't have a quorum to approve the PR.