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Equivalent Functionality


Section 508:

  • §1194.21(b)
  • §1194.21(l)
  • §1194.22(a)
  • §1194.22(k)
  • §1194.22(l)
  • §1194.31(a)
  • §1194.31(b)
  • §1194.31(f)

WCAG 2.0:

Ensure content that provides alternatives for non-accessible content provides equivalent functionality

When alternative content is provided for inaccessible content, the equivalent functionality must be provided, and the alternative should have an equivalent number of steps. Additionally, the alternative content must be updated whenever the standard content is updated. When alternatives do not provide the same functionality, users with disabilities do not have access to the same features. For example, if an alternative report view page does not contain a functional quiz the inaccessible page does not let users with disabilities have access to this functionality. Users with disabilities must have the same level of access to the features supplied to other users.


iOS description

iOS Example

- Informational displays provide support for multiple sensory methods
(color, accessible text, accessible icons, etc.)
- Multiple input methods that support assistive technologies.

iOS Failure

- Colored text providing (not displayed) accessibility label indicating the
purpose of the text coloring such as a required field.
- Gesture based input methods that cannot be performed by users with motor
impairments and has no alternative input method support.


Android description

Android Example

An Alternative page where the user is able to take a functioning quiz.

Android Failure

An Alternative quiz page where the quiz is self scored.


HTML Description

HTML Example

HTML Example

HTML Failure

HTML Failure  


Developers must implement the same functionality in a roughly equivalent number of steps to access the functionality as in the inaccessible content. Developers must implement the accessibility of the alternative page to the relevant best practices for the type of elements used.

Developers must ensure that the alternative content is updated whenever the standard content is updated and that the path to access the alternative content is an equivalent number of steps and is clearly visible in an accessible manner to users.

Developers should ensure the both input and output methods support multiple disabilities. Output should not be dependent upon a single sensory characteristic such as color and all elements should fully implement the Accessibility API. Input should likewise not be limited to a single input method and support alternative input methods provided by the Accessibility API or alternate input devices.


Recommended tool/method: Manual

Ensure content that provides alternatives for non-accessible content provides equivalent functionality (Implied Global)
  1. Open the app
  2. Navigate to the desired content
  3. Determine if the content is an alternative to standard content
  4. Verify that all of the following are true:
    1. The alternative content is up-to-date with the standard content
    2. The alternative provides the same functionality as the standard content
    3. The same functionality can be achieved in approximately the same number of steps as the standard content
Enhancements that are provided for users with disabilities shall not be provided in a mutually exclusive fashion (Manual)


  1. Open the module that has been enhanced for users with disabilties
  2. Verify that the module still complies with all applicable best practices and standards and that the enhancements do not impede the accessibility of the application functionality, input, and output to users with other types of disabilities