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My only real criticism of WCAG-EM is that WCAG-EM still drops the same ball that WCAG 2.x does by not having more granular details on the test criteria. WCAG is structured as Principle -> Guideline -> Success Criteria, with no normative definition of how one may meet the criteria. As a result, not only are the mechanism of meeting the SC not defined, nor are the methods of judging conformance.
Clearly, it is beyond the scope of WCAG-EM to take that on. However, the document should include steps and descriptions for the evaluator(s) to come up with their own itemized criteria against which the product is judged.
IMO this is a critical missing piece of WCAG-EM
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