WCAG 3.1.5: Reading Level

What This Rule Means

WCAG Success Criterion 3.1.5 Reading Level (Level AAA) states: "When text requires reading ability more advanced than the lower secondary education level after removal of proper names and titles, supplemental content, or a version that does not require reading ability more advanced than the lower secondary education level, is available."

In practical terms, this criterion asks content authors and developers to assess whether their written content exceeds the reading comprehension level typically achieved after completing lower secondary school — roughly equivalent to an eighth-grade or age 14 reading level in most international frameworks. When content does exceed this threshold, the criterion requires that one of two remedies be provided: either a supplemental simplified summary or explanation of the content, or an alternative version of the entire content written at the lower reading level.

The criterion specifically carves out proper names (such as names of people, places, or organisations) and titles (such as job titles, book titles, or formal designations) when measuring reading complexity. These terms are not counted against the content when evaluating whether it surpasses the lower secondary threshold, because they cannot reasonably be simplified without losing accuracy.

A pass for this criterion occurs when: (1) the main body content does not exceed lower secondary reading level on its own; or (2) a simplified version or summary of sufficiently complex content is made available and clearly accessible to users — for example, a plain-language summary at the top of a dense policy document, or a link to an easy-read version. A fail occurs when text is written at a high complexity level — using advanced vocabulary, long sentences, passive constructions, and abstract concepts — without any simplified supplement, and no alternative version is provided.

This criterion does not require organisations to remove technical or specialised language from their primary content. Legal documents, medical reports, scientific papers, and regulatory texts often must maintain precise language for professional accuracy. The requirement is simply that an accessible alternative pathway exists for users who cannot navigate the complex version independently.

Why It Matters

Reading comprehension difficulties affect a significantly broader population than many designers and developers assume. Globally, an estimated 773 million adults lack basic literacy skills, according to UNESCO data. Beyond absolute literacy, a large share of the population reads at or below a sixth-grade level, including many people with no formal disability diagnosis. When web content assumes advanced literacy, it excludes these users entirely.

People with cognitive disabilities — including intellectual disabilities, dyslexia, attention deficit disorders, acquired brain injuries, and dementia — are among the most directly affected. Complex sentence structures, abstract vocabulary, and dense paragraph formatting impose disproportionate cognitive load on these users, making it difficult or impossible to extract meaning, follow instructions, or make informed decisions. For someone with a mild intellectual disability trying to navigate a government benefits portal, or a person recovering from a stroke attempting to read a hospital discharge summary, impenetrable language is not a minor inconvenience — it is a complete barrier to access.

Non-native speakers of a language are also significantly impacted. In Turkey, for example, millions of citizens speak Kurdish, Arabic, or other languages as their first language and may have learned Turkish as a second language. A government website written in highly formal Turkish bureaucratic prose creates real-world exclusion for these populations. Similarly, older adults, people with limited formal education, and individuals experiencing cognitive fatigue (such as those managing chronic illness) benefit enormously from plain-language content.

Consider a concrete scenario: a person with a moderate intellectual disability needs to understand the terms and conditions of a mobile phone contract from a major Turkish telecom provider. The document is written in dense legal language at an advanced academic level. Without a plain-language summary or easy-read alternative, this person cannot meaningfully consent to the contract terms — a situation with serious legal and ethical implications. If the provider offered a clear, illustrated summary alongside the formal document, this same person could participate fully and independently in the process.

Beyond accessibility, plain language offers measurable SEO and usability benefits. Search engines reward content that matches user intent and comprehension; simpler, clearer writing tends to have lower bounce rates, higher engagement, and better task completion rates. Organisations that invest in plain language consistently report reduced customer service calls, fewer errors in form completion, and greater user trust.

Related Axe-core Rules

WCAG 3.1.5 requires entirely manual testing. No axe-core automated rule exists that can reliably detect or flag reading level violations. The reasons for this are both technical and linguistic:

• Automated readability analysis is language-dependent and contextually limited: Tools like the Flesch-Kincaid Grade Level formula or Gunning Fog Index were developed primarily for English and do not translate reliably to Turkish, Arabic, or other languages used on Turkish websites. Automated readability scores measure surface features — average sentence length, syllable counts, word frequency — but cannot assess whether a simplified alternative exists elsewhere on the page or site, whether technical terms are justified by the subject matter, or whether the overall communication achieves its purpose for users with cognitive disabilities. A passage could score at a low reading grade level while still being practically incomprehensible due to domain jargon, unclear structure, or missing context.
• No axe-core rule maps to this criterion: Because reading level assessment requires human judgment about content intent, audience, subject matter justification, and the presence and quality of alternatives, axe-core does not include an automated rule for 3.1.5. Automated scanners cannot distinguish between a legitimately complex legal disclaimer (which might need a plain-language summary) and a deliberately simplified user interface text (which already complies). Manual content review by qualified editors or accessibility specialists is the only reliable method for evaluating this criterion.

How to Test

1. Automated pre-screening (readability tools): While automated tools cannot definitively pass or fail this criterion, they can flag content for manual review. Run your page content through a readability analysis tool such as the Hemingway Editor (hemingwayapp.com) or a Flesch-Kincaid calculator. For Turkish content, consider tools developed for Turkish text complexity or use manual judgment. Note any passages flagged at high grade levels as candidates for manual review. These results are indicative only — they do not constitute a pass or fail determination.
2. Identify the target reading level: Determine what reading level the content is aimed at. Lower secondary education corresponds roughly to CEFR B1 language level or an 8th-grade reading level. Content aimed at general public audiences — government services, consumer e-commerce, healthcare information — should generally meet this threshold or provide alternatives.
3. Review content manually for reading complexity: Read each significant block of body text and assess: Are sentences longer than 20–25 words on average? Is the vocabulary dominated by low-frequency or specialised terms? Are abstract concepts presented without concrete examples or analogies? Is the passive voice used heavily? If the answer to most of these is yes, the content likely exceeds the lower secondary reading level.
4. Check for simplified alternatives: Look for a plain-language summary, easy-read version, or simplified explanation accompanying any complex content. This may appear as a summary box at the top of the page, a separate linked document, an illustrated alternative, or an audio explanation. Verify that any such alternative is clearly labelled, easy to find, and genuinely covers the key points of the complex content.
5. Screen reader and assistive technology testing: Using NVDA with Firefox, VoiceOver with Safari, or JAWS with Chrome, navigate to the page and listen to the content read aloud. While screen readers do not assess reading level directly, listening to content being read linearly often reveals sentences that are excessively long, convoluted, or dependent on visual formatting to convey meaning — all signals of complexity that harms users who rely on text-to-speech.
6. User testing with representative audiences: For the most reliable evaluation, conduct usability testing with participants who represent the intended audience, including people with cognitive disabilities or limited literacy. Observe whether they can successfully complete key tasks (finding information, understanding instructions, filling forms) using the content as written.

How to Fix

Dense policy document without a summary — Incorrect

<!-- A terms and conditions page with no plain-language alternative -->
<article>
  <h1>Terms and Conditions of Service</h1>
  <p>
    Notwithstanding any provisions to the contrary contained herein, the subscriber
    irrevocably acknowledges and agrees that the service provider retains the unilateral
    right to amend, modify, or rescind any and all terms delineated within this agreement
    without prior notification, subject to applicable statutory obligations.
  </p>
  <!-- No plain-language summary, no simplified alternative provided -->
</article>

Dense policy document with a plain-language summary — Correct

<!-- A terms and conditions page with a clearly labelled plain-language summary -->
<article>
  <h1>Terms and Conditions of Service</h1>

  <!-- Plain-language summary provided before the complex legal text -->
  <section aria-labelledby='plain-summary-heading'>
    <h2 id='plain-summary-heading'>Plain-Language Summary</h2>
    <p>
      We can change these terms at any time. If we do, we will let you know.
      By using our service, you agree to the current terms.
    </p>
  </section>

  <!-- Full legal text follows for those who need it -->
  <section aria-labelledby='full-terms-heading'>
    <h2 id='full-terms-heading'>Full Legal Terms</h2>
    <p>
      Notwithstanding any provisions to the contrary contained herein, the subscriber
      irrevocably acknowledges and agrees that the service provider retains the unilateral
      right to amend, modify, or rescind any and all terms delineated within this agreement
      without prior notification, subject to applicable statutory obligations.
    </p>
  </section>
</article>

Healthcare instructions written above lower secondary level — Incorrect

<!-- Patient discharge instructions using clinical language with no alternative -->
<section>
  <h2>Post-Operative Care Instructions</h2>
  <p>
    Administer analgesic medication at four-hour intervals to mitigate nociceptive
    responses. Monitor the incision site for erythema, oedema, or purulent discharge
    indicative of infection. Abstain from ambulation exceeding 500 metres per diem
    during the initial convalescent period.
  </p>
</section>

Healthcare instructions with plain-language rewrite and link to simplified version — Correct

<!-- Patient instructions rewritten in plain language, with easy-read version linked -->
<section>
  <h2>After Your Operation: What to Do at Home</h2>
  <p>
    <a href='/easy-read/post-op-care'>Read the easy-read version of these instructions</a>
  </p>
  <p>
    Take your pain medicine every four hours as directed. Check your wound each day.
    Call us if you see redness, swelling, or any discharge from the wound.
    Do not walk more than 500 metres a day for the first week after your operation.
  </p>
</section>

Government form instructions written in bureaucratic language — Incorrect

<!-- Complex form instructions with no simplified guidance -->
<div class='form-instructions'>
  <p>
    Applicants are hereby notified that pursuant to the relevant statutory provisions
    governing the submission of documentation, all requisite evidentiary materials
    must be furnished in authenticated facsimile or notarially certified original form,
    accompanied by a comprehensive declaration of veracity executed by a legally
    recognised authority.
  </p>
</div>

Government form instructions with clear plain-language guidance — Correct

<!-- Form instructions rewritten clearly, with a summary at the top -->
<div class='form-instructions'>
  <!-- Brief plain summary first -->
  <p><strong>In short:</strong> You must send certified copies of your documents. A notary or official authority must sign them to confirm they are real.</p>

  <!-- More detail follows in still-plain language -->
  <p>
    Please include copies of all required documents with your application.
    Each copy must be either a certified photocopy or a notarised original.
    A notary, lawyer, or authorised official must confirm the documents are genuine
    by signing a declaration of authenticity.
  </p>
</div>

Common Mistakes

• Assuming the criterion only applies to specialist or academic content: Legal terms and conditions, privacy policies, product manuals, and government service pages written for general audiences commonly exceed lower secondary reading level without authors realising it. Every public-facing text should be evaluated, not just formally academic documents.
• Providing a summary that omits critical information: A plain-language summary that leaves out key decisions, rights, obligations, or risks is worse than none — it may mislead users with limited literacy into missing essential content. The simplified version must cover all points that matter for user decision-making.
• Placing the simplified version at the bottom of a long page: If a user with cognitive disabilities must scroll through pages of dense text to reach the plain-language summary, the summary fails its purpose. Place simplified summaries or links to alternative versions at the very top of the content, before the complex text begins.
• Using passive voice throughout: Passive constructions such as "applications must be submitted" instead of "you must submit your application" significantly increase cognitive load. Converting passive constructions to active voice is one of the simplest and most effective plain-language techniques.
• Writing sentences averaging more than 25 words: Long, compound-complex sentences with multiple subordinate clauses are a primary driver of high reading difficulty scores. Break them into shorter units, each expressing a single idea.
• Replacing complex words with synonyms that are equally complex: Swapping "remuneration" for "compensation" does not simplify for users with limited vocabulary. Plain language requires choosing words that are genuinely familiar to a broad audience, or explaining technical terms immediately when they cannot be avoided.
• Relying on layout or visual formatting to carry meaning in the complex version: Users relying on screen readers or who have converted content to plain text lose visual signals like bold, colour, and indentation. If understanding the complex version depends on these visual cues, both the complex and simplified versions become harder to use.
• Treating the easy-read link as the complete solution without quality-checking the alternative: Organisations sometimes link to a simplified version that was never properly reviewed, uses jargon, or is out of date with the main content. The alternative version must be maintained in sync with the primary content and reviewed by people who represent the intended audience.
• Not considering multilingual contexts: In markets like Turkey, where a significant portion of users speak Turkish as a second language, a text written at lower secondary level in Turkish may still be inaccessible to users with limited Turkish proficiency. Consider whether multilingual or visual alternatives are also needed.
• Using numerals and statistics without contextual explanation: Dense tables of statistics, financial figures, or percentages without narrative explanation effectively increase reading difficulty even if the surrounding prose is simple. Summarise key numbers in plain sentences and explain what they mean in context.

Relation to Turkey's Accessibility Regulations

Turkey's Presidential Circular 2025/10, published in the Official Gazette No. 32933 on 21 June 2025, establishes web and mobile application accessibility obligations for a broad range of entities operating in Turkey. The circular mandates compliance with WCAG 2.2 as the technical standard for accessibility. The covered entity types include public institutions and agencies, e-commerce platforms, banks and financial institutions, hospitals and healthcare providers, telecommunications companies with 200,000 or more subscribers, travel agencies, private transport companies, and private schools authorised by the Ministry of National Education (MoNE).

WCAG 3.1.5 Reading Level sits at conformance Level AAA, which is not mandated as a blanket legal requirement under the 2025/10 Circular. The circular's baseline legal obligation aligns with WCAG 2.2 Level AA. However, Level AAA compliance — including Reading Level — is strongly encouraged for organisations that serve populations with high diversity in literacy levels or cognitive abilities, and may be specifically required for certain specialised public services where accessible communication is a fundamental right rather than an enhancement.

In the Turkish context, Reading Level compliance carries particular weight for several regulated sectors. Public institutions serving citizens with intellectual disabilities or low literacy — including social welfare agencies, health ministries, and municipal services — have a strong ethical and increasingly legal obligation to provide plain-language content. Telecom providers reaching millions of subscribers are required to present contract terms, pricing information, and service conditions in language that consumers can genuinely understand, aligning with both accessibility principles and consumer protection law. Private schools authorised by MoNE serve families and students with diverse literacy levels and cognitive abilities; accessible communication from such institutions directly supports educational inclusion.

Organisations aiming to demonstrate best-in-class accessibility — particularly those seeking certification, tendering for public contracts, or building trust with a broad audience — should treat WCAG 3.1.5 as a meaningful commitment beyond minimum legal compliance. Plain language is not only an accessibility requirement; it is a marker of institutional respect for the full diversity of the public being served. For organisations using Accsible's overlay SDK, plain-language content remains a content authoring responsibility that complements, but is not replaced by, technical overlay features — ensuring that users at every literacy level can access, understand, and act on the information they need.