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Draft Digital Accessibility Standard

This draft version of the proposed Digital Accessibility Standard (DAS) is for the public consultation from to . The final version of the DAS is expected early and will replace the current Web Accessibility Standard.

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Text in square brackets, for example, “[the start date]”, is still to be confirmed.

1. Purpose

1.1 What this Standard is for

This Standard helps make sure that disabled people can access information and services that the New Zealand Government uses or provides.

2. Application

2.1 When the Standard starts

This Standard starts on [the start date] and replaces the Web Accessibility Standard 1.2.

2.2 Authority

The authority issuing this Standard is still to be confirmed.

This Standard is issued by the Government Chief Digital Officer (GCDO) under section 57(1) of the Public Service Act (the Act).

2.3 Who must follow this Standard

The agencies that will have to meet this Standard are still being confirmed.

2.3.1 Mandated Organisations

All public service agencies, as defined in section 10(a) of the Act, must comply with this Standard.

In this Standard, these agencies are called Mandated Organisations.

2.3.2 Other organisations

For other parts of the public sector, this Standard is issued as guidance under section 57(6) of the Act.

2.4 Use of terms

The words “must”, “should”, and “may” in this Standard indicate different levels of requirement. Their meanings are defined in the Glossary and apply throughout this Standard.

3. Requirements for ICT Products and Services

3.1 What this section applies to

Section 3 applies to government products and services that use information and communication technology (ICT) that a Mandated Organisation is responsible for.

These products and services are called ICT Products and Services, and include:

3.2 When the requirements apply

3.2.1 New or changed ICT Products and Services

From [the start date], the requirements apply to:

  1. all new ICT Products and Services
  2. any ICT Product and Service that is updated, replaced, or republished, but only the parts that change.

3.2.2 Existing ICT Products and Services

For ICT Products and Services that existed before [the start date]:

  • after 1 year: all web pages, mobile applications, and non-web documents
  • after 3 years: all non-web software
  • after 5 years: all other ICT Products and Services, including hardware.

3.3 What is excluded

3.3.1 When this Standard does not apply

This Standard does not apply to:

  1. Internal working materials, like drafts or personal notes, unless they are:
    1. given to others as part of delivering ICT Products and Services
    2. directly involved in decisions that seriously affect people’s rights or duties
    3. needed for reasonable accommodation.
  2. Inactive ICT Products and Services, or inactive parts of ICT Products and Services, if there are clear and accessible instructions for getting an accessible alternative.
  3. Third-party content in ICT Products and Services, if:
    1. the Mandated Organisation does not fund, build, or control it, and
    2. it is not needed to use the Mandated Organisation’s ICT Products and Services.

3.4 Core accessibility requirement

Each ICT Product and Service must meet [EN 301 549 Accessibility requirements for ICT products and services, version 4.1.1].

3.5 Accessibility Statements

3.5.1 Accessibility Statements for web pages and mobile applications

Each publicly facing ICT Product and Service delivered as one or more web pages or a mobile application must have a statement describing the accessibility of the ICT Product and Service.

This statement is called an Accessibility Statement.

3.5.2 Where it must be

The Accessibility Statement must be:

  1. included in the ICT Product and Service, or
  2. linked to from the ICT Product and Service to another online location the Mandated Organisation is responsible for.

3.5.3 How users can find it

The Accessibility Statement, or a link to it, must:

  1. appear in a clearly visible location on the home page, main screen or view of the ICT Product and Service
  2. be clearly labelled so people know what it is (for example, “Accessibility” or “Āheinga”).

3.5.4 What it must include

The Accessibility Statement must include:

  1. a reference to this Standard
  2. contact details for accessibility help or feedback about the ICT Product and Service
  3. information about how feedback is handled
  4. any exceptions claimed for the ICT Product and Service and alternative access options
  5. known accessibility problems with the ICT Product and Service and plans to fix them
  6. a link to the organisation’s latest Accessibility Plan.

3.6 Contact Information

3.6.1 Contact Information for web pages and mobile applications

Each publicly facing ICT Product and Service delivered as one or more web pages or a mobile application must clearly tell users how they can ask for accessibility help or give feedback.

This information is called Contact Information.

3.6.2 Where it must be

Contact Information must be:

  1. included in the ICT Product and Service, or
  2. linked to from the ICT Product and Service to another online location the Mandated Organisation is responsible for.

3.6.3 How users can find it

Contact Information, or a link to it, must:

  1. appear in a clearly visible location on the home page, main screen or view of the ICT Product and Service
  2. be clearly labelled so people know what it is (for example, “Contact us” or “Whakapā mai”).

3.6.4 What it must include

Contact Information must include:

  1. an email address monitored daily during business hours
  2. a phone number available and monitored daily during business hours
  3. call centre phone numbers (if the ICT Product and Service has a call centre)
  4. a postal address monitored during business hours
  5. a public street address (if there is one)
  6. a link to the New Zealand Relay Service.

3.6.5 Contact Information for non-web documents

Each publicly facing ICT Product and Service that is a non-web document must include at least one way to get help, such as:

  1. an email address monitored daily during business hours
  2. a link to a web page with accessible contact information.

3.7 HTML-first publishing

Publicly facing ICT Products and Services that deliver digital information or services should be delivered:

  1. primarily as accessible HTML web pages
  2. not only as mobile applications or non-web documents.

4. Requirements for Mandated Organisations

4.1 Accessibility planning

4.1.1 Accessibility Plan

Each Mandated Organisation must have a plan covering all its ICT Products and Services that describes:

  1. how they will meet this Standard
  2. progress made so far
  3. any current exceptions claimed under Section 5 and how they will be addressed.

This plan is called an Accessibility Plan.

4.1.2 Review cycle

The Accessibility Plan must:

  1. be reviewed every year
  2. be updated when needed
  3. be updated at least once every three years.

4.1.3 Publication

The latest Accessibility Plan must be published on at least one publicly facing web page that the Mandated Organisation is responsible for.

4.2 Plain language

Each Mandated Organisation must take reasonable steps to make sure user-facing content in its ICT Products and Services uses plain language.

4.3 Testing

Each Mandated Organisation must use a mix of testing methods with its ICT Products and Services, such as:

  1. testing with disabled people
  2. manual testing
  3. automated testing (including artificial intelligence (AI) tools, where suitable).

4.4 Monitoring and reporting

4.4.1 Ongoing monitoring

Each Mandated Organisation must regularly monitor and assess how accessible its ICT Products and Services are.

4.4.2 Reporting

When the GCDO asks, each Mandated Organisation must report on accessibility progress using a method provided by the GCDO.

4.4.3 GCDO testing

When the GCDO asks, each Mandated Organisation must allow its ICT Products and Services to be reasonably accessed for testing and monitoring using GCDO tools.

4.4.4 Response-time expectations

Each Mandated Organisation must:

  1. confirm receipt of accessibility feedback or requests within 3 business days
  2. tell users when to expect a full response.

4.4.5 Record-keeping

Each Mandated Organisation must keep records of actions taken in response to accessibility feedback and requests.

4.5 Procurement

Each Mandated Organisation must make sure that all contracts and procurement related to ICT Products and Services require those ICT Products and Services to meet Section 3 of this Standard.

5. Exceptions

5.1 Conditions for exceptions

5.1.1 When exceptions can be claimed

A Mandated Organisation may claim an exception only for a specific failure to meet a requirement when meeting that requirement:

  1. is technically infeasible, or
  2. would be a disproportionate burden.

5.1.2 Exceptions for specific failures only

An exception can only apply to specific failures, not to whole sections of this Standard.

5.2 Record-keeping for exceptions

5.2.1 What must be recorded

Mandated Organisations must keep records explaining:

  1. why the exception applies
  2. the evidence supporting the exception.

5.2.2 How long records must be kept

Records must be kept:

  1. while the exception applies
  2. for a reasonable time after.

5.3 Reviewing exceptions

Exceptions are temporary and must be reviewed:

  1. regularly
  2. whenever something changes that could affect whether the exception is still valid.

Glossary

Disproportionate burden

A situation where meeting a requirement would place unreasonable strain on an organisation compared with the benefit the change would give users.

To determine if a burden is disproportionate, the following factors should be considered:

  • Cost: the financial impact of the work on the organisation
  • Capacity: the organisation’s ability to take on the work
  • Impact: the improvement the change would make for people using the product or service.

For example, a small agency has millions of old paper documents saved as scanned images. Converting them to accessible digital text could cost more money than the agency’s whole budget for the year.

Inactive

Content, product, or service that is:

  • no longer needed for active administration purposes
  • neither modified nor updated after the date of inactivity
  • marked as inactive or archived.
Information and communication technology (ICT)

As defined in EN 301 549, technology or systems that are used to create, process, send, receive, store, or display information, or to receive commands from people.

Examples of ICT include, but are not limited to:

  • websites and web pages
  • documents that are not web pages, including office documents, presentations and emails
  • electronic content and digital media
  • hardware, computers and related equipment
  • software, including mobile applications
  • communication products and services
  • information kiosks and self service or transaction machines
  • audiovisual technologies and videos
  • intelligent user agents (such as automated assistants)
  • information and digital services.
May

Indicates an optional course of action.

Mobile application

Software designed to run on a mobile operating system (like iOS or Android). It is installed and run on mobile devices including smartphones and tablets.

Types of mobile application include:

  • Native applications: built for a specific operating system using that platform’s dedicated programming languages and user interface components
  • Hybrid applications: installed as mobile software but using web technologies (HTML, CSS, and JavaScript) to display some or all of the user interface, typically through an embedded browser.

For the purposes of this Standard, both native and hybrid mobile applications are in scope, even if a hybrid app displays web content. This includes all features, content, and components that users must interact with, including any embedded content hosted on third-party platforms.

Must

Indicates an absolute requirement.

Non-web document

Document that is not a web page, not embedded in web pages nor used in the rendering or functioning of the page.

[EN 301 549 v4.1.1]

Non-web digital documents include letters, spreadsheets, emails, presentations, and all downloadable office document files.

Non-web software

Software that is not a web page, not embedded in web pages nor used in the rendering or functioning of the page.

[EN 301 549 v4.1.1]

Non-web software is installed and runs outside a web browser, such as desktop applications, native mobile applications, and other stand-alone software. This includes all features, content, and interfaces that users interact with when using the software.

Plain language

Communication that is:

  • appropriate for its intended audience
  • clear, concise, and well-organised
  • allows people to easily find, understand, and use the information they need.
Publicly facing

Can be accessed by members of the general public, or people who are not employees, staff or authorised paid personnel of a New Zealand government public sector organisation.

This includes web pages, mobile applications, and non-web software that are available to external users, including where access is controlled by a login or other authentication mechanism.

Examples of publicly facing digital products include:

  • an organisation’s corporate website
  • an extranet used to interact with service providers or partners
  • a mobile application that members of the public use to access a service.
Reasonable accommodation

[The] necessary and appropriate modification and adjustments not imposing a disproportionate burden, where needed in a particular case, to ensure persons with disabilities the enjoyment or exercise on an equal basis with others of all human rights and fundamental freedoms.

United Nations Convention on the Rights of Persons with Disabilities
Responsible for

Provides, operates, maintains, commissions, procures, funds, controls, or otherwise determines, in whole or in part, the use, content, or delivery of.

Should

Indicates a recommended course of action that should be followed unless there is a valid reason not to, and the implications of not following it are understood and considered.

Technically infeasible

A situation where there is no practical technical way to achieve conformance without fundamentally altering the product or service or making it unusable.

This applies where conformance cannot be achieved using reasonable and recognised technical approaches, even if enough money and time were available.

For example, some tools, like 3D maps, are purely visual. Right now, there is no way to make the 3D experience work for someone who is blind without changing the tool entirely.

Web page

A file downloaded from a single URI (Uniform Resource Identifier) using HTTP (Hypertext Transfer Protocol), along with any extra files needed to display it properly in a web browser.

Web pages include web applications, web services and single page applications.

Web pages also include any embedded content that is hosted on external, third-party platforms.

Most web pages are downloaded from a URL (Uniform Resource Locator) that starts with https://.

[Definition of web page in EN 301 549 v4.1.1]

Alternate formats

All the information about the DAS is available in the following formats:

Utility links and page information

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