Context

Effective 01 July 2019, the New Zealand Government Web Accessibility Standard 1.1 (the Standard) replaces the Web Accessibility Standard 1.0.

Version 1.0 of the Web Accessibility Standard required that web pages meet the Web Content Accessibility Guidelines (WCAG) 2.0. Version 1.1 of the Standard requires conformance to WCAG 2.1, which will help agencies deliver more accessible experiences to people:

• with low vision
• with reading, learning or intellectual disabilities
• who use mobile and touch-based devices, voice assistant and speech recognition software.

The Web Accessibility Standard 1.0 included a graduated implementation schedule that gave NZ Government organisations 4 years to fully meet the Standard for all their web pages. By contrast, there is no implementation schedule in version 1.1 of the Standard which, as of 01 July 2019, applies with immediate effect to all relevant web pages.

Terminology

The keywords ‘must’, ‘should’ and ‘should not’ used in the Standard signify different types of requirements as defined by RFC 2119:

• ‘must’ signifies that the defined course of action is absolutely required
• ‘must not’ defines a course of action that must absolutely be avoided
• ‘should’ defines a recommended course of action that may be ignored as long as the full implications of doing so are clearly understood and the organisation is prepared to accept them.

RFC 2119

Other terms used in the Standard, for example web page, archived web page, website, main content, also have specific meanings, all of which are defined in the Standard's glossary.

What’s required

The Standard contains 1 principal requirement, namely that each web page within scope must meet the Web Content Accessibility Guidelines (WCAG) 2.1 at level AA (subject to a few exceptions).

WCAG 2.1

Conformance requirements

In turn, adhering to WCAG 2.1 means fulfilling its 5 conformance requirements.

• WCAG 2.1 conformance requirements
• Understanding conformance

1. Conformance level

Each web page must satisfy all of the level A and level AA success criteria, subject to a few exceptions as described below.

2. Full pages

Only full pages can conform to WCAG requirements. If part of a web page is excluded from the assessment, conformance cannot be achieved for that page. In some cases, where content on a page is not under the organisation’s control, a statement of partial conformance can be made. Note that all the other parts of such a web page still need to conform.

Making statements of partial conformance

3. Complete processes

For web pages that are part of a process, all of the web pages that are part of that process must conform to WCAG 2.1 at level AA.

4. Only accessibility-supported ways of using technologies

Technologies that are relied on to meet WCAG are:

• used in ways that are interoperable with users’ assistive technology, and

• supported in a widely-distributed and accessibility-supported user agent or plug-in, or in an accessibility-supported user agent that can be downloaded or purchased in a way that does not cost a person with a disability any more than a person without a disability and is as easy to find and obtain for a person with a disability as it is for a person without disabilities.

This translates, at least for the time being, into a general requirement that content delivered in PDF or Microsoft Word must be accompanied by an accessible alternative. It equally permits websites to use and rely on JavaScript for delivering content and functionality without having to duplicate that content and functionality in a non JavaScript dependent manner. 

• Understanding accessibility support
• Accessibility supported technologies

5. Non-interference

If technologies that are not accessibility supported are used, they must not interfere with users’ ability to access the rest of the page. At the same time, if a web page uses a technology that is not relied on or that is not supported by the user’s browser or assistive technology, turning that technology on or off must not impact the web page’s conformance to WCAG 2.1 at Level AA.

Exceptions

The Standard includes some temporary exceptions to the application of certain WCAG 2.1 success criteria. These exceptions, to be reviewed annually, are designed to acknowledge various resource constraints experienced by organisations, while helping to ensure, in a practical and cost-effective manner, that online information and services are accessible. The current exceptions relate to the use of complex visual maps, audio and video media.

Exceptions to WCAG 2.1 under the Web Accessibility Standard 1.1

Mandated organisations

Based on a 2003 mandate established by Cabinet (Cabinet Minute (03)41/2B), all Public Service departments and Non-Public Service departments in the State Services are directed to implement the Standard.

Other State sector organisations are not required to implement the Standard, but are strongly encouraged to do so. By virtue of the legislation (i.e. Human Rights Act 1993, Bill of Rights Act 1990) and NZ’s ratification of the United Nations Convention on the Rights of Persons with Disabilities that underlie the requirement for mandated organisations to produce accessible websites, there is a reasonable expectation that the websites of all government organisations will be accessible to the widest range of NZers, including disabled people.

United Nations Convention on the rights of Persons with Disabilities

Scope

The Standard applies to web pages that are produced or maintained, in part or in whole, by NZ Government organisations mandated to apply the Standard. It applies to both public facing and internally facing web pages.

Public facing web pages can be accessed by individuals who are not employed by a NZ Government organisation. This includes web pages that require users to authenticate themselves through some kind of login, for example a government extranet that restricts access to specific non-government organisations.

Internally facing web pages can be accessed only by individuals who are employed by a NZ Government organisation. This includes web pages that are part of a government organisation’s intranet.

Internally facing web pages are subject to the Standard in order to help government organisations:

• employ and support staff with disabilities, and
• align with provisions generally accepted as necessary for the fair and proper treatment of employees, as identified in section 77A of the State Sector Act 1998.

Note that the definition of web page used in this Standard includes what are typically referred to as web applications, but also resources such as MS Word and PDF documents.

Definition of web page

Archived web pages

The one exception to the above is archived web pages. For the purposes of this Standard, an archived web page is one that remains available on a website for reference purposes, but whose main content is not maintained or updated. An archived web page’s main content must be clearly marked as archived and include accessible instructions on how a user can request an accessible version of its content.

Website owners are strongly encouraged to audit their site’s content to identify those web pages that contain redundant, out-of-date, or trivial content. In most cases, such pages should be either updated or removed from the website. However, in some instances there may be value in retaining them on the website, but not in maintaining or updating them, in which case they must be marked as archived web pages.

High-stakes information and services

High-stakes information and services are those whose inaccessibility at the time of publication could reasonably be expected to have a negative impact on an individual’s emergency preparedness and response, health and safety, critical citizenship rights, entitlements and services.

Definition of high-stakes information and services

The definition of high-stakes information and services is informed by the Human Rights Commission’s report, Better information for Everyone, and the results from an online survey of disability groups as part of the 2011 review of the NZ Government Web Standards 2.0.

In the first year of the Standard’s implementation, government organisations will be able to prioritise their efforts to meet the Standard by focussing on fixing web pages that feature high-stakes information and services. If an organisation has few or no web pages delivering high-stakes content, it‘s strongly recommended that they take the opportunity to get a head start on the following years’ implementation requirements.

Exemptions

There is no process by which a mandated organisation can secure an exemption from the requirement to meet the Standard. Instead, each organisation is responsible for meeting the Standard, and accordingly accepts any risks associated with not doing so.

Assessment and reporting

Organisations must be prepared, when notified, to assess and report within a reasonable time frame on their conformance with the Standard. The assessment methodology and reporting mechanism will be communicated to organisations at the time of notification.

In the case that an organisation does not fully meet the Standard, it will be required to manage any risk associated with that lack of conformance by performing a risk assessment and submitting a plan to address, over time, those areas of non-conformance.