About the Web Accessibility Standard

Note: This overview is informative only and does not constitute part of the New Zealand Government Web Accessibility Standard. It is subject to change without notice.

For help related to specific aspects of this Standard, refer to the guidance.

Context

Effective 01 July 2013, the New Zealand Government Web Accessibility Standard (the Standard) replaces the Technical section of the New Zealand Government Web Standards 2.0.

While the previous NZ Government Web Standards 2.0 combined both accessibility and non-accessibility requirements, the NZ Government Web Accessibility Standard includes only accessibility-specific requirements. Other requirements unrelated to accessibility have been included in the NZ Government Web Usability Standard. Having two separate standards helps to clarify the focus and application of each, and makes it easier to update each one as required.

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.

Other terms used in the Standard, e.g. 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 one principal requirement, namely that each web page within scope must meet all five of the Web Content Accessibility Guidelines (WCAG) 2.0 conformance requirements.

WCAG 2.0 conformance requirements

Briefly, the five conformance requirements are:

  1. Conformance Level — To meet this Standard, 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 Success Criteria. 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.
  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 at the specified conformance level.
  4. Only Accessibility-Supported Ways of Using Technologies — Technologies that are relied upon to meet WCAG:
    • are used in ways that are interoperable with users’ assistive technology; and,
    • are supported in a widely-distributed and accessibility-supported user agent or plug-in, or in an accessibility-supported user agent that is available for download/purchase 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 Flash 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 it in a non-scripted manner. For more on the concept of accessibility support and how this relates to what technologies can be relied on, see the guide, Accessibility supported technologies.

  5. Non-Interference — Technologies that are not relied on to meet WCAG do not interfere with users’ ability to access the rest of the page. Nor does the page as a whole fail to conform if a technology that is not relied on is turned on or off, or is not supported by, the user’s browser or assistive technology.

For a more detailed account of the conformance requirements, see Understanding Conformance Requirements.

Exceptions

The Standard includes some temporary exceptions to the application of certain WCAG 2.0 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, video, and synchronised media.

The specific exceptions are described in Section 3 of the Standard.

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 New Zealand’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 New Zealanders, including people with disabilities.

Scope

The Standard applies to two classes of web pages that are produced or maintained, in part or in whole, by New Zealand Government organisations to which this Standard applies:

  • publicly available web pages that can be accessed by individuals who are not employed by a NZ Government organisation subject to the Standard. This includes web pages that require users to authenticate themselves through some kind of login, e.g. a Government extranet that restricts access to specific non-Government organisations.
  • internally facing web pages that have been created, redesigned, or redeveloped since 01 July 2014, and that can be accessed only by individuals who are employed by a NZ Government organisation subject to the Standard. This includes web pages that are part of a Government organisation’s intranet.

Including internally facing web pages within the scope of the Standard is intended to help Government organisations build a work environment that is:

  • more open to the employment of people with disabilities, and
  • consistent 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, or standalone Adobe Flash files.

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.

Implementation

While the Standard applies to all the web pages defined above, not all web pages need to conform immediately or at the same time. Instead, an organisation’s web pages are to be made compliant according to a gradual four-year implementation schedule. Every year, an increasing number of web pages are required to conform. By 01 July 2017, all web pages must conform to the Standard.

This should enable more flexibility in the application of the Standard and help reduce costs by providing organisations an opportunity to:

  • align compliance to the Standard with their website development cycle; and
  • prioritise compliance and the remediation of web pages.

Schedule

There are different implementation schedules for publicly available web pages versus internally facing web pages. The schedule is as follows.

Web pages that must be made conforming
Phase Publicly available Internally facing
#1
July 2013 – June 2014
  • not applicable
#2
July 2014 – June 2015
  • every home page
  • every “Contact us” (or similar) web page
  • every web page delivering high-stakes information or services
  • the top 25% most visited web pages delivering core information or services
  • every web page created, redesigned, or redeveloped since 01 July 2014
  • every web page created, redesigned, or redeveloped since 01 July 2014
#3
July 2015 – June 2016
  • every home page
  • every “Contact us” (or similar) web page
  • every web page delivering high-stakes information or services
  • the top 50% most visited web pages delivering core information or services
  • every web page created, redesigned, or redeveloped since 01 July 2014
  • every web page created, redesigned, or redeveloped since 01 July 2014
#4
July 2016 – June 2017
  • all web pages
  • every web page created, redesigned, or redeveloped since 01 July 2014

Publicly available

Where publicly available web pages are concerned, those that need to be made compliant during the first year of the Standard’s implementation are:

  • every home page,
  • every “Contact us” (or similar) web page, and
  • every web page delivering high-stakes information or services.

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. See the Standard’s glossary for a more comprehensive definition of high-stakes.

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 is strongly recommended that they take the opportunity to get a head start on the following years’ implementation requirements.

Core information and services

All information and services that are not considered high-stakes are considered core information and services.

During the first year of the Standard’s implementation, the priority is web pages delivering high-stakes information and services. All other web pages (with the exception of home and contact us pages) do not need to be made conforming during that first year. However, by the end of the second year, on 30 June 2015, the top 25% most visited web pages delivering core information and services must meet the Standard. By the end of the third year, on 30 June 2016, 50% must comply, and by the end of the fourth year, on 30 June 2017, all publicly available web pages must meet the Standard.

Created, redesigned, or redeveloped since 01 July 2014

After the first year of the Standard’s implemention, any new page that is created, or any page that goes through a deliberate redesign or redevelopment project, must comply with the Standard. To prepare for this requirement, organisations should take the time during that first year to consider any necessary changes to internal systems and workflows that will help them to ensure that web pages created, redesigned, or redeveloped after 01 July 2014 will comply with the Standard.

Note that this does not include simple, impromptu, incidental, or minor changes that are not part of a broader project whose express aim is the redesign or redevelopment of the website or a major part of it. For example, fixing a typo or other mistake, making a small content update, no matter how important, or moving a widget from the right to the left of the page, do not, on their own, constitute the creation, redesign, or redevelopment of a web page.

See the glossary in the Standard for the formal definition of created, redesigned or redeveloped.

Internally facing

All internally facing web pages created, redesigned, or redeveloped since 01 July 2014 must meet the Standard. In other words, from 01 July 2013, organisations have a one year grace period, after which every new web page, or every page that is redesigned or redeveloped, must comply with the Standard.

Assuming that many or most organisations use web content management systems to produce their intranets, and will continue to use those systems to add new intranet pages after 30 June 2014, this gives them one year to modify their systems as necessary to enable the creation of web pages compliant with the Standard.

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.