Short and long-term plans for the Web Standards

The GCDO has plans for 2 rounds of changes to the Web Standards:

1. Long-term plans — It’s proposed that, starting in the 2025 to 2026 financial year, the Web Accessibility Standard be turned into a Digital Accessibility Standard. This new standard would address the accessibility of all digital content procured, produced and used by a much greater number of government organisations than the current Web Accessibility Standard. For more information, see The broader context: A future Digital Accessibility Standard below.
2. Short-term plans — Immediate changes to the Web Standards are being proposed this year to keep them up to date and make them easier to understand. These are the changes we’re seeking your feedback on now. For details on these short-term changes, see Interim updates to the Web Standards below.

Review the draft Web Standards

The following draft Web Standards include all the changes being proposed at this time:

• Web Accessibility Standard 1.2 — Draft
• Web Usability Standard 1.4 — Draft

The broader context: A future Digital Accessibility Standard

There’s a reasonable expectation that all publicly funded NZ government digital content and services will be accessible, that is, usable by disabled people, who make up almost a quarter (24%) of New Zealanders. This expectation is set by the:

• Human Rights Act 1993
• Bill of Rights Act 1990
• UN Convention on the Rights of Persons with Disabilities (UNCRPD), which New Zealand ratified in 2008.

To better meet this expectation, the GCDO is proposing to turn the Web Accessibility Standard into a Digital Accessibility Standard that extends:

• accessibility requirements to all digital content and services, including non-web office documents, native mobile applications and desktop software
• the Web Standards mandate to potentially include all entities subject to a direction as a group under sections 107(2) and 107(2A) of the Crown Entities Act 2004. The Web Standards mandate currently includes only Public Service Departments and non-Public Service Departments in the Executive branch.

Timeline

The Digital Accessibility Standard is proposed as part of the Service Modernisation programme for the 2025 to 2026 fiscal year. If approved, it could be a few years before a Digital Accessibility Standard comes into effect.

Interim updates to the Web Standards

In the meantime, to keep the Web Standards current with international standards and fit for purpose for the New Zealand context, as well as to improve their readability and ease of implementation, the following updates to the Web Standards are proposed right now:

• align the Web Accessibility Standard to the latest Web Content Accessibility Guidelines (WCAG) 2.2 and remove exceptions to WCAG that are no longer needed
• update the contact information requirements in the Web Usability Standard to address the public’s ongoing need for non-digital access to government information and services
• update the privacy statement requirements in the Web Usability Standard to better meet the Privacy Act 2020
• update the requirements for what content must, should and should not be included when printing a web page
• apply a variety of editorial changes to improve readability and ease of implementation.

It’s these changes that we’re seeking your feedback on.

The proposed interim changes in detail

The interim changes proposed for the Web Standards include both editorial and substantive updates. The editorial updates are to improve readability and ease of implementation. Some of these changes are recommendations from the Ministry of Social Development (MSD) Accelerating Accessibility programme, part of which involved applying the Ministry of Business, Innovation and Employment (MBIE) Better Rules approach to the Web Standards.

The substantive updates to the Standards are described in what follows. The editorial changes are not listed.

Changes common to both Web Standards

1. To clarify the 2 types of relationships an organisation can have with a website, 2 new terms have been defined:
   • ‘responsible for’ — means most legally accountable for the website or web page in question
   • ‘contributes to’ — means participates in the creation, production or maintenance of, but is not most legally accountable for, the website or web page in question.

   The new Web Accessibility Standard applies to web pages that a mandated organisation is responsible for or contributes to. The Web Usability Standard applies just to websites that the organisation is responsible for.

   In both current Web Standards, the requirements apply only to those websites or web pages that are “produced or maintained, in part or in whole,” by the mandated organisation.

2. Some requirements in the Web Standards apply only to publicly facing websites. To clarify this distinction, ‘publicly facing’ (previously ‘public facing’) now refers to websites and webpages that can be accessed by members of the general public and people who are not employees, staff, or authorised personnel of a New Zealand Government public sector organisation.

   This includes a website or web page behind a login authentication process that controls access by members of the general public or people who are not employees, staff, or authorised personnel of a New Zealand government public sector organisation.

   Examples of publicly-facing websites include an:

   • organisation’s corporate website
   • extranet for liaising with service providers.

   The definition of ‘public facing’ in the current Standards refers only to people who are not employed by the mandated organisation.

3. Some requirements in the Web Standards also apply to internally facing websites. The definition of ‘internally facing’ now refers to websites and web pages that can be accessed only by people who are employees, staff, or authorised personnel of a New Zealand Government public sector organisation.

   For example, an intranet is an internally facing website.

   The definition of ‘internally facing’ in the current Standards refers only to people who are employed by the mandated organisation.

4. Archived web pages are exempt from some Web Standards requirements. The definition of ‘archived web page’ now includes the following additional traits:
   • no longer needed for active administrative purposes
   • neither modified nor updated after the date of archiving.
5. The assessment and reporting requirements are now clearer, in their own section, and include these newly defined terms:
   • assess — in the context of conformance, assess means to determine the rate, level or amount of conformance to a given standard, guideline, or specification
   • risk assessment — an evaluation of the potential risks of non-conformance with a standard’s requirements
   • risk management plan — a plan to mitigate the potential risks of non-conformance with a standard’s requirements.

Changes specific to the Web Accessibility Standard 1.2

6. The Web Content Accessibility Guidelines (WCAG) that form the basis of the Web Accessibility Standard were updated to version 2.2 in October 2023. To stay current with the latest WCAG, the Web Accessibility Standard now requires that web pages meet the Web Content Accessibility Guidelines (WCAG) 2.2 at Level AA, whereas the current Standard requires WCAG 2.1 at Level AA.
7. Each mandated organisation must report on the conformance of web pages it’s responsible for and describe its efforts to ensure the conformance of web pages it contributes to.
8. As is the case in the current Standard, complex visual maps still do not require a text alternative that serves the equivalent purpose, but the definition of ‘complex visual map’ has been rewritten. It now refers to a graphical map that’s:
   • used to convey a large amount of information, and
   • detailed to the extent that creating a reasonably usable text alternative becomes practically impossible.

   Examples of a complex visual map include a:

   • topographic map that uses contour lines to represent the terrain elevations for a specific land area
   • weather map showing meteorological features, such as the barometric pressures or the median annual rainfall, across a specific region
   • network map showing all the devices connected to the internet in Aotearoa New Zealand.

   The full definition of complex visual map includes more information and examples.

9. The low cost and high availability of captioning services means that captions are now required for all live video, and not just live video that delivers high-stakes information or services.
10. The availability of audio description services keeps increasing. However, while the cost of audio description keeps going down, it remains relatively high at a minimum of around NZD$16 per minute. In the current Standard, only videos delivering high-stakes information or services must have audio description. That remains the case in the new Standard, but there’s now an additional requirement that all video should have audio description.

Changes specific to the Web Usability Standard 1.4

11. Principle 4 of the Digital Service Design Standard, as well as the Face to Face with Digital Exclusion (PDF 3.1MB) report from the Citizens Advice Bureaux New Zealand, establish the ongoing need for offline channels where people can engage with government organisations face-to-face or person-to-person over the phone.

    To help agencies deliver on this need, a website’s contact information must now include all of the following for the mandated organisation responsible for the website:

    • an email address monitored daily during business hours and to which emails received are acknowledged within 3 business days indicating the timeframe that a full response can be expected
    • a postal address monitored daily during business hours
    • a physical street address open to the public during business hours, if one exists
    • the number of a monitored telephone line available during business hours
    • the telephone number for each call centre that supports a service provided by the website, and
    • a link to the New Zealand Relay Service (NZ Relay) for people who are deaf or hard of hearing, deafblind, or who’ve a speech-impairment.

    Currently, the contact information only needs to include a regularly monitored:

    • email address
    • phone number for each call centre that supports a service provided by the website
    • postal address.
12. Mandated organisations must meet legal requirements of the Privacy Act 2020 to provide transparent and detailed notice of their collection, use, and storage of personal information. 

    To support this, there are now 2 types of privacy statement that each website must provide access to:

    • Organisation Privacy Statement — this addresses all the ways, across all channels, that the mandated organisation collects and uses personal information. This statement can live on the website in question, or on another website that the mandated organisation is responsible for.
    • Website Privacy Statement — this addresses all the ways that personal information is collected through the website in question and how it’s used. The Website Privacy Statement must either be part of the Organisation Privacy Statement or link to it.
13. According to the current Standard, the main content of a web page must be printable in its entirety on standard sheets of paper. In the new Standard, the main content should be printable in its entirety on A4 size paper. The new requirement:
    • specifies A4 size paper to clarify what’s meant by ‘standard sheets of paper’
    • changes the ‘must’ to a ‘should’ to acknowledge that some main content — for example, a complex, interactive data visualisation — cannot reasonably be printed in its entirety on sheets of A4 paper.

    In the Standard, ‘should’ means that unless there are good reasons for ignoring a requirement, and the full implications of doing so are considered and weighed beforehand, the requirement must be followed. In other words, unless there are valid reasons that the main content of a web page should not or cannot be printed in its entirety, and the impact of that’s been fully considered, the main content needs to be printable in its entirety. To do otherwise would fail to meet the requirement.

    Other changes to the requirements for printed web pages include:

    • removing breadcrumbs from the list of content that should not be printed by default, and
    • recommending that the following information should be included in the printed page:
      • web page’s complete URL
      • web page’s title as specified in the HTML
      • name of the Mandated Organisation
      • copyright notice.

Consultation questions

We’re happy to receive any feedback you have on these proposed changes to the Web Standards, but we’re especially interested in responses to the following questions.

General questions

1. Are the definitions of ‘responsible for’ and ‘contributes to’ clear? Do they help identify and distinguish those websites that an organisation is responsible for as opposed to those it simply contributes to?
2. Are the definitions of ‘publicly facing’ and ‘internally facing’ clear? Do they help distinguish between these 2 types of website?

Web Accessibility Standard

3. All live videos must now be captioned. Do you agree with this change?
4. Videos that do not deliver high-stakes information or services remain exempt from the requirement to include audio description. However, it’s recommended that all videos should have audio description. Do you agree, or should all videos be required without exception to have audio description? Keep in mind that audio description costs between NZD$15 and NZD$50 per minute of video.
5. Should websites be required to have an accessibility statement that:
   • identifies how well the site conforms to WCAG
   • identifies and describes in plain language the non-compliant content on the site and its potential impact on users
   • provides a contact method for people to get in touch with the site owner about non-compliant content and how to get accessible versions of that content?
6. What aspects of the current Web Accessibility Standard 1.1 do you find problematic, and why?
7. What kind of support, training or guidance would help NZ Government organisations meet the new Web Accessibility Standard, especially WCAG 2.2?
8. What other changes to the Web Accessibility Standard would you like to see, and why? Note that we might not be able to implement any changes you propose, but your feedback will inform our discussions on the future of the Web Standards.

Web Usability Standard

9. Do you have any concerns with the new contact information requirements to include a phone number and a physical office location, if one exists?
10. Each website must now provide access to an Organisation Privacy Statement and a Website Privacy Statement. Is it clear what each of these statements must include and where they need to live?
11. Do you agree with the changes to the requirements around what content should and should not be included when printing a web page?
12. What aspects of the current Web Usability Standard 1.3 do you find problematic, and why?
13. What other changes to the Web Usability Standard would you like to see, and why? Note that we might not be able to implement any changes you propose, but your feedback will inform our discussions on the future of the Web Standards.

More information

If you’ve any questions or would like more information about the proposed changes to the Web Standards, please email web.standards@dia.govt.nz.