About the Web Accessibility Standard 1.2
This overview is informative only and does not constitute part of the New Zealand Government Web Accessibility Standard. It’s subject to change without notice.
Context
Effective , the New Zealand Government Web Accessibility Standard 1.2 (the Standard) replaces the Web Accessibility Standard 1.1.
Version 1.1 of the Web Accessibility Standard required that web pages meet the Web Content Accessibility Guidelines (WCAG) 2.1. Version 1.2 of the Standard requires conformance to WCAG 2.2, which will help agencies deliver more accessible experiences to disabled people.
For an account of all the substantive changes in the Web Accessibility Standard 1.2, see Web Standards effective from .
Mandated organisations
Based on a mandate established by Cabinet, all Public Service departments, the Defence Force, the Police, and the Parliamentary Counsel Office are directed to implement the Standard.
Cabinet Minute (03)41/2B — New Zealand Government Web Guidelines: Mandatory Requirements
Public Service departments — Te Kawa Mataaho
Other public sector and local government organisations are not required to implement the Standard, but are encouraged to do so.
There’s a reasonable expectation that the websites of all public sector organisations will be accessible to the widest range of New Zealanders, including disabled people. This is due to:
- the Human Rights Act
- the Bill of Rights Act , and
- NZ’s ratification of the United Nations Convention on the Rights of Persons with Disabilities.
United Nations Convention on the rights of Persons with Disabilities
Terminology
The keywords ‘must’ and ‘should’ 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
- ‘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, for example web page, inactive web page (previously archived web page), website, main content, also have specific meanings, all of which are defined in the Web Accessibility Standard’s glossary.
What’s required
The Standard contains 1 principal requirement, namely that each web page within scope must meet WCAG 2.2 at level AA (subject to a few exceptions).
WCAG conformance requirements
Adhering to WCAG 2.2 means fulfilling its 5 conformance requirements.
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 — W3C
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 2.2 at level AA.
4. Only accessibility-supported ways of using technologies
Technologies that are relied on to meet WCAG are:
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used in ways that are interoperable with users’ assistive technology, and
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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.
Understanding accessibility support — W3C
Accessibility supported technologies — NZ Government Web Accessibility Guide
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.
Publishing PDF and office documents — NZ Government Web Accessibility Guide
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’s not relied on or that’s 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 2.2 at Level AA.
Exceptions
The Standard includes some exceptions to the application of certain WCAG 2.2 success criteria. These exceptions are designed to acknowledge various fiscal, technical and capability constraints experienced by organisations, while helping to ensure that online information and services are accessible. The current exceptions relate to the use of complex visual maps and some audio and video media.
Exceptions to WCAG 2.2 under the Web Accessibility Standard 1.2
Complex visual maps
Complex visual maps are graphical maps used to convey a large amount of information, and detailed to the extent that creating a usable text alternative is impractical. As such, they are exempt from WCAG success criterion 1.1.1 Non-text content and do not require a text alternative that serves the equivalent purpose.
Full definition of complex visual map
Audio description and live captioning
A few exceptions apply to WCAG requirements around audio and video. The 2 notable exceptions are that:
- captions should be provided for live video, but must be provided for live video that includes high-stakes information or services where the equivalent information or services are not simultaneously published as text
- audio description should be provided for all prerecorded video published on or after , but must be provided for prerecorded video that includes high-stakes information or services.
A ‘should’ requirement is not optional, but a requirement that must be met unless there are valid reasons not to and the impact of that decision has been considered. Organisations that deliver video will need to start, if they haven’t already, planning and budgeting for both captioning and audio description.
2 things to note with regard to these exceptions are that, as far as WCAG is concerned:
- live video means video broadcast and not 2-way multimedia calls between 2 or more people through web applications or services like Zoom or Microsoft Teams. In the latter scenario, the host caller is responsible for providing captions if required by any participants.
- only ‘standard audio description’ is required where the descriptive narration is added during existing pauses in the video’s dialogue. If there are no existing pauses, then no standard audio description can be provided. Also note that in a well-planned video, the speakers in the video will describe in the main audio track all meaningful visual information, making audio description unnecessary.
Plan for audio description of visual information — storyboarding, recording — W3C
Scope
The Web Accessibility Standard applies to publicly facing and internally facing web pages that a mandated government organisation is responsible for.
Publicly facing
Publicly facing web pages can be accessed by members of the general public or people who are not employees, staff or authorised paid personnel of a NZ government public sector organisation. This includes web pages that require users to authenticate themselves through some kind of login, for example an extranet for liaising with service providers.
Internally facing
Internally facing web pages can be accessed only by people who are employees, staff or authorised paid personnel of a NZ government public sector organisation. This includes web pages that are part of a government organisation’s intranet or web-based document management system.
Internally facing web pages are subject to the Standard in order to help government organisations:
- employ and support disabled staff, and
- align with provisions generally accepted as necessary for the fair and proper treatment of employees, as identified in section 73(3) of the Public Service Act .
Public Service Act — New Zealand Legislation
Web apps and office documents
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 Microsoft Word and PDF documents.
Pages that an organisation simply contributes to
The 2003 Cabinet Minute is the formal mechanism that established the Standards and their scope of application. That scope does not include any website that a mandated organisation contributes to in some way.
It’s recommended that mandated organisations take deliberate steps to ensure the websites to which they make substantive contributions are produced and/or maintained to meet the Standards.
Inactive web pages
Inactive web pages do not need to meet WCAG. An inactive web page (‘archived web page’ in the previous version of the Standard) is one that remains available on a website for reference purposes, but whose main content is no longer needed for active administration purposes and is no longer updated or modified.
An inactive web page’s main content must be clearly marked as inactive or 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 inactive web pages.
High-stakes information or services
High-stakes information or services are those whose inaccessibility at the time of publication could reasonably be expected to have a negative impact on a disabled person’s emergency preparedness and response, health and safety, critical citizenship rights, entitlements and services.
Definition of high-stakes information or services
The definition of high-stakes information or services is informed by the Human Rights Commission’s report, and can help government organisations prioritise their efforts to meet the Standard by focusing on fixing web pages that feature high-stakes information or services.
What qualifies as high-stakes information or services is to some degree up to the mandated organisation to decide. Where the content in question is only made available to a disabled person a day or 2 after being made available to non-disabled people, how will that disabled person be disadvantaged with respect to the scenarios listed in the definition.
Note that internally facing web content can also be considered high-stakes information or services, for example, content related to a structural reorganisation and positions open to affected staff.
Third party content and widgets
Third-party content widgets that are not funded, developed or controlled by a mandated agency, do not need to meet the Standard. However, third-party content or widgets that a mandated agency has made the decision to use on its website are expected to meet the Standard.
For example, if a mandated organisation embeds on its web page a video from another website, that video as well as the player used to show it, must meet the Standard, as the organisation controls the decision to use and publish that content.
Captions and accuracy
Currently, automated captions are not accurate enough to rely on. Some degree of human intervention is necessary to ensure that captions are accurate. The industry standard is 99% accuracy for captions, including spelling, grammar and punctuation. In some cases, a single incorrect word or poorly placed comma can significantly change the meaning of a caption.
Free and paid services are available for creating accurate captions.
How to create closed captions — NZ Government Web Accessibility Guide
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 accepts the risks associated with not doing so.
Assessment and reporting
Mandated organisations must be prepared, when notified by the Government Chief Digital Officer (GCDO), to assess and report on how their web pages conform 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.
Utility links and page information
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