Proposed changes to the Web Standards— Review 2018
The Web Standards are being revised to incorporate WCAG 2.1 and feedback from the Government Web Community—give your views on the proposed changes.
The recommended changes will help agencies create more usable websites and deliver more accessible experiences to:
- people with low vision
- people with reading, learning, or intellectual disabilities
- people who use mobile and touch-based devices, voice assistant and speech recognition software.
Have your say
The deadline for feedback is 5pm on Thursday 31 January 2019.
On this page
Two updated Web Standards are proposed: the Web Accessibility Standard 1.1, and Web Usability Standard 1.3. The revisions they contain reflect an underlying aim to keep changes to the current Standards' structure and requirements to a minimum. This was to enable some degree of consistency, continuity, interoperability, and backwards compatibility between them.
Accordingly, the suggested changes are an attempt to strike a balance between, on the one hand, not making too many changes, and on the other, making the Standards easier to understand, apply, and test against, as well as more reflective of current web technologies and their use by government and its different customers.
One benefit of this approach is that both of the proposed new Standards are backwards compatible. That is, a web page that conforms to the Web Accessibility Standard 1.1 already conforms to version 1.0 of the same Standard. Similarly, websites that meet version 1.3 of the Web Usability Standard automatically comply with version 1.2.
Some—admittedly few—words and phrases have been changed with the intention of improving readability or clarifying meaning, while leaving the substantive meaning of the term or passage unaffected. However, the language unfortunately remains relatively technical and difficult to understand. While this is something that should continue to be improved, some of the difficulty in the language reflects the nature of technical standards that need to describe in precise terms what each requirement means and how to apply and test it.
As a way to address this aspect of the Standards, more comprehensive companion guidance in plain language with examples of how to interpret and apply each Standard and requirement should be developed.
Implementation schedule removed
To make application of the Standards more straightforward, there is no implementation schedule: After a brief promulgation, it's proposed that the new Standards come into effect 1 July 2019, and become the Standards that websites are expected to meet.
It has been 8 years since WCAG 2.0 became a requirement for NZ Government websites. Based on the 2014 and 2017 Web Standards Self-Assessments, we know that, on average, NZ Government websites fail more than half the time to meet a number of basic accessibility requirements for images, content readability, and keyboard use. Transitioning over a short period to WCAG 2.1, which remains mostly made up of the current standard, WCAG 2.0, is not likely to have a notable impact on the government's levels of web accessibility. But it does offer agencies another opportunity to address any shortcomings they have meeting the Web Standards.
Clarify Cabinet mandate
Section 1.2 of each proposed Standard now notes that the agencies directed to apply the Web Standards are so obliged via Cabinet directive. This serves to clarify the source and meaning of this mandate for agencies.
Web applications are web pages, and sometimes websites
To address a longstanding confusion, the glossary definitions for "website" and "web page" more clearly note that they include things like web applications, web services, and single page applications.
All sites, produced or maintained, in part or in whole
That the Web Standards apply to websites produced or maintained, in part or in whole, by any mandated agency is currently hidden away in the glossary definitions for "publicly available" and "internally facing".
In the proposed Standards, this feature is brought forward from the glossary and into section 1.3 which sets out which types of website the Standard applies to.
Adopting WCAG 2.1
It is recommended that the Web Accessibility Standard be updated to require WCAG 2.1 Level AA. Released in June 2018 after several years in development by the W3C, WCAG 2.1 represents the latest version of the de facto international standard for web accessibility. WCAG has also served as the basis for the accessibility component of the NZ Government Web Standards in their various forms since 2003.
The New Zealand Government was the first in the world to formally adopt WCAG 2.0 in 2010. Moving to WCAG 2.1 would be a clear acknowledgement by the NZ Government of the need to maintain basic web accessibility requirements that are fit for purpose and better reflect not only current and future web technologies, but the changing needs and demographics of its customers.
What's new in WCAG 2.1?
The past 10 years have seen significant changes in technology, population demographics, and the ways we interact with the web. In response to these changes, and perceived gaps in the current version, the W3C released WCAG 2.1 in June 2018.
WCAG 2.1 includes new requirements to help ensure that web content is usable for people who:
- use touch interfaces (like smartphones and tablets, but also larger touch-enabled screens)
- have low vision
- have intellectual or learning disabilities
- use speech recognition software.
There are 17 new requirements in total, but only 12 that apply at the target AA conformance level, bringing to 50 the total number of requirements needed to meet WCAG 2.1 Level AA. These include requirements such as the following:
- 1.3.4 Orientation: Do not prevent content from displaying and working in mobile devices in both portrait and landscape modes. Websites pass this requirement by default: extra development work is required to fail it. Testing is straightforward: tilt a phone or tablet.
- 1.4.11 Non-text contrast: Not only text, but meaningful icons and graphics and interactive components like buttons must have sufficient contrast against their backgrounds to be easily seen. This requirement could introduce some additional testing time per page, but is a critical aspect of accessible design for anyone with diminished contrast vision or who might be viewing a screen in the bright sun.
- 1.4.12 Text-spacing: To help low vision users read text, certain features of text, such as the spaces between letters, words, lines of text, or paragraphs, must be changeable without losing any of the web page's content or functionality. There's an easy tool that in one click sets these different text settings allowing the tester to verify if there's been any loss of content or functionality.
- 2.5.1 Pointer gestures: If some functionality requires two or more fingers on the screen, or a particular path to be drawn on the screen, there's a way for users to perform the same function with a single finger and without having to follow a particular path.
In the short time since WCAG 2.1 was released in June 2018, the European Union has updated EN 301 549, its standard establishing accessibility requirements for information and communication technology (ICT) procured by the public sector. Web sites, services, and applications purchased by EU member states must now meet WCAG 2.1. The Australian Government has also adopted EN 301 549 (as AS EN 301 549).
Government web standards from around the world have been slow to take up WCAG 2.1, but it is early yet. And it is not unexpected, given that such standards are often part of a framework of legislation, policy, and business rules that can be slow to respond.
That said, since July 2018, the UK Government has set WCAG 2.1 Level AA as the basis for its accessibility requirements. While the Australian Government's Digital Service Standard still requires WCAG 2.0, the Digital Transformation Agency mentioned in August 2018 that it was testing its Design System and beta website against the new WCAG 2.1 requirements.
It is fully expected that the European Union, and countries like Australia and Canada, all of whose web standards refer to WCAG 2.0, will update them to point to WCAG 2.1.
WCAG 2.1 helps websites meet the needs of current and future users and their devices. It tells us how our web content and services can be made more accessible in the following contexts:
- touch interfaces, small devices, voice assistants, speech recognition
- people with low vision or intellectual disabilities
As the population ages, the numbers of people with low vision or learning/reading/memory difficulties are only growing.
More requirements, more work, more testing
Meeting the new requirements in WCAG 2.1 involves a bit more effort, but is generally not any more complicated than meeting WCAG 2.0. Meanwhile, the lost benefits in not addressing accessibility for the growing numbers of people addressed by the changes in 2.1 are potentially significant.
Of the 12 new requirements in WCAG 2.1, only a few lend themselves to automated testing. However, a majority of them can be reliably tested with a quick manual check. There are already free testing tools available for a few of them.
There are more requirements, so testing will cost more, but that cost will be marginal in almost all cases, and certainly reduce over time as implementer and tester knowledge and skill increase, and support or testing tools are developed.
Other changes: No more grace period for captions
The proposed changes to the Web Accessibility Standard include one other major change: The current exception in section 3.4 regarding the grace period for videos without captions is removed.
That exception gave agencies 10 business days to caption a video after publishing it online. It was set because in 2013 there remained notable cost and effort to providing captions for video. Today, with the online captioning services available, as well as relatively simple and free DIY methods suitable for captioning short videos, it is arguably easy and inexpensive enough to expect all prepared video to be published with captions at the same time.
There are a few more substantive changes proposed for the Web Usability Standard. These are described in more detail in the sections below.
Overall, the revised Web Usability Standard includes:
- a slight repositioning of the home page link requirements in the Contact information, Copyright, and Privacy statement sections for a more logical ordering
- minor clarifications to some glossary definitions, but none that modify or broaden the intended meaning of any term from its original definition in the 2013 Standard.
Otherwise, there were very few edits to the existing requirements, and only some very minor word changes for clarification or readability.
In the proposed changes to the Web Usability Standard, section 2.1 Home page has been renamed to "Government identity" to more clearly reflect its purpose, which is to ensure that the government agency or agencies primarily responsible for the website are identified, and that a link to the NZ Government's primary website, Govt.nz, is provided to more firmly brand the site as a NZ Government website.
The requirement to link to Govt.nz has been updated. It is proposed that website home pages include a link to www.govt.nz, and not to newzealand.govt.nz since that domain no longer exists.
A new requirement to use a suitable all-of-government logo, such as the common “New Zealand Government” or “Te Kāwanatanga o Aotearoa” logos from SSC, for the link to Govt.nz has also been added. However, it remains a "should" (as opposed to a stronger "must") requirement because the SSC All-of-Government branding guidelines have not been updated since 2011. SSC is working on the creation of a new all-of-government brand, but this will not be released for another 18 months.
In the current Web Usability Standard, the Contact information requirements in section 2.2 refer to the "Contact Us Page" that each website needs to link to. To remove any impression that the contact information needs to exist as its own web page, the requirements in this section now refer to the "Contact Information" that each website needs to include or link to. This should also make it easier for websites of different types to meet the Contact information requirements, or reuse the contact information on another website.
Section 2.2.2 in the current Standard has been removed since it is redundant, simply adding another requirement that prescribes in unnecessary detail what is already required by section 2.2.1. It is considered safe to remove this as it does not involve any legal considerations like the requirements for copyright and privacy statements do.
Some requirements now apply to all websites
In one of the major changes proposed for this Standard, the Links to Non-HTML files and Printable pages requirements now apply to all public facing and internally facing websites. These two requirements represent basic accommodations to improve usability for a general audience. For some of the same common sense reasons that the accessibility standards apply to internally facing websites, it is reasonable to provide all government employees and contractors these same usability accommodations.
New, explicit usability requirement
The most significant change proposed for the Web Usability Standard is the addition of an explicit usability-related requirement around researching, setting and testing user needs.
That the Web Usability Standard does not include any usability requirements as they are typically understood is a common complaint. One reason for the lack of such usability requirements is that they are difficult to reliably test, or to write in a meaningful way that clearly translates into specific, unambiguous, testable outcomes.
The new requirement falls under section 3.1 User needs research and testing. It requires that agencies be able to produce evidence of:
- the research they have done to identify and understand the website's users and their needs
- the testing with users they've done throughout the design and delivery of the website.
It is a cornerstone of usability that a site needs to be designed and built for, and tested by, its users. The proposed requirement aligns with Principle 1, Identify your users and understand their ongoing needs, from the Digital Service Design Standard. It is expected to have a positive impact on the way that agencies approach the delivery of quality, usable websites. (It additionally makes the Standard a real usability standard in more than name only.)
It is a "must" requirement (as opposed to "should") because any website built is expected to have some user research and testing behind it to make the investment fit for purpose. The requirement also applies to both public facing and internally facing sites, as both involve an investment of public funds in a website for use by people.
The new requirement is testable, in that it requires agencies be able to demonstrate (the measure that is used can be established at the time of assessment) some research and testing artefacts. While it doesn't set any specific kind or amount of user research and testing that an agency must do, it does challenge agencies to consider and investigate the website's users and their needs.
The review of the Web Standards was partly informed by a consultation with the New Zealand Government Web Standards Reference Group and the NZ Government Web Community Yammer group.
The Reference Group is an email discussion group made up of central and local government employees, vendors, and members of the disability community with an interest in the Government Web Standards and web accessibility.
The Yammer group, restricted to government employees and contractors, effectively serves as the all-of-government online forum for discussions about using the web in delivering government.
Between 16 and 31 October 2018, the Reference and Yammer groups were invited to submit responses to the following questions:
Web Accessibility Standard
- Should the Web Accessibility Standard adopt the latest Level A and AA requirements from WCAG 2.1?
- What aspects of the current Web Accessibility Standard 1.0 do you find problematic, and why?
- What other changes to the Web Accessibility Standard would you like to see, and why?
Web Usability Standard
- What aspects of the current Web Usability Standard 1.2 do you find problematic, and why?
- What other changes to the Web Usability Standard would you like to see, and why?
- What changes, if any, would you like to see regarding the Web Standards generally, and why?
The feedback received from respondents in almost all cases echoed comments that have been raised previously—and repeatedly—since 2013 in different government communities and forums. It includes emails to the Government Web Standards mailbox.
Participants' responses are summarised below.
Web Accessibility Standard
All responses to the question of adopting WCAG 2.1 were positive. However, a number of issues and recommendations regarding the Web Accessibility Standard were expressed:
- Some respondents noted that questions around the publication and accessibility of non-HTML document formats, in particular PDF and MS Word, continue to be of concern.
- A few respondents expressly noted a lack of Web Standards skill and understanding in the industry.
- 1 respondent asked for better advice and clarity on captions and transcripts for videos, particularly in regards to NZSL videos. Questions regarding captions and transcripts to the Government's Web Standards mailbox are common.
These 3 issues and recommendations are reasonable, but are best addressed through practical interventions as part of a programme of support and guidance.
Meanwhile, two other requests from respondents have been addressed to some degree by changes suggested to the Standard:
- make it clearer that the Web Accessibility Standard applies to internally facing web applications.
- make the Standard easier to understand and use.
Web Usability Standard
A wider range of comments were provided regarding the Web Usability Standard.
The following comments have been addressed to varying degrees in the proposed changes to the Standard.
- The Web Usability Standard should include some explicit usability-related requirements. It currently doesn't, making its name misleading. This is not an uncommon concern or recommendation.
- Make the requirement to provide contact details more flexible and easier to apply across different contexts.
- Apply the requirements regarding links to non-HTML files and printable web pages to internally facing sites as well as public-facing sites.
- Provide clearer direction regarding the requirement for a link to Govt.nz on a website's home page.
Another few comments make good recommendations for future supporting guidance:
- Provide greater clarity around what is required in terms of copyright and use of Creative Commons. One respondent suggested something like an umbrella government copyright statement that individual agencies could expand on, and that it would be good to have some statement in general that applies to all agencies to make it easier for agencies and the public. Even if a base copyright statement that applies across all agencies is not possible, one or more exemplars or base templates would be helpful for agencies.
- Update the privacy statement requirements to account for updated international privacy policies and the General Data Protection Regulation (GDPR). This could be addressed sufficiently through additional guidance about how to meet any GDPR obligations.
A number of general comments about the Web Standards overall were received.
A number of respondents were positive about the idea of making the Web Standards mandatory for local government agencies, and District Health Boards (DHBs) especially, if not all government-funded bodies. This would involve a change to a Cabinet decision, and is outside the scope of this review
Two other comments should be addressed through a future programme of support and guidance:
- The Government needs to put more weight and resource behind the Web Standards.
- Guidance on accessibility issues should prioritise those that are most problematic to people (based on real feedback from the community).
One respondent requested that both Standards be clearer about their application to partnership sites, or sites where the NZ Government is not the only investor or contributor. Both Standards have always applied to such sites, but this has been made clearer in the proposed revisions.