Chapter 3 | Standards and Guidelines on digital accessibility

Contents

• Introduction
• W3C Standards
• Australian Standards
• Australian Government standards
• State Government requirements
• Industry requirements
• Additional Guidance

Introduction

This Chapter includes brief summaries of technical standards and guidance mentioned in the Guidelines. As explained in the Guidelines, the Disability Discrimination Act requires that providers of goods and services do not discriminate against persons with disability. The technical standards and guidance described in this document will assist those developing digital products to meet this requirement.

The versions of the listed standards and guidelines are current as of February 2025; newer versions can be released at any time and should be used when available.

W3C Standards

The W3C Guidelines and Technical Reports are the international standards for the web and mobile apps.

Web Content Accessibility Guidelines (WCAG)

The latest version is WCAG 2.2 (released in October 2023).

Organisations should conform with WCAG 2.2 at a minimum Level AA and consider appropriate Level AAA success criteria such as video transcripts, audio contrast, clear links and section headings.

The Web Content Accessibility Guidelines (WCAG) are an internationally recognised set of recommendations for improving web accessibility. They explain how to make digital services, websites and apps accessible to everyone.

Australia has followed the Worldwide Web Consortium (W3C) Web Content Accessibility Guidelines (WCAG)^[29] since the first version was released in 1999. The applicability of WCAG under the Disability Discrimination Act was upheld in the Commission’s decision Maguire v Sydney Organising Committee for the Olympic Games (No 2) [2000] HREOCA 31 (24 August 2000).

WCAG is the accepted international standard for web accessibility; it also applies to non-web documents, apps, software and digital interfaces. WCAG has been updated several times since 1999 and is required by government and non-government sectors alike.

WCAG 2.2 has four principles – web services need to be:

Conformance with WCAG 2.2 requires that ‘all Web pages in the process conform at the specified level or better’ and that ‘only accessibility-supported ways of using technologies are relied upon to satisfy the success criteria’.

WCAG has several supporting documents to help understand the criteria and apply potential techniques.

Authoring Tool Accessibility Guidelines (ATAG)

The latest version is ATAG 2.0 (released in September 2015).

Organisations creating tools that allow for user contributions should conform with ATAG 2.0 applying WCAG 2.2 instead of WCAG 2.0 as appropriate.

Authoring tools are software and services that “authors” (web developers, designers, writers, etc.) use to produce web content (static web pages, dynamic web applications, social media posts, etc.). Authoring Tool Accessibility Guidelines (ATAG) explains how to:

• make the authoring tools themselves accessible, so that people with disability can create web content, and
• help authors create more accessible web content, specifically enable, support, and promote the production of content that conforms to WCAG.

Accessible Rich Internet Applications (WAI-ARIA)

The latest version is WAI ARIA 1.2 (released in June 2023).

Organisations should use WAI ARIA appropriately for complex web applications.

WAI-ARIA, the Accessible Rich Internet Applications Suite, defines a way to make web content applications more accessible to people with disability. It especially helps with dynamic content and advanced user interface controls developed with HTML, JavaScript, and related technologies. Without WAI-ARIA, certain functionality used in Web sites is not available to some users with disability, especially people who rely on screen readers and people who cannot use a mouse. WAI-ARIA addresses this inaccessibility, for example, by defining ways for functionality to be provided to assistive technology. With WAI-ARIA, developers can make advanced Web applications accessible and usable to people with disability.

To support WAI ARIA, the W3C have also published the ARIA Authoring Practices Guide (APG) which recommends approaches to help web application developers make widgets, navigation, and behaviours accessible using WAI-ARIA roles, states, and properties. This guide describes considerations that might not be evident to most authors from the WAI-ARIA specification, which is oriented primarily at user agent implementers.

Furthermore, there are some rules about using WAI ARIA:

1. If possible, a native HTML element or attribute with the required semantics and behaviour built in should be used.
2. Native semantics should not be changed, unless necessary.
3. All interactive ARIA controls must be usable with the keyboard.
4. The following should not be used on a focusable element: role="presentation" or aria-hidden="true".
5. All interactive elements must have an accessible name.

EPUB Standard for Accessible Digital Documents (EPUB)

The latest version is EPUB 3.3 (released in May 2023).

Organisations should consider using EPUB for publishing accessible digital documents; other formats may also be provided.

EPUB defines a distribution and interchange format for digital publications and documents. The EPUB format provides a means of representing, packaging, and encoding structured and semantically enhanced web content — including HTML, CSS, SVG, and other resources — for distribution in a single-file container.

Accessibility of EPUB publications was an essential consideration in the development of EPUB 3.3. As a result, the EPUB Accessibility specification has been updated and is now an integral part of the EPUB Standard.

There is also a comprehensive test suite that systematically tests all normative features of the specification. In conjunction with the release of EPUB 3.3, EPUBCheck has been updated to be fully compatible with EPUB 3.3.

Additional W3C guidance

Organisations should consider the following additional W3C guidance in the development of digital products and services and in the preparation and publishing of digital information.

Applying WCAG to Non-Web ICT

The W3C have written ‘Guidance on Applying WCAG to Non-Web Information and Communications Technologies’ (WCAG2ICT) to assist organisations to apply WCAG to other ICT products, particularly non-web documents and software.

Collaboration Tools Accessibility User Requirements

This W3C Note about accessibility requirements in collaboration tools outlines various accessibility-related user needs and requirements for both synchronous and asynchronous web-based collaboration tools based on various collaborative engagement scenarios. The Note is particularly relevant to software developers contributing to the development of collaborative experiences. It addresses various aspects of collaborative tool accessibility including managing complexity, delineation between content creation and collaboration management, and social considerations.

Cognitive Accessibility Guidance

Cognitive impairment can impact how people process information.

Whilst some of the WCAG Success Criteria do increase accessibility for people with cognitive impairment, this is often more by chance than design. Further guidance is therefore available to assist in the creation of content which will be more accessible to people with cognitive impairment.

See Cognitive Accessibility at W3C for an overview and also their informative guidance:

• Cognitive Accessibility Guidance — short design patterns (explained briefly in About Supplemental Guidance)
• Making Content Usable for People with Cognitive and Learning Disabilities — a longer document that covers many different aspects for many different design, development and content creation roles, including a discussion of the importance of Easy to Understand language or Easy Read

W3C Accessibility Maturity Model

The Accessibility Maturity Model is designed to work for any size organisation. From small consultancies and large enterprises to nonprofit/NGOs and government agencies, it provides actionable guides for establishing or improving policies, employee-communication, training, and tools. It also includes a way to measure and document organisational, cultural and technical capabilities.

Australian Standards

The following standards have all been published by Standards Australia as direct adoptions of International or European standards.

Accessibility Requirements for ICT Products and Services (AS EN 301 549:2024)

Supersedes AS EN 301 549:2020 and AS EN 301 549:2016

Requirements of AS EN 301 549 should be met for all digital products including hardware. However, as AS EN 301 549 references WCAG 2.1, WCAG 2.2 should be used where appropriate instead.

This Australian Standard directly adopts EN 301 549:2020 (V3.1.1) from Europe. It specifies the functional accessibility requirements applicable to ICT products and services, together with a description of the test procedures and evaluation methodology for each accessibility requirement. It incorporates WCAG 2.1 but is applicable more broadly than websites. AS EN 301 549 covers:

• Web
• Non-web documents
• Software
• ICT with two-way voice or with video capabilities
• Hardware
• Documentation and support services
• ICT providing relay or emergency service access

AS EN 301 549 also has two overarching functional performance statements to be met.

• The digital product, similarly to the WCAG principles, enables users to locate, identify, understand and operate functions in digital technologies.
• Any accessibility features within the good or service maintains the privacy of people using those features at the same level as other users.

In practical terms, AS EN 301 549 requires that digital goods and services must be able to be used equally and independently by people:

• with no or limited vision
• with no or limited perception of colour
• with no or limited hearing
• with no or limited vocal capability
• with limited manipulation or strength
• with limited reach
• with photosensitivity seizure triggers
• with limited cognition, language, or learning.

An HTML version of EN 301 549 is available from Accessibility Standards Canada as CAN/ASC - EN 301 549:2024.

Document management applications — Electronic document file format enhancement for accessibility, Part 1: Use of ISO 32000-1 (PDF/UA-1)’ (AS ISO 14289.1:2017)

PDF files cannot be made fully accessible, especially on mobile devices. Utilising EPUB can ensure a fully accessible document is provided. Where PDFs are provided, they should meet the requirements of AS ISO 14289.1.

This Australian standard adopts ISO 14289-1:2014, which specifies the use of ISO 32000-1:2008 to produce accessible electronic documents through the inclusion of a variety of semantic information and defining requirements for conforming readers and conforming assistive technology.

This standard is developed and maintained by the PDF/UA Foundation. The Foundation also provides a PDF accessibility checker (PAC).

Copies of ISO 32000-2 (PDF 2.0) and ISO 14289 (PDF/UA) standards are available from the PDF Association for free.

Information Technology – Development of user interface technology, Part 1: Code of practice for creating accessible ICT products and service (AS ISO/IEC 30071.1:2022)

AS ISO/IEC 30071.1:2022 takes a holistic approach to the accessibility of information and communications technology (ICT) by combining guidance on implementing the accessibility of ICT systems (ICT accessibility) at the organizational and system development levels. This standard is about strategy and policy for accessibility and applies to the adoption of any technical standard.

Risk management – Guidelines (AS ISO 31000:2018)

Accessibility is often treated as a nice-to-have. However, taking a risk-based perspective prioritises areas where problems are most likely to occur so they don’t happen.

AS ISO 31000:2018 specifies guidelines on managing risk faced by organisations with the application of these guidelines able to be customised to any organisation. As one of the risk management standards, this standard provides a common approach to managing any type of risk and is not industry or sector specific.

Compliance Management Systems – Requirements with guidance for use (AS ISO 37301:2023)

AS ISO 37301:2023 specifies requirements and provides guidelines for establishing, developing, implementing, evaluating, maintaining and improving an effective compliance management system within an organisation. This document is applicable to all types of organisations regardless of the type, size and nature of the activity, as well as whether the organisation is from the public, private or non-profit sector.

Plain language, Part 1: Governing principles and guidelines (AS ISO 24495.1:2024)

AS ISO 24495.1:2024 establishes governing principles and guidelines for developing plain language documents. The guidelines detail how the principles are interpreted and applied. This document is for anybody who creates or helps create documents. The widest use of plain language is for documents that are intended for the general public. However, it is also applicable, for example, to technical writing, legislative drafting or using controlled languages.

Plain language helps people find what they need, understand it, and use it. Thus, plain language focuses on how successfully readers can use a document, rather than on mechanical measures such as readability formulas.

Australian Government standards

Digital Sourcing Consider First Policy

The Digital Sourcing Consider First Policy aims to guide agencies through early consideration of important factors that help investments meet their intended outcomes.

Principle 5 requires alignment with relevant whole-of-government requirements early to ensure that digital investments deliver their outcomes with lower cost and reduced effort. Digital investments must be designed for all users, including people with disability, older people, and those who find technology difficult.

The Commonwealth Procurement Rules contain mandatory requirements for applying Australian Standards, this is relevant to most investments subject to this policy. The Australian Standard for ICT Accessibility (AS EN 301 549:2024) discussed earlier is applicable to most ICT goods or services being procured by government.

Digital Experience Policy

The Australian Government released its Digital Experience Policy (DX Policy) in July 2024. This policy requires Australian Government agencies to be more inclusive in their digital offerings. In conjunction it released 3 new standards to complement the existing Digital Service Standard:

• Digital Inclusion Standard – aims to ensure services are designed to be inclusive, leaving no one behind
• Digital Access Standard – aims to improve service discoverability and ease of access points for all users
• Digital Performance Standard – sets criteria for monitoring and reporting on the performance of digital services

Collectively, the DX Policy and associated standards are designed to improve the experience for people and business interacting digitally with government information and services.

Digital Service Standard

The Digital Service Standard (DSS) is mandatory for digital websites, mobile apps and other digital platforms and services created by Federal Government departments and agencies.

People and businesses need to be at the centre of government digital service delivery. The Digital Service Standard sets the requirement for government to create and maintain services that meet the needs of people and business.

The DSS Version 2.0 was released in December 2023 and covers informational, transactional and staff-facing services. It requires the application of the latest version of WCAG along with requirements to “know your user” and to “leave no one behind”.

Most Australian States have similar requirements – see below.

Digital Inclusion Standard

The Digital Inclusion Standard (DIS) sets the requirements for inclusive and accessible digital government experiences. It comes into effect from January 2025 for new services and July 2025 for existing services. Agencies will be required to report on their progress.

Picking up on the DSS criteria to “leave no one behind”, the DIS has requirements to “embrace diversity” and to “make it accessible”.

Digital Access Standard

The Digital Access Standard requires agencies to consider how people already access services and the context in which they might access it. This should maximise discoverability of a service. Existing services should be built on in preference to building something new.

Digital Performance Standard

The Digital Performance Standard requires agencies to establish key performance indicators and to implement a performance monitoring approach that focuses on the end-user experience. Agencies also need to assess the user’s journey across different channels, aiming to make the whole service smoother.

Australian Government Architecture

The Australian Government Architecture (AGA) was developed to help government to assess new and existing digital solutions by seeing how they “fit in” with existing systems, whether a new solution helps “fill a gap,” or whether existing system is no longer “fit for purpose” and needs to be retired.

The AGA Content Management Policy requires government to meet the Web Content Accessibility Guidelines.

The AGA Complaints and Issue Resolution section requires “managing the collection of and effective resolution for complaints from individuals about government services and operations”. This should include specific avenues for handling accessibility related complaints.

Data and Digital Government Strategy

The Australian Government’s Data and Digital Government Strategy was developed to help government to use data and digital technologies to improve our service delivery and decision-making, with a goal of better outcomes for all people and business.

The Strategy commits the Australian Government to use data and digital technologies to deliver connected, accessible services which are centred around the needs of people and business. As part of this, agencies are expected to embed co-design and inclusion and accessibility in its data collection, use and governance activities. Specifically, government is committed to:

“ensure all people can access and benefit from its services, the Australian Government commits to:

• providing omni-channel service delivery to ensure digitally delivered services are accessible over the phone or face to face
• ensuring all websites and services meet the latest Web Content Accessibility Guidelines
• implementing the Digital Service Standard to embed best-practice service design and accessibility across the Australian Public Service
• embracing new technologies and leveraging data and insights to increase empathetic service design (e.g., natural language processing to enhance services for non-English speakers).”

The Implementation plan has a roadmap which also specifically mentions the Digital Service Standard Version 2.0.

State Government requirements

All the Australian State and Territory Governments have made accessibility commitments – most have supporting resources.

Australian Capital Territory

• Aims to meet the Digital Service Standard

New South Wales

• Design Standards
• Accessibility resources
• Accessibility and Inclusivity Toolkit

Northern Territory

• Endorsed Web Content Accessibility Guidelines 2.0

Queensland

• Digital service standard
• Make digital services accessible
• Consistent User Experience Standard

South Australia

• Digital Service Standard Policy
• Online Accessibility Toolkit

Tasmania

• Accessibility commitment
• Accessible and inclusive communications

Victoria

• Digital guides
• Make content accessible

Western Australia

• Digital Services Policy Framework
• Accessibility and Inclusivity Standard

Industry requirements

Banking Inclusivity and Accessibility

The Accessibility and Inclusion Principles for Banking Services promote equitable access, usability, and inclusivity for customers with disability and their carers to banking services. The Australian banking industry is committed to ensuring the inclusivity and accessibility of all banking products and services for all people, including those with disability and their carers. The inclusive and accessible banking services extend beyond just physical branches to digital and telephonic offerings, including websites, mobile apps, phone lines and artificial intelligence (AI) chatbots.

Guidelines for Accessibility in PIN Entry on Touchscreen Terminals

The Guidelines for Accessibility in PIN Entry are designed to address access to point-of-sale (POS) touchscreen technology (PIN on glass) and are a key step in efforts to ensure innovations in payments technology are accessible to the widest population.

Telecommunications Consumer Protection Code

The Telecommunications Consumer Protections (TCP) Code C628:2019 applies to all Carriers and Carriage Service Providers that provide carriage services to consumers including xDSL services, wifi and dial-up services, mobile services, fixed line services and VoIP services.

A telecommunications supplier must ensure that its web content complies with the most recent version of WCAG Level A success criteria. However, the Commission recommends WCAG 2.2 Level AA or higher to minimise discrimination.

Additional Guidance

Game Accessibility Guidelines

The Game Accessibility Guidelines are a collaborative effort between a group of studios, specialists and academics, to produce a straightforward developer friendly reference for ways to avoid unnecessarily excluding players, and ensure that games are just as fun for as wide a range of people as possible. These guidelines do not have a version number as they are continually updated as required.

Accessible eText

Guidelines for Producing Accessible eText (2024)

eText is structured electronic text which is accessible to people with a print disability. The Guidelines for Producing Accessible eText provide document creators with best practice accessibility methods across a variety of electronic formats in common use.

Produced by the Round Table on Information Access for People with Print Disabilities Inc., these updated Guidelines replace the Round Table’s 2018 Guidelines.

Plain Language considerations

Plain language makes it easier for anyone to read, understand, and use government and corporate communications. In addition to AS ISO 24495.1 – Plain language, Part 1 – listed earlier, this section contains additional Australian and international plain language resources.

Australian Government Style Manual

The Australian Government Style Manual (Style Manual) is the definitive resource for Australian Government content. It is also widely applicable to any other sector looking for a consistent approach to writing for their audience.

How to write in plain English

The How to write in plain English guide from the Plain English Campaign, in addition to general guidance and lists of alternative words, contains specific guidance for content such as forms, reports and websites.

Dyslexia friendly style guide

The Dyslexia friendly style guide from the British Dyslexia Association provides principles that can help ensure that written material considers the difficulties experienced by some dyslexic people.

Multimedia (Audio & Visual Media) Guidance

With the increasing volume of multimedia, including video and podcasts, on platforms such as YouTube, TikTok and similar as well as provided via streaming services, the accessibility of these forms of communications is imperative.

W3C Making Audio and Video Media Accessible Guide

Making Audio and Video Media Accessible explains how to make media accessible, whether it is developed in house or outsourced. It helps identify which accessibility aspects is needed for specific audio or video, provides project management guidance, and includes requirements from the Web Content Accessibility Guidelines (WCAG) standard.

Endnotes