Government accessibility standards for ICT
Inclusive ICT Procurement Standards
Under the Disability Discrimination Act (DDA), all digital products should be accessible and inclusive for all users. This includes content, software infrastructure systems and/or services.
- A person with a disability has a right to obtain goods and use services and facilities in the same way as people without a disability.
- As an employer, the NSW government has a legal obligation to remove barriers that people with disabilities may face at work.
To meet our legislative obligations and enable people with a disability to participate on the same basis, all digital products procured and/or developed should possess the features and qualities that make them usable by all intended users from the beginning.
How we define, measure, and procure accessible products
The NSW Government uses the Australian ICT procurement Standard, AS EN 301 549 (EN301) to clearly identify and include both the level of functional performance and accessibility requirements when procuring ICT.
EN301 uses existing international standards that define accessibility and provide technical standards for measuring digital accessibility.
In practical terms, accessible products work seamlessly with the inbuilt accessibility features and assistive technologies found on mainstream devices. These include screen magnifiers, screen readers, speech recognition tools, captioning, and switch access.
These short instruction videos can provide guidance on what to expect when implementing AS EN301.
There are some simple steps you can follow to ensure accessibility is an essential part of your ICT procurement process.
How we implement accessibility requirements into procurement
Currently, the Core& contract provides an option that makes it simple to include the relevant parts of EN301 into your department's standard procurement processes and protocols (i.e. Functional Performance Statements (FPS) and Functional Accessibility Requirements (FAR) in EN301).
Vendors supplying any digital product that fits under EN301 should provide verifiable evidence to confirm their compliance with these requirements.
Note that preauthorisation of vendors can be a challenge. Even major international vendors acknowledge that not all their products meet accessibility requirements, and that accessibility can change from one version of a product to another.
If your procurement team is unsure, you can reach out to a certified accessibility professional for assistance.
Before you go to tender or quote
- Use Section 4 of EN301 to identify the Functional Performance Statements (FPS) to include. These describe the functional performance of the technology that enables people to locate, identify, and operate ICT functions, and to access the information regardless of physical, cognitive, or sensory abilities. Use clause 4.2 of EN301 to identify the relevant FPS that match your user needs and the ICT you are purchasing.
- Consider whether the digital products you're purchasing will need to meet both the generic requirements outlined in Section 5, as well as any additional sections related to the specific requirements of the technology type you're procuring (e.g. section 9 relates to web-based content.)
- Use Annex B of EN301 to identify relevant Functional Accessibility Requirements (FAR), i.e. the detailed and specific accessibility requirements for different technologies.
- Create a spreadsheet or table identifying all relevant clauses and include these in your request for quote or request for tender.
Evaluating tenders and quotes
The further a vendor progresses through the selection process, the more evidence they should provide for meeting the accessibility requirements.
- provide easy entry for vendors
- promote the use of clear, consistent evidence
- provide a mechanism for easy, practical demonstration of the accessibility of the product.
See below for an example of evaluation rounds.
Round 1: Vendors provide written confirmation of the product’s level of accessibility compliance against EN 301, indicating whether the product provides complete, partial, or nil compliance.
Round 2: Vendors provide a completed copy of ‘AS EN 301 549 Accessibility Declaration of Conformance documentation’. This should accurately detail the level of accessibility of the product (against WCAG 2.1 or AS EN 301 549). The documentation should include the testing method(s) used to determine the level of accessibility. This document should be used by the procurement panel to draw up a shortlist of preferred products.
Round 3: Vendors who are shortlisted (e.g. final three) and/or their nominated representative are required to demonstrate to the procurement panel how the product performs, using the inbuilt accessibility features/assistive technologies found on both Apple and Microsoft devices used by the Department.
What to do if vendors can’t meet EN301
These standards are international and long-standing, so vendors should be aware of them. For reference, WCAG was first released in 1999 and EN301 was released in Europe in 2014 and adopted in Australia in 2016.
If current products don’t meet standards, you can ask vendors to outline where their products fall short (the above conformance document will help), and ask them to provide a product roadmap of later releases that demonstrates when the product will meet standards. You can also ask vendors to outline any known workarounds that you can implement in the meantime.