Digital Accessibility Policies and Practices for PDF Forms | New Zealand National Report

Introduction

This report provides an analysis of New Zealand's digital accessibility policies, specifically in the context of PDF forms and other static formats. As governments worldwide increasingly aim to make digital services inclusive, New Zealand’s approach exemplifies a strong commitment to accessibility. The New Zealand Government’s Web Accessibility Standard 1.1 mandates compliance with WCAG 2.1 Level AA, ensuring that public and non-public service agencies prioritize accessibility and usability for all citizens, including individuals with disabilities.

Through a digital-first perspective, New Zealand’s guidelines discourage using static formats like PDFs, favouring adaptable web-native formats such as HTML to better support accessibility. This stance aligns with New Zealand’s view of accessibility as a fundamental human right and its commitment to international standards, including the United Nations Convention on the Rights of Persons with Disabilities. By examining core requirements, PDF accessibility challenges, recommendations for digital transformation, and areas for improvement, this report outlines New Zealand’s strategies to enhance accessibility across government digital services.

1. Core Accessibility Requirements Across Policies

• WCAG 2.1 Level AA Compliance: New Zealand requires all public service and non-public service agencies to meet WCAG 2.1 Level AA compliance under its Web Accessibility Standard 1.1. This standard aligns New Zealand with international accessibility expectations, ensuring that online government services are accessible to all users, including people with disabilities and those using assistive technologies.
• Accessibility as a Human Right: The guidelines reference accessibility as a fundamental human right, citing Article 9 of the United Nations Convention on the Rights of Persons with Disabilities. This principle reflects New Zealand’s commitment to inclusive digital services, which must be accessible to provide equal access and opportunity.

2. Differences in PDF Accessibility Requirements

• Preference for Web Content over PDFs: The guidelines discourage publishing content designed for print (like PDFs) directly to the web. Instead, they recommend content be created specifically for the web to ensure accessibility, reflecting a strong preference for HTML over static formats.
• Detailed Web Content Recommendations: New Zealand’s approach includes guidelines for using plain English, including alternative text for images, providing captions for videos, and ensuring adequate colour contrast. These recommendations favour web content that is naturally more accessible than PDFs, which often lack these adaptive features.

3. Recommendations for Digital Transformation

• Proactive Accessibility Considerations: The guidelines stress that accessibility should be considered from the start of a project, reinforcing a digital-first approach where content is created for the web. This strategy is in line with a phased transition away from static formats like PDFs, as they are often less adaptable and harder to make accessible.
• Assessment and Reporting Requirements: Agencies must assess and report their compliance with accessibility standards, submitting risk assessments for any areas of non-conformance. This rigorous process encourages a proactive approach to digital accessibility, aligning well with the goal of creating accessible, adaptive digital services.

4. Common Themes and Gaps in PDF vs Digital Form Accessibility

• Inclusive Design for Web Content: New Zealand’s guidelines encourage using correct HTML elements for structuring content (e.g., headings, lists, and tables), enhancing accessibility for assistive technologies. The emphasis on web-native content design shows a recognition of the accessibility gaps that exist in PDFs, which can often lack the adaptability required for user inclusivity.
• Gap in PDF-Specific Accessibility Guidance: While the guidelines discourage PDFs, there is no detailed framework for making PDFs accessible if they are used. This gap reinforces the stance that PDFs should be avoided in favour of web formats, underscoring HTML’s advantages for accessibility and ease of use.

5. Policy Summary and Practical Recommendations

• New Zealand Government Stance: The guidelines strongly encourage creating content specifically for the web and discourage static formats like PDFs. With an emphasis on proactive accessibility planning, New Zealand’s approach aligns with best practices in digital accessibility and responsive content design.
• Subject Matter Expertise Positioning: The clear preference for web-based formats aligns well with your whitepaper’s objectives to advocate for transitioning away from PDFs. By championing a digital-first approach, New Zealand’s guidelines bolster the case for adaptive formats that support a fully inclusive experience for all users.

This analysis highlights New Zealand's commitment to responsive, web-first content, providing a strong reference for advocating adaptive digital formats in the public sector.

Conclusion

New Zealand’s digital accessibility policies emphasize the importance of proactive, inclusive design, demonstrating a preference for web-based content over static formats like PDFs. The country's alignment with WCAG 2.1 Level AA and commitment to accessibility as a human right reflect its dedication to creating an inclusive digital environment. New Zealand’s guidelines encourage agencies to adopt a digital-first approach, prioritising HTML and other adaptive formats for their accessibility advantages. Although the current framework lacks detailed guidance for making PDFs accessible, the recommendation to minimise their use reinforces a commitment to dynamic, accessible web content.

In summary, New Zealand’s policies serve as a valuable model for governments aiming to transition towards responsive digital formats. By prioritising HTML and adaptive design principles, New Zealand supports accessible digital services that meet diverse user needs, establishing a robust foundation for long-term digital inclusivity in public sector content delivery.

References

New Zealand Government. (n.d.). Accessibility Standards and Guidance. Digital.govt.nz. Retrieved from https://www.digital.govt.nz/standards-and-guidance/design-and-ux/accessibility