If your organization supplies products or services to Australian government, WCAG compliance isn't optional - it's a mandatory procurement requirement. This comprehensive guide explains what you need to know, what evidence to prepare, and how to ensure your offerings meet government accessibility standards.
Key Takeaways for Government Suppliers
- WCAG 2.1 Level AA compliance is mandatory for all digital products supplied to Australian government
- Procurement-ready evidence must be prepared before tender submission
- Documentation requirements vary by jurisdiction - know your target procurement requirements
- Non-compliance can result in tender rejection or contract termination
Why Australian Government Requires WCAG Compliance
Australian government accessibility requirements stem from multiple legislative and policy drivers:
Legal Obligations
- Disability Discrimination Act 1992 (Cth) - Government must ensure services are accessible to people with disabilities
- Commonwealth Disability Strategy - Requires accessible ICT procurement
- State/Territory anti-discrimination laws - Each jurisdiction has equivalent legislation
- Public Service Act obligations - Requirements for inclusive service delivery
Policy Framework
Government digital service policies mandate accessibility:
- Digital Service Standard - All government digital services must be accessible
- Procurement policies - Accessibility is a mandatory evaluation criterion
- Web Content Accessibility Guidelines - WCAG 2.1 Level AA is the required standard
The Business Case for Suppliers
Beyond compliance, accessibility offers commercial advantages:
- Access to substantial government procurement budgets
- Competitive advantage over non-compliant suppliers
- Broader market applicability (accessible products work for everyone)
- Reduced risk of costly retrofitting
- Enhanced brand reputation
Commonwealth Government Requirements
Digital Service Standard (DSS)
The Commonwealth Digital Service Standard includes specific accessibility criteria that apply to suppliers of digital products and services:
Criterion 9: Make it Accessible
Requirements include:
- • Meet WCAG 2.1 Level AA as a minimum
- • Test with assistive technologies
- • Conduct user research with people with disabilities
- • Publish an accessibility statement
- • Provide an accessible feedback mechanism
- • Ensure third-party components are accessible
Procurement Requirements
When responding to Commonwealth tenders, you'll typically need:
1. Accessibility Conformance Report
Detailed report documenting WCAG 2.1 Level AA conformance, typically using VPAT (Voluntary Product Accessibility Template) format
2. Testing Evidence
Documentation of accessibility testing including automated scans, manual testing, and assistive technology testing
3. Accessibility Statement
Public statement of accessibility conformance, known issues, and contact information for accessibility feedback
4. Remediation Plan
If full conformance isn't yet achieved, a detailed plan with timelines for addressing outstanding issues
Contract Clauses
Government contracts typically include:
- Mandatory WCAG 2.1 Level AA compliance
- Rights for government to conduct accessibility audits
- Remediation obligations for accessibility issues
- Penalties for non-compliance
- Requirements to maintain compliance over contract life
Important Note
Accessibility conformance must be maintained throughout the contract. One-time testing at procurement is insufficient - ongoing monitoring and documentation is required.
State and Territory Requirements
Each Australian state and territory has its own digital service policies and procurement requirements:
New South Wales
- • Policy: NSW Government Digital Service Standard
- • Standard: WCAG 2.1 Level AA mandatory
- • Key requirement: Accessibility must be addressed in all stages of digital service delivery
- • Documentation: Accessibility statement and conformance report required
Victoria
- • Policy: Victorian Government Digital Standards
- • Standard: WCAG 2.1 Level AA minimum
- • Key requirement: Whole of Victorian Government (WoVG) Standards
- • Documentation: Detailed accessibility testing evidence
Queensland
- • Policy: Queensland Government Digital Service Standard
- • Standard: WCAG 2.1 Level AA
- • Key requirement: Accessibility must be built in from the start
- • Documentation: VPAT or equivalent conformance documentation
Western Australia
- • Policy: WA Government Digital Policy
- • Standard: WCAG 2.1 Level AA
- • Key requirement: Accessibility integrated into ICT procurement
- • Documentation: Accessibility statement and testing reports
South Australia, Tasmania, ACT, NT
- • Standard: All require WCAG 2.1 Level AA compliance
- • Approach: Generally aligned with Commonwealth Digital Service Standard
- • Documentation: Conformance reports and accessibility statements
Practical Tip for Multi-Jurisdiction Suppliers
While specific policies vary, all Australian jurisdictions require WCAG 2.1 Level AA as the baseline. Prepare comprehensive documentation that covers Commonwealth requirements - this will satisfy most state and territory procurement needs.
Preparing Procurement-Ready Evidence
Government procurement processes are rigorous. Having the right documentation prepared before tender submission is critical for success.
Essential Documentation Checklist
VPAT Documentation
Complete Voluntary Product Accessibility Template documenting conformance to WCAG 2.1 Level AA. Use the latest VPAT format (currently VPAT 2.5).
Automated Testing Reports
Timestamped automated scan results from recognized tools (axe, WAVE, ComplyWeb, etc.) showing WCAG 2.1 AA compliance testing.
Manual Testing Evidence
Documentation of manual accessibility testing including keyboard navigation, screen reader testing, and color contrast verification.
Accessibility Statement
Public statement of conformance level, testing methodology, known limitations, and feedback mechanism.
Testing Methodology
Document your testing approach, tools used, testing frequency, and quality assurance processes.
Remediation Process
Documented process for identifying, prioritizing, and fixing accessibility issues, including SLA commitments.
Staff Training Records
Evidence that development and design staff have accessibility training and expertise.
Third-Party Component Documentation
If using third-party components, provide their accessibility conformance documentation and your testing of their integration.
Sample VPAT Structure
A complete VPAT should include:
- Product information - Name, version, description
- Evaluation methods - Testing tools and processes used
- WCAG 2.1 Level A criteria - Conformance status for each success criterion
- WCAG 2.1 Level AA criteria - Conformance status for each success criterion
- Supporting notes - Explanations of partial conformance or limitations
- Contact information - How to report accessibility issues
Ongoing Compliance Maintenance
Procurement-ready evidence isn't a one-time exercise:
- Update VPAT documentation with each product release
- Maintain current testing reports (no older than 3-6 months)
- Document all accessibility fixes and improvements
- Keep accessibility statements up to date
- Track and respond to accessibility feedback
Common Pitfalls for Government Suppliers
Avoid these common mistakes that can jeopardize procurement opportunities:
Pitfall 1: Last-Minute Testing
Waiting until tender submission to test for accessibility often reveals significant issues without time to fix them.
Solution:
Build accessibility testing into your development process. Test continuously, not just before procurement deadlines.
Pitfall 2: Incomplete Documentation
Submitting partial VPAT or missing testing evidence can result in immediate tender rejection.
Solution:
Maintain a complete documentation package at all times. Update it with each product release.
Pitfall 3: Assuming Level A is Sufficient
Some suppliers mistakenly believe WCAG Level A meets government requirements.
Solution:
Level AA is mandatory. Don't waste resources testing only Level A conformance.
Pitfall 4: Ignoring Third-Party Components
Using inaccessible third-party libraries, widgets, or plugins affects your overall conformance.
Solution:
Evaluate accessibility before selecting third-party components. Test their integration thoroughly.
Pitfall 5: No Remediation Plan for Partial Conformance
If you haven't achieved full conformance, failing to provide a credible remediation plan will eliminate your tender.
Solution:
Document all known issues with specific remediation timelines and milestones. Show commitment to achieving full conformance.
Pitfall 6: Outdated Testing Evidence
Submitting accessibility reports that are 12+ months old suggests lack of ongoing commitment.
Solution:
Refresh testing evidence regularly - ideally within the last 3 months.
Building Competitive Advantage Through Accessibility
Accessibility compliance isn't just about meeting minimum requirements - it can be a differentiator in government procurement.
Beyond Minimum Compliance
- WCAG 2.2 adoption - Show forward-thinking by adopting the latest WCAG version
- Level AAA for critical features - Exceed minimum requirements where practical
- User testing with people with disabilities - Demonstrate real-world validation
- Accessibility innovation - Highlight novel approaches to inclusive design
- Ongoing monitoring - Show continuous commitment, not just point-in-time compliance
Demonstrating Expertise
Strengthen your tender by showcasing accessibility expertise:
- Certified accessibility professionals on staff (IAAP certifications)
- Case studies of accessible solutions delivered to other government clients
- Published accessibility guidelines or contributions to accessibility community
- Regular staff training programs on accessibility
- Accessibility integrated into your development methodology
Long-Term Relationship Building
Position yourself as a trusted accessibility partner:
- Proactive communication about accessibility improvements
- Regular reporting on conformance status
- Transparent disclosure of known issues and remediation progress
- Willingness to conduct third-party audits
- Commitment to maintain conformance over contract life
Prepare Your Procurement-Ready Evidence
Start building your accessibility documentation with a comprehensive WCAG 2.1 Level AA compliance scan
Legal Disclaimer: This guide provides general information about government accessibility procurement requirements in Australia. Specific requirements may vary by jurisdiction and procurement process. Suppliers should review individual tender documentation carefully and seek qualified legal and technical advice for their specific circumstances. ComplyWeb provides monitoring and compliance evidence but does not guarantee tender success or full legal compliance.