Guest Post: Get ready for 1 May 2011 – the FOI Information Publication Scheme

Kelly Wood - OAIC
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This post is from the Office of the Australian Information Commissioner (OAIC). The OAIC is working with AGIMO to develop accessibility advice for agencies for the Information Publication Scheme (IPS).

We hope this post will contribute to agencies’ understanding of how to comply with the accessibility requirements in the context of the IPS, and to help agencies get ready for 1 May 2011.

Part 2 of the Freedom of Information Act 1982 (FOI Act) establishes the IPS for Australian government agencies subject to the Act. The IPS commences on 1 May 2011 and requires agencies to publish a broad range of information on their websites, and to make that information available online where possible.

The OAIC has released an Issues Paper on ‘Towards an Australian Government Information Management Policy’. Formal comment on the draft public sector information principles in this Issues Paper can be made until 1 March 2011. Keep an eye out for the OAIC’s blog on the draft principles on govspace in February.


For the IPS agencies will be required to:

  • publish agency plans
  • publish specified categories of information, and
  • consider proactively publishing other government information.1

The specific categories of information loosely cover the existing publication provisions in the FOI Act that require agencies to publish information concerning the functions and documents of the agency2 and to make certain documents available for inspection and purchase.3 A key addition is ‘the agency’s operational information’.4

Agencies will also be required to publish in a disclosure log, with some exceptions, information accessed through documents released as a result of an FOI requests.5

Get ready!

When you are preparing your agency plan for publishing information, you need to consider:

  • what information your agency plans to publishe.g. Working out what to publish will be guided by the FOI Act and existing administrative release processes.
  • how your agency plans to publish the informatione.g. Information should be published on the agency website in formats that facilitate discoverability and reuse. Where the format or content of the information makes online publication impractical, information about how it can otherwise be obtained will be published.
    • How are people going to use the information? (read online, email, print, download)
    • Will the content published online be accessible to the mandatory standard (WCAG 2.0)? If not, are two formats being used to limit discrimination?6
    • How will your agency address accessibility of information only available in hardcopy (where no electronic equivalent currently exists)?
  • to whom your agency plans to publish the informatione.g. Information is published generally to the Australian community. Will your agency also target specialist audiences? Why are they using it? (compliance, interest, research, work)
  • how your agency otherwise plans to comply with the scheme and its intent e.g. Will your agency publish information in stages? How often will your agency review its IPS? How will old information be archived? What is your agency trying to achieve by publishing the information?
Further discussion points
  • What accessibility issues do you need guidance about for preparing your Agency Plan and IPS compliance?
  • Which areas in your agency are collaborating on the IPS?
  • What procedures will your agency adopt to ensure that information published under the IPS complies with WCAG 2.0 for existing information holdings and new information holdings?
  • Do you anticipate any difficulties implementing these procedures by 1 May 2011?
  • Do you have any lessons learnt that can be shared?


1. FOI Act, s 8(2).*
2. FOI Act, s 8(1)(a).
3. FOI Act, s 9(1).
4. FOI Act, ss 8(2)(j) and 8A.*
5. FOI Act, s 11C.*
6. The Australian Government position on the use of Alternative Formats can be found on the Web Publishing Guide at:

* Update: These sections commence on 1 May 2011 and are published in a Schedule to the current compilation of the FOI Act available on Comlaw.


Comments on this blog are now closed. Please let us know if you would like to discuss this post or have any general comments.

Comments (5)

Get involved in discussing the OAIC’s draft principles for open PSI at

There seems to be some misconceptions around with regards to "alternative formats" and especially in relation to providing an alternative to all those PDFs out there. In the advice which makes up footnote 6 above it states "any technology may be used, but where it cannot prove its accessibility support, agencies must provide an additional alternative format." it seems unclear whether that additional alternative format should be an accessible one.

I think we can all agree it *should* be accessible, but is it required? And if the additional alternative format must be accessible does an RTF qualify as an accessible alternative?

I'm still a little confused about all this.

When Sufficient Techniques are published for PDFs, there will be a requirement to implement these techniques - is that right? Otherwise the resource will not be compliant.

On another point, I recall that there was the issue of vision impaired users having older AT equipment or not knowing how to use AT equipment. Will this still be an issue, or will the use of Sufficient Techniques mean that this is no longer important?

Putting aside the format of the published content, where is everyone publishing this information? Creating a new section on the site or integrating it into existing information architectures?

Finance is currently

Last updated: 28 July 2016