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Web Accessibility National Transition Strategy: Scope

WCAG 2.0 is applicable to all online government information and services. Conformance is required on all government websites owned and/or operated by government under any domain. This includes external (public-facing or private) and internal (closed community) sites. That is, conformance is required for all internet, intranet and extranet sites.

Agencies are reminded that accessibility is a requirement for all websites even when the audience is known. People who have a disability are not legally bound to disclose it and many do not. Agencies that do not implement WCAG 2.0 for their intranet must accept they may be at greater risk of complaint under the Disability Discrimination Act 1992 and other anti-discrimination Acts4. Agencies are required to report on the conformance of all websites, including departmental intranets and private extranets.

A website is defined by Wikipedia as “a collection of related web pages, images, videos or other digital assets that are addressed with a common domain name or IP address in an Internet Protocol-based network. A website is hosted on at least one web server, accessible via the Internet or a private local area network5.

Further to this, the W3C provides the following definition of a web page: “… the term ‘Web page’ includes much more than static HTML pages. The term ‘Web Page’ was used in these guidelines to allow the guidelines to be more understandable. But the term has grown in meaning with advancing technologies to encompass a wide range of technologies, many of which are not at all ‘page-like’. It also includes the increasingly dynamic Web pages that are emerging on the Web, including ‘pages’ that can present entire virtual interactive communities. For example, the term ‘Web page’ would include an immersive interactive movie-like experience that you find at a single URL.”6

For the purposes of the National Transition Strategy, a ‘government website’ is defined as one that:

Cross-jurisdictional or cross-portfolio websites, with more than one government agency owning or significantly contributing to the website, or websites created under public– private partnerships, should meet the mandated level of accessibility relevant to the main authoring agency, or the highest conformance level applicable to an authoring agency. Government funded programs (including grants) or initiatives delivered through third-party providers should meet the endorsed accessibility requirements if the information provided is portrayed as, or is considered to be, ‘government information’. This is especially important for entities that are funded for information dissemination.

Inclusions and Exclusions

WCAG 2.0 will be implemented in three phases with explicit timeframes. Depending on the type of web content and when it was created, WCAG 2.0 may or may not be applicable. The three phases and respective timeframes are:

  1. Preparation Phase – July 2010 to December 2010
  2. Transition Phase – January 2011 to December 2011
  3. Implementation Phase – Completed by December 2012 (Single A) and December 2014 (Double A).

All websites and web content created after July 2010 (commencement of Preparation Phase) must meet WCAG 2.0 to at least Single A level by December 2012.

Websites and web content created before July 2010 that will be archived or decommissioned before December 2012 are not required to meet WCAG 2.0.

Similarly, any web content created before July 2010 that is no longer current, but that is still important and/or popular and not yet appropriate for archival, should remain WCAG 1.0 conformant. Where this type of content is not WCAG 1.0 conformant, agencies should upgrade to WCAG 2.0 (as WCAG 1.0 is technically superseded). A content upgrade flowchart is provided to assist agencies with decision making.

Content Upgrade Flowchart

Text description: Image describes a workflow for an agency to determine whether content should be upgraded to WCAG 2.0 or decommissioned.

Question 1 - Was the content created before July 2010? If no, upgrade to WCAG 2.0. If yes, proceed to next question. Question 2 – Is the content current? If yes, upgrade to WCAG 2.0. If no, proceed to next question. Question 3 – Is the content still important or popular? If no, archive or decommission content. If yes, proceed to final question. Question 4 (final) – Does the content conform to WCAG 1.0? If yes, then content should remain WCAG 1.0 with disclaimer. If no, agencies should upgrade content to WCAG 2.0.

Along with the structure and navigational elements of a website, all information that is required under the jurisdiction’s website policy is included within the scope for upgrade to WCAG 2.0. Federal government agencies should be guided by the Web Guide’s Online Content Requirements7. At a minimum, the following information should always be up to date and conform to WCAG 2.0:

Retrospectivity and Legacy Content

Retrofitting accessibility features to a website or web content can be expensive and time-consuming, and such sites are also generally more expensive to manage than those created to conform to WCAG 2.0 from launch. (A similar problem occurs, for example, when accessible ramps and elevators are not planned for during a building’s construction rather than at its initial design stage.) A website built from the outset with accessibility in mind is more usable for everyone.

Agencies will therefore need to go through a process to identify all current and relevant information on their existing websites, and should decommission or archive old information where appropriate. To improve the transparency of government information, agencies are encouraged to archive information online, as citizens expect to retain access to electronic information. An archived web page is:

An archived web page may be provided on the website, but must be clearly identified as being archived. Agencies should not unnecessarily archive or decommission any content unless it has been identified as outdated, superfluous, irrelevant or replicated elsewhere. Agencies are still liable for complaint under the Disability Discrimination Act 1992 for all websites that are not accessible, regardless of their proposed archival or decommissioned status.

WCAG 2.0 Single A should be applied where possible. Where no WCAG 2.0 Sufficient Techniques8 exist to test the conformance of a technology or product, then WCAG 2.0 conformance cannot be claimed.

Along with WCAG 2.0, agencies developing and implementing advanced web technologies and custom widgets are encouraged to consider other W3C guidelines in order to be more accessible – for example, the proposed Web Accessibility Initiative Accessible Rich Internet Applications (WAI-ARIA) guideline and other relevant technical standards.


Temporary exemptions will only be considered on a whole-of-government arrangement where technical solutions cannot be found that sufficiently address WCAG 2.0 conformance. Such arrangements will be subject to a review process and reconsidered as technology advances and further WCAG 2.0 conformance techniques are published. AGIMO will keep agencies informed of solutions.

Opt-out Arrangements (Federal Government Only)

In response to the Review of the Australian Government’s Use of Information and Communication Technology9, the Australian Government has changed the system of self-approved opt-in by agencies to whole-of-government ICT arrangements. Under the new system, agencies must seek approval from the Expenditure Review Committee to opt-out from agreed arrangements. Arrangements in this case include the endorsement and implementation of WCAG 2.0 for all federal government websites to Double A level by the end of 2014.

If an agency is unable to conform to WCAG 2.0, it could seek exemption through the opt-out process10. However, agencies seeking to opt-out of WCAG 2.0 conformance, either in part or in full, would not negate their responsibilities under the Disability Discrimination Act 1992 or the UN Convention on the Rights of Persons with Disabilities. Agencies seeking opt-out would need to review the Australian Human Rights Commission’s advisory notes to the Disability Discrimination Act 1992, to help ensure that their alternative strategies for the provision of information and services online were non-discriminatory.


The National Transition Strategy will be accompanied by a reporting regime capturing government progress in meeting WCAG 2.0 conformance. For federal government agencies (those subject to the FMA Act), AGIMO will provide a reporting system similar to that used to report progress of implementation under Internet Protocol version 6. Federal agencies (those subject to CAC Act) opting-in to the strategy are encouraged to report using the same system and will need to advise AGIMO of their intention to do so.

For state and territory agencies, reporting will be coordinated by jurisdictional representative agencies, or via existing reporting mechanisms. Jurisdictions will provide consolidated reporting from their state to AGIMO to enable national progress to be monitored.

Resources, Guidance and Tools

AGIMO provides advice and guidance around web accessibility on the Web Guide11. Further advice and guidance is being developed to support the National Transition Strategy. It is anticipated that advice, guidance and tools particular to the implementation phases will be made available on the Web Guide.

In addition, states, territories and international jurisdictions have a wealth of web accessibility information that may be useful to both web and business managers during the transition to WCAG 2.0. Where possible and relevant, AGIMO will provide links to this information, creating a centralised repository of all WCAG 2.0 implementation guidance.

AGIMO has established a collaborative space to support a community of expertise for the transition to, and implementation of, WCAG 2.0. If you are interested in participating in this, register your interest via

Next section: Work Plan


  1. All Australian laws on anti-discrimination are outlined on the National Anti-Discrimination Information Gateway [External Site]. The Disability Discrimination Act 1992 specifically addresses web accessibility.
  2. [External Site]
  3. [External Site]
  4. [External Site]
  5. [External Site]
  8. Previously named the “Web Publishing Guide” [External Site]

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Last Modified: 13 March, 2013