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Buy accessible ICT products and services

People with disability have a right to obtain goods and use services in the same way as people without disability.This is a requirement under the Digital services policy.  Use this guide to help you buy information and communication technology (ICT) products and services that are designed and developed with this in mind.

The importance of accessible ICT

Based on the Web Content Accessibility Guidelines (WCAG) 2.1, Australian Standard AS EN 301 549:2020 – Accessibility requirements for ICT products and services encourages the development and procurement of inclusive ICT solutions. By enabling people with disabilities to participate equally in using ICT products and services, it fosters greater workforce and economic participation.

Include all users

Under the Disability Discrimination Act (DDA), ICT products and services must be accessible and inclusive for all users, including people with disability. This includes those with visual, auditory, cognitive, or motor impairments, who may be using assistive technologies or other adaptive strategies, such as screen magnifiers and readers, speech recognition tools, captioning, and switch access.

Benefits of accessible ICT

Accessible ICT enables equal use for all, fostering greater participation of people with disabilities in the workforce and society. It also helps avoid complaints and legal issues and saves money by preventing the need for retrofitting.

Considerations when buying ICT

When buying ICT, consider accessibility for:

  • products with a digital user interface, such as software, websites, apps, and systems
  • digital content, such as videos, social media posts, guides, and infographics
  • products with control mechanisms, such a hardware, keyboards, printers, kiosks, etc.

Reference: New South Wales Government. (2023) Buying, NSW Accessibility Toolkit. Available at: https://www.digital.nsw.gov.au/delivery/accessibility-and-inclusivity-toolkit/buying (Accessed: October 2023)

Before you begin

Steps for accessible procurement

AS EN 301 549:2020 outlines essential accessibility requirements for procuring ICT products and services. It serves as a key tool to identify, describe, and assess the accessibility of technology to be procured, developed, or adapted.

Before you go to tender or quote, refer to AS EN 301 549 to identify the accessibility requirements to request.  You should request these requirements as part of your evaluation criteria evidence.

  1. Identify functional performance statements (FPS)—use clause 4 to identify user accessibility needs that describe how they will find, interact with and access information in the ICT product or service.
  2. Identify functional accessibility requirements (FAR)—refer to clauses 5 to 13 to identify specific testable criteria for different ICT products and services. Consider if the ICT you're buying should   meet both the generic requirements in clause 5, and any extra requirements for specific technology types, such as clause 9 which relates to web-based information.
  3. Refer to the tables in Annex B to identify the mapped requirements of clauses 5 to 13 that support the user accessibility needs from clause 4—this shows the impact an accessibility issue might have on different users. Use a list or table to add them to your request.
  4. Refer to Annex C for examples on how to test conformance.

Include accessibility requirements in documents such as:

  • request for quote (RFQ)
  • request for proposal (RFP)
  • invitation to offer (ITO)
  • business case
  • evaluation plan
  • contract.

Request the following evidence in your evaluation criteria to allow vendors to understand what is required and how to respond.

  1. Conformance with AS EN 301 549 mapped requirements from step 1 and WCAG 2.1 AA.
  2. Usability testing with people with disability and who use assistive or adaptive technology, or the offer to demonstrate this as part of the evaluation. You may prefer to organise this testing   yourself or with help from a trusted testing partner.
  3. A product roadmap outlining accessibility improvements.
  4. Quality assurance (QA) processes in place such as scheduled periodic audits or continual automated and manual accessibility testing processes, and usability testing with people with disability and users of assistive or adaptive technology.
  5. Web accessibility training undertaken by the   designers, developers and testers who are likely to be involved in the development, specifically WCAG compliance.

Conformance report templates

Request vendors provide an AS EN 301 549 or WCAG 2.1 (level AA) conformance report using either of the following template options.

Option 1. Accessibility conformance report (ACR)

For procurement activities of third-party owned ICT, request a recent (less than 18 months) accessibility conformance report using the relevant voluntary product accessibility template (VPAT). It is preferred that an ACR is completed by an independent third-party.

  • Rev WCAG template—use for digital product or services such as websites, web applications, mobile websites and mobile applications etc.
  • Rev EU template—use for ICT products hardware, software, printers, kiosks etc.

Refer to training for preparing an ACR

Option 2. W3C evaluation report

Use the W3C template for Accessibility Evaluation Reports for a supplier to:

  • complete an accessibility audit on your self-owned, developed and managed websites, web applications and mobile websites
  • provide a final comprehensive accessibility review of procured web development work.

If your technology is a website or digital service and already meets the WCAG 2.1 AA standard, it should also meet the requirements of AS EN 301 549.

Assemble panel members

To help evaluate accessibility responses your panel should include specialist accessibility advice, such as:

  • Internal accessibility expert
  • External accessibility expert
  • People with lived experience of disability and who may use different types of assistive or adaptive technologies.

Evaluate and compare responses

Ensure all the requirements requested in step 2 are included as appropriately weighted and scored criteria when evaluating submissions.

Compare responses on the following.

  1. Conformance report with AS EN 549 301 and WCAG   2.1.
    1. Summary of the level of accessibility compliance—noting if a VPAT is used ‘partially supports’ is usually not compliant.
    2. Identifies if manual testing or assistive technology was or will be used.
    3. States if the report was done by an external third party or internally.
  2. Usability testing with people with disability and who use assistive or adaptive technology.
    1. Documented evidence is provided.
    2. Practical   demonstrations are offered, including with users with a disability (if   requested).
  3. Product roadmap for continuous accessibility improvements.
    1. Should indicate acknowledgement and understanding of how issues impact access for users.
    2. Outline commitment to fixing issues with short and long-term timeframes.
    3. Offer known workarounds to implement in the meantime.
  4. Quality assurance (QA) processes.
  5. Web accessibility training for vendor staff who work on the product.

Learn more about Interpreting Accessibility Conformance Reports (and VPATs)

If vendors can’t meet the standards

Vendors should be aware of the long-standing international standards. WCAG was first released in 1999 and AS EN 301 549 was released in Europe in 2014 and adopted in Australia in 2016.

If the product or vendor cannot demonstrate the required level of accessibility:

  • Engage an internal accessibility subject matter expert or a third-party digital accessibility consultancy to validate compliance and impact before entering any arrangements with the product or vendor.
  • Determine if another product can be selected or if the vendor needs to address the identified issues.

Select product or service

If no other product or service meets all accessibility requirements:

  • Select the most accessible product or service, that is preferred by people with disability.
  • Request the vendor or supplier provide an accessibility roadmap and outlines any known workarounds that you can implement in the meantime.

Add inaccessible products to your risk register to manage if there are no other suitable options.

Any purchase arrangement or contract (including renewals) must include terms confirming the vendor’s commitment to meet government accessibility requirements.

Contracts must contain:

  • outline of accessibility requirements
  • agreed roadmap with timeframes for accessibility improvements
  • requirements for periodic auditing of compliance
  • actions if contractual requirements are not met (e.g. termination or payment withheld clauses).

Monitor the product or service after deployment:

  • Monitor to ensure it remains compliant with accessibility standards.
  • Seek feedback at set intervals from people with disability to understand if there are any accessibility barriers.