Accessibility laws · New Zealand

New Zealand: Web Accessibility Standard

The New Zealand Government Web Accessibility Standard names five categories of organisation and binds nobody else. Every Public Service department is the first of them, and then the Police, the Defence Force, the Parliamentary Counsel Office, and the Security Intelligence Service. So it is five entries on a list rather than five organisations, and the first entry alone covers every department in the Public Service. Since 17 March 2025 it has asked for WCAG 2.2 Level AA, subject to six exceptions written into the standard itself. And it reaches inside the building, because intranets and document management systems are in scope alongside the public website.

WCAG version named: 2.2 AA
For public service: Mandatory
Human Rights Act: 1993
Compliance model: Self-assess

What the law is

The Standard is at version 1.2, and the version chain is worth having. Standard 1.0 took effect on 1 July 2013 on WCAG 2.0. Standard 1.1 took effect on 1 July 2019 on WCAG 2.1. Standard 1.2 took effect on 17 March 2025 on WCAG 2.2. Behind all three sits a Cabinet minute from 2003, which is the instrument that actually directs the mandated organisations to implement it. One caution if you go checking. The Standard's own normative clause and its glossary both name five organisations, while the government's informative overview page names only four and leaves out the Security Intelligence Service. The normative text governs, and it says five.

Scope here goes further than most people expect, in three separate directions. It covers every publicly facing and every internally facing web page the organisation is responsible for. So the intranet is in, and so is the web-based document management system. The stated reason is to employ and support disabled staff properly. A logged-in citizen portal counts as publicly facing rather than internal, because the login is controlling access by members of the general public. And web page is defined broadly enough to take in web applications, web services, single page applications, and Word and PDF documents. The government draws a hard practical rule out of that. Content delivered in PDF or Microsoft Word has to be accompanied by an accessible alternative.

Nobody else is bound, and the government says so plainly. Local government, Crown entities, universities, hospitals, and private business are encouraged to follow the Standard, not required to. What reaches them instead is section 44 of the Human Rights Act 1993. It makes it unlawful to refuse to provide goods, facilities, or services, or to treat a person less favourably in providing them, on a prohibited ground. Disability is one of those grounds. The government names two further reasons a public sector body should be accessible anyway. The Bill of Rights Act 1990, and New Zealand's ratification of the UN Convention on the Rights of Persons with Disabilities.

This applies to you if…

You are inside one of the five named categories, meaning any Public Service department, the New Zealand Police, the New Zealand Defence Force, the Parliamentary Counsel Office, or the New Zealand Security Intelligence Service. Nothing else is mandated by this Standard.
You supply websites or digital services to one of those five under contract, where the obligation reaches you through what the agency asks for rather than through the Standard itself.
You are a public sector or local government organisation that is not on the list, in which case you are encouraged rather than required. Version 1.2 also narrowed the scope wording to pages an organisation is responsible for, which means a site you merely contribute to is outside the Standard even for a mandated agency.
You provide goods or services to the New Zealand public, where the Human Rights Act applies whether or not the Standard does. Two limits in section 44 are worth knowing. Supplying at a reduced rate on the ground of disability is not a breach. And a supplier may refuse to provide services in a special manner, where the person's disability requires that manner and the supplier cannot reasonably be expected to provide it.

What it technically requires

Conform to WCAG 2.2 Level AA on every page you are responsible for, publicly facing and internally facing alike, and treat the PDFs and Word documents as pages too. The Standard also splits websites finely for reporting. Sections of a department site owned by organisationally distinct units can count as separate websites, and different fourth-level domains under one third-level domain count separately as well.
Read Section 3 before you scope the work, because the WCAG 2.2 requirement is qualified by six exceptions and two of them are outright exemptions. Complex visual maps are exempt from the text-alternative criterion, on condition the underlying data is published in open, machine-readable formats. The definition is tight, so a topographic map with contour lines qualifies and a weather map made of sun and cloud icons over named regions does not. Inactive web pages are exempt from WCAG conformance entirely, on four conditions, one of which is that the page carries accessible instructions for requesting an accessible version. The other four exceptions modify the audio and video criteria rather than removing them.
Treat a should as a requirement, because New Zealand says so in writing. The Standard uses the formal keyword sense, and the government defines a should requirement as one that has to be met unless there are valid reasons not to and the impact of that decision has been considered. Live captions should now be provided for all live audio in synchronised media, and must be provided where the content carries high-stakes information or services. Audio description should be provided for all prerecorded video published on or after 17 March 2025, and must be provided for high-stakes content.
Learn the high-stakes definition, because it is the best prioritisation list any government has published. It covers content whose inaccessibility could reasonably be expected to hurt a disabled person's emergency preparedness and response, their health and safety, or their critical civil and political rights and entitlements. The list names disability, emergency response and recovery, and entitlement to benefits, food, housing, education, consumer protections, passports and visas. It goes on to name rights in criminal and civil proceedings, national elections and referenda, tax obligations and rebates, health information and advice, health and safety at work, and public consultations on policy and legislation. Internal content can be high-stakes too, and the example given is a restructure and the positions open to affected staff.
Caption properly, and the government has put a number on properly. Its guidance says automated captions are not accurate enough to rely on, that human intervention is needed, and that the industry standard is 99% accuracy including spelling, grammar, and punctuation. Live video there means broadcast video, not two-way calls on Zoom or Teams, where the host is responsible for captions if a participant needs them. Third-party widgets you neither funded nor developed nor control are outside the Standard, but a widget you chose to put on your site is expected to meet it.
Meet the companion Web Usability Standard, now at version 1.4 and effective on the same date, which binds the same five organisations and covers what WCAG never touches. Publicly facing websites need a government identity element, contact information, a general copyright statement, and both an organisation privacy statement and a website privacy statement. The contact rules are specific. An email address monitored daily, with emails acknowledged inside 3 business days and an indication of when a full answer will come. Plus a link to the New Zealand Relay Service, which moved from a should to a must in this version. Two of its requirements reach internal sites too. Links to non-HTML files carry the format and size, and should carry them inside the link text itself. A screen reader announcing a link out of context reads the link text and nothing else.

All roads lead to WCAG. Start with Level AA, the legal standard or the full 55-rule library. Unfamiliar term along the way? The A to Z glossary decodes it.

How it is enforced

For the mandated five, this runs on assessment rather than on courts. When the Government Chief Digital Officer notifies you, you assess your conformance, submit a conformance report, and submit a risk assessment and a risk management plan covering your non-conformances, using the methodology the office supplies. There is also no exemption process. The government states flatly that no mandated organisation can secure an exemption, and that each one is responsible for meeting the Standard and accepts the risks of not doing so.

For everyone else, the route starts with a complaint to the Human Rights Commission and can go on to the Human Rights Review Tribunal. That Tribunal issues binding decisions and it can award money, which the page never used to say. Its remedies run to declarations of breach, restraining orders, orders to perform specified acts, training orders, and damages covering pecuniary loss, the loss of a benefit, and humiliation, loss of dignity, and injury to feelings.

On the size of those awards, we will give you the range and its caveat. The Ministry of Justice's own remedies list runs from around $400 to about $120,000 in New Zealand dollars, and those are awards across every kind of case the Tribunal hears rather than accessibility cases. You will find figures quoted online as a statutory cap, and we could not verify any of them against the Tribunal's own material, so we are not going to repeat them. Ask a New Zealand lawyer what the Tribunal's current monetary jurisdiction is before you plan around a number. We also found no decided New Zealand case applying section 44 to a website.

The bigger change is the one that has not landed yet. The Government Chief Digital Officer is working to replace the Web Accessibility Standard with a Digital Accessibility Standard. It would cover all digital content and services rather than websites alone, mobile apps included. The office has also said it intends to recommend the new standard apply to more public sector organisations than the current one reaches. Nothing has commenced, and the organisations in scope are still being settled, so treat published timings as a plan rather than a date you can rely on. If you are building for a New Zealand agency now, build for the wider scope.

Key dates

2013Web Accessibility Standard first mandated
2019Standard updated to reference WCAG 2.1
Mar 17, 2025Standard 1.2 takes effect, requiring WCAG 2.2 Level AA

What to do about it

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Orientation only, current as of August 2026. Not legal advice, and no attorney-client relationship is created. For your specific situation, talk to your own lawyer.