Submission to the Digital Accessibility Standard (DAS) consultation

Download a PDF of submission HERE

Submitted by: Marie Silberstein, Communications and Projects Lead
Organisation: Digital Equity Coalition Aotearoa (DECA) Email: kiaora@digitalequity.nz

Document this submission relates to: https://www.digital.govt.nz/standards-and-guidance/nz-government-web-standards/digital-accessibility-standard/draft-das

Consultation questions:​​https://www.digital.govt.nz/standards-and-guidance/nz-government-web-standards/digital-accessibility-standard/das-consultation/das-consultation-questions

Consultation closes 7 August 2026. Submitted by email to web.standards@gdda.govt.nz on 30 July 2026

Introduction

The Digital Equity Coalition Aotearoa (DECA) is the hub for the digital inclusion community in Aotearoa. We believe that every Kiwi should have clear, appropriate and affordable pathways to participate in digital life. We connect and support the people and organisations working to close the digital divide, from grassroots doers to funders and infrastructure providers, because together we are stronger and have greater impact.

We are not a disability-led or disability-focused organisation, and we do not speak on behalf of disabled people. Our comments here come from our broader work tracking digital equity across government transformation, and from the same evidence base we bring to that wider programme.

We welcome the DAS. Extending accessibility requirements beyond websites to all ICT, and issuing the standard with a statutory mandate and a monitoring and exceptions regime under section 57 of the Public Service Act, sets a stronger accountability model than most digital equity work currently has access to. Our comments below focus on where the draft's technical accessibility requirements could be read as sufficient for inclusion when they are not, and where the standard offers a template worth extending.

Question 1: Preferred contact channels

We support Section 3.6's requirement for multiple contact channels, including a monitored phone line and postal address alongside digital options. We would ask that this be read as a floor, not a ceiling. People who are digitally excluded for reasons other than disability, cost, motivation, low trust, low skills, still need equivalent channel choice. We would welcome this same multi-channel requirement being referenced explicitly as a model when other government services (for example, electoral communications) are reviewed for channel access.

Question 2: How an Accessibility Plan embeds accessibility into organisational culture

We agree that a plan can confirm leadership commitment and set out how exceptions are managed (Section 4.1). We would ask that Accessibility Plans be required to state, in plain language, what a person can expect if the plan's targets are not yet met, not just that an exception has been claimed, but what alternative is available to them today. A plan that is accurate about current gaps is more useful to the people affected by them than one that reads as fully resolved.

Question 4 / Question 16: What would help agencies meet the standard

Case studies from disabled people and communities, and a clear official requirement to comply, are the two most important levers in our view. We would add one point not on either list: agencies need help understanding that meeting EN 301 549 conformance (Section 3.4) is necessary but not sufficient. The iMASTS framework identifies Identity, Motivation, Access, Skills, Trust and Safety as the dimensions of digital inclusion. Technical conformance addresses Access. It does not tell you whether people trust the service enough to use it, have the skills to navigate it, or have a reason to engage with it at all. A conformant, accessibility-statement-compliant service can still leave people excluded if these other dimensions aren't addressed.

Question 6: How organisations should be held to their Accessibility Plan

We support regular reporting to the GDDA and public plan publication (Sections 4.1.3, 4.4.2). We would ask that reporting be genuinely public and comparable across agencies, not just submitted to the GDDA on request, so that the same kind of headline-metric problem we see elsewhere in government digitisation, where an aggregate success figure obscures the excluded group within it, does not repeat here with accessibility scores.

Question 7: Should all public websites and apps have an Accessibility Statement

Yes. We support the requirements in Section 3.5, in particular that the statement must name known accessibility problems and plans to fix them, not only current conformance. This is a good example of an accountability requirement other government standards, including those DECA tracks in the digital inclusion space, currently lack.

Question 10: Where an Accessibility Statement should sit

We have no strong view on central versus per-product statements, but would note that whichever model is chosen, it should be discoverable through the same channel a person would use to raise a general service complaint, not require them to already know DAS exists.

Question 11: Scope of the DAS

We support the broader option, expanding to all ICT including hardware and software, with the staged timeline set out in Section 3.2.2. Limiting scope to websites and documents would leave a widening category of government-facing technology, including connected devices, self-service kiosks, and non-web software, outside any accessibility requirement at all.

We would also note that scope expansion needs to sit alongside enforcement of the contact requirements already in Section 3.6. In our experience, agencies increasingly push people toward app or web-based self-service by making other channels harder to use in practice, phone numbers that are difficult to find, long wait times, or no option for simple email contact. An app can be fully DAS-compliant and still function as the only realistic way to reach an agency, which defeats the purpose of requiring alternative channels at all. We would ask that GDDA's monitoring under Section 4.4 specifically check that listed contact channels are genuinely functional, not just present.

We would also ask that as scope expands, government consider where the same devices and services intersect with sectors currently sitting outside any single agency's clear mandate, so gaps do not fall through jurisdictional lines between accessibility, health, and digital inclusion policy.

Question 13: Exceptions must show technical infeasibility or disproportionate burden

We agree with this test in principle. We would highlight that the "Impact" factor in the disproportionate burden definition, weighing the improvement a change would make for people against its cost, is a genuinely useful accountability mechanism. We would like to see the same cost-versus-impact-on-people test applied more widely across government digital transformation decisions, most of which currently proceed without any equivalent requirement to weigh who is affected against what is saved.

Question 14: Exceptions should be recorded, evidenced, and public

Strongly agree. We would ask that "for a reasonable time after" (Section 5.2.2) be defined with a minimum retention period, so the record survives changes in staff or systems and remains available for public scrutiny over time, not just while the original decision-makers are in post.

Question 17: Other feedback on the draft

We note that the draft was shaped through direct engagement with Whaikaha, Disabled People's Organisations, and disabled people themselves (as described in the accompanying DAS overview). This is the kind of formal, resourced co-design relationship that digital inclusion more broadly does not currently have with any single government agency.

We would welcome the chance to meet with the GDDA to talk through how DAS was developed and what digital inclusion might learn from it. DECA would bring our evidence base and our connections across the digital inclusion community to that conversation.

Ngā mihi,

Marie Silberstein

Digital Equity Coalition Aotearoa (DECA)

kiaora@digitalequity.nz