An accessibility policy is not just about intent. It’s also where the minimum bar is set. And when that bar is still WCAG 2.1 AA, originally released in 2018, that decision affects how seriously accessibility gets embedded into digital delivery.

The ACT Government Web Accessibility Policy applies to Government content delivered through a web browser.

That includes websites, intranets, extranets, social media, web forms, web applications, and PDFs.

Crucially, it also extends to government information delivered through third parties, partnerships, and funded programs.

At the centre of the policy is the requirement that in-scope web content must comply with the Disability Discrimination Act 1992 by following WCAG 2, specifically 2.1 at Level double A for new or redeveloped sites.

The problem is that WCAG 2.1 is now an older version. It was first released in 2018, and when organisations adopt an earlier version, the minimum bar usually falls below current accessibility practice.

This ultimately weakens procurement rules and design and delivery expectations. It also leaves out newer criteria introduced in WCAG 2.2, including stronger focus visibility, larger touch targets, and alternatives to drag-only interactions. In practice, introducing more usability barriers and slower accessibility uplift across government.

Now, to be fair, the policy does try to encourage agencies to aim higher, particularly toward WCAG 2.2 at level double A or even level triple A.

But that also reflects the broader position being taken by the DTA. So, the benchmark here feels shaped more by federal government inertia than adopting the best available accessibility standard of the day.

The policy says disability-focused or critical information should ideally conform to WCAG 2.2 level triple A. Which on the surface sounds strong and user-focused. But in practice, triple A is not usually used as a full site-wide target because triple A success criteria are often difficult to apply broadly.

So, this creates a mixed message.

A clearer approach would be something like “all new or redeveloped content must meet WCAG 2.2 double A. For high-impact content, agencies should also consider relevant triple A criteria where feasible.”

So that keeps the baseline clear while still encouraging stronger accessibility support where it makes sense.

The policy also says legacy sites and content must either be brought up to WCAG 2.1 double A or decommissioned. But it doesn’t explain how that’s meant to happen.

There’s no delivery mechanism, no timeframe and no migration strategy. Without that practical pathway, agencies can end up tolerating large volumes of inaccessible material and relying on risk acceptance instead of real remediation.

Non-conforming content is meant to be recorded on the agency’s risk register, along with mitigation strategies and action plans. That’s promising in one sense, because it builds accessibility into risk management rather than treating it as just a publishing issue.

But it can also become an administrative safety valve. Accessibility debt gets recorded and managed rather than fixed. From our point of view, risk registers are useful, but they shouldn’t become a substitute for remediation efforts and release controls.

The policy says agencies should prioritise making all new content, sites, and functionality accessible, with particular attention to high-priority areas like customer services, education, revenue collection, emergency information, health information, and content aimed at disability-related audiences.

Agencies are expected to make prioritisation decisions based on use, audience, legal publishing obligations, sensitivity of function, and risk, cost, and benefit.

In terms of ownership, responsibility for accessibility is shared across government.

Digital Canberra maintains the policy and provides advice and support.

Directors-General and agency heads are accountable for compliance.

System owners are expected to coordinate implementation, maintain registers and mitigation plans, arrange testing, ensure skills and training, procure accessible goods and services, and handle complaints or requests for accessible alternatives.

Staff involved in web systems are also expected to understand the requirements, undertake training, follow the policy, and support conformance checking and reporting.

So overall, the ACT Government has kept WCAG 2.1 double A, a version released in 2018, as the minimum enforceable release standard, while signalling that WCAG 2.2 is the direction of travel and current best practice.

It frames accessibility as a whole-of-agency responsibility tied to legal risk, publishing, procurement, testing, and governance, rather than something left to developers at the end.

So the policy points in the right direction. But if the minimum bar is still WCAG 2.1 double A, then the real question is whether this will genuinely lift the delivery of ACT Government digital services, or simply make an older standard easier to defend. Because in the end, what matters is not the wording of the policy. It is whether it changes what gets built, and what is allowed to go live.