Summer 2023 // Canadian Government Executive / 7 ACCESSIBILITY Canadian government departments are not required to publish data on the accessibility of their digital services. This year, we should start to see department specific reports against the accessibility action plans of that department. Unfortunately, this is way too general. It is unclear if these will be public. The lack of specificity makes it impossible to provide a government-wide report on digital accessibility for the Government of Canada. We will not be able to know if the government as a whole is making progress. Most government websites do not even meet Web Content Accessibility Guidelines (WCAG) 2.0 AA, let alone the current best practices. More importantly, government services continue to present barriers to Canadians. For many working in government, this will be new information. The assumption for most federal employees is that the government is already meeting the WCAG 2.0 AA requirements. There was a clear decision of the 2012 Supreme Court in the Donna Jodhan Case which reinforced that having an inaccessible site is a violation of Charter rights. At that point all government websites were mandated by the courts to ensure that they meet WCAG 2.0 AA. The Accessible Canada Act was intended to be a brave step in improving services for disabled Canadians. The act targets the Government of Canada and about 20,000 federally regulated organizations. There is space within the act to regulate those organizations, but the act was signed in 2019 and Canada seems to be falling further behind. Progress on digital inclusion in the Canadian government has just not kept up with the changes in technology, or advances made by other governments. Fortunately, there are best practices in digital inclusion that can be applied from other governments globally, including the UK and the EU. Canada clearly needs to jumpstart its accessibility maturity, to ensure that it is addressing the inclusion challenges of 2023 with approaches that are appropriate for today. 1) Clearly state that PDFs must be avoided The most cost-effective and inclusive approach to document accessibility was provided by the UK government. They highlighted not only that PDFs are a problem to assistive technology users, which they are, but also that they present a significant problem for anyone using a smartphone. Unlike HTML, PDFs generally do not reflow to fit the size of the screen. PDFs are an ongoing problem with accessibility. It is commonly known that most PDFs present barriers to access for people with disabilities. PDFs were never built to be accessible. Efforts to add accessibility into the format are only partially successful. They exclude low vision users as well as anyone trying to read a document on their cell phone. They are an outdated format that excludes many Canadians. It is still too easy to publish PDFs, and too difficult to make them accessible. This is especially true with PDF forms. Sadly, for people without accessibility expertise, it is still nearly impossible to distinguish between accessible and inaccessible PDFs. The Treasury Board should clearly state that government content should be published in HTML, and that PDFs should be avoided. Write clear guidance indicating how to write accessible documents and warning people about the challenges that are inherent with PDFs. Provide accessible templates for agency document policies to help enforce this. Automate Basic PDF Validation If government agencies insist on using PDFs, there needs to be automated validation built in to block the PDFs that obviously fail to meet accessibility standards. Canada should build on open source tools like Luxembourg’s simplA11y PDFCrawler, which can collect PDFs and evaluate them for basic accessibility issues. While Luxembourg is a very small country, this approach could be expanded so that it could serve much larger government agencies to automate the process of identifying inaccessible documents. Many of the approaches here could also be incorporated into CMS like Drupal or WordPress. It is possible to evaluate if documents have basic semantic markup within the PDF and block files from being The Treasury Board should clearly state that government content should be published in HTML, and that PDFs should be avoided.
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