A digital accessibility standard that (maybe?) forgot the health system

Callum McMenamin — 28 July 2026

NZ’s public health system is one of the most important government services we interact with. So why does the government’s draft accessibility standard exclude health?

A new draft standard is announced

The Government Digital Delivery Agency (GDDA) opened public consultation on a new draft Digital Accessibility Standard (DAS) from 13 July to 7 August 2026. Disabled people have been given a whopping 26 days to read, understand, and reply to a large shift in disability policy in Aotearoa.

The new draft standard does have some significant improvements over the old Web Accessibility Standard it replaces. The old standard only applied to webpages, but the new draft applies to software, apps, non-web documents like Word files, and hardware. It certainly does have a number of positive changes, but my concern is a larger, more structural flaw.

Upon opening the DAS, the first thing I checked was: who does this apply to?

And I was immediately annoyed. The health system isn’t in the scope of the the mandatory digital accessibility standard requirements.

Now, I might seem unreasonable here — but I think our health system should be accessible for disabled people. And to achieve that, accessibility standards should apply to Te Whatu Ora (Health NZ) and ACC.

A quick note: from here on, when I refer to “health” or the “health system”, I also mean ACC. ACC is a core agency that interacts with disabled people.

I continued reading the draft standard. I looked at the main explainer page of the DAS, which states:

And, section 2.3 of the draft standard states:

Well… that’s not helpful. How can I know if I support the standard if I have no clue what parts of government will have to meet it? 🫪

So, it’s time for me to dust off my amateur investigative journalist skills, and figure out how this all happened.

How was health considered in the development of the DAS?

On 20 July 2026, I fired off a fairly meaty Official Information Act request to the Public Service Commission. The request will (hopefully) reveal how the GDDA came to the conclusion to exclude health from the draft DAS. I should hear back by 17 August 2026.

While we wait for the OIA to cook, what can we infer from publicly available information? Let’s start digging 🕵️‍♂️

The DAS’s explainer page has a “How we created the new standard” section:

I am happy that Whaikaha was involved. But notice that the explainer above contains no concrete mention of consulting with the health system. Is this evidence of a bureaucratic silo leading to bad outcomes? Maybe.

The research that informed the standard

The “how we wrote this” explainer does state that they used findings from the 2025 Accessible Digital Government Services for New Zealand research.

So, we must now ask: did this research cover the accessibility of health services?

I opened the report and whipped out the trusty ol’ Cmd + F and typed in “health”.

Unfortunately, there are only 3 results — none of which were particularly relevant.

What if we search for “ACC”? Zero results.

Okay, so with a couple of searches we can conclude this research did not properly inform standards development related to health systems.

This sounds like the bureaucratic crack is gaping wide, for every hospital in the nation to fly through.

Why do I think they’re excluding health?

While I can’t prove intent, I have a fairly likely idea of what is going on here.

TL;DR — the law has silly boundaries. Those silly boundaries may lead to the health system being excluded from mandatory requirements. There are other mechanisms that could include health, but they are not mentioned in any available public evidence.

It all lies in the legal intricacies of the Public Service Act 2020.

The Public Service Act 2020 created things called “system leaders”. They are a handful of Public Service chief executives who are appointed to lead specific areas across the public sector.

The chief executive of the Public Service Commission is the “Digital Lead” or GCDO (Government Chief Digital Officer).

The Public Service Act 2020 section 57 gives System Leads powers to create standards and guidance, which is how the Digital Accessibility Standard will be enacted:

So s 57 basically says system leaders can:

• issue standards for public service agencies, and
• issue guidance for all State services.

I suspect most normal humans would have no idea what this means.

Basically, there are different categories of government agency. Some are in the “public service agency” category (like Ministries). Some agencies, like Te Whatu Ora are not public service agencies — they are instead in a category called “Crown agents”.

“Crown agents” are within the “State services”, though.

Huh? 🤯 What does all that mean? 😭

It means:

• the Public Service Act does not allow the Digital Lead to set a standard that Te Whatu Ora must follow.
• the Digital Lead can issue guidance for Te Whatu Ora.
• however, guidance is not required to be implemented by Chief Executives.

So, the Digital Lead can just point at the Digital Accessibility Standard and say to Te Whatu Ora “hey guys, pretty please meet this standard?”, with literally zero legal authority requiring Te Whatu Ora to actually listen.

So from this point onward, I consider “guidance” to be practically equivalent to excluding the health system from the Digital Accessibility Standard’s requirements.

So where does this leave us?

Well, it leaves us in an astoundingly absurd situation where the Ministry of Health is required to have accessible ICT for disabled people, but Te Whatu Ora is not.

The agency responsible for policy (the Ministry) is required to be accessible, but the agency that actually provides health services is just “encouraged”.

This policy does not make sense, and it cannot be allowed to seem normal or logical.

What could be done?

Currently, I suspect the GDDA is using the Public Service Act’s provisions to justify not having a cohesive standard. I can’t prove this suspicion until I get an OIA response, however.

The GDDA must look past the Public Service Act’s limitations. This will require co-ordinating across different sectors of government. Actually talking to Te Whatu Ora and the Ministry of Health, to try and understand from their experts, how a cohesive standard could be created and applied.

Don’t just roll over and say “this is too hard”. Because what is currently proposed is an unmitigated disaster. “Guidance” and “strong encouragement” is no substitute for actual requirements.

There are certainly mechanisms that could be used, it’d just take a bit more legwork. I’m no legal expert, but the Crown Entities Act s 107 allows for the Minister for the Public Service and the Minister of Finance to set requirements on Crown agents — this could be used to cover the health system and ACC in a single sweep. Given GDDA is literally inside the Public Service Commission (they report to the Minister for the Public Service!) it surely couldn’t be that difficult to coordinate.

What I will be watching closely is whether the government actually adequately explored these avenues, or whether carving out the entirety of health was simply accepted without inter-agency collaboration, or proper analysis of the consequences.

The harms are not just theory

I have written extensively about the failures of standards that were not monitored or enforced in the health system before. See: ManageMyHealth Hack: A failure of standards

When a health system has incompetent IT security, it often leads to scary headlines and large amounts of media attention. People get freaked out about spooky hackers and data breaches.

But the harms of a non-accessible health system are far more dangerous and insidious. The harms occur without a large fiasco or a storm of media attention. The harms occur when standards are designed to suit the bureaucracy instead of human beings.

The harms occur when a nurse with vision impairment is bullied out of her job by colleagues, because she takes longer to use the patient management system as the company that built it did not factor in supporting increased font sizes.

The harms occur when a hospital administrator becomes blind due to genetic macular degeneration, and the hospital’s Microsoft Excel documents are not compatible with screen readers. The management starts pulling her up on minor errors in an effort to make her resign. Not because she’s a bad employee — but because they are afraid of disabled people and want them out of their team. She resigns. She ends up on a benefit and loses her home and all her belongings as a result.

The harms occur when a high school student with cerebral palsy is considering a career as a doctor, but they are told the software they’d be using only works for people who can use a mouse precisely. The people who designed the software thought to themselves “there are no disabled doctors, that’s ridiculous!” and removed WCAG compliance from the requirements, and Te Whatu Ora had no rule to stop that. The student gives up on their dream to be a doctor as a result.

The harm occurs when disabled people are systematically removed from working in the health sector; so nobody in the health system understands us or our needs.

The harms occur in the accumulation of small moments of exclusion that nobody seems to care about, except the disabled people who experience them. Those moments where I am sent a physical letter I can’t see. The moments I can’t see what medication I am about to take. The moment I can’t read what dose I should take. The moment I go to a hospital and I cannot see the signage and become lost. The moment I am asked to fill out a huge paper form at the hospital and nobody is there to help me. The moments I open my GP’s portal app and the font size physically cannot be increased to see a test result.

Health is not an insignificant part of government. It’s literally the biggest part of government. It deserves to be included in the Digital Accessibility Standard.

— Callum