OpenAccess

Do NZ Government videos need audio description?

Callum McMenamin — 15 May 2025

Audio description makes videos accessible for people with low vision or blindness. Does the NZ Govt Web Accessibility Standard require audio description?

What is audio description?

Audio description is a method of including additional spoken narration into a video to make it more accessible for people who are blind, or have vision impairment.

Videos that contain graphical information or text without a spoken narration of that information cause obvious and significant accessibility problems if you can’t see that information.

Audio description can also include narration of actions, facial expressions, hand gestures, and scenery — any visual details essential to understanding the video.

You might notice most Netflix and Apple TV shows have audio description tracks available by default. When first enabling audio description, you might find the voice somewhat distracting, but after a couple of episodes it fades into the background and you stop noticing it.

As someone with vision impairment myself, I can’t stress enough how important audio description is for producing accessible video — any assumption that it’s a ‘nice to have’ is plain wrong, in my opinion.

What does the Web Accessibility Standard require?

The NZ Govt Web Accessibility Standard applies to:

• every Public Service department
• the New Zealand Police
• the New Zealand Defence Force
• the Parliamentary Counsel Office
• and the New Zealand Security Intelligence Service (never underestimate disabled spies)

Annoyingly, the Web Accessibility Standard doesn’t apply to local councils, Crown agents like the entire god damn health system, and ACC. There are, however, plans to change this by 2027.

The Web Accessibility Standard audio description clause

Note: “synchronised media” basically means video with sound.

The problem with the requirement

The audio description requirement inside the NZ Govt Web Accessibility Standard has been routinely criticised by blind disability rights advocates many times (including myself).

The issue, is it starts by making audio description a should requirement, rather than a must requirement. Given Netflix and Apple TV are capable of making audio description standard practice, it doesn’t seem unreasonable to expect a literal nation state to be capable of the same accessible design practice.

What’s even more amazing, is I’m unsure if I’ve ever heard a single audio-described video produced by the New Zealand Government. Maybe they’ve never made one. I’d love to be corrected on this.

What does “should” and “must” mean?

One important aspect of the requirement, is to really understand what the words “should” and “must” mean in the Web Accessibility Standard.

“Must” and “should” actually have special, precisely defined meanings in the Web Accessibility Standard, that conflict with an informal understanding of the words.

Most people, reading a requirement that says “you should do this”, leaves you with the impression that it’s just a suggestion, a totally optional task.

But, here’s how the Web Accessibility Standard defines “must” and “should”:

This definition does show that a should requirement is a “recommended course of action”, however, the definition clearly requires that the full implications of ignoring the requirement need to be understood and carefully weighed. I suspect many organisations accidentally skip that step before they make those decisions — and most audio description on video is skipped simply due to ignorance of the requirement.

But, there’s high-stakes information or services!

The requirement for audio description clearly states, that if information or services are high-stakes, then audio description gets bumped from a should to a must requirement.

Helpfully, the Web Accessibility Standard also provides a definition for what constitutes high-stakes information or services:

The definition of “high-stakes” is so broad, it basically just describes everything the government does.

The phrase “critical civil and political rights, entitlements, services, or obligations” in the high-stakes definition, is basically the core of it. It’s such a broad definition, it’s hard to think of a single government video or piece of information that wouldn’t somehow become high-stakes.

Arguably, if any government information were inaccessible to a disabled person, it would clearly breach their critical civil rights, assuming we, as a society, agree that disability rights are critical civil rights.

The Web Accessibility Standard also requires a descriptive text transcript, which generally requires that videos have a text-based alternative that includes all visual and auditory information within the video. But in practice, these transcripts are often a poor substitute for audio-described video content. The user experience of a blind person having to use a screen reader to access a video transcript’s visual descriptions just to understand what the video is about — is not fair or equitable, if technologies like audio description exist.

But, audio description is too expensive!

Often, cost is used as a way to deny disabled people access to things.

Audio description, if retrofitted into existing video, could conceivably be relatively costly, if you outsource it. It involves video editing, narration, and expertise in good audio description techniques.

However, there are two serious problems with this mindset:

1. the assumption that video should be costed without accessibility costs baked in
2. the assumption that audio description is always expensive.

So, if a public sector agency is considering making a video, these are generally relatively expensive forms of communication, compared to text-based web pages.

The entire idea that video accessibility features like captions and audio description are bolted-on extras is an inherently discriminatory way of thinking.

If you’re budgeting for a video, then captions, audio description, and transcripts are part of the production process — as essential as a camera or microphone.

Secondly, audio description doesn’t necessarily need to be expensive — when developing the script for the video, simply ensure you have a narrator that verbally explains what’s going on visually. It’s not exactly rocket science.

Imagine for a moment — if the roles were reversed. Would a public sector agency allow a video to be published if it were totally inaccessible to people with sight? Would you release the video if all of the visual information were missing and instead replaced with static? No, of course not. So why would we provide that same experience for disabled people?

So… is audio description on video mandatory?

Well, if I were working in a government agency, I would consistently argue that all videos released by government agencies must have audio description.

I think the scenarios where video would not meet the definition of “high-stakes” would be very limited and rare.

Unfortunately, I suspect many organisations either aren’t aware of the audio description requirements, or they latch on to the word “should”, and assume it’s totally optional. The combination of these factors has led to a situation where practically no government videos have audio description.

Don’t even get me started on TVNZ+ totally lacking audio description. What’s most absurd, is they actually fund audio description to be produced for their media, but it’s only available via Freeview/Sky broadcasts, not on the web. The fact TVNZ still hasn’t addressed this problem is genuinely appalling.

So, in the absence of a standard that clearly makes audio description a “must” requirement, I think public servants owe it to the blind and low vision community to argue this case to the fullest extent.

— Callum