Québec’s web accessibility standard: what it requires of public bodies

Which organizations it covers

The standard is published in French only. It applies to the public bodies listed in section 2 of the Act respecting the governance and management of the information resources of public bodies and government enterprises (chapter G-1.03). In the English version of the Act, section 2 lists, among others:

• “government departments;”
• the budget-funded and non-budget-funded bodies listed in Schedules 1 and 2 of the Financial Administration Act, and the Sûreté du Québec;
• “school service centres, school boards”;
• “general and vocational colleges and the educational institutions at the university level” named in the Act;
• Santé Québec (named in the current French text), health and social services institutions and several network bodies, including the Office des personnes handicapées du Québec and the Régie de l'assurance maladie du Québec;
• “other bodies designated by the Government.”

Municipalities are not in section 2. They fall under a different provision: section 61.1 of the Act to secure handicapped persons in the exercise of their rights with a view to achieving social, school and workplace integration (chapter E-20.1) states that “every local municipality with at least 10,000 inhabitants shall adopt an action plan” identifying barriers to the integration of persons with disabilities. That section does not mention the web or refer to the standard. A municipality can still ask its supplier to follow the standard; the contract or call for tenders then sets the requirement.

The standard stems from the government policy on access to documents and services offered to the public for persons with disabilities, provided for in section 26.5 of the same Act, under which “the Government shall establish a policy directing government departments and public agencies” to adopt reasonable accommodation measures.

What content, and since when

The version in force is SGQRI 008 3.0, which took effect on April 29, 2024. It is not retroactive across a whole site: it applies to all new web content from the design stage, and to existing content when that content undergoes a significant modification.

The scope is broad. It covers public websites as well as intranets, extranets and web forms, and all web content, including downloadable documents and multimedia. PDFs, videos and forms on a rebuilt site are part of the job.

The required level: WCAG 2.1 AA, with adjustments

The standard uses WCAG 2.1, described as the most recent version available in French, and sets level AA as its general target. In detail:

• all WCAG 2.1 level A success criteria;
• level AA criteria, except 1.2.4 Captions (Live) and 1.2.5 Audio Description (Prerecorded);
• at level AAA, only criteria 2.3.2, 3.1.4 and 2.5.6.

The standard also goes beyond WCAG 2.1. It states that WCAG 2.2, while not yet officially translated into French, contains essential criteria that must be met now, and lists seven of them:

• level A: 3.2.6 Consistent Help and 3.3.7 Redundant Entry;
• level AA: 2.4.11 Focus Not Obscured (Minimum), 2.5.7 Dragging Movements, 2.5.8 Target Size (Minimum) and 3.3.8 Accessible Authentication (Minimum);
• level AAA: 2.4.13 Focus Appearance.

These are among the criteria added in WCAG 2.2, a W3C Recommendation published on October 5, 2023. They land squarely in design and front-end work: target size, focus that must not disappear under a sticky header, an alternative to drag-and-drop, sign-in without a cognitive test, and help placed consistently across pages.

The Accessibility page

A requirement often missing from quotes: every web page must include an “Accessibilité” link to a page describing the main measures taken. That page includes a link to the standard's web page, the name and version of each assistive technology used for verification, a description of the site's icons, and an offer of assistance. Agencies should therefore record the tools and assistive technologies used during testing, since that information has to appear there.

Exempt content and exceptional circumstances

The standard provides exemptions, among others for:

• external web services, including social media and live video;
• non-informative interactive games and dynamic web mapping;
• raw data published in an open format, and content that can only be offered as a scanned image;
• content from a third party not subject to the standard, or produced in response to an access-to-information request.

An exemption is not silence: exempt content must carry a notice that it may not meet the requirements, and it must be made accessible on request, or assistance offered when that is impossible. The standard also describes exceptional circumstances in which content that does not meet its requirements may be published temporarily; the conditions are set out in the section of the same name.

What it means for the agency

The standard is addressed to the public body, not its supplier: it mentions neither contractors nor calls for tenders. The deputy minister or head of the body is responsible for carrying out the necessary audits, applying corrections, monitoring new WCAG versions and keeping the organization's Accessibility page up to date. The agency that builds the site supplies what those responsibilities rely on. In practice:

1. check at the proposal stage whether the client is listed in section 2 of the G-1.03 Act, or whether its contract refers to the standard;
2. build the seven selected WCAG 2.2 criteria into mockups and the component library before development;
3. include downloadable documents, videos and forms in the testing scope;
4. record the tools and assistive technologies used for testing, and prepare the Accessibility page;
5. pair automated testing with manual review. As the W3C puts it, “Tools cannot check all accessibility aspects automatically. Human judgement is required.”

For the first pass, AccessAudit runs its scans with axe-core, applying the rules tagged for WCAG 2.0, 2.1 and 2.2 levels A and AA, and produces a report and PDF carrying the agency's name, logo and colour. That automated pass does not replace manual review or testing with the assistive technologies the Accessibility page has to name.