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Digital Experience Policy Exemption Guide
Introducing the Exemption Guide
The DTA recognises that government may face challenges in applying the requirements of one or more of the standards mandated by the Digital Experience Policy to their digital service/s.
The Exemption Guide provides information on when an exemption might be appropriate, how to apply for an exemption and agency responsibilities.
The Digital Experience Policy
The Digital Experience Policy sets a whole-of-government focus on improving the experience for people and businesses interacting digitally with government information and services. It strengthens government’s Investment Oversight Framework (IOF) by implementing a centralised approach to measuring digital experiences to support a targeted approach to investments. It also uplifts the digital service experience by providing clear guardrails for agencies to design, deliver and improve digital services with greater consistency, aligned to best practice that leave no-one behind.
The Digital Experience Policy includes a suite of standards and guidance that support the government to deliver more cohesive and consistent digital experiences, aligned to the Data and Digital Government Strategy.
The Digital Experience Policy’s suite of standards includes the:
- Digital Service Standard, which ensures consistent and high-quality digital service delivery across government.
- Digital Inclusion Standard, which ensures services are designed to be inclusive, leaving no one behind
- Digital Access Standard, which aims to improve service discoverability and ease of access points for all users.
- Digital Performance Standard, which sets criteria for monitoring and reporting on the performance of digital services.
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Informational services
Informational services provide information, such as reports, fact sheets or videos, to users.
They may include:
- government agency websites
- smart answers and virtual assistants
- e-learning
- publications
- multimedia.
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Transactional services
Transactional services lead to a change in government-held records, typically involving an exchange of information, money, licences or goods.
Examples of transactional services include:
- submitting a claim
- registering a business
- updating contact details
- lodging a tax return.
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The Digital Experience Policy does not cover services such as state and territory services, however agencies may still choose to apply the policy and standards to improve a quality digital experience for their users.
Each standard should be consulted individually to determine if, and when, it will apply to your entity’s planned or existing digital services.Availability of exemptions for my service
The DTA acknowledges that some agencies may be unable to meet the requirements due to a range of circumstances.
Exemptions will not apply at a Whole of Policy level. This means your service will not be made exempt from complying with the Digital Experience Policy in its entirety. Instead, exemptions may be granted for one or more of the criteria set out by the standards mandated by the Digital Experience Policy, depending on the circumstances.
Exemptions being sought for new or transformation of existing services being brought forward through the budget process can be raised through the most appropriate state of the Investment Oversight Framework. Exemptions being sought against the Digital Service Standard requirements for existing services (applicable after 1 July 2025) should be made in writing to standard@dta.gov.au.
Exemptions could vary in nature, being permanent, temporary, partial or full and may apply to one or more criteria or the entire standard. This will be assessed on a case-by-case basis and must be applied for through the DTA.
The Compliance and Reporting Framework sets out the requirements and thresholds for reporting under the Digital Experience Policy. To reduce the administrative burden on agencies, the DTA will only assess exemption requests that fall within the scope identified in the Compliance and Reporting Framework.
Guidance about the exemption requirements for each standard are highlighted below. If you believe your service won’t be unable to meet the requirements for a reason not listed below, please contact the DTA by sending an email to standard@dta.gov.au.
On request, the DTA will work with agencies to consider exemption eligibility and support them through the exemption process.
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Digital Access Standard
Under the Digital Experience Policy, the Digital Access Standard is mandatory and applies to digital services that are:
- owned by non-corporate Commonwealth entities
- informational or transactional
- authenticated or unauthenticated
- new or replacement of existing services that are public facing.
Agencies may seek an exemption from the Digital Access Standard due to a range of circumstances. These circumstances may include, but are not limited to:
- legacy technology barriers that cannot reasonably overcome
- substantial financial burden caused by changing a service to meet criteria
For services being considered for integration into myGov these circumstances may include, but are not limited to:
- lack of user access to myGov, ineligibility for a myGov account or where it does not make sense for users to have a myGov account.
- legislative or regulatory barriers preventing the service from being delivered via myGov.
- circumstances where Services Australia has indicated that it is unable to onboard the service onto myGov.
Example:
Agency X is replacing an existing digital platform where tourists can apply for tax refunds for some goods bought in Australia that are then taken out of the country with the traveller on a plane or ship. Agency X understands that the new Digital Access Standard is applicable to new and replacement services suitable for myGov from 1 January 2025.The Agency applies the decision-making framework under criterion 4 of the Digital Access Standard. The target users of the replacement service are tourists visiting Australia on a temporary basis, even though the service targets individuals, myGov is not considered the best place to locate access to the service.
Agency X applies for an exemption under criterion 4 of the Digital Access Standard. In their request, Agency X provides information and evidence to build a case that their system is unsuitable to be onboarded onto myGov. After reviewing the exemption request and accompanying information and evidence, the DTA grants an exemption from the relevant Digital Access Standard criteria.
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Digital Inclusion Standard
Under the Digital Experience Policy, the Digital Inclusion Standard is mandatory and applies to digital services that are:
- owned by non-corporate Commonwealth entities
- informational and transactional
- new or existing public facing (from 1 January 2025)
- new staff facing (from 1 January 2026).
Agencies may seek an exemption from the Digital Inclusion Standard due to a range of circumstances.
These circumstances may include, but are not limited to:
- legacy technology barriers that cannot reasonably overcome
- substantial financial burden caused by changing a service to meet criteria.
Example:
Agency X operates an informational website about their suite of services available to the public. Agency X understands that the new Digital Inclusion Standard is applicable to for existing services from 1 January 2026. The agency does not believe they will meet the deadline for compliance, without significant investment and risk to other priority programs.
Agency X applies for an exemption from the requirements and requests an additional 6 months to allow the agency to complete some minor system upgrades and meet the Digital Inclusion Standard’s criteria. Agency X provides the DTA with evidence of their system upgrades and their expected completion dates.
After reviewing the exemption request and accompanying information and evidence, the DTA grants an exemption from relevant Digital Inclusion Standard criteria for a period of 6 months. In their response, the DTA highlights that Agency X has been granted a limited exemption noting that once their system upgrades have been completed, they would then need to reconsider and apply the Digital Inclusion Standard requirements or seek a separate exemption from the Digital Inclusion Standard criteria.
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Digital Service Standard
Under the Digital Experience Policy, the Digital Service Standard is mandatory and applies to digital services that are:
- owned by non-corporate Commonwealth entities
- informational and transactional
- new public or staff facing (from 1 July 2024)
- existing public facing (from 1 July 2025).
Agencies may seek an exemption from the Digital Service Standard due to a range of circumstances.
These circumstances may include, but are not limited to:
- legacy technology barriers that cannot reasonably overcome
- substantial financial burden caused by changing a service to meet criteria.
Example:
Agency X owns and operates an existing digital grants system using technology that doesn’t support easy interoperability with other systems. Agency X understands that the new Digital Service Standard is applicable to existing services from 1 July 2025. They assess their system and believe they can meet all criteria of the Digital Service Standard except criterion 4, without significant investment due to the technology barriers.
Agency X applies for an exemption from criterion 4 of the Digital Service Standard. In their request, Agency X provides information and evidence to demonstrate how their system is unable to meet criterion 4.
After reviewing the exemption request and accompanying information and evidence, the DTA grants an exemption from criterion 4. In their response, the DTA highlights that any enhancements or changes made to the system in the future would need to be reconsidered and to apply the Digital Service Standard requirements or seek a separate exemption from the Digital Service Standard criteria.
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Digital Performance Standard
Under the Digital Experience Policy, the Digital Performance Standard is mandatory and applies to digital services that are:
- subject to the requirements of the Investment Oversight Framework
- considered during, and after the 2025-26 Budget process and thereafter
- new or replacement public-facing services.
Agencies may seek an exemption from the Digital Performance Standard due to a range of circumstances. These circumstances may include but are not limited to:
- legacy technology barriers that cannot reasonably overcome
- substantial financial burden caused by changing a service to meet criteria.
Example:
Agency X provides a digital service that supports users that are experiencing extreme circumstances. The agency may feel it is not appropriate to ask customers for feedback on the digital service at the time of transaction.
Agency X applies for an exemption from criterion 4 of the Digital Performance Standard. In their request, Agency X provides information and evidence to demonstrate how it would not be reasonable for their system to meet criterion 4.
After reviewing the exemption request and accompanying information and evidence, the DTA grants an exemption from criterion 4. In their response, the DTA highlights that any enhancements or changes made to the system in the future would need to be reconsidered. If enhancements or changes apply, the agency must meet the Digital Performance Standard requirements or seek a separate exemption from the Digital Performance Standard criteria.
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What to consider when applying for an exemption
Exemptions should only be sought where there are genuine barriers in applying the standards, as listed above.
Agencies must outline which criteria they are seeking an exemption from, why they are unable to apply the criteria and provide evidence to support their request.
Any agency who believes that they are unable to fully comply with a standard are encouraged to apply for an exemption, noting that this does not guarantee the request will be approved.
Exemptions will be tracked by the DTA in a Digital Experience Policy Exemption Register to make sure agencies are not inadvertently reported as non-compliant. This register will be managed internally to the DTA and will not be reported publicly.How to apply for an exemption
Exemptions for new services going through the budget process can be raised through the most appropriate state of the Investment Oversight Framework.
Exemptions for existing services against the Digital Service Standard and Digital Inclusion Standard should be made in writing to standard@dta.gov.au (applicable after 1 July 2025 and 1 January 2026 respectively).
Exemptions for new and existing services need to include:
- which standard the exemption applies to
- which criterion of the standard/s the exemption applies to
- the reason why the agency cannot comply with the standard, including any evidence that supports this reasoning
- appropriate contacts to discuss the exemption, if required.
If an exemption is granted, agencies must:
- formally advise the DTA if further changes apply to their service that may make their exemption invalid
- plan how they will achieve compliance within a set timeframe, if relevant.
Roles and responsibilities
Digital Transformation Agency
The DTA is the owner of the Digital Experience Policy and accompanying standards. This includes managing and overseeing the exemption process.
The DTA will support agencies through the exemption process by:
- reviewing and assessing applications for exemption by agencies
- providing support and ongoing engagement with agencies to understand their exemption obligations
- setting the exemption terms and conditions and communicating it to agencies
- advising of any reporting requirements for agencies
- keeping a register of exemptions
- reviewing exemptions periodically to make sure the register remains current and applicable.
The DTA will regularly review the Exemption Guide as government service delivery and digital services mature. We will make improvements to the guide in line with agency application and feedback.
Agencies in scope of the Policy
Agencies in scope of the Digital Experience Policy will be responsible for maintaining their services and meeting the requirements set out in the standards.
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Digital Experience Policy
The policy sets agreed benchmarks for the performance of digital services and supports agencies to design and deliver better experiences by considering the broader digital service ecosystem.
The Digital Experience Policy (DX Policy) supports a whole-of-government focus on improving the experience for people and business interacting digitally with government information and services, setting a benchmark for good digital services and integrating data based on real-world use.
This will strengthen the government’s Investment Oversight Framework (IOF), further assuring that investments deliver on their commitments and are aligned to whole-of-government strategic objectives.
The policy includes a suite of standards and guidance that support agencies to deliver more cohesive and consistent digital experiences, aligned to the Data and Digital Government Strategy.
This policy is relevant for anyone involved in:
- developing digital and ICT proposals
- designing, delivering and operating digital government services
- improving existing government digital government services.
Digital Experience Policy implementation timeline
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Policy application and compliance
The DX Policy primarily applies to new digital service investments being considered under the Digital and ICT Investment Oversight Framework (IOF), with the exception of the Digital Service Standard and the Digital Inclusion Standard, which apply more broadly
To minimise administrative burden on agencies, administration and compliance activities will be integrated within existing processes under the IOF, such as the Digital Capability Assessment Process (DCAP) and ICT Approved Programs Collection (referred to as Wave).
Compliance refers to an Agency meeting the requirements as set out in the DX Policy and accompanying standards. Compliance is mandatory for services considered in scope of the DX Policy, unless services are granted a full or partial exemption by the Digital Transformation Agency (DTA). Where an exemption has been granted, services should comply to the maximum extent possible.
The DTA will undertake regular evaluation of the policy and standards, including compliance mechanisms, in consultation with impacted agencies to ensure they remain fit for purpose and effective
Each standard sets out the touchpoints throughout each state of the IOF to assist agencies with their planning and design. Further guidance on compliance and alignment to the IOF can be found in the Compliance and Reporting Framework and Digital Experience Toolkit.
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Digital Service Standard
The Digital Service Standard establishes the requirements for designing and delivering digital government services. The Standard puts people and business at the centre of government digital service delivery. It guides digital teams to create and maintain digital services that are user-friendly, inclusive, adaptable and measurable.
IOF touchpoints
State 1 Strategic planning: Data on compliance with the Digital Service Standard will indicate which systems or areas require uplift.
State 3 Contestability: Assessment will be undertaken to determine if proposals have a plan to meet the Digital Service Standard requirements.
State 4 Assurance: Monitoring and assurance will be undertaken to understand if the service is being delivered in line with the Digital Service Standard as planned.
State 5 Digital sourcing: Digital Service Standard requirements should be considered throughout procurement practices.
State 6 Operations: Compliance data will drive continuous improvement, targeted insights and a feedback loop to support strategic planning and prioritisation.
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Digital Inclusion Standard
The Digital Inclusion Standard establishes specific requirements for designing and delivering inclusive and accessible digital government services through best practice principles, building on the criteria set out by the Digital Service Standard.
IOF touchpoints
State 1 Strategic planning: Data on compliance with the Digital Inclusion Standard will indicate which systems or areas require uplift.
State 3 Contestability: Assessment will be undertaken to determine if proposals have a plan to meet minimum inclusion requirements, as set out in the Digital Inclusion Standard.
State 4 Assurance: Monitoring and assurance activities will determine if the service is being delivered in line with the Digital Inclusion Standard as planned.
State 5 Digital sourcing: Digital Inclusion Standard requirements should be considered throughout procurement practices.
State 6 Operations: Monitoring and reporting will determine agency compliance with inclusion requirements, using existing mechanisms such as the digital and ICT Approved Programs Collection, also referred to as Wave.
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Digital Access Standard
The Digital Access Standard requires agencies to make more informed investment decisions and reduce the duplication of digital ‘front doors’, wallets and other government digital services to provide people and business with a more unified experience when interacting with Australian Government.
Performance of the Digital Access Standard will be monitored and managed through a Digital Register that will track current digital service access points.
IOF touchpoints
State 2 Prioritisation: Assessment to understand if a proposed new access point has been considered or planned for integration with an existing access point (including in any indicative or high-level costs provided during this IOF state).
State 3 Contestability: Assessment to ensure proposals have considered and planned for integration with existing access points and that solutions will be interoperable, in line with the requirements of the Digital Access Standard.
State 4 Assurance: Monitoring and assurance to understand if the service is being delivered in line with planned integration to access points, in line with the requirements in the Digital Access Standard.
State 6 Operations: Ongoing monitoring of digital access points to track agency compliance and progress in simplifying the digital service ecosystem, using existing mechanisms such as the digital and ICT Approved Programs Collection (referred to as Wave).
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Digital Performance Standard
The Digital Performance Standard builds upon the Digital Service Standard Criteria 9 – Monitor your service and establishes the requirements for monitoring and reporting the performance of government digital services. Providing a greater focus on the performance of digital services, the Digital Performance Standard supports the Data and Digital Government Strategy’s mission to put people and business at the centre of government digital services.
It sets an approach to monitor digital performance across components of digital government services and supports data-driven digital and ICT investment decisions. It will provide the ability to monitor digital services to make sure they are:
- available
- accessible
- meeting customer needs.
It will provide additional data to assist in assuring benefits are realised under the Benefits Management Policy (where benefits intersect with included metrics).
IOF touchpoints
State 1 Strategic planning: Performance data will support and monitor the digital ecosystem and the identification of exemplary services, or those requiring uplift.
State 2 Prioritisation: Performance data will enable evidence-based decision making to support prioritisation of new investment proposals, and understand their potential impact on user experience.
State 3 Contestability: Assessment will ensure that proposals have planned for and will be able to comply with minimum performance monitoring requirements, as set out in the Digital Performance Standard.
State 4 Assurance: Monitoring and assurance activities will determine if the service is being delivered in line with the Digital Performance Standard as planned.
State 5 Digital sourcing: Consideration of the need to measure service performance throughout ICT procurement practices.
State 6 Operations: Data will provide validation and increased certainty to government to assist decision making, including where metrics intersect with identified benefits. Existing mechanisms such as the digital and ICT Approved Programs Collection (referred to as Wave) will be used.
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