UBC Wiki - User contributions [en]

Sandbox:Open Resource Working Group/June Meeting 2026

2026-06-29T21:40:41Z

WillEngle: /* Introductions and Updates */

==Meeting Details==
*''Date:'' Monday, June 29
*''Time:'' 3:00pm to 4:00pm

==Introductions and Updates==
*What Brings You Here today and what would you like to chat about?
:*Are you working on a project; do you incorporate open practices in your work or teaching?

*Overview of the Open UBC Working Group
:* Themes:
::*''Connecting'': Connecting interested groups and people involved in different aspect of open scholarship - instructors, Library, ctlt, students, AMS, faculty support professionals
::*''Building'': Doing and reflecting
::*''Advocating'': Raising issues and bringing attention, identifying challenges and opportunities, developing strategies to support open
::*''Contributing'': To the wider open ed community

*Open Education at UBC

*Current and Upcoming Activities
:*[https://alt-grading.open.ubc.ca/ Alt-Grading Symposium] (October 23-24) Keynotes include Robin DeRosa, Jesse Stommel, Asao Inoue
:*[https://oerfund.open.ubc.ca/oer-rapid-innovation-grants/ OER Rapid Innovation Grants] (ongoing)
:*[https://oerfund.open.ubc.ca/oer-affordability-grants/ OER Fund Affordability Grants] (Will open in the Fall)
:*[https://open.ubc.ca/oer-award/OER Excellence and Impact Awards] (Will open in the Fall)

==2026 Fall Project Brainstorming==
*Course Markings
:*SIS (Workday) information indicate that a class uses free or low-cost OER instead of traditional textbooks.
:*[https://open.ubc.ca/ubc-senate-endorses-principles-for-digital-learning-materials-used-for-assessment/ 2019 Principles for Digital Learning Materials Used for Assessment] "Students should have agency, options, and the ability to make informed decisions about compulsory non-tuition-related fees for learning materials. Students should know the full cost of all courses at the time of or, ideally, before registration."
:*Resources:
::*https://universitybusiness.com/how-course-marking-can-bring-oer-to-the-mainstream/
::*Possible resource on this topic here: https://uta.pressbooks.pub/markingopenandaffordablecourses/
::*BCcampus OER Course Markings Project (just kicking off) - bit more info in this call: https://bccampus.ca/call-for-proposals-oer-course-markings/
:*Questions:
::*This would impact both technology and process - Were at UBC could this discussion take place? (e.g. faculty support units, AMS, central units such as Library, CTLT, LTIC, etc).

*Research
:*More research on OEP at UBC? Could a research project be spun up out of this group? What would be an interesting topic to propose?
:*Possible idea: Invite ISoTL rep to future meeting to help us brainstorm?
:*Reach out to faculty who may be interested in leading such research?

*Metrics
:*Do an environmental scan and create a framework for reporting impacts of use of OER (similar to impact factor type metrics).
::*Maybe a white paper?
:*Create OER Impact Toolkit for Open UBC Site

*Projects
:*OER Collection Updating: https://oer.open.ubc.ca/

*Uptake
:*Recognizing "open" in T&P for research stream faculty

Sandbox:Open Resource Working Group/June Meeting 2026

2026-06-29T21:40:31Z

WillEngle: /* Introductions and Updates */

==Meeting Details==
*''Date:'' Monday, June 29
*''Time:'' 3:00pm to 4:00pm

==Introductions and Updates==
*What Brings You Here today and what would you like to chat about?
:*Are you working on a project; do you incorporate open practices in your work or teaching?

*Overview of the Open UBC Working Group
:* Themes:
::*''Connecting'': Connecting interested groups and people involved in different aspect of open scholarship - instructors, Library, ctlt, students, AMS, faculty support professionals
::*''Building'': Doing and reflecting
::*''Advocating'': Raising issues and bringing attention, identifying challenges and opportunities, developing strategies to support open
::''Contributing'': To the wider open ed community

*Open Education at UBC

*Current and Upcoming Activities
:*[https://alt-grading.open.ubc.ca/ Alt-Grading Symposium] (October 23-24) Keynotes include Robin DeRosa, Jesse Stommel, Asao Inoue
:*[https://oerfund.open.ubc.ca/oer-rapid-innovation-grants/ OER Rapid Innovation Grants] (ongoing)
:*[https://oerfund.open.ubc.ca/oer-affordability-grants/ OER Fund Affordability Grants] (Will open in the Fall)
:*[https://open.ubc.ca/oer-award/OER Excellence and Impact Awards] (Will open in the Fall)

==2026 Fall Project Brainstorming==
*Course Markings
:*SIS (Workday) information indicate that a class uses free or low-cost OER instead of traditional textbooks.
:*[https://open.ubc.ca/ubc-senate-endorses-principles-for-digital-learning-materials-used-for-assessment/ 2019 Principles for Digital Learning Materials Used for Assessment] "Students should have agency, options, and the ability to make informed decisions about compulsory non-tuition-related fees for learning materials. Students should know the full cost of all courses at the time of or, ideally, before registration."
:*Resources:
::*https://universitybusiness.com/how-course-marking-can-bring-oer-to-the-mainstream/
::*Possible resource on this topic here: https://uta.pressbooks.pub/markingopenandaffordablecourses/
::*BCcampus OER Course Markings Project (just kicking off) - bit more info in this call: https://bccampus.ca/call-for-proposals-oer-course-markings/
:*Questions:
::*This would impact both technology and process - Were at UBC could this discussion take place? (e.g. faculty support units, AMS, central units such as Library, CTLT, LTIC, etc).

*Research
:*More research on OEP at UBC? Could a research project be spun up out of this group? What would be an interesting topic to propose?
:*Possible idea: Invite ISoTL rep to future meeting to help us brainstorm?
:*Reach out to faculty who may be interested in leading such research?

*Metrics
:*Do an environmental scan and create a framework for reporting impacts of use of OER (similar to impact factor type metrics).
::*Maybe a white paper?
:*Create OER Impact Toolkit for Open UBC Site

*Projects
:*OER Collection Updating: https://oer.open.ubc.ca/

*Uptake
:*Recognizing "open" in T&P for research stream faculty

Sandbox:Open Resource Working Group/June Meeting 2026

2026-06-29T21:37:17Z

WillEngle:

==Meeting Details==
*''Date:'' Monday, June 29
*''Time:'' 3:00pm to 4:00pm

==Introductions and Updates==
*What Brings You Here today and what would you like to chat about?
:*Are you working on a project; do you incorporate open practices in your work or teaching?

*Overview of the Open UBC Working Group
:*Open Education at UBC

*Current and Upcoming Activities
:*[https://alt-grading.open.ubc.ca/ Alt-Grading Symposium] (October 23-24) Keynotes include Robin DeRosa, Jesse Stommel, Asao Inoue
:*[https://oerfund.open.ubc.ca/oer-rapid-innovation-grants/ OER Rapid Innovation Grants] (ongoing)
:*[https://oerfund.open.ubc.ca/oer-affordability-grants/ OER Fund Affordability Grants] (Will open in the Fall)
:*[https://open.ubc.ca/oer-award/OER Excellence and Impact Awards] (Will open in the Fall)

==2026 Fall Project Brainstorming==
*Course Markings
:*SIS (Workday) information indicate that a class uses free or low-cost OER instead of traditional textbooks.
:*[https://open.ubc.ca/ubc-senate-endorses-principles-for-digital-learning-materials-used-for-assessment/ 2019 Principles for Digital Learning Materials Used for Assessment] "Students should have agency, options, and the ability to make informed decisions about compulsory non-tuition-related fees for learning materials. Students should know the full cost of all courses at the time of or, ideally, before registration."
:*Resources:
::*https://universitybusiness.com/how-course-marking-can-bring-oer-to-the-mainstream/
::*Possible resource on this topic here: https://uta.pressbooks.pub/markingopenandaffordablecourses/
::*BCcampus OER Course Markings Project (just kicking off) - bit more info in this call: https://bccampus.ca/call-for-proposals-oer-course-markings/
:*Questions:
::*This would impact both technology and process - Were at UBC could this discussion take place? (e.g. faculty support units, AMS, central units such as Library, CTLT, LTIC, etc).

*Research
:*More research on OEP at UBC? Could a research project be spun up out of this group? What would be an interesting topic to propose?
:*Possible idea: Invite ISoTL rep to future meeting to help us brainstorm?
:*Reach out to faculty who may be interested in leading such research?

*Metrics
:*Do an environmental scan and create a framework for reporting impacts of use of OER (similar to impact factor type metrics).
::*Maybe a white paper?
:*Create OER Impact Toolkit for Open UBC Site

*Projects
:*OER Collection Updating: https://oer.open.ubc.ca/

*Uptake
:*Recognizing "open" in T&P for research stream faculty

Sandbox:Open Resource Working Group/June Meeting 2026

2026-06-29T21:37:01Z

WillEngle:

==Meeting Details==
*''Date:'' Monday, June 29
*''Time:'' 3:00pm to 4:00pm

===Introductions and Updates===
*What Brings You Here today and what would you like to chat about?
:*Are you working on a project; do you incorporate open practices in your work or teaching?

*Overview of the Open UBC Working Group
:*Open Education at UBC

*Current and Upcoming Activities
:*[https://alt-grading.open.ubc.ca/ Alt-Grading Symposium] (October 23-24) Keynotes include Robin DeRosa, Jesse Stommel, Asao Inoue
:*[https://oerfund.open.ubc.ca/oer-rapid-innovation-grants/ OER Rapid Innovation Grants] (ongoing)
:*[https://oerfund.open.ubc.ca/oer-affordability-grants/ OER Fund Affordability Grants] (Will open in the Fall)
:*[https://open.ubc.ca/oer-award/OER Excellence and Impact Awards] (Will open in the Fall)

===2026 Fall Project Brainstorming===
*Course Markings
:*SIS (Workday) information indicate that a class uses free or low-cost OER instead of traditional textbooks.
:*[https://open.ubc.ca/ubc-senate-endorses-principles-for-digital-learning-materials-used-for-assessment/ 2019 Principles for Digital Learning Materials Used for Assessment] "Students should have agency, options, and the ability to make informed decisions about compulsory non-tuition-related fees for learning materials. Students should know the full cost of all courses at the time of or, ideally, before registration."
:*Resources:
::*https://universitybusiness.com/how-course-marking-can-bring-oer-to-the-mainstream/
::*Possible resource on this topic here: https://uta.pressbooks.pub/markingopenandaffordablecourses/
::*BCcampus OER Course Markings Project (just kicking off) - bit more info in this call: https://bccampus.ca/call-for-proposals-oer-course-markings/
:*Questions:
::*This would impact both technology and process - Were at UBC could this discussion take place? (e.g. faculty support units, AMS, central units such as Library, CTLT, LTIC, etc).

*Research
:*More research on OEP at UBC? Could a research project be spun up out of this group? What would be an interesting topic to propose?
:*Possible idea: Invite ISoTL rep to future meeting to help us brainstorm?
:*Reach out to faculty who may be interested in leading such research?

*Metrics
:*Do an environmental scan and create a framework for reporting impacts of use of OER (similar to impact factor type metrics).
::*Maybe a white paper?
:*Create OER Impact Toolkit for Open UBC Site

*Projects
:*OER Collection Updating: https://oer.open.ubc.ca/

*Uptake
:*Recognizing "open" in T&P for research stream faculty

Sandbox:Open Resource Working Group/May Meeting 2026

2026-06-29T21:35:52Z

WillEngle:

==Meeting Details==
*''Date:'' Monday, May 25
*''Time:'' 3:00pm to 4:00pm

==Agenda==
*Introductions and Welcome
*Updates:
:*ETUG this past week; some good Open talks
*Discussion:
:*Open Pedagogy and AI:
::*What does an open AI assignment look like? What new forms of open assignments become more impactful with the use of AI?
::*Can we ensure AI tools support student agency and original thought in open assignments? What ethical frameworks do we need?
::*Looking ahead, what does a an AI-augmented and open learning environment look like aand what foundational support, professional development, and technical infrastructures do we need to build for it?

Sandbox:Open Resource Working Group/May Meeting 2026

2026-06-29T21:35:44Z

WillEngle: Created page with "==Meeting Details== *''Date:'' Monday, May 25 *''Time:'' 3:00pm to 4:00pm ==Agenda== *Introductions and Welcome *Updates: :*ETUG this past week; some good Open talks: h *Discussion: :*Open Pedagogy and AI: ::*What does an open AI assignment look like? What new forms of open assignments become more impactful with the use of AI? ::*Can we ensure AI tools support student agency and original thought in open assignments? What ethical frameworks do we need? ::*Looking ahead,..."

==Meeting Details==
*''Date:'' Monday, May 25
*''Time:'' 3:00pm to 4:00pm

==Agenda==
*Introductions and Welcome
*Updates:
:*ETUG this past week; some good Open talks: h
*Discussion:
:*Open Pedagogy and AI:
::*What does an open AI assignment look like? What new forms of open assignments become more impactful with the use of AI?
::*Can we ensure AI tools support student agency and original thought in open assignments? What ethical frameworks do we need?
::*Looking ahead, what does a an AI-augmented and open learning environment look like aand what foundational support, professional development, and technical infrastructures do we need to build for it?

Open UBC Working Group

2026-06-29T21:34:56Z

WillEngle: /* 2026 Meeting Schedule */

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<div style="padding-left:+0.5em; margin-top:+0.5em; font-size:140%; line-height:100%; border-left:2px solid #FFFFFF; line-height:1.3;"><i>a community of UBC faculty, students, and staff <br /> who share, communicate, and partner on resources and strategies to support open scholarship at UBC.</i>
</div><br><br>
[[File:OpenUBC WG.png|600px|center]]<br><br>
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{{Template:Infobox_Open_Working_Group}}
==About==
The Open UBC Working Group is a great way to share with and learn from others on the UBC campus and beyond.
The Open UBC Working Group, which is comprised of faculty, students, and staff, has been meeting regularly to advise, communicate, and partner on the [[Documentation:Open UBC|development of resources and strategies]] for supporting open scholarship at UBC.

Open Scholarship is a broad and somewhat loose term that has emerged in response to a need to identify and speak to a growing number of open practices within academia. Open Access, Open Science, Open Data, and Open Education make up a sprawling landscape of interconnected approaches to and focuses on “openness”.

Collectively, the Open UBC Working Group is a place to discuss, share, and develop advocacy strategies for open scholarship at UBC. In addition to serving as a place of community for those interested in various areas of open, the working group reviews and approves applications to the OER Rapid Innovation Grant Program and works closely with representatives from the Library, CTLT and AMS to operationalize institutional approaches to open scholarship.

==Themes==
===Connecting===
*Connecting interested groups and people involved in different aspect of open scholarship - instructors, Library, ctlt, students, AMS, faculty support professionals
*Examples: Updates, Newsletter, etc

===Building===
*Doing and reflecting
*Examples: Open UBC, events (OA Week, OE Week, etc), POSE

===Advocating===
*Raising issues and bringing attention, identifying challenges and opportunities, developing strategies to support open
*Examples: recognizing OER in SAC Guidelines for Tenure and Promotion, advocating for OER funding

===Contributing===
*To the wider open ed community
*Examples: Open Ubc public facing website/resources; conference presentations, open workshops, consulting, etc.

== Meeting Plan ==
Each meeting will have two standing items, a Roundtable and OER Rapid Innovation Grant Application Review.

* '''Updates''' - This part of the meeting will provide updates about open education activities and initiatives happening at UBC and beyond.
* '''Roundtable or Presentations''' - This part of the meeting will encourage participants to share their work and engagement in open scholarship with the group. Emerging topics and themes will be explored.
* '''Collaborative Project Work''' - This is a working group and meeting time may be set aside to work on specific projects.

The remainder of the meeting agendas will be planned based on the thematic coverage for the month.

==Meeting Schedule, Agendas, & Note==

===2026 Meeting Schedule===
*Monday, July 27 - 3:00pm to 4:00pm -[[Sandbox:Open Resource Working Group/July Meeting 2026|Meeting Agenda & Notes]]
*Monday, June 29 - 3:00pm to 4:00pm -[[Sandbox:Open Resource Working Group/June Meeting 2026|Meeting Agenda & Notes]]
*Monday, May 25 - 3:00pm to 4:00pm -[[Sandbox:Open Resource Working Group/May Meeting 2026|Meeting Agenda & Notes]]
*Monday, March 30 - 3:00pm to 4:00pm -[[Sandbox:Open Resource Working Group/March Meeting 2026|Meeting Agenda & Notes]]
*Monday, January 26 - 3:00pm to 4:00pm - [[Sandbox:Open Resource Working Group/January Meeting 2026|Meeting Agenda & Notes]]

===2025 Meeting Schedule===
*Monday, November 24 - 3:00pm to 4:00pm - [[Sandbox:Open Resource Working Group/Nov Meeting 2025|Meeting Agenda & Notes]]
*<s>Monday, October 27 - 3:00pm to 4:00pm</s> - Cancelled
*Monday, September 29 - 3:00pm to 4:00pm - [[Sandbox:Open Resource Working Group/Sept Meeting 2025|Meeting Agenda & Notes]]
*Monday, June 30 - 3:00pm to 4:00pm - [[Sandbox:Open Resource Working Group/June Meeting 2025|Meeting Agenda & Notes]]
*Monday, May 26 - 3:00pm to 4:00pm - [[Sandbox:Open Resource Working Group/May Meeting 2025|Meeting Agenda & Notes]]
*Monday, April 28 - 3:00pm to 4:00pm - [[Sandbox:Open Resource Working Group/April Meeting 2025|Meeting Agenda & Notes]]
*Monday, March 31 - 3:00pm to 4:00pm - [[Sandbox:Open Resource Working Group/March Meeting 2025|Meeting Agenda & Notes]]
*Monday, February 19 - 3:00pm to 4:00pm -[[Sandbox:Open Resource Working Group/February Meeting 2025|Meeting Agenda & Notes]]
*Monday, January 27 - 3:00pm to 4:00pm - [[Sandbox:Open Resource Working Group/January Meeting 2025|Meeting Agenda & Notes]]

===2024===
*Monday, November 25 - 3:00pm to 4:00pm - [[Sandbox:Open Resource Working Group/November Meeting 2024|Meeting Agenda & Notes]]

=== Past Meeting Agendas and Notes: ===

* [[Open UBC Working Group/Meeting|Archive]]

[[Category: Open UBC]][[Category:CTLT]][[Category:Open Education]]

Sandbox:Open Resource Working Group/June Meeting 2026

2026-06-29T21:26:14Z

WillEngle:

===Introductions and Updates===
*What Brings You Here today and what would you like to chat about?
:*Are you working on a project; do you incorporate open practices in your work or teaching?

*Overview of the Open UBC Working Group
:*Open Education at UBC

*Current and Upcoming Activities
:*[https://alt-grading.open.ubc.ca/ Alt-Grading Symposium] (October 23-24) Keynotes include Robin DeRosa, Jesse Stommel, Asao Inoue
:*[https://oerfund.open.ubc.ca/oer-rapid-innovation-grants/ OER Rapid Innovation Grants] (ongoing)
:*[https://oerfund.open.ubc.ca/oer-affordability-grants/ OER Fund Affordability Grants] (Will open in the Fall)
:*[https://open.ubc.ca/oer-award/OER Excellence and Impact Awards] (Will open in the Fall)

===2026 Fall Project Brainstorming===
*Course Markings
:*SIS (Workday) information indicate that a class uses free or low-cost OER instead of traditional textbooks.
:*[https://open.ubc.ca/ubc-senate-endorses-principles-for-digital-learning-materials-used-for-assessment/ 2019 Principles for Digital Learning Materials Used for Assessment] "Students should have agency, options, and the ability to make informed decisions about compulsory non-tuition-related fees for learning materials. Students should know the full cost of all courses at the time of or, ideally, before registration."
:*Resources:
::*https://universitybusiness.com/how-course-marking-can-bring-oer-to-the-mainstream/
::*Possible resource on this topic here: https://uta.pressbooks.pub/markingopenandaffordablecourses/
::*BCcampus OER Course Markings Project (just kicking off) - bit more info in this call: https://bccampus.ca/call-for-proposals-oer-course-markings/
:*Questions:
::*This would impact both technology and process - Were at UBC could this discussion take place? (e.g. faculty support units, AMS, central units such as Library, CTLT, LTIC, etc).

*Research
:*More research on OEP at UBC? Could a research project be spun up out of this group? What would be an interesting topic to propose?
:*Possible idea: Invite ISoTL rep to future meeting to help us brainstorm?
:*Reach out to faculty who may be interested in leading such research?

*Metrics
:*Do an environmental scan and create a framework for reporting impacts of use of OER (similar to impact factor type metrics).
::*Maybe a white paper?
:*Create OER Impact Toolkit for Open UBC Site

*Projects
:*OER Collection Updating: https://oer.open.ubc.ca/

*Uptake
:*Recognizing "open" in T&P for research stream faculty

Sandbox:Open Resource Working Group/June Meeting 2026

2026-06-29T21:25:34Z

WillEngle:

===Introductions and Updates===
*What Brings You Here today and what would you like to chat about?
:*Are you working on a project; do you incorporate open practices in your work or teaching?

*Overview of the Open UBC Working Group

*Current and Upcoming Activities
:*[https://alt-grading.open.ubc.ca/ Alt-Grading Symposium] (October 23-24) Keynotes include Robin DeRosa, Jesse Stommel, Asao Inoue
:*[https://oerfund.open.ubc.ca/oer-rapid-innovation-grants/ OER Rapid Innovation Grants] (ongoing)
:*[https://oerfund.open.ubc.ca/oer-affordability-grants/ OER Fund Affordability Grants] (Will open in the Fall)
:*[https://open.ubc.ca/oer-award/OER Excellence and Impact Awards] (Will open in the Fall)

===2026 Fall Project Brainstorming===
*Course Markings
:*SIS (Workday) information indicate that a class uses free or low-cost OER instead of traditional textbooks.
:*[https://open.ubc.ca/ubc-senate-endorses-principles-for-digital-learning-materials-used-for-assessment/ 2019 Principles for Digital Learning Materials Used for Assessment] "Students should have agency, options, and the ability to make informed decisions about compulsory non-tuition-related fees for learning materials. Students should know the full cost of all courses at the time of or, ideally, before registration."
:*Resources:
::*https://universitybusiness.com/how-course-marking-can-bring-oer-to-the-mainstream/
::*Possible resource on this topic here: https://uta.pressbooks.pub/markingopenandaffordablecourses/
::*BCcampus OER Course Markings Project (just kicking off) - bit more info in this call: https://bccampus.ca/call-for-proposals-oer-course-markings/
:*Questions:
::*This would impact both technology and process - Were at UBC could this discussion take place? (e.g. faculty support units, AMS, central units such as Library, CTLT, LTIC, etc).

*Research
:*More research on OEP at UBC? Could a research project be spun up out of this group? What would be an interesting topic to propose?
:*Possible idea: Invite ISoTL rep to future meeting to help us brainstorm?
:*Reach out to faculty who may be interested in leading such research?

*Metrics
:*Do an environmental scan and create a framework for reporting impacts of use of OER (similar to impact factor type metrics).
::*Maybe a white paper?
:*Create OER Impact Toolkit for Open UBC Site

*Projects
:*OER Collection Updating: https://oer.open.ubc.ca/

*Uptake
:*Recognizing "open" in T&P for research stream faculty

Sandbox:Open Resource Working Group/June Meeting 2026

2026-06-29T21:24:50Z

WillEngle: /* 2026 Fall Project Brainstorming */

===Introductions and Updates===
*What Brings You Here today and what would you like to chat about?
:*Are you working on a project; do you incorporate open practices in your work or teaching?

*Overview of the Open UBC Working Group

*Current and Upcoming Activities
:*[https://alt-grading.open.ubc.ca/ Alt-Grading Symposium] (October 23-24) Keynotes include Robin DeRosa, Jesse Stommel, Asao Inoue
:*[https://oerfund.open.ubc.ca/oer-affordability-grants/ OER Fund Affordability Grants] (in process)
:*[https://oerfund.open.ubc.ca/oer-rapid-innovation-grants/ OER Rapid Innovation Grants] (ongoing)
:*[https://open.ubc.ca/oer-award/OER Excellence and Impact Awards] (in process)

===2026 Fall Project Brainstorming===
*Course Markings
:*SIS (Workday) information indicate that a class uses free or low-cost OER instead of traditional textbooks.
:*[https://open.ubc.ca/ubc-senate-endorses-principles-for-digital-learning-materials-used-for-assessment/ 2019 Principles for Digital Learning Materials Used for Assessment] "Students should have agency, options, and the ability to make informed decisions about compulsory non-tuition-related fees for learning materials. Students should know the full cost of all courses at the time of or, ideally, before registration."
:*Resources:
::*https://universitybusiness.com/how-course-marking-can-bring-oer-to-the-mainstream/
::*Possible resource on this topic here: https://uta.pressbooks.pub/markingopenandaffordablecourses/
::*BCcampus OER Course Markings Project (just kicking off) - bit more info in this call: https://bccampus.ca/call-for-proposals-oer-course-markings/
:*Questions:
::*This would impact both technology and process - Were at UBC could this discussion take place? (e.g. faculty support units, AMS, central units such as Library, CTLT, LTIC, etc).

*Research
:*More research on OEP at UBC? Could a research project be spun up out of this group? What would be an interesting topic to propose?
:*Possible idea: Invite ISoTL rep to future meeting to help us brainstorm?
:*Reach out to faculty who may be interested in leading such research?

*Metrics
:*Do an environmental scan and create a framework for reporting impacts of use of OER (similar to impact factor type metrics).
::*Maybe a white paper?
:*Create OER Impact Toolkit for Open UBC Site

*Projects
:*OER Collection Updating: https://oer.open.ubc.ca/

*Uptake
:*Recognizing "open" in T&P for research stream faculty

Sandbox:Open Resource Working Group/June Meeting 2026

2026-06-29T21:22:20Z

WillEngle: Created page with "===Introductions and Updates=== *What Brings You Here today and what would you like to chat about? :*Are you working on a project; do you incorporate open practices in your work or teaching? *Overview of the Open UBC Working Group *Current and Upcoming University Activities :*[https://oerfund.open.ubc.ca/oer-affordability-grants/ OER Fund Affordability Grants] (in process) :*[https://oerfund.open.ubc.ca/oer-rapid-innovation-grants/ OER Rapid Innovation Grants] (ongoin..."

===Introductions and Updates===
*What Brings You Here today and what would you like to chat about?
:*Are you working on a project; do you incorporate open practices in your work or teaching?

*Overview of the Open UBC Working Group

*Current and Upcoming University Activities
:*[https://oerfund.open.ubc.ca/oer-affordability-grants/ OER Fund Affordability Grants] (in process)
:*[https://oerfund.open.ubc.ca/oer-rapid-innovation-grants/ OER Rapid Innovation Grants] (ongoing)
:*[https://open.ubc.ca/oer-award/OER Excellence and Impact Awards] (in process)

===2026 Fall Project Brainstorming===
*Course Markings
:*SIS (Workday) information indicate that a class uses free or low-cost OER instead of traditional textbooks.
:*[https://open.ubc.ca/ubc-senate-endorses-principles-for-digital-learning-materials-used-for-assessment/ 2019 Principles for Digital Learning Materials Used for Assessment] "Students should have agency, options, and the ability to make informed decisions about compulsory non-tuition-related fees for learning materials. Students should know the full cost of all courses at the time of or, ideally, before registration."
:*Resources:
::*https://universitybusiness.com/how-course-marking-can-bring-oer-to-the-mainstream/
::*Possible resource on this topic here: https://uta.pressbooks.pub/markingopenandaffordablecourses/
::*BCcampus OER Course Markings Project (just kicking off) - bit more info in this call: https://bccampus.ca/call-for-proposals-oer-course-markings/
:*Questions:
::*This would impact both technology and process - Were at UBC could this discussion take place? (e.g. faculty support units, AMS, central units such as Library, CTLT, LTIC, etc).

*Research
:*More research on OEP at UBC? Could a research project be spun up out of this group? What would be an interesting topic to propose?
:*Possible idea: Invite ISoTL rep to future meeting to help us brainstorm?
:*Reach out to faculty who may be interested in leading such research?

*Metrics
:*Do an environmental scan and create a framework for reporting impacts of use of OER (similar to impact factor type metrics).
::*Maybe a white paper?
:*Create OER Impact Toolkit for Open UBC Site

*Projects
:*OER Collection Updating: https://oer.open.ubc.ca/

*Uptake
:*Recognizing "open" in T&P for research stream faculty

Open UBC Working Group

2026-06-29T21:20:58Z

WillEngle: /* 2026 Meeting Schedule */

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<div style="padding-left:+0.5em; margin-top:+0.5em; font-size:140%; line-height:100%; border-left:2px solid #FFFFFF; line-height:1.3;"><i>a community of UBC faculty, students, and staff <br /> who share, communicate, and partner on resources and strategies to support open scholarship at UBC.</i>
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[[File:OpenUBC WG.png|600px|center]]<br><br>
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{{Template:Infobox_Open_Working_Group}}
==About==
The Open UBC Working Group is a great way to share with and learn from others on the UBC campus and beyond.
The Open UBC Working Group, which is comprised of faculty, students, and staff, has been meeting regularly to advise, communicate, and partner on the [[Documentation:Open UBC|development of resources and strategies]] for supporting open scholarship at UBC.

Open Scholarship is a broad and somewhat loose term that has emerged in response to a need to identify and speak to a growing number of open practices within academia. Open Access, Open Science, Open Data, and Open Education make up a sprawling landscape of interconnected approaches to and focuses on “openness”.

Collectively, the Open UBC Working Group is a place to discuss, share, and develop advocacy strategies for open scholarship at UBC. In addition to serving as a place of community for those interested in various areas of open, the working group reviews and approves applications to the OER Rapid Innovation Grant Program and works closely with representatives from the Library, CTLT and AMS to operationalize institutional approaches to open scholarship.

==Themes==
===Connecting===
*Connecting interested groups and people involved in different aspect of open scholarship - instructors, Library, ctlt, students, AMS, faculty support professionals
*Examples: Updates, Newsletter, etc

===Building===
*Doing and reflecting
*Examples: Open UBC, events (OA Week, OE Week, etc), POSE

===Advocating===
*Raising issues and bringing attention, identifying challenges and opportunities, developing strategies to support open
*Examples: recognizing OER in SAC Guidelines for Tenure and Promotion, advocating for OER funding

===Contributing===
*To the wider open ed community
*Examples: Open Ubc public facing website/resources; conference presentations, open workshops, consulting, etc.

== Meeting Plan ==
Each meeting will have two standing items, a Roundtable and OER Rapid Innovation Grant Application Review.

* '''Updates''' - This part of the meeting will provide updates about open education activities and initiatives happening at UBC and beyond.
* '''Roundtable or Presentations''' - This part of the meeting will encourage participants to share their work and engagement in open scholarship with the group. Emerging topics and themes will be explored.
* '''Collaborative Project Work''' - This is a working group and meeting time may be set aside to work on specific projects.

The remainder of the meeting agendas will be planned based on the thematic coverage for the month.

==Meeting Schedule, Agendas, & Note==

===2026 Meeting Schedule===
*Monday, June 29 - 3:00pm to 4:00pm -[[Sandbox:Open Resource Working Group/June Meeting 2026|Meeting Agenda & Notes]]
*Monday, March 30 - 3:00pm to 4:00pm -[[Sandbox:Open Resource Working Group/March Meeting 2026|Meeting Agenda & Notes]]
*Monday, January 26 - 3:00pm to 4:00pm - [[Sandbox:Open Resource Working Group/January Meeting 2026|Meeting Agenda & Notes]]

===2025 Meeting Schedule===
*Monday, November 24 - 3:00pm to 4:00pm - [[Sandbox:Open Resource Working Group/Nov Meeting 2025|Meeting Agenda & Notes]]
*<s>Monday, October 27 - 3:00pm to 4:00pm</s> - Cancelled
*Monday, September 29 - 3:00pm to 4:00pm - [[Sandbox:Open Resource Working Group/Sept Meeting 2025|Meeting Agenda & Notes]]
*Monday, June 30 - 3:00pm to 4:00pm - [[Sandbox:Open Resource Working Group/June Meeting 2025|Meeting Agenda & Notes]]
*Monday, May 26 - 3:00pm to 4:00pm - [[Sandbox:Open Resource Working Group/May Meeting 2025|Meeting Agenda & Notes]]
*Monday, April 28 - 3:00pm to 4:00pm - [[Sandbox:Open Resource Working Group/April Meeting 2025|Meeting Agenda & Notes]]
*Monday, March 31 - 3:00pm to 4:00pm - [[Sandbox:Open Resource Working Group/March Meeting 2025|Meeting Agenda & Notes]]
*Monday, February 19 - 3:00pm to 4:00pm -[[Sandbox:Open Resource Working Group/February Meeting 2025|Meeting Agenda & Notes]]
*Monday, January 27 - 3:00pm to 4:00pm - [[Sandbox:Open Resource Working Group/January Meeting 2025|Meeting Agenda & Notes]]

===2024===
*Monday, November 25 - 3:00pm to 4:00pm - [[Sandbox:Open Resource Working Group/November Meeting 2024|Meeting Agenda & Notes]]

=== Past Meeting Agendas and Notes: ===

* [[Open UBC Working Group/Meeting|Archive]]

[[Category: Open UBC]][[Category:CTLT]][[Category:Open Education]]

Documentation:Open UBC/Guide/OER Accessibility Toolkit

2026-06-02T16:21:15Z

WillEngle: /* Best Practices 8: PDFs, Word Docs and Excel Files */

==Accessibility for Open Education==

{{#widget:YouTube|id=KcvYG-rkO-Y|height=315|width=420}}

The focus of many open education projects is to provide access to education. But what does access mean? If the materials are not accessible for each and every student, do they fulfill the mandate to deliver fully open education? The open education movement has helped people in different parts of the world access content that they would otherwise not be able to view or interact with. Open education resources reduce costs for students and allow for greater flexibility for instructors. Accessibility can help push the movement even further forward.

The goal of the ''OER Accessibility Toolkit'' is to provide the needed resources to each content creator, instructor, instructional designer, educational technologist, librarian, administrator, and teaching assistant to create a truly open and accessible educational resource — one that is accessible for all students.

As you work through the content of the ''OER Accessibility Toolkit'', you will find that the suggestions provided are intended for the non-technical user. If you are looking for more technical descriptions of how to make your work accessible, we suggest you review the [https://www.w3.org/TR/WCAG20/ WCAG (Web Content Accessibility Guidelines)].

==Key Concepts: Universal Design and Personas==

Universal Design is the process of creating products (devices, environments, systems, and processes) that are usable by people with the widest possible range of abilities, operating within the widest possible range of situations (environments, conditions, and circumstances). Universal Design emerged from the slightly earlier concept of being barrier-free, the broader accessibility movement, and adaptive and assistive technology. It also seeks to blend aesthetics into these core considerations.

Let’s review some common definitions of Universal Design.

===Definition 1===

Universal Design or Universal Instructional Design (UID)
{| class="ambox ambox-notice"
| class="mbox-text" | <div>
"is an approach to teaching that consists of the proactive design and use of inclusive instructional and evaluation strategies. This approach provides academic access to a broad range of learners, including students with disabilities, while:
*maintaining academic standards […]
*reducing the need to having to retrofit after a course is already underway<ref>FAIR ([http://web2.uvcs.uvic.ca/fair/ Facilitating Accessible Instruction & Resources]). University of Victoria </ref>"

</div>
|}

===Definition 2===
{| class="ambox ambox-notice"
| class="mbox-text" | <div>
Universal Instructional Design (UID)

is an approach to designing course instruction, materials and content to benefit people of all learning styles without adaptation or retrofitting. UID provides equal access to learning, not simply equal access to information. UID allows the student to control the method of accessing information while the instructor monitors the learning process and initiates any beneficial methods. …It should be noted that UID does not remove academic challenges; it removes barriers to access.<ref>Universal Design for Learning. Ohio State University</ref>
</div>
|}

===Why Universal Design?===

For our purposes, we frame the practice of using Universal Design in a holistic and manageable way, and begin by addressing the barriers that are easy to anticipate and proactively re-mediate. This toolkit, therefore, will provide guidance to you if the answers to any of the following questions is “yes”:

*Do I have visual materials that present core concepts that not all students may be able to see or understand?
*Do I have multimedia (audio, video) materials that present core concepts that not all students may be able to be hear, see, or access?
*Do I have documents that present core concepts in a format that not all students may be able to access?

For the purpose of the ''OER Accessibility Toolkit'', we focus on an adjunct to Universal Design, that being Universal Design for Learning (UDL), which is a set of principles for curriculum development that gives all individuals equal opportunities to learn. UDL provides a blueprint for creating instructional goals, methods, materials, and assessments that work for everyone. Rather than a single, one-size-fits-all solution, it offers a flexible approach that can be customized and adjusted for individual needs.<ref>http://www.udlcenter.org/aboutudl/whatisudl ↵</ref>

The principles of Universal Design for Learning can be summarized by the following points.

*Present information and content in various ways.
*Provide more than one way for learners to express what they know.
*Stimulate interest and motivation for learning.

OER creators can apply these principles in course design by following several guidelines:

*Design resources and activities that can be accessed by learners in a variety of ways. For example, if there is a text component, provide the ability to enlarge the font size or change the text color. For images and diagrams, always provide an equivalent text description. For video, include text captions.
*Provide multiple ways for learners to engage with information and demonstrate their knowledge. This is particularly important to keep in mind as you design activities and assessments.
*Identify activities that require specific sensory or physical capability and for which it might be difficult or impossible to accommodate the accessibility needs of learners. For example, an activity that requires learners to identify objects by color might cause difficulties for learners with visual impairments. In these cases, consider whether there is a pedagogical justification for the activity being designed in that way. If there is a justification, communicate these requirements to prospective learners in the course description and establish a plan for responding to learners who encounter barriers.

===Persona===
{{#widget:YouTube|id=_YpNrOkW0Mw|height=315|width=420}}

This video shows a demonstration of students using accessibility softwares (ZoomText, JAWs and TextDragon) .

Designers use personas to represent the different types of people who may be accessing a website or product. Using a persona can be a helpful when you are designing an accessible open resources. Take a look at the personals from [http://uxmag.com/articles/book-excerpt-a-web-for-everyone Book Excerpt: A Web for Everyone] to get an idea on how your audiences navigate your course/resources.

==Best Practices 1: Online Content Organization and Weblinks==

HTML is a good format for creating accessible content. It is well supported and adaptable across browsers and devices. Also, the information in HTML markup helps assistive technologies, such as screen reader software, to provide information and functionality to people with vision impairments.

Organizing your html and online content so it has a logical flow just makes sense. Using headings, and subheadings to organize content allows students to clearly see how the main concepts are related. Headings are one of the main ways that students using a screen reader navigate through a webpage or online resource.

A weblink is a link from a file or document to another location (such as a website address) or file, typically activated by clicking on a highlighted word or image on the screen. Generally weblinks are included within content to provide the user with additional information that is available at a another location.

'''File types''': .html, .pdf, .doc, .xls

===Who Are You Doing This For?===

Everyone benefits from having content that’s clearly organized. In addition, well-organized content and descriptive weblinks support students who:

*Have a learning disability (For a example, a student with ADHD) - Having an organized content allow them to easily go back and find the important points.
*Are blind or have low vision - It gives them more control in navigating through different chapters.
*Have a form of cognitive disability
*Have a physical disability,
*Are deaf or hard of hearing

===What Do You Need to Do?===

====Content Organization====
Headings help to identify the hierarchical structure of a document (e.g., sections, sub-sections). Headings provide a visual cue that helps sighted readers quickly navigate through sections of a document, skimming through content until they find a section they are looking for. Similarly, headings create logical divisions in the content and allow a non-sighted user to navigate a page or document easily using a screen reader.

When it comes to using visual references to indicate the hierarchy and structure of a document, you may be accustomed to just changing the font, enlarging the type size, making it bold or underlined or italicized, creating the impression of a heading. This approach presents problems when creating material with accessibility in mind because screen readers won’t identify the text as a heading. Instead, a screen reader will just “read” through the text of a heading as if it were part of another paragraph of content, missing your intended cues about structure and organization.

[[File:Headings in wordpress.png|thumb|center|Headings in WordPress(UBC Blogs)]]
Keep the following guidelines in mind when you create online content.

*Use HTML tags to describe the meaning of content, rather than changing its appearance. For example, you should tag a section title with the appropriate heading level (such as <nowiki><h3></nowiki>) rather than making the text appear like a heading by applying visual elements such as bold text and a larger font size. Format list items into a list rather than using images of bullets or indents. Using HTML to describe your content’s meaning is valuable for learners who use screen readers, which, for example, can read through all headings of a specific level or announce the number of items in a list.
*Use HTML heading levels in sequential order to represent the structure of a document. Well-structured headings help learners and screen reader users to navigate a page and efficiently find what they are looking for.
*Use HTML list elements to group related items and make content easier to skim and read.

====Content Organization How tos====
*[https://en.support.wordpress.com/visual-editor/#styles How to create headings in WordPress(UBC Blogs)]
*[[Help:Formatting#Headers_.26_Lines|How to create headings in UBC Wiki]]
*[https://ccs.instructure.com/courses/1181412/pages/accessibility-basics-on-canvas-pages-headers-colors-and-tables?module_item_id=21897445 How to create headings in Canvas]
*[http://edx.readthedocs.io/projects/edx-partner-course-staff/en/latest/course_components/create_html_component.html#the-visual-editor How to create headings in EdX]

====Link Descriptions====

Ensure that all web pages and weblinks have titles that describe a topic or purpose. The purpose of the link can be determined by the text alone. That is, you don’t need to include additional information justifying the use of the link. You want the link to be meaningful in context. For example, do not use generic text such as “click here” or “read more” unless the purpose of the link can be determined by meaning in the surrounding content.<ref>https://www.webaccessibility.com/best_practices.php?best_practice_id=1301</ref>

Consider the following examples.

'''Example 1''' — unclear:

Click [http://open.ubc.ca here] for information on open at UBC.

'''Example 2''' — clear and accessible:

Information on [http://open.ubc.ca UBC Open education projects and resources] is available online.

====New Tabs/Windows====

In general, it is better if weblinks do not open new windows and tabs since they can be disorienting for people, especially people who have difficulty perceiving visual content.<ref>http://www.w3.org/TR/2014/NOTE-WCAG20-TECHS-20140916/G200</ref>. However, if a link must open in a new window, it is best practice to include a textual reference. For example, IInformation on [http://open.ubc.ca UBC Open education projects and resources (New Window)] is available online.<ref>http://accessibility.psu.edu/linkshtml</ref>

==Best Practices 2: Images==
In this section, we provide recommendations to guide your inclusion of accessible, image-based content.

===What Are Images?===

'''Images include''': photographs, diagrams, pictures, charts, graphs, maps

'''File types''': .gif, .jpg, .png

===Before You Begin===

====Why Are You Including the Images You Have Selected?====

Before you can determine what you need to do to make an image accessible, you first need to identify its purpose or value to your open resources. Consider the following questions:

#Does your image serve a functional purpose? In other words, is it conveying non-text content to students? If so, you should:
#*Provide a text alternative that serves the equivalent purpose of the non-text material<ref> Web Content Accessibility Guidelines (WCAG) 2.0, Guideline 1.1 Text Alternatives. Accessed from: http://www.w3.org/TR/WCAG20/#text-equiv </ref>
#*Not use colour as the only visual means of conveying information <ref> Web Content Accessibility Guidelines (WCAG) 2.0, Guideline 1.4.1 Use of Color. Accessed from: http://www.w3.org/TR/WCAG20/#visual-audio-contrast</ref>
#Does your image serve more of a decorative purpose? In other words, is it primarily a design element that does not convey content? If so, you should:
#*Avoid unnecessary text descriptions

====Who Are You Doing This For?====

This work supports students who:

*Are blind or have low vision
*Have poor contrast vision
*Are colour blind and cannot differentiate between certain colours
*Are using a device with monochrome display
*Have a form of cognitive disability

===What do you need to do? ===
====Functional Images and Alternative Text Description====
Consider what your content page would look like if the images didn’t load. Now try writing alternative text for each image that would work as a replacement and provide the same service as the image.

As you work on developing your alternative text descriptions, keep the following recommendations and guidelines in mind:
*Remember that alternative text must convey the content and functionality of an image and is rarely a literal description of the image (e.g., “photo of cat”). Rather than providing what the image looks like, alternative text should convey what the content of the image is and what it does. <ref>webAccess (2012). Adapted from: Top Ten Tips for making your website accessible. Accessed from: http://webaccess.berkeley.edu/developer-information/top-ten-tips/#alt </ref>
*For relatively simple images (e.g., photographs, illustrations), try to keep your text descriptions short. You should aim to create a brief alternative (one or two short sentences) that is an accurate and concise equivalent to the information in the image.
*For more complex images (e.g., detailed charts, graphs, maps), you will need to provide more than a one- to two-sentence description to ensure all users will benefit from the content or context you intended to provide. In these cases, you should either provide the details in the text surrounding the image or write a longer text description that students can link to on a separate page. You should still include a short text description (one to two sentences) that tells students where they can find the details you have provided in the longer description.
*Leave out any unnecessary information. For example, you do not need to include information like “image of…” or “photo of…”; assistive technologies will automatically identify the material as an image, so including that detail in your alternative description is superfluous.

Avoid redundancy of content in your alternative description. Don’t repeat the same information that already appears in text adjacent to the image.

=====Example 1: [https://opentextbc.ca/introductiontosociology/chapter/chapter20-population-urbanization-and-the-environment/ (from Introduction to Sociology)] =====

[[File:Rio-de-janeiro-and-london.png|thumb|center|Figure 20.11. The slum city and the global city: the Favéla Morro do Prazères in Rio de Janeiro and the London financial district show two sides of global urbanization (Photos courtesy of dany13/Flickr and Peter Pearson/Flickr). |alt="Figure 20.11 includes two photos. The first photo shows crowded buildings located on the hillside. They are small and shabby. The second photo shows magnificent buildings located by water."]]

This photograph could be described in this way:

{| class="ambox ambox-notice"
| class="mbox-text" | <div>
"Figure 20.11 includes two photos. The first photo shows crowded buildings located on the hillside. They are small and shabby. The second photo shows magnificent buildings located by water."
</div>
|}

=====Example 2 (Figure 18.1. Two-Atom, Double-Flask Diagram from [http://opentextbc.ca/introductorychemistry/chapter/entropy-and-the-second-law-of-thermodynamics/ Introductory Chemistry]): =====
[[File:Double flask gas atom diagram.png|center|thumb|(Figure 18.1. Two-Atom, Double-Flask Diagram from Introductory Chemistry) ]]
When the stopcock is opened between the flasks, the two atoms can distribute in four possible ways.

Figure 18.1 could be described as follows:
{| class="ambox ambox-notice"
| class="mbox-text" | <div>
"Figure 18.1 shows a diagram with five pairs of circles. All of these circles are open. The left one opens on the right and the right one opens on the left. They are connected with lines at their open points. One pair is located on the left and between their two connecting lines is a black dot with a red vertical line going across. The other four pairs arranged in a column are located on the right and between the connecting lines of each pair is a a small circle with a red horizontal line going through. A right arrow labelled Open Stopcock links the pair sitting on the left to the four pairs on the right. Each of these five pairs has two dots (green and blue) arranged in different patterns. For the pair on the left, the two dots, sitting obliquely, appear only in left circle. The green dot is at the left upper part of the circle and following it the blue dot is close to the bottom right. The first pair on the right has the similar situation. The only difference is that the green dot is at the right upper part of the circle and the blue dot is close the middle left. The second pair has a green dot in the centre of the left circle and a blue dot in the centre of the right circle. The third pair has a blue dot sitting at the left upper part of the left circle and a green dot sitting close to bottom right of the right circle. For the last pair, the two dots appear in oblique direction only in the right circle. A green dot is at the right upper part of the circle and a blue dot is close to bottom left.
"
</div>
|}

====Using Colour====
Consider what your images would look like if they only displayed in black and white. Would any necessary context or content be lost if the colour was “turned off”? Images should not rely on colour to convey information; if the point you are making depends on colour to be understood, you may need to edit your image or formatting so that concepts presented are not lost to those who are colour blind or who require high contrast between colours.

[[File:Colour-depend-1.jpg|thumb|center|In this example of a bar chart, colour is the sole means of communicating the data.]]

'''Example 1 - not accessible''':
In this basic bar chart, colour is the only means by which information is conveyed.

[[File:Colour-depend-2.jpg|thumb|center|This view of the same bar chart displays how the chart might appear to a student who is colour blind, or whose device does not display colour. All of the meaningful data is lost.]]

'''Example 2 — not accessible: '''
For a student who is colour blind or who has poor contrast vision, all of the relevant information is lost in a colour chart.

'''Example 3 — accessible:'''
Students who are colour blind can distinguish between high-contrast shades. In this example, contextual labels have been added to each bar at the bottom of the chart. Note that the chart will still require an [https://opentextbc.ca/accessibilitytoolkit/chapter/imageschartsgraphsmaps/#AltText alternative text description].
[[File:Colour-depend-3.jpg|thumb|center|In this view of the bar chart, high-contrast colours have been used so that shading differences will still display in grey scale. Text labels have also been added so that the data is not just being communicated with colour.]]

====Decorative Images====
If your image does not add meaning and is included for decorative or design purposes only, the space for the alternative text description should still be included with your image, but it should be left empty or blank. Assistive technologies will detect the image, and by leaving the alternative text description blank, you will signal to the student that there isn’t any contextual content embedded. Including alternative text descriptions for decorative images “simply slows the process down with no benefit because the screen-reading software vocalizes the content of the [alternative text description], whether that alternative text adds value or not.”<ref> webAccess (2012). Adapted from: Top Ten Tips for making your website accessible. Accessed from: http://webaccess.berkeley.edu/developer-information/top-ten-tips/#alt </ref>

====Complex Visuals====
Complex images refer to substantial information that may be challenging to describe in a short phrase or sentence. Learners may not
understand the images without a long description. Making complex images accessible for everyone can be challenging. It involves understanding the purpose, the content itself, the audiences, and the technology to create and access alternative formats.

{| class="ambox ambox-notice"
| class="mbox-text" | <div>
For strategies on how to make complex visuals such as graphs, tables, charts, and more accessible, see the following resource created by Supada Amornchat (CC BY-NC-SA): [https://www.pcc.edu/instructional-support/wp-content/uploads/sites/17/2017/11/complex-images.pdf Complex Images for All Learners: A Guide to Making Visual Content Accessible]</div>
|}

====How tos====
*[[Help:Adding_Media/Images_and_Pictures#Other_specific_options:|adding alt text on UBC Wiki]]
*[https://codex.wordpress.org/Inserting_Images_into_Posts_and_Pages#Step_4_.E2.80.93_Attachment_Details Adding image description in WordPress]
*[http://edx.readthedocs.io/projects/edx-developer-guide/en/latest/conventions/accessibility.html#make-images-accessible Edx Accessibility Guidelines - Make Images Accessible]
*[https://community.canvaslms.com/docs/DOC-2060#jive_content_id_Images Canvas General Accessibility Guidelines - Images]

==Best Practices 3: Tables==
In this section, we provide guidelines and recommendations for formatting tables.

===What Are Tables?===

'''Tables:''' In this context, we are referring to data tables, which are tables that include row and/or column header information to categorize content)

'''File types:''' .doc, .html, .pdf

===Are Your Tables Simple or Complex?===

A simple table includes a maximum of one header column and/or one header row. A complex table includes more than one header column and/or header row, and may include merged or split cells. <ref>AccessAbility: Accessibility and Usability at Penn State. Table Headers and Captions. Accessed from: http://accessibility.psu.edu/tables</ref>

We recommend you make every effort to keep data tables as simple in structure as possible. The more complex the design of a data table, the less accessible it will be for some students using screen-reading technology to access their textbook materials. Screen readers move left-to-right, top-to-bottom, one cell at a time, and because a screen reader does not repeat a cell, merging or splitting cells may affect the reading order of a table.

===Who Are You Doing This For?===

This work supports students who:
*Are blind or have low vision.
*Have a form of cognitive disability.

===What Do You Need To Do?===

In the same way that your [http://opentextbc.ca/accessibilitytoolkit/chapter/organizing-content/ content hierarchy needs true headings and structure], tables need a properly defined structure to be accessible. This means that you must add row and column headers to define the different sections of data. Screen readers read tables horizontally – cell by cell, row by row – and row and column headers help give the context of the data in each cell to students who are blind, have low vision, or have a cognitive disability.

===Creating Simple Tables===

A simple table includes:

#A table title or caption
#Maximum of one row of column headers and/or maximum of one column of row headers
#No merged or split cells
#Adequate cell padding for visual learners.

'''Example:'''

The table below is a simple table. Reviewed against the preceding requirements list, this table:

#Includes a '''title''' (Spring Blossoms)
#Has one row in which cells are tagged as '''column headers''' (Colour Family, Bulbs, Shrubs, Trees), and one column (beginning on the second row) in which the cells are tagged as '''row headers''' (Pink, Yellow)
#Contains no merged or split cells
#Has adequate '''cell padding''' to provide space buffering around the data in each cell. (Cell padding in this table is set at “3”).

{| border="1" cellspacing="0" cellpadding="3"
|-
!scope="col"| Colour Family
!scope="col"| Bulbs
!scope="col"| Shrubs
!scope="col"| Trees
|-
!scope="row"| Pink
| Tulips
| Flowering currant
|Ornamental plum
|-
!scope="row"| Yellow
| Daffodils
| Forsythia
|Star magnolia
|-
|}

For a student accessing the table through a screen reader, the first row of data will be presented along the lines of:
*Pink, Bulbs: Tulips
*Pink, Shrubs: Flowering currant
*Pink, Trees: Ornamental plum

===How tos===
*WordPress (UBC Blogs) - In order to add tables in UBC Blogs through visual editor, activate [http://support.cms.ubc.ca/cms-manual/adding-functionality/plugins/list-of-available-plugins/#MCE_Table_Buttons MCE Table Buttons]
*[[Help:Tables|Adding tables in UBC Wiki]]
*[https://community.canvaslms.com/docs/DOC-10346 Adding Tables in Canvas]

==Best Practices 4: Video and Multimedia==
Video and multimedia open resources can help to convey concepts and can bring information to life. In this section, we provide recommendations to guide your inclusion of accessible multimedia content.

===What Is Multimedia?===

'''Multimedia includes:''' videos, audio, animations, slideshows

'''File types:''' .mp3, .mp4, ppt., etc.

===Before You Begin===
'''What Type of Multimedia Are You Including?'''

Before you can determine what you need to do to make media materials accessible, you need to understand what is required for different types of multimedia. Consider the following questions:

1. Does your multimedia resource include audio narration or instruction? If so, you should: Provide a complete transcript of all speech content and relevant non-speech content in the resource.

2. Does your multimedia resource include audio that is synchronized with a video presentation? If so, you should: Provide captions of all speech content and relevant non-speech content in the resource.

3. Does your multimedia resource include contextual visuals (e.g., charts, graphs) that are not addressed in the spoken content? If so, you should: Provide audio descriptions of relevant visual materials in the resource.

===Who Are You Doing This For?===

This work supports students who:
*Are deaf or hard of hearing
*Are blind or have low vision
*Have a form of cognitive disability
*Are in a location where they cannot play or hear audio
*Are not native-English speakers and need written-word formats to support understanding

===What Do You Need To Do?===
====Transcripts====

Consider what your students would get out of your multimedia resource if they were not able to hear the audio portion, or if they had difficulty understanding your spoken word. A text transcript provides students with equivalent information to the audio content in a multimedia resource.<ref>Web Content Accessibility Guidelines (WCAG) 2.0, Guideline 1.2 Time-based Media: Provide alternatives for time-based media. Accessed from: http://www.w3.org/TR/WCAG20/#media-equiv</ref>

As you work on developing your text transcript, keep in mind the following recommendations about what to include:

#'''Speaker’s name'''
#'''All speech content:''' If there is speech that is not relevant, it is usually best to indicate that it has been excluded from the transcript. For example: “[A & B chatted while slides were loading].”'''
#'''Relevant descriptions about the speech: Descriptions that convey emotions, mood, etc. are usually provided in brackets. For example: “Don’t touch that! [shouted].”
#Descriptions of relevant non-speech audio: These are usually provided in brackets. For example: “[metal pipes crashing to concrete floor].” Background noise that isn’t relevant can be left out.
#'''Headings and sub-headings:''' Where they will make the transcript more usable or easy to navigate, headings and sub-headings can be helpful aids, especially when the transcript is long. When including these, put them in brackets to show that they were not part of the original audio. For example: [I

====Transcripts and third-party videos====

If you are not producing your own video resource but are planning to embed video materials from a third-party source (e.g., YouTube), be aware that not all third-party sources include transcripts. While services like YouTube technically support transcripts, not all contributors to YouTube include these. If you select a video resource that does not already have a transcript, you will need to produce one yourself.*

*''Copyright note:'' Producing your own transcript for a third-party video could infringe on copyright, depending on how the video has been licensed. Before you proceed with producing a transcript for media materials you did not create yourself, you should contact the copyright holder of that material to obtain permission to do so.

====Captions====

Timed text captions are essential to opening up a world of information for persons with hearing loss or literacy needs by making the readable equivalent of audio content available to them in a synchronized manner. Globally hearing loss affects about 10% of the population to some degree. It causes disability in 5% (360 to 538 million) and moderate to severe disability in 124 million people. Timed text captions also be helpful for learners whose native languages are languages other than the primary language of the media or who have cognitive conditions that benefit from visual.Captions are the text that is synchronized with the audio in a video presentation. Captions are important when people need to see what’s happening in the video and get the audio information in text at the same time.

The work you put into creating a text transcript for a video resource can be repurposed to provide the captions. Keep in mind the following recommendations about what to include in your captions:

#'''All speech content:''' If there is speech that is not relevant, it is usually best to indicate that it has been excluded from the captions. For example: “[A & B chatted while slides were loading].”
#'''Descriptions of relevant non-speech audio:''' These are usually provided in brackets. For example: “[metal pipes crashing to concrete floor]”; “[background music by XXX plays].” Background noise that isn’t relevant can be left out.

Text captions can be uploaded to YouTube and other platforms along with the video to create a timed text file in SubRip (SRT) format. Additional best practices for timed captions include:

*Each caption frame should not be on screen for less than three seconds.
*Each caption frame must not be on screen for less than two seconds.
*Each caption frame should not exceed more than 2 lines.
*Each caption frame must not exceed more than 3 lines.
*Each line should not exceed more than 32 characters
*All caption frames should be precisely time synched to the audio.
*When multiple speakers are present, it is sometimes helpful to identify who is speaking, especially when the video does not make this clear.
*Non-speech sounds like [MUSIC] or [LAUGHTER] should be added in square brackets.

====Downloadable Transcripts====
For both audio and video transcripts, consider including a text file that learners can download and review using tools such as word processing, screen reader, or literacy software. All learners can use transcripts of media-based learning materials for study and review.

====Audio Descriptions====

Consider what your students would get out of a multimedia resource if they were not able to see embedded visual materials critical for comprehension. Audio descriptions are helpful if visual content (e.g., a chart or a map) in a video or presentation provides important context that is not available through the audio alone.<ref>Web Content Accessibility Guidelines (WCAG) 2.0, Guideline 1.2.3 Audio Description or Media Alternative (Prerecorded). Accessed from: http://www.w3.org/TR/WCAG20/#media-equiv</ref> Actions that are only visible on screen without any audible equivalent are not accessible to learners who have visual impairments.

When describing visual elements in your multimedia resources, keep in mind the following recommendations and guidelines.

1. When contextual visual content on the screen is not described in the audio itself, you will need to provide an audio description that is an objective description of the visual element. ''Example:''

:::To help students fully grasp a concept that you are trying to convey in your video, you have included some contextual visual references (e.g., maps, charts, physical demonstrations of a process). However, you realize after making the video that the audio portion does not describe these visuals in enough detail for a student with visual impairments to be able to access all of the concepts you intended to convey.

::In this case, you would need to record an audio description of the visual material that provides enough detail to provide students like Jacob with the same content available to visual learners.

2. Whenever possible, avoid creating the need for audio descriptions in the first place by being proactive at the time of recording. If you pay attention to contextual visuals during the recording of the media piece, you may find opportunities to convey the visual content within the spoken material itself; you will not need to provide audio descriptions of the visual content after the fact. ''Example:''

::You are recording a video or presentation that includes a chart that tracks coal production in British Columbia, and as part of the presentation you want to focus attention on specific data in the chart. The narrator or presenter might point to sections on the chart and say:

:::“As you can see, metallurgical coal projection increased by 3 million tonnes over these two years.“

::In this case, audio descriptions would be necessary to provide the missing context to students with visual disabilities; these students cannot see the data on the chart that tells visual learners what the production figures are and for what dates. However, if the narrator or presenter instead says:

:::“This chart illustrates that metallurgical coal production in B.C. increased from 23 million tonnes in 1999 to 26 million tonnes in 2001,”

::the visual content is conveyed through the audio and no audio description will be necessary.

====Accessible Media Resources====

*[http://ncam.wgbh.org/invent_build/web_multimedia/accessible-digital-media-guide Accessible Digital Media Guidelines] provides detailed advice on creating online video and audio with accessibility in mind.
*[https://dcmp.org/public_content/ai/captioningkey/index.html Captioning Key by the National Association for the Deaf] provides excellent guidance on creating described and captioned media.

==Best Practices 5: Font size==

In this section, we review the two main concerns of font size on the web.

===What Is Font Size?===

'''Font size:''' The size of text visible on the screen.

===Who Are You Doing This For?===

This work supports students who:

*Are blind or have low vision
*Have a form of cognitive disability
*Are deaf or hard of hearing
*Have a physical disability

===What Do You Need To Do?===

There are two main concerns when working with font sizes.

# Ensuring that default font sizes are not too small.
# Ensuring that text can be expanded to 200% on websites<ref>http://sites.psu.edu/accessibility/fontsizehtml/ </ref>.

Keep in mind these recommendations and guidelines:

*'''12 point for body text''': For most documents, body text should be around 12 points. Small fonts may be illegible for some audiences.

*'''9 point for footnotes''': If a document contains footnotes or endnotes, the minimum size should be about 9 points

* '''200% zoom''': The Web Content Accessibility Guidelines (WCAG 2.0) recommend ensuring that text can be zoomed to 200%. As well, we recommend using liquid layouts that can accommodate 200% text. Liquid layout are layouts that are based on percentages of the current browser window's size. They flex with the size of the window, even if the current viewer changes their browser size as they're viewing the site. Liquid width layouts allow a very efficient use of the space provided by any given Web browser window or screen resolution.

==Best Practices 6: Colour Contrast==
In this section, we provide guidelines and recommendations about colour contrast in your open educational materials.

===What is Colour Contrast?===

'''Colour contrast includes''': hue, lightness and saturation of text, images, and background
'''File types''': .doc, .html, .pdf, .jpg, .gif

===What What Role Does Colour Play in the Delivery of Your Content?===

When documents or web pages do not provide enough contrast between foreground elements (e.g., text, images) and background elements (e.g., colour, watermark images), some students will have difficulty reading the content. Consider the following questions:

1. Have you presented text- or image-based content on a coloured or textured background? If so, you should:
*Confirm that there is sufficient contrast between your foreground content and the chosen background colour or texture.

2. Have you included links in your content? If so, you should:
*Confirm that the colour of your web links is distinct from both your background colour and the colour of the surrounding text.

3. Have you used colour to convey concepts or information? If so, you should:
*Confirm that you are not using colour alone to convey this information.

===Who Are You Doing This For?===

This work supports students who:

*Have low vision
*Have poor contrast vision
*Are colour blind and cannot differentiate between certain colours
*Are using a device with monochrome display

===What Do You Need To Do?===

====Contrast====

Students with low vision and/or a form of colour blindness may have difficulty reading text that does not contrast enough with the background colour you have selected. If the colour palette you have adopted is too subtle (e.g., white text on a pastel background; medium-grey text on a light-grey background), the contrast between your foreground and background is probably insufficient for some students.

Web Content Accessibility Guidelines (WCAG 2.0) require that “the visual presentation of text and images of text has a contrast ratio of at least 7:1.”<ref>Web Content Accessibility Guidelines (WCAG) 2.0, Guideline 1.4.6 Contrast (Enhanced). Accessed from: http://www.w3.org/TR/UNDERSTANDING-WCAG20/visual-audio-contrast7.html</ref> The image below presents four different foreground/background colour-contrast examples to illustrate insufficient and sufficient colour contrast ratios.
<br /><br />
[[File:Colour_Contrast.png|thumb|center|500px|Image displays four examples of foreground (text) colour against background colours; only the example on the far right presents combinations with sufficient colour contrast.]]
<br /><br />
{| class="ambox ambox-notice"
| class="mbox-text" | <div>
'''Not sure how to test your materials for colour contrast ratios?'''

There are many online and downloadable tools available to help you evaluate colour contrast ratios. Here are a few we have tried and like:
*'''WebAIM’s [http://webaim.org/resources/contrastchecker/ Color Contrast Checker]''': This web-based tool allows you to select or enter colour values to test and provides you with a “pass” or “fail” on your contrast ratio.
*'''ACART’s [http://www.contrastchecker.com/ Contrast Checker]''': This is a straightforward, web-based tool you can use to both check colour contrast and view your selections in grey scale. This tool also allows you to keep a history of the colour combinations you have tested.
*'''Giacomo Mazzocato’s [http://gmazzocato.altervista.org/colorwheel/wheel.php Accessibility Color Wheel]''': This web-based tool includes several options for testing your colour selections, including simulations of three types of colour blindness. You can also opt to test what your contrast ratio is when the foreground and background colour selections are inverted.
</div>
|}

====Weblink Colours====

Weblinks must be visually distinct from both the surrounding, non-linked text and background colour. If you do not underline your links (or provide some other non-colour cue), you must ensure that you provide both sufficient contrast between the link and background colours and between the link colour and that of the surrounding text.

Web Content Accessibility Guidelines (WCAG 2.0) require a:
*4.5:1 contrast between the link text color and the background
*3:1 contrast between the link text color and the surrounding non-link text color<ref>WebAIM (2015), WCAG 2.0 and Link Colors. Accessed from: http://webaim.org/blog/wcag-2-0-and-link-colors/ </ref>

====High-Contrast Mode====

Some students need to see light text on a dark background for it to be readable, while others require dark text on a light background. Students with low vision must be able to see content when it is displayed in high-contrast mode. This can be a subjective experience, based on individual student needs. We recommend that you try testing your text and image-based content as you go by using high-contrast mode on your own computer and making adjustments as needed.

All content items such as text, images, bullets, and table borders must be visible in both regular and high-contrast modes.

{| class="ambox ambox-notice"
| class="mbox-text" | <div>
'''Not sure how to test your content in high-contrast mode?
'''
To test the visibility of your content in this mode, turn on high contrast by simultaneously pressing the following keys on your (PC) keyboard:
::'''Left ALT + Left SHIFT + Print Screen.'''
To turn off high contrast mode, repeat this step.
</div>
|}

====Use of Colour====

You should not rely on colour as the sole means of conveying information and instruction. If the point you are making depends on colour to be understood, you will need to edit your materials so that concepts presented in the visuals are not lost to those who are colour blind or who require high contrast between colours.<ref>Web Content Accessibility Guidelines (WCAG) 2.0, Guideline 1.4.1 Use of Color. Accessed from: http://www.w3.org/TR/WCAG20/#visual-audio-contrast</ref>

==Best Practices 7: Formulas==

Math or Science formulas in open educational resources can be challenging to deliver in a way that is accessible to people with vision impairments. Non-scalable images of mathematical content cannot be sufficiently enlarged or navigated by low-vision users and are not accessible to blind users at all.

===What Are Formulas?===

'''Formulas include:''' Math equations or science formulas

'''File types:''' LaTex or MathType

===Before You Begin===
'''Who Are You Doing This For?'''

This work supports students who:

*Are blind or have low vision
*Have a form of cognitive disability,
*Have a physical disability

The following content is a derivative of Equations: Images vs. MathML from Accessibility and Usability at Penn State, http://accessibility.psu.edu/equations.

===What Do You Need to Do?===

There are several ways to handle equations from images with ALT tags to MathML. Having access to an equation editor such as MathType or MathMagic can streamline processing and converting equations considerably. These tools are similar to equation editors found in the ANGEL HTML Editor and Microsoft Office.

====MathML====

[http://accessibility.psu.edu/math/mathml/ Math ML] is a text-based XML markup language designed for math equations. Browsers that support MathML are able to translate the XML into a formatted equation. Since MathML with MathJax can be rendered in many systems, including HTML, Sites at Penn State, ANGEL and Drupal, it is considered the best choice for accessibility.

Information about [http://accessibility.psu.edu/math/mathml/ creating and viewing MathML] is available on that page.

MathML may vary from system to system and the content can change rapidly.

====Image with ALT tag====

A safe option to create an image of an equation (or export it from an equation editor) and then insert the image into a document with an ALT tag.

''Note:'' ALT tags can be written in Nemeth MathSpeak for students who have learned that system.

<math>
m = \frac{m_0}{\sqrt{1-\frac{v^2}{c^2}}}
</math>

View the ALT Tag

ALT= “m equals begin fraction m sub 0 over begin square root 1 minus begin fraction v sup 2 over c sup 2 end fraction end square root end fraction”

====LaTex====

LaTeX is a math markup language familiar to many in the science and math community, but unfortunately it is not currently supported by screen reader technology. However, it is fairly simple to convert LaTeX to an image or MathML in most equation editors.

For example, in the [http://wiki.ubc.ca UBC Wiki] you can insert a piece of LaTeX code using the <nowiki><math></nowiki> tag:
<pre>
<math>
m = \frac{m_0}{\sqrt{1-\frac{v^2}{c^2}}}
</math>
</pre>
The equation should appear fully formatted. Make minor adjustments as needed.

====Audio Files====
User testing with students have indicated that it would helpful to have an audio file of the formula or equation. The audio file would be placed beside the formula or equation and would allow the user to hear exactly how the formula or equation is interpreted.

====Audio Files====
User testing with students have indicated that it would helpful to have an audio file of the formula or equation. The audio file would be placed beside the formula or equation and would allow the user to hear exactly how the formula or equation is interpreted.
=====Example — equation with audio=====
[[File:MM0over.png|200px|center|math formular]]
[https://soundcloud.com/user-262382099-529580848/equation Listen to the audio file of this equation]:

===Additional Resources===

*In 2012, Portland Community College departments took a closer look at making math accessible to blind students. Read more about the math accessibility study on our website: http://www.pcc.edu/access.
*The [http://www.washington.edu/doit/are-there-guidelines-creating-accessible-math?465= DO-IT project from the University of Washington] provides guidance on creating accessible math content.
*The [http://www.washington.edu/doit/programs/accessstem/overview AccessSTEM] website provides guidance on creating accessible science, technology, engineering and math educational content.

==Best Practices 8: PDFs, Word Docs and Excel Files==
This section describes guidelines for creating accessible content in PDFs, Word documents, and Excel spreadsheets. Many of the same accessibility techniques and principles that apply to authoring in HTML also apply to creating document based OERs.

===PDFs===
Converting or publishing open resources as PDF documents can create accessibility barriers, particularly for learners with visual impairments. Accessibility issues are very common in PDF files that were scanned from printed sources or exported from a non-PDF document format. Scanned documents are simply images of text. To make scanned documents accessible, you must perform Optical Character Recognition (OCR) on these documents, and proofread the resulting text for accuracy before embedding it within the PDF file. You must also add semantic structure and other metadata (headings, links, alternative content for images, and so on) to the embedded text.

When you export documents to PDF from other formats, it is important to ensure that the source document contains all the required semantic structure and metadata before exporting. Unfortunately, some applications do not include this information when exporting and require the author to add or “tag” the document manually using PDF editing software. You should carefully consider whether exporting to PDF is necessary at all.

For more information on PDF accessibility, please see [https://pressbooks.bccampus.ca/accessibilityhandbook/chapter/the-people-v-pdf/ The People v. PDF] by Luke McKnight.

====Best Practices for Authoring Accessible PDF Documents====

*Explicitly define the language of the document so that screen readers know what language they should use to parse the document.
*Explicitly set the document title. When you export a file to PDF format, the document title usually defaults to the file name, not a human readable title.
*Verify that all images have alternative content defined or are marked as decorative only.
*Verify that the PDF file is “tagged”. Make sure the semantic structure from the source document has been correctly imported to the PDF file.
*Verify that a logical reading order is defined. This is especially important for documents that have atypical page layouts or structure.
*If your document includes tables, verify that table headers for rows and columns are properly defined.

====Accessible PDF Resources====
*[http://webaim.org/techniques/acrobat/ WebAIM's PDF Accessibility site] provides a detailed and illustrated guide on creating accessible PDFs.
*The [http://ncdae.org/resources/cheatsheets/ National Center of Disability and Access to Education has a collection of one-page “cheat sheets”] on accessible document authoring.
*Microsoft provides detailed [https://support.office.com/en-gb/article/Create-accessible-PDFs-064625e0-56ea-4e16-ad71-3aa33bb4b7ed?CorrelationId=9b8d28cf-aa96-4816-9536-b4aea195b51c&ui=en-US&rs=en-GB&ad=GB&ocmsassetID=HA102478227 guidance on generating accessible PDFs from Microsoft Office applications], including Word, Excel, and PowerPoint.
*Adobe provides [https://helpx.adobe.com/acrobat/using/create-verify-pdf-accessibility.html documentation on how to create and verify PDF accessibility].

===Word Documents===
Many of the same accessibility techniques and principles that apply to authoring one content also apply to creating Word documents. Keep formatting simple. Use headings, paragraphs, lists, images, and captions. Use tables for tabular data. Do not add unnecessary indents, rules, columns, blank lines, or typographic variation. Use standardized styles for formatting your text, such as Normal, Heading 1, and Heading 2, rather than manually formatting text using text styles and indents. Formatting text for its semantic meaning and not for its visual appearance allows users of assistive technology to consume and navigate documents effectively and efficiently.

Additional best practices include;

*Images must have descriptive text associated with them.
*Documents should be well structured.
*Hyperlinks should be meaningful and describe the destination.
*Tables should include properly defined column and row headers.
*Color combinations should be high contrast.
*Verify the accessibility of your document using [https://support.office.com/en-us/article/Use-the-Accessibility-Checker-on-your-Windows-desktop-to-find-accessibility-issues-a16f6de0-2f39-4a2b-8bd8-5ad801426c7f?ui=en-US&rs=en-US&ad=US Microsoft’s Accessibility Checker].

===Excel Spreadsheets===
Many of the same accessibility techniques and principles that apply to authoring data tables in HTML also apply to creating Excel spreadsheets. Microsoft has a [https://support.office.com/en-us/article/Make-your-Excel-spreadsheets-accessible-6CC05FC5-1314-48B5-8EB3-683E49B3E593?ui=en-US&rs=en-US&ad=US guide to creating accessible Excel workbooks].

*Images must have descriptive text associated with them.
*Column and row headings should be programmatically identified.
*Hyperlinks in spreadsheets should be meaningful and describe the destination.
*Use a unique and informative title for each worksheet tab.
*Do not use blank cells for formatting.
*Colour combinations should be high contrast.
*Verify the accessibility of your workbook using [https://support.office.com/en-us/article/Use-the-Accessibility-Checker-on-your-Windows-desktop-to-find-accessibility-issues-a16f6de0-2f39-4a2b-8bd8-5ad801426c7f?ui=en-US&rs=en-US&ad=US Microsoft’s Accessibility Checker].

===Additional Microsoft Accessibility Resources===
*[https://support.office.com/en-us/article/Make-your-Word-documents-accessible-D9BF3683-87AC-47EA-B91A-78DCACB3C66D?ui=en-US&rs=en-US&ad=US Microsoft guide to creating accessible Word documents.]
*[https://support.office.com/en-us/article/Use-the-Accessibility-Checker-on-your-Windows-desktop-to-find-accessibility-issues-a16f6de0-2f39-4a2b-8bd8-5ad801426c7f?ui=en-US&rs=en-US&ad=US Microsoft tool that allows you to check Word documents for accessibility issues.]
*Microsoft guide to creating [https://support.office.com/en-us/article/Make-your-PowerPoint-presentations-accessible-6F7772B2-2F33-4BD2-8CA7-DAE3B2B3EF25?ui=en-US&rs=en-US&ad=US accessible PowerPoint presentations].
*[https://support.office.com/en-us/article/Make-your-Excel-spreadsheets-accessible-6CC05FC5-1314-48B5-8EB3-683E49B3E593?ui=en-US&rs=en-US&ad=US Microsoft guide to creating accessible Excel workbooks].
*Microsoft tool that allows you to check [https://support.office.com/en-us/article/Use-the-Accessibility-Checker-on-your-Windows-desktop-to-find-accessibility-issues-a16f6de0-2f39-4a2b-8bd8-5ad801426c7f?ui=en-US&rs=en-US&ad=US Excel workbooks for accessibility issues].
*Microsoft guide to creating [http://webaim.org/techniques/powerpoint/ accessible PowerPoint presentations].
*[http://webaim.org/techniques/powerpoint/ WebAIM’s guide to PowerPoint accessibility].

==UBC Platform Specific Accessibility Guidelines==

===Canvas===
*[https://community.canvaslms.com/docs/DOC-2061 Accessibility within Canvs]
*[https://community.canvaslms.com/groups/accessibility Canvas Accessibility Group]
*[https://community.canvaslms.com/groups/accessibility/blog/2018/05/08/how-to-fix-and-prevent-accessibility-issues-in-your-canvas-course How to Fix and Prevent Accessibility Issues in Your Canvas ]

===Edx===
*[http://edx.readthedocs.io/projects/edx-partner-course-staff/en/latest/accessibility/index.html Accessibility Best Practices Guidance for Content Providers]

===WordPress===
*[https://en.support.wordpress.com/accessibility/ Accessibility in WordPress]
*[http://khan.github.io/tota11y/ Tota11y] - a tool to check if your site is accessible or not. There is also a [https://chrome.google.com/webstore/detail/tota11y-plugin-from-khan/oedofneiplgibimfkccchnimiadcmhpe?hl=en chrome extension] available

===MediaWiki/UBC Wiki===
*[https://en.wikipedia.org/wiki/Wikipedia:Manual_of_Style/Accessibility Manual of Style- Accessibility]

===UBC Centre for Accessibility===
*[https://students.ubc.ca/about-student-services/centre-for-accessibility UBC Centre for Accessibility] (CfA) provides leadership on issues of accessibility for people with disabilities at UBC Vancouver, working in partnership with faculties to foster inclusive learning, living and working environments for students, faculty and staff. The Centre for Accessibility provides support and programming initiatives designed to remove barriers for students with disabilities and facilitates disability related accommodations for members of the UBC Vancouver community.

===UBC Centre for Workplace Accessibility===
*[https://hr.ubc.ca/health-and-wellbeing/workplace-accessibility/centre-workplace-accessibility The Centre for Workplace Accessibility] (CWA) is a hub for resources, tools, and programs that help remove barriers for faculty and staff with disabilities or ongoing medical conditions. It offers support to improve workplace accessibility using a trauma-informed, person-centred approach. Its initiatives also include projects and workshops designed to build disability inclusion literacy throughout the UBC community.

==Appendix: Checklist for OER Accessibility==

===Organizing Content===

☐ Contents is organized under headings and subheadings

☐ Headings and subheadings are used sequentially (e.g. Heading 1, heading 2, etc)

===Images===

☐ Images that convey information include Alternative Text (alt-text) descriptions of the image’s content or function.

☐ Graphs, Charts, and Maps also include contextual or supporting details in the text surrounding the image.

☐ Images do not rely on colour to convey information.

☐ Images that are purely decorative contain empty alternative text descriptions. (Descriptive text is unnecessary if the image doesn’t convey contextual content information).

===Tables===

☐ Tables include row and column headers.

☐ Table includes title or caption.

☐ Table does not have merged or split cells.

☐ Table has adequate cell padding.

===Weblinks===

☐ The weblink is meaningful in context, does not use generic text such as “click here” or “read more”.

☐ Weblinks do not open new windows or tabs.

☐ If weblink must open in a new window, a textual reference is included in the link information.

===Multimedia===

☐ A transcript has been made available for a multimedia resource that includes audio narration or instruction. Transcript includes:
:Speaker’s name
:All speech content
:Relevant descriptions of speech
:Descriptions of relevant non-speech audio

===Headings and subheadings===

☐ Captions of all speech content and relevant non-speech content are included in the multimedia resource that includes audio synchronized with a video presentation.

☐ Audio descriptions of contextual visuals (graphs, charts, etc) are included in the multimedia resource.

===Formulas===

☐ Formulas have been created using MathML.

☐ Formulas are images with alternative text descriptions, if MathML is not an option.

===Font Size===

☐ Font size is 12 point or higher for body text.

☐ Font size is 9 point for footnotes or end notes.

☐ Font size can be zoomed to 200%.

==Appendix: Accessibility 2-Page Handout==

[[File:Accessibility Handout Thumbnail.png|thumb|centre|400px|link=http://wiki.ubc.ca/images/5/5b/UBC_Accessibility_Handout.pdf|Click to Download PDF ]]

==Appendix: Additional OER Accessibility Resources==
*[https://accessibility.ctlt.ubc.ca/ UBC Accessibility 101] - A UBC resource that focuses on improving access to digital content for students with vision or hearing impairments and similar learning barriers.
*[https://blogs.ubc.ca/accessibleactivelearning/ Accessible Active Learning] - A resource designed for Instructional Skills Workshop (ISW) and TA Training facilitators at UBCV. It is meant as a resource to help them design activities with accessibility in-mind, to help make activities accessible to more students and participants.
*[https://equity.ubc.ca/resources/accessible-and-inclusive-event-planning/ UBC Accessible Event Planning Guide] - provides practical tools to help event organizers create inclusive and welcoming experiences for everyone, including particularly people with disabilities.
*[https://opentextbc.ca/accessibilitytoolkit/ BC Open Textbook Accessibility Toolkit] - (also in [https://opentextbc.ca/troussedoutildaccessibilite/ French]). See also the [https://cdn.collection.bccampus.ca/assets/B_Ccampus_Accessibility_Criteria_6b42ab8ce8.pdf BCcampus OER Accessibility Criteria checklist] and the [https://opentextbc.ca/accessibilitytoolkit/back-matter/inclusive-design-webinar-series/ BCcampus Inclusive Design Webinar Series].
*[https://students.ubc.ca/about-student-services/centre-for-accessibility UBC Centre for Accessibility] provides support and programming initiatives designed to remove barriers for students with disabilities and facilitates disability related accommodations for members of the UBC Vancouver community.
*[https://pressbooks.bccampus.ca/a11yondemand/ Digital Accessibility On-demand] - a resource by Luke McKnight designed as a just-in-time resource to guide creators to the step-by-step instructions they need to maximize accessibility and increase inclusivity.
*[https://pressbooks.bccampus.ca/accessibilityhandbook/ Accessibility Handbook for Teaching and Learning] - a guidebook by Luke McKnight and Briana Fraser to introduce concepts of digital accessibility and to provide detailed instructions to use the accessibility features of software such as Word and PowerPoint.
*[https://hr.ubc.ca/health-and-wellbeing/workplace-accessibility/centre-workplace-accessibility The Centre for Workplace Accessibility (CWA)] is a hub for resources, tools, and programs that help remove barriers for faculty and staff with disabilities or ongoing medical conditions. It offers support to improve workplace accessibility using a trauma-informed, person-centred approach.
*Inclusive Design Research Centre’s [http://floeproject.org/ Flexible Learning for Open Education]
*[http://www.udlcenter.org/implementation/postsecondary The National Center on Universal Design for Learning] provides a helpful overview on Universal Design for Learning.
*Portland Community College’s [http://www.pcc.edu/resources/instructional-support/access/ Accessibility for Online Course Content: A Guide for Instructors]
*[https://inclusive.microsoft.design/ Inclusive Design at Microsoft]
*[https://wiki.ubc.ca/images/0/02/Complex_Images_for_All_Learners.pdf Accessibility for Complex Images]: resource for making charts, graphs, figures, and other complex images accessible.
*[https://pressbooks.bccampus.ca/accessibilityhandbook/chapter/the-people-v-pdf/ The People v. PDF] - a semi-academic take on some of accessibility issues of PDFs
*The [https://bccampus.ca/wp-content/uploads/2023/04/OER-Equity-Rubric-1.pdf BCcampus OER Equity Rubric] is designed to help identify opportunities to adapt and improve the equity of open resources.

==References==
<references/>

==About this Toolkit==
[[File:CC-SA_button.png|left|CC by|100px]] The OER Accessibility Toolkit is licensed under a [https://creativecommons.org/licenses/by-sa/4.0/ Creative Commons Attribution-ShareAlike 4.0 International License], except where otherwise noted. Source files for this resource may be found on the [http://wiki.ubc.ca/Documentation:Open_UBC/Guide/OER_Accessibility_Toolkit UBC Wiki].

Content for this toolkit was adapted from the [https://opentextbc.ca/accessibilitytoolkit/ BC Open Textbook Accessibility Toolkit] by Amanda Coolidge, Sue Doner, and Tara Robertson. The [https://opentextbc.ca/accessibilitytoolkit/ BC Open Textbook Accessibility Toolkit] is licensed under a [https://creativecommons.org/licenses/by/4.0/ Creative Commons Attribution 4.0 International License], except where otherwise noted. Additional material has been adapted from the [http://edx.readthedocs.io/projects/edx-partner-course-staff/en/latest/accessibility/index.html edX Accessibility Best Practices for Developing Course Content] guidelines under a [https://creativecommons.org/licenses/by-sa/4.0/ Creative Commons Attribution Share Alike 4.0 International License].

[[Category:Open UBC]][[Category:Accessibility]] [[Category:Accessibility Toolkits]] [[Category:OER]] [[Category:Open Education]] [[Category:Universal Design]]

Documentation:Open UBC/Guide/OER Accessibility Toolkit

2026-06-02T16:20:51Z

WillEngle: /* PDFs */

==Accessibility for Open Education==

{{#widget:YouTube|id=KcvYG-rkO-Y|height=315|width=420}}

The focus of many open education projects is to provide access to education. But what does access mean? If the materials are not accessible for each and every student, do they fulfill the mandate to deliver fully open education? The open education movement has helped people in different parts of the world access content that they would otherwise not be able to view or interact with. Open education resources reduce costs for students and allow for greater flexibility for instructors. Accessibility can help push the movement even further forward.

The goal of the ''OER Accessibility Toolkit'' is to provide the needed resources to each content creator, instructor, instructional designer, educational technologist, librarian, administrator, and teaching assistant to create a truly open and accessible educational resource — one that is accessible for all students.

As you work through the content of the ''OER Accessibility Toolkit'', you will find that the suggestions provided are intended for the non-technical user. If you are looking for more technical descriptions of how to make your work accessible, we suggest you review the [https://www.w3.org/TR/WCAG20/ WCAG (Web Content Accessibility Guidelines)].

==Key Concepts: Universal Design and Personas==

Universal Design is the process of creating products (devices, environments, systems, and processes) that are usable by people with the widest possible range of abilities, operating within the widest possible range of situations (environments, conditions, and circumstances). Universal Design emerged from the slightly earlier concept of being barrier-free, the broader accessibility movement, and adaptive and assistive technology. It also seeks to blend aesthetics into these core considerations.

Let’s review some common definitions of Universal Design.

===Definition 1===

Universal Design or Universal Instructional Design (UID)
{| class="ambox ambox-notice"
| class="mbox-text" | <div>
"is an approach to teaching that consists of the proactive design and use of inclusive instructional and evaluation strategies. This approach provides academic access to a broad range of learners, including students with disabilities, while:
*maintaining academic standards […]
*reducing the need to having to retrofit after a course is already underway<ref>FAIR ([http://web2.uvcs.uvic.ca/fair/ Facilitating Accessible Instruction & Resources]). University of Victoria </ref>"

</div>
|}

===Definition 2===
{| class="ambox ambox-notice"
| class="mbox-text" | <div>
Universal Instructional Design (UID)

is an approach to designing course instruction, materials and content to benefit people of all learning styles without adaptation or retrofitting. UID provides equal access to learning, not simply equal access to information. UID allows the student to control the method of accessing information while the instructor monitors the learning process and initiates any beneficial methods. …It should be noted that UID does not remove academic challenges; it removes barriers to access.<ref>Universal Design for Learning. Ohio State University</ref>
</div>
|}

===Why Universal Design?===

For our purposes, we frame the practice of using Universal Design in a holistic and manageable way, and begin by addressing the barriers that are easy to anticipate and proactively re-mediate. This toolkit, therefore, will provide guidance to you if the answers to any of the following questions is “yes”:

*Do I have visual materials that present core concepts that not all students may be able to see or understand?
*Do I have multimedia (audio, video) materials that present core concepts that not all students may be able to be hear, see, or access?
*Do I have documents that present core concepts in a format that not all students may be able to access?

For the purpose of the ''OER Accessibility Toolkit'', we focus on an adjunct to Universal Design, that being Universal Design for Learning (UDL), which is a set of principles for curriculum development that gives all individuals equal opportunities to learn. UDL provides a blueprint for creating instructional goals, methods, materials, and assessments that work for everyone. Rather than a single, one-size-fits-all solution, it offers a flexible approach that can be customized and adjusted for individual needs.<ref>http://www.udlcenter.org/aboutudl/whatisudl ↵</ref>

The principles of Universal Design for Learning can be summarized by the following points.

*Present information and content in various ways.
*Provide more than one way for learners to express what they know.
*Stimulate interest and motivation for learning.

OER creators can apply these principles in course design by following several guidelines:

*Design resources and activities that can be accessed by learners in a variety of ways. For example, if there is a text component, provide the ability to enlarge the font size or change the text color. For images and diagrams, always provide an equivalent text description. For video, include text captions.
*Provide multiple ways for learners to engage with information and demonstrate their knowledge. This is particularly important to keep in mind as you design activities and assessments.
*Identify activities that require specific sensory or physical capability and for which it might be difficult or impossible to accommodate the accessibility needs of learners. For example, an activity that requires learners to identify objects by color might cause difficulties for learners with visual impairments. In these cases, consider whether there is a pedagogical justification for the activity being designed in that way. If there is a justification, communicate these requirements to prospective learners in the course description and establish a plan for responding to learners who encounter barriers.

===Persona===
{{#widget:YouTube|id=_YpNrOkW0Mw|height=315|width=420}}

This video shows a demonstration of students using accessibility softwares (ZoomText, JAWs and TextDragon) .

Designers use personas to represent the different types of people who may be accessing a website or product. Using a persona can be a helpful when you are designing an accessible open resources. Take a look at the personals from [http://uxmag.com/articles/book-excerpt-a-web-for-everyone Book Excerpt: A Web for Everyone] to get an idea on how your audiences navigate your course/resources.

==Best Practices 1: Online Content Organization and Weblinks==

HTML is a good format for creating accessible content. It is well supported and adaptable across browsers and devices. Also, the information in HTML markup helps assistive technologies, such as screen reader software, to provide information and functionality to people with vision impairments.

Organizing your html and online content so it has a logical flow just makes sense. Using headings, and subheadings to organize content allows students to clearly see how the main concepts are related. Headings are one of the main ways that students using a screen reader navigate through a webpage or online resource.

A weblink is a link from a file or document to another location (such as a website address) or file, typically activated by clicking on a highlighted word or image on the screen. Generally weblinks are included within content to provide the user with additional information that is available at a another location.

'''File types''': .html, .pdf, .doc, .xls

===Who Are You Doing This For?===

Everyone benefits from having content that’s clearly organized. In addition, well-organized content and descriptive weblinks support students who:

*Have a learning disability (For a example, a student with ADHD) - Having an organized content allow them to easily go back and find the important points.
*Are blind or have low vision - It gives them more control in navigating through different chapters.
*Have a form of cognitive disability
*Have a physical disability,
*Are deaf or hard of hearing

===What Do You Need to Do?===

====Content Organization====
Headings help to identify the hierarchical structure of a document (e.g., sections, sub-sections). Headings provide a visual cue that helps sighted readers quickly navigate through sections of a document, skimming through content until they find a section they are looking for. Similarly, headings create logical divisions in the content and allow a non-sighted user to navigate a page or document easily using a screen reader.

When it comes to using visual references to indicate the hierarchy and structure of a document, you may be accustomed to just changing the font, enlarging the type size, making it bold or underlined or italicized, creating the impression of a heading. This approach presents problems when creating material with accessibility in mind because screen readers won’t identify the text as a heading. Instead, a screen reader will just “read” through the text of a heading as if it were part of another paragraph of content, missing your intended cues about structure and organization.

[[File:Headings in wordpress.png|thumb|center|Headings in WordPress(UBC Blogs)]]
Keep the following guidelines in mind when you create online content.

*Use HTML tags to describe the meaning of content, rather than changing its appearance. For example, you should tag a section title with the appropriate heading level (such as <nowiki><h3></nowiki>) rather than making the text appear like a heading by applying visual elements such as bold text and a larger font size. Format list items into a list rather than using images of bullets or indents. Using HTML to describe your content’s meaning is valuable for learners who use screen readers, which, for example, can read through all headings of a specific level or announce the number of items in a list.
*Use HTML heading levels in sequential order to represent the structure of a document. Well-structured headings help learners and screen reader users to navigate a page and efficiently find what they are looking for.
*Use HTML list elements to group related items and make content easier to skim and read.

====Content Organization How tos====
*[https://en.support.wordpress.com/visual-editor/#styles How to create headings in WordPress(UBC Blogs)]
*[[Help:Formatting#Headers_.26_Lines|How to create headings in UBC Wiki]]
*[https://ccs.instructure.com/courses/1181412/pages/accessibility-basics-on-canvas-pages-headers-colors-and-tables?module_item_id=21897445 How to create headings in Canvas]
*[http://edx.readthedocs.io/projects/edx-partner-course-staff/en/latest/course_components/create_html_component.html#the-visual-editor How to create headings in EdX]

====Link Descriptions====

Ensure that all web pages and weblinks have titles that describe a topic or purpose. The purpose of the link can be determined by the text alone. That is, you don’t need to include additional information justifying the use of the link. You want the link to be meaningful in context. For example, do not use generic text such as “click here” or “read more” unless the purpose of the link can be determined by meaning in the surrounding content.<ref>https://www.webaccessibility.com/best_practices.php?best_practice_id=1301</ref>

Consider the following examples.

'''Example 1''' — unclear:

Click [http://open.ubc.ca here] for information on open at UBC.

'''Example 2''' — clear and accessible:

Information on [http://open.ubc.ca UBC Open education projects and resources] is available online.

====New Tabs/Windows====

In general, it is better if weblinks do not open new windows and tabs since they can be disorienting for people, especially people who have difficulty perceiving visual content.<ref>http://www.w3.org/TR/2014/NOTE-WCAG20-TECHS-20140916/G200</ref>. However, if a link must open in a new window, it is best practice to include a textual reference. For example, IInformation on [http://open.ubc.ca UBC Open education projects and resources (New Window)] is available online.<ref>http://accessibility.psu.edu/linkshtml</ref>

==Best Practices 2: Images==
In this section, we provide recommendations to guide your inclusion of accessible, image-based content.

===What Are Images?===

'''Images include''': photographs, diagrams, pictures, charts, graphs, maps

'''File types''': .gif, .jpg, .png

===Before You Begin===

====Why Are You Including the Images You Have Selected?====

Before you can determine what you need to do to make an image accessible, you first need to identify its purpose or value to your open resources. Consider the following questions:

#Does your image serve a functional purpose? In other words, is it conveying non-text content to students? If so, you should:
#*Provide a text alternative that serves the equivalent purpose of the non-text material<ref> Web Content Accessibility Guidelines (WCAG) 2.0, Guideline 1.1 Text Alternatives. Accessed from: http://www.w3.org/TR/WCAG20/#text-equiv </ref>
#*Not use colour as the only visual means of conveying information <ref> Web Content Accessibility Guidelines (WCAG) 2.0, Guideline 1.4.1 Use of Color. Accessed from: http://www.w3.org/TR/WCAG20/#visual-audio-contrast</ref>
#Does your image serve more of a decorative purpose? In other words, is it primarily a design element that does not convey content? If so, you should:
#*Avoid unnecessary text descriptions

====Who Are You Doing This For?====

This work supports students who:

*Are blind or have low vision
*Have poor contrast vision
*Are colour blind and cannot differentiate between certain colours
*Are using a device with monochrome display
*Have a form of cognitive disability

===What do you need to do? ===
====Functional Images and Alternative Text Description====
Consider what your content page would look like if the images didn’t load. Now try writing alternative text for each image that would work as a replacement and provide the same service as the image.

As you work on developing your alternative text descriptions, keep the following recommendations and guidelines in mind:
*Remember that alternative text must convey the content and functionality of an image and is rarely a literal description of the image (e.g., “photo of cat”). Rather than providing what the image looks like, alternative text should convey what the content of the image is and what it does. <ref>webAccess (2012). Adapted from: Top Ten Tips for making your website accessible. Accessed from: http://webaccess.berkeley.edu/developer-information/top-ten-tips/#alt </ref>
*For relatively simple images (e.g., photographs, illustrations), try to keep your text descriptions short. You should aim to create a brief alternative (one or two short sentences) that is an accurate and concise equivalent to the information in the image.
*For more complex images (e.g., detailed charts, graphs, maps), you will need to provide more than a one- to two-sentence description to ensure all users will benefit from the content or context you intended to provide. In these cases, you should either provide the details in the text surrounding the image or write a longer text description that students can link to on a separate page. You should still include a short text description (one to two sentences) that tells students where they can find the details you have provided in the longer description.
*Leave out any unnecessary information. For example, you do not need to include information like “image of…” or “photo of…”; assistive technologies will automatically identify the material as an image, so including that detail in your alternative description is superfluous.

Avoid redundancy of content in your alternative description. Don’t repeat the same information that already appears in text adjacent to the image.

=====Example 1: [https://opentextbc.ca/introductiontosociology/chapter/chapter20-population-urbanization-and-the-environment/ (from Introduction to Sociology)] =====

[[File:Rio-de-janeiro-and-london.png|thumb|center|Figure 20.11. The slum city and the global city: the Favéla Morro do Prazères in Rio de Janeiro and the London financial district show two sides of global urbanization (Photos courtesy of dany13/Flickr and Peter Pearson/Flickr). |alt="Figure 20.11 includes two photos. The first photo shows crowded buildings located on the hillside. They are small and shabby. The second photo shows magnificent buildings located by water."]]

This photograph could be described in this way:

{| class="ambox ambox-notice"
| class="mbox-text" | <div>
"Figure 20.11 includes two photos. The first photo shows crowded buildings located on the hillside. They are small and shabby. The second photo shows magnificent buildings located by water."
</div>
|}

=====Example 2 (Figure 18.1. Two-Atom, Double-Flask Diagram from [http://opentextbc.ca/introductorychemistry/chapter/entropy-and-the-second-law-of-thermodynamics/ Introductory Chemistry]): =====
[[File:Double flask gas atom diagram.png|center|thumb|(Figure 18.1. Two-Atom, Double-Flask Diagram from Introductory Chemistry) ]]
When the stopcock is opened between the flasks, the two atoms can distribute in four possible ways.

Figure 18.1 could be described as follows:
{| class="ambox ambox-notice"
| class="mbox-text" | <div>
"Figure 18.1 shows a diagram with five pairs of circles. All of these circles are open. The left one opens on the right and the right one opens on the left. They are connected with lines at their open points. One pair is located on the left and between their two connecting lines is a black dot with a red vertical line going across. The other four pairs arranged in a column are located on the right and between the connecting lines of each pair is a a small circle with a red horizontal line going through. A right arrow labelled Open Stopcock links the pair sitting on the left to the four pairs on the right. Each of these five pairs has two dots (green and blue) arranged in different patterns. For the pair on the left, the two dots, sitting obliquely, appear only in left circle. The green dot is at the left upper part of the circle and following it the blue dot is close to the bottom right. The first pair on the right has the similar situation. The only difference is that the green dot is at the right upper part of the circle and the blue dot is close the middle left. The second pair has a green dot in the centre of the left circle and a blue dot in the centre of the right circle. The third pair has a blue dot sitting at the left upper part of the left circle and a green dot sitting close to bottom right of the right circle. For the last pair, the two dots appear in oblique direction only in the right circle. A green dot is at the right upper part of the circle and a blue dot is close to bottom left.
"
</div>
|}

====Using Colour====
Consider what your images would look like if they only displayed in black and white. Would any necessary context or content be lost if the colour was “turned off”? Images should not rely on colour to convey information; if the point you are making depends on colour to be understood, you may need to edit your image or formatting so that concepts presented are not lost to those who are colour blind or who require high contrast between colours.

[[File:Colour-depend-1.jpg|thumb|center|In this example of a bar chart, colour is the sole means of communicating the data.]]

'''Example 1 - not accessible''':
In this basic bar chart, colour is the only means by which information is conveyed.

[[File:Colour-depend-2.jpg|thumb|center|This view of the same bar chart displays how the chart might appear to a student who is colour blind, or whose device does not display colour. All of the meaningful data is lost.]]

'''Example 2 — not accessible: '''
For a student who is colour blind or who has poor contrast vision, all of the relevant information is lost in a colour chart.

'''Example 3 — accessible:'''
Students who are colour blind can distinguish between high-contrast shades. In this example, contextual labels have been added to each bar at the bottom of the chart. Note that the chart will still require an [https://opentextbc.ca/accessibilitytoolkit/chapter/imageschartsgraphsmaps/#AltText alternative text description].
[[File:Colour-depend-3.jpg|thumb|center|In this view of the bar chart, high-contrast colours have been used so that shading differences will still display in grey scale. Text labels have also been added so that the data is not just being communicated with colour.]]

====Decorative Images====
If your image does not add meaning and is included for decorative or design purposes only, the space for the alternative text description should still be included with your image, but it should be left empty or blank. Assistive technologies will detect the image, and by leaving the alternative text description blank, you will signal to the student that there isn’t any contextual content embedded. Including alternative text descriptions for decorative images “simply slows the process down with no benefit because the screen-reading software vocalizes the content of the [alternative text description], whether that alternative text adds value or not.”<ref> webAccess (2012). Adapted from: Top Ten Tips for making your website accessible. Accessed from: http://webaccess.berkeley.edu/developer-information/top-ten-tips/#alt </ref>

====Complex Visuals====
Complex images refer to substantial information that may be challenging to describe in a short phrase or sentence. Learners may not
understand the images without a long description. Making complex images accessible for everyone can be challenging. It involves understanding the purpose, the content itself, the audiences, and the technology to create and access alternative formats.

{| class="ambox ambox-notice"
| class="mbox-text" | <div>
For strategies on how to make complex visuals such as graphs, tables, charts, and more accessible, see the following resource created by Supada Amornchat (CC BY-NC-SA): [https://www.pcc.edu/instructional-support/wp-content/uploads/sites/17/2017/11/complex-images.pdf Complex Images for All Learners: A Guide to Making Visual Content Accessible]</div>
|}

====How tos====
*[[Help:Adding_Media/Images_and_Pictures#Other_specific_options:|adding alt text on UBC Wiki]]
*[https://codex.wordpress.org/Inserting_Images_into_Posts_and_Pages#Step_4_.E2.80.93_Attachment_Details Adding image description in WordPress]
*[http://edx.readthedocs.io/projects/edx-developer-guide/en/latest/conventions/accessibility.html#make-images-accessible Edx Accessibility Guidelines - Make Images Accessible]
*[https://community.canvaslms.com/docs/DOC-2060#jive_content_id_Images Canvas General Accessibility Guidelines - Images]

==Best Practices 3: Tables==
In this section, we provide guidelines and recommendations for formatting tables.

===What Are Tables?===

'''Tables:''' In this context, we are referring to data tables, which are tables that include row and/or column header information to categorize content)

'''File types:''' .doc, .html, .pdf

===Are Your Tables Simple or Complex?===

A simple table includes a maximum of one header column and/or one header row. A complex table includes more than one header column and/or header row, and may include merged or split cells. <ref>AccessAbility: Accessibility and Usability at Penn State. Table Headers and Captions. Accessed from: http://accessibility.psu.edu/tables</ref>

We recommend you make every effort to keep data tables as simple in structure as possible. The more complex the design of a data table, the less accessible it will be for some students using screen-reading technology to access their textbook materials. Screen readers move left-to-right, top-to-bottom, one cell at a time, and because a screen reader does not repeat a cell, merging or splitting cells may affect the reading order of a table.

===Who Are You Doing This For?===

This work supports students who:
*Are blind or have low vision.
*Have a form of cognitive disability.

===What Do You Need To Do?===

In the same way that your [http://opentextbc.ca/accessibilitytoolkit/chapter/organizing-content/ content hierarchy needs true headings and structure], tables need a properly defined structure to be accessible. This means that you must add row and column headers to define the different sections of data. Screen readers read tables horizontally – cell by cell, row by row – and row and column headers help give the context of the data in each cell to students who are blind, have low vision, or have a cognitive disability.

===Creating Simple Tables===

A simple table includes:

#A table title or caption
#Maximum of one row of column headers and/or maximum of one column of row headers
#No merged or split cells
#Adequate cell padding for visual learners.

'''Example:'''

The table below is a simple table. Reviewed against the preceding requirements list, this table:

#Includes a '''title''' (Spring Blossoms)
#Has one row in which cells are tagged as '''column headers''' (Colour Family, Bulbs, Shrubs, Trees), and one column (beginning on the second row) in which the cells are tagged as '''row headers''' (Pink, Yellow)
#Contains no merged or split cells
#Has adequate '''cell padding''' to provide space buffering around the data in each cell. (Cell padding in this table is set at “3”).

{| border="1" cellspacing="0" cellpadding="3"
|-
!scope="col"| Colour Family
!scope="col"| Bulbs
!scope="col"| Shrubs
!scope="col"| Trees
|-
!scope="row"| Pink
| Tulips
| Flowering currant
|Ornamental plum
|-
!scope="row"| Yellow
| Daffodils
| Forsythia
|Star magnolia
|-
|}

For a student accessing the table through a screen reader, the first row of data will be presented along the lines of:
*Pink, Bulbs: Tulips
*Pink, Shrubs: Flowering currant
*Pink, Trees: Ornamental plum

===How tos===
*WordPress (UBC Blogs) - In order to add tables in UBC Blogs through visual editor, activate [http://support.cms.ubc.ca/cms-manual/adding-functionality/plugins/list-of-available-plugins/#MCE_Table_Buttons MCE Table Buttons]
*[[Help:Tables|Adding tables in UBC Wiki]]
*[https://community.canvaslms.com/docs/DOC-10346 Adding Tables in Canvas]

==Best Practices 4: Video and Multimedia==
Video and multimedia open resources can help to convey concepts and can bring information to life. In this section, we provide recommendations to guide your inclusion of accessible multimedia content.

===What Is Multimedia?===

'''Multimedia includes:''' videos, audio, animations, slideshows

'''File types:''' .mp3, .mp4, ppt., etc.

===Before You Begin===
'''What Type of Multimedia Are You Including?'''

Before you can determine what you need to do to make media materials accessible, you need to understand what is required for different types of multimedia. Consider the following questions:

1. Does your multimedia resource include audio narration or instruction? If so, you should: Provide a complete transcript of all speech content and relevant non-speech content in the resource.

2. Does your multimedia resource include audio that is synchronized with a video presentation? If so, you should: Provide captions of all speech content and relevant non-speech content in the resource.

3. Does your multimedia resource include contextual visuals (e.g., charts, graphs) that are not addressed in the spoken content? If so, you should: Provide audio descriptions of relevant visual materials in the resource.

===Who Are You Doing This For?===

This work supports students who:
*Are deaf or hard of hearing
*Are blind or have low vision
*Have a form of cognitive disability
*Are in a location where they cannot play or hear audio
*Are not native-English speakers and need written-word formats to support understanding

===What Do You Need To Do?===
====Transcripts====

Consider what your students would get out of your multimedia resource if they were not able to hear the audio portion, or if they had difficulty understanding your spoken word. A text transcript provides students with equivalent information to the audio content in a multimedia resource.<ref>Web Content Accessibility Guidelines (WCAG) 2.0, Guideline 1.2 Time-based Media: Provide alternatives for time-based media. Accessed from: http://www.w3.org/TR/WCAG20/#media-equiv</ref>

As you work on developing your text transcript, keep in mind the following recommendations about what to include:

#'''Speaker’s name'''
#'''All speech content:''' If there is speech that is not relevant, it is usually best to indicate that it has been excluded from the transcript. For example: “[A & B chatted while slides were loading].”'''
#'''Relevant descriptions about the speech: Descriptions that convey emotions, mood, etc. are usually provided in brackets. For example: “Don’t touch that! [shouted].”
#Descriptions of relevant non-speech audio: These are usually provided in brackets. For example: “[metal pipes crashing to concrete floor].” Background noise that isn’t relevant can be left out.
#'''Headings and sub-headings:''' Where they will make the transcript more usable or easy to navigate, headings and sub-headings can be helpful aids, especially when the transcript is long. When including these, put them in brackets to show that they were not part of the original audio. For example: [I

====Transcripts and third-party videos====

If you are not producing your own video resource but are planning to embed video materials from a third-party source (e.g., YouTube), be aware that not all third-party sources include transcripts. While services like YouTube technically support transcripts, not all contributors to YouTube include these. If you select a video resource that does not already have a transcript, you will need to produce one yourself.*

*''Copyright note:'' Producing your own transcript for a third-party video could infringe on copyright, depending on how the video has been licensed. Before you proceed with producing a transcript for media materials you did not create yourself, you should contact the copyright holder of that material to obtain permission to do so.

====Captions====

Timed text captions are essential to opening up a world of information for persons with hearing loss or literacy needs by making the readable equivalent of audio content available to them in a synchronized manner. Globally hearing loss affects about 10% of the population to some degree. It causes disability in 5% (360 to 538 million) and moderate to severe disability in 124 million people. Timed text captions also be helpful for learners whose native languages are languages other than the primary language of the media or who have cognitive conditions that benefit from visual.Captions are the text that is synchronized with the audio in a video presentation. Captions are important when people need to see what’s happening in the video and get the audio information in text at the same time.

The work you put into creating a text transcript for a video resource can be repurposed to provide the captions. Keep in mind the following recommendations about what to include in your captions:

#'''All speech content:''' If there is speech that is not relevant, it is usually best to indicate that it has been excluded from the captions. For example: “[A & B chatted while slides were loading].”
#'''Descriptions of relevant non-speech audio:''' These are usually provided in brackets. For example: “[metal pipes crashing to concrete floor]”; “[background music by XXX plays].” Background noise that isn’t relevant can be left out.

Text captions can be uploaded to YouTube and other platforms along with the video to create a timed text file in SubRip (SRT) format. Additional best practices for timed captions include:

*Each caption frame should not be on screen for less than three seconds.
*Each caption frame must not be on screen for less than two seconds.
*Each caption frame should not exceed more than 2 lines.
*Each caption frame must not exceed more than 3 lines.
*Each line should not exceed more than 32 characters
*All caption frames should be precisely time synched to the audio.
*When multiple speakers are present, it is sometimes helpful to identify who is speaking, especially when the video does not make this clear.
*Non-speech sounds like [MUSIC] or [LAUGHTER] should be added in square brackets.

====Downloadable Transcripts====
For both audio and video transcripts, consider including a text file that learners can download and review using tools such as word processing, screen reader, or literacy software. All learners can use transcripts of media-based learning materials for study and review.

====Audio Descriptions====

Consider what your students would get out of a multimedia resource if they were not able to see embedded visual materials critical for comprehension. Audio descriptions are helpful if visual content (e.g., a chart or a map) in a video or presentation provides important context that is not available through the audio alone.<ref>Web Content Accessibility Guidelines (WCAG) 2.0, Guideline 1.2.3 Audio Description or Media Alternative (Prerecorded). Accessed from: http://www.w3.org/TR/WCAG20/#media-equiv</ref> Actions that are only visible on screen without any audible equivalent are not accessible to learners who have visual impairments.

When describing visual elements in your multimedia resources, keep in mind the following recommendations and guidelines.

1. When contextual visual content on the screen is not described in the audio itself, you will need to provide an audio description that is an objective description of the visual element. ''Example:''

:::To help students fully grasp a concept that you are trying to convey in your video, you have included some contextual visual references (e.g., maps, charts, physical demonstrations of a process). However, you realize after making the video that the audio portion does not describe these visuals in enough detail for a student with visual impairments to be able to access all of the concepts you intended to convey.

::In this case, you would need to record an audio description of the visual material that provides enough detail to provide students like Jacob with the same content available to visual learners.

2. Whenever possible, avoid creating the need for audio descriptions in the first place by being proactive at the time of recording. If you pay attention to contextual visuals during the recording of the media piece, you may find opportunities to convey the visual content within the spoken material itself; you will not need to provide audio descriptions of the visual content after the fact. ''Example:''

::You are recording a video or presentation that includes a chart that tracks coal production in British Columbia, and as part of the presentation you want to focus attention on specific data in the chart. The narrator or presenter might point to sections on the chart and say:

:::“As you can see, metallurgical coal projection increased by 3 million tonnes over these two years.“

::In this case, audio descriptions would be necessary to provide the missing context to students with visual disabilities; these students cannot see the data on the chart that tells visual learners what the production figures are and for what dates. However, if the narrator or presenter instead says:

:::“This chart illustrates that metallurgical coal production in B.C. increased from 23 million tonnes in 1999 to 26 million tonnes in 2001,”

::the visual content is conveyed through the audio and no audio description will be necessary.

====Accessible Media Resources====

*[http://ncam.wgbh.org/invent_build/web_multimedia/accessible-digital-media-guide Accessible Digital Media Guidelines] provides detailed advice on creating online video and audio with accessibility in mind.
*[https://dcmp.org/public_content/ai/captioningkey/index.html Captioning Key by the National Association for the Deaf] provides excellent guidance on creating described and captioned media.

==Best Practices 5: Font size==

In this section, we review the two main concerns of font size on the web.

===What Is Font Size?===

'''Font size:''' The size of text visible on the screen.

===Who Are You Doing This For?===

This work supports students who:

*Are blind or have low vision
*Have a form of cognitive disability
*Are deaf or hard of hearing
*Have a physical disability

===What Do You Need To Do?===

There are two main concerns when working with font sizes.

# Ensuring that default font sizes are not too small.
# Ensuring that text can be expanded to 200% on websites<ref>http://sites.psu.edu/accessibility/fontsizehtml/ </ref>.

Keep in mind these recommendations and guidelines:

*'''12 point for body text''': For most documents, body text should be around 12 points. Small fonts may be illegible for some audiences.

*'''9 point for footnotes''': If a document contains footnotes or endnotes, the minimum size should be about 9 points

* '''200% zoom''': The Web Content Accessibility Guidelines (WCAG 2.0) recommend ensuring that text can be zoomed to 200%. As well, we recommend using liquid layouts that can accommodate 200% text. Liquid layout are layouts that are based on percentages of the current browser window's size. They flex with the size of the window, even if the current viewer changes their browser size as they're viewing the site. Liquid width layouts allow a very efficient use of the space provided by any given Web browser window or screen resolution.

==Best Practices 6: Colour Contrast==
In this section, we provide guidelines and recommendations about colour contrast in your open educational materials.

===What is Colour Contrast?===

'''Colour contrast includes''': hue, lightness and saturation of text, images, and background
'''File types''': .doc, .html, .pdf, .jpg, .gif

===What What Role Does Colour Play in the Delivery of Your Content?===

When documents or web pages do not provide enough contrast between foreground elements (e.g., text, images) and background elements (e.g., colour, watermark images), some students will have difficulty reading the content. Consider the following questions:

1. Have you presented text- or image-based content on a coloured or textured background? If so, you should:
*Confirm that there is sufficient contrast between your foreground content and the chosen background colour or texture.

2. Have you included links in your content? If so, you should:
*Confirm that the colour of your web links is distinct from both your background colour and the colour of the surrounding text.

3. Have you used colour to convey concepts or information? If so, you should:
*Confirm that you are not using colour alone to convey this information.

===Who Are You Doing This For?===

This work supports students who:

*Have low vision
*Have poor contrast vision
*Are colour blind and cannot differentiate between certain colours
*Are using a device with monochrome display

===What Do You Need To Do?===

====Contrast====

Students with low vision and/or a form of colour blindness may have difficulty reading text that does not contrast enough with the background colour you have selected. If the colour palette you have adopted is too subtle (e.g., white text on a pastel background; medium-grey text on a light-grey background), the contrast between your foreground and background is probably insufficient for some students.

Web Content Accessibility Guidelines (WCAG 2.0) require that “the visual presentation of text and images of text has a contrast ratio of at least 7:1.”<ref>Web Content Accessibility Guidelines (WCAG) 2.0, Guideline 1.4.6 Contrast (Enhanced). Accessed from: http://www.w3.org/TR/UNDERSTANDING-WCAG20/visual-audio-contrast7.html</ref> The image below presents four different foreground/background colour-contrast examples to illustrate insufficient and sufficient colour contrast ratios.
<br /><br />
[[File:Colour_Contrast.png|thumb|center|500px|Image displays four examples of foreground (text) colour against background colours; only the example on the far right presents combinations with sufficient colour contrast.]]
<br /><br />
{| class="ambox ambox-notice"
| class="mbox-text" | <div>
'''Not sure how to test your materials for colour contrast ratios?'''

There are many online and downloadable tools available to help you evaluate colour contrast ratios. Here are a few we have tried and like:
*'''WebAIM’s [http://webaim.org/resources/contrastchecker/ Color Contrast Checker]''': This web-based tool allows you to select or enter colour values to test and provides you with a “pass” or “fail” on your contrast ratio.
*'''ACART’s [http://www.contrastchecker.com/ Contrast Checker]''': This is a straightforward, web-based tool you can use to both check colour contrast and view your selections in grey scale. This tool also allows you to keep a history of the colour combinations you have tested.
*'''Giacomo Mazzocato’s [http://gmazzocato.altervista.org/colorwheel/wheel.php Accessibility Color Wheel]''': This web-based tool includes several options for testing your colour selections, including simulations of three types of colour blindness. You can also opt to test what your contrast ratio is when the foreground and background colour selections are inverted.
</div>
|}

====Weblink Colours====

Weblinks must be visually distinct from both the surrounding, non-linked text and background colour. If you do not underline your links (or provide some other non-colour cue), you must ensure that you provide both sufficient contrast between the link and background colours and between the link colour and that of the surrounding text.

Web Content Accessibility Guidelines (WCAG 2.0) require a:
*4.5:1 contrast between the link text color and the background
*3:1 contrast between the link text color and the surrounding non-link text color<ref>WebAIM (2015), WCAG 2.0 and Link Colors. Accessed from: http://webaim.org/blog/wcag-2-0-and-link-colors/ </ref>

====High-Contrast Mode====

Some students need to see light text on a dark background for it to be readable, while others require dark text on a light background. Students with low vision must be able to see content when it is displayed in high-contrast mode. This can be a subjective experience, based on individual student needs. We recommend that you try testing your text and image-based content as you go by using high-contrast mode on your own computer and making adjustments as needed.

All content items such as text, images, bullets, and table borders must be visible in both regular and high-contrast modes.

{| class="ambox ambox-notice"
| class="mbox-text" | <div>
'''Not sure how to test your content in high-contrast mode?
'''
To test the visibility of your content in this mode, turn on high contrast by simultaneously pressing the following keys on your (PC) keyboard:
::'''Left ALT + Left SHIFT + Print Screen.'''
To turn off high contrast mode, repeat this step.
</div>
|}

====Use of Colour====

You should not rely on colour as the sole means of conveying information and instruction. If the point you are making depends on colour to be understood, you will need to edit your materials so that concepts presented in the visuals are not lost to those who are colour blind or who require high contrast between colours.<ref>Web Content Accessibility Guidelines (WCAG) 2.0, Guideline 1.4.1 Use of Color. Accessed from: http://www.w3.org/TR/WCAG20/#visual-audio-contrast</ref>

==Best Practices 7: Formulas==

Math or Science formulas in open educational resources can be challenging to deliver in a way that is accessible to people with vision impairments. Non-scalable images of mathematical content cannot be sufficiently enlarged or navigated by low-vision users and are not accessible to blind users at all.

===What Are Formulas?===

'''Formulas include:''' Math equations or science formulas

'''File types:''' LaTex or MathType

===Before You Begin===
'''Who Are You Doing This For?'''

This work supports students who:

*Are blind or have low vision
*Have a form of cognitive disability,
*Have a physical disability

The following content is a derivative of Equations: Images vs. MathML from Accessibility and Usability at Penn State, http://accessibility.psu.edu/equations.

===What Do You Need to Do?===

There are several ways to handle equations from images with ALT tags to MathML. Having access to an equation editor such as MathType or MathMagic can streamline processing and converting equations considerably. These tools are similar to equation editors found in the ANGEL HTML Editor and Microsoft Office.

====MathML====

[http://accessibility.psu.edu/math/mathml/ Math ML] is a text-based XML markup language designed for math equations. Browsers that support MathML are able to translate the XML into a formatted equation. Since MathML with MathJax can be rendered in many systems, including HTML, Sites at Penn State, ANGEL and Drupal, it is considered the best choice for accessibility.

Information about [http://accessibility.psu.edu/math/mathml/ creating and viewing MathML] is available on that page.

MathML may vary from system to system and the content can change rapidly.

====Image with ALT tag====

A safe option to create an image of an equation (or export it from an equation editor) and then insert the image into a document with an ALT tag.

''Note:'' ALT tags can be written in Nemeth MathSpeak for students who have learned that system.

<math>
m = \frac{m_0}{\sqrt{1-\frac{v^2}{c^2}}}
</math>

View the ALT Tag

ALT= “m equals begin fraction m sub 0 over begin square root 1 minus begin fraction v sup 2 over c sup 2 end fraction end square root end fraction”

====LaTex====

LaTeX is a math markup language familiar to many in the science and math community, but unfortunately it is not currently supported by screen reader technology. However, it is fairly simple to convert LaTeX to an image or MathML in most equation editors.

For example, in the [http://wiki.ubc.ca UBC Wiki] you can insert a piece of LaTeX code using the <nowiki><math></nowiki> tag:
<pre>
<math>
m = \frac{m_0}{\sqrt{1-\frac{v^2}{c^2}}}
</math>
</pre>
The equation should appear fully formatted. Make minor adjustments as needed.

====Audio Files====
User testing with students have indicated that it would helpful to have an audio file of the formula or equation. The audio file would be placed beside the formula or equation and would allow the user to hear exactly how the formula or equation is interpreted.

====Audio Files====
User testing with students have indicated that it would helpful to have an audio file of the formula or equation. The audio file would be placed beside the formula or equation and would allow the user to hear exactly how the formula or equation is interpreted.
=====Example — equation with audio=====
[[File:MM0over.png|200px|center|math formular]]
[https://soundcloud.com/user-262382099-529580848/equation Listen to the audio file of this equation]:

===Additional Resources===

*In 2012, Portland Community College departments took a closer look at making math accessible to blind students. Read more about the math accessibility study on our website: http://www.pcc.edu/access.
*The [http://www.washington.edu/doit/are-there-guidelines-creating-accessible-math?465= DO-IT project from the University of Washington] provides guidance on creating accessible math content.
*The [http://www.washington.edu/doit/programs/accessstem/overview AccessSTEM] website provides guidance on creating accessible science, technology, engineering and math educational content.

==Best Practices 8: PDFs, Word Docs and Excel Files==
This section describes guidelines for creating accessible content in PDFs, Word documents, and Excel spreadsheets. Many of the same accessibility techniques and principles that apply to authoring in HTML also apply to creating document based OERs.

===PDFs===
Converting or publishing open resources as PDF documents can create accessibility barriers, particularly for learners with visual impairments. Accessibility issues are very common in PDF files that were scanned from printed sources or exported from a non-PDF document format. Scanned documents are simply images of text. To make scanned documents accessible, you must perform Optical Character Recognition (OCR) on these documents, and proofread the resulting text for accuracy before embedding it within the PDF file. You must also add semantic structure and other metadata (headings, links, alternative content for images, and so on) to the embedded text.

When you export documents to PDF from other formats, it is important to ensure that the source document contains all the required semantic structure and metadata before exporting. Unfortunately, some applications do not include this information when exporting and require the author to add or “tag” the document manually using PDF editing software. You should carefully consider whether exporting to PDF is necessary at all.

For more information on PDF accessibility, please see [https://pressbooks.bccampus.ca/accessibilityhandbook/chapter/the-people-v-pdf/ The People v. PDF by Luke McKnight].

====Best Practices for Authoring Accessible PDF Documents====

*Explicitly define the language of the document so that screen readers know what language they should use to parse the document.
*Explicitly set the document title. When you export a file to PDF format, the document title usually defaults to the file name, not a human readable title.
*Verify that all images have alternative content defined or are marked as decorative only.
*Verify that the PDF file is “tagged”. Make sure the semantic structure from the source document has been correctly imported to the PDF file.
*Verify that a logical reading order is defined. This is especially important for documents that have atypical page layouts or structure.
*If your document includes tables, verify that table headers for rows and columns are properly defined.

====Accessible PDF Resources====
*[http://webaim.org/techniques/acrobat/ WebAIM's PDF Accessibility site] provides a detailed and illustrated guide on creating accessible PDFs.
*The [http://ncdae.org/resources/cheatsheets/ National Center of Disability and Access to Education has a collection of one-page “cheat sheets”] on accessible document authoring.
*Microsoft provides detailed [https://support.office.com/en-gb/article/Create-accessible-PDFs-064625e0-56ea-4e16-ad71-3aa33bb4b7ed?CorrelationId=9b8d28cf-aa96-4816-9536-b4aea195b51c&ui=en-US&rs=en-GB&ad=GB&ocmsassetID=HA102478227 guidance on generating accessible PDFs from Microsoft Office applications], including Word, Excel, and PowerPoint.
*Adobe provides [https://helpx.adobe.com/acrobat/using/create-verify-pdf-accessibility.html documentation on how to create and verify PDF accessibility].

===Word Documents===
Many of the same accessibility techniques and principles that apply to authoring one content also apply to creating Word documents. Keep formatting simple. Use headings, paragraphs, lists, images, and captions. Use tables for tabular data. Do not add unnecessary indents, rules, columns, blank lines, or typographic variation. Use standardized styles for formatting your text, such as Normal, Heading 1, and Heading 2, rather than manually formatting text using text styles and indents. Formatting text for its semantic meaning and not for its visual appearance allows users of assistive technology to consume and navigate documents effectively and efficiently.

Additional best practices include;

*Images must have descriptive text associated with them.
*Documents should be well structured.
*Hyperlinks should be meaningful and describe the destination.
*Tables should include properly defined column and row headers.
*Color combinations should be high contrast.
*Verify the accessibility of your document using [https://support.office.com/en-us/article/Use-the-Accessibility-Checker-on-your-Windows-desktop-to-find-accessibility-issues-a16f6de0-2f39-4a2b-8bd8-5ad801426c7f?ui=en-US&rs=en-US&ad=US Microsoft’s Accessibility Checker].

===Excel Spreadsheets===
Many of the same accessibility techniques and principles that apply to authoring data tables in HTML also apply to creating Excel spreadsheets. Microsoft has a [https://support.office.com/en-us/article/Make-your-Excel-spreadsheets-accessible-6CC05FC5-1314-48B5-8EB3-683E49B3E593?ui=en-US&rs=en-US&ad=US guide to creating accessible Excel workbooks].

*Images must have descriptive text associated with them.
*Column and row headings should be programmatically identified.
*Hyperlinks in spreadsheets should be meaningful and describe the destination.
*Use a unique and informative title for each worksheet tab.
*Do not use blank cells for formatting.
*Colour combinations should be high contrast.
*Verify the accessibility of your workbook using [https://support.office.com/en-us/article/Use-the-Accessibility-Checker-on-your-Windows-desktop-to-find-accessibility-issues-a16f6de0-2f39-4a2b-8bd8-5ad801426c7f?ui=en-US&rs=en-US&ad=US Microsoft’s Accessibility Checker].

===Additional Microsoft Accessibility Resources===
*[https://support.office.com/en-us/article/Make-your-Word-documents-accessible-D9BF3683-87AC-47EA-B91A-78DCACB3C66D?ui=en-US&rs=en-US&ad=US Microsoft guide to creating accessible Word documents.]
*[https://support.office.com/en-us/article/Use-the-Accessibility-Checker-on-your-Windows-desktop-to-find-accessibility-issues-a16f6de0-2f39-4a2b-8bd8-5ad801426c7f?ui=en-US&rs=en-US&ad=US Microsoft tool that allows you to check Word documents for accessibility issues.]
*Microsoft guide to creating [https://support.office.com/en-us/article/Make-your-PowerPoint-presentations-accessible-6F7772B2-2F33-4BD2-8CA7-DAE3B2B3EF25?ui=en-US&rs=en-US&ad=US accessible PowerPoint presentations].
*[https://support.office.com/en-us/article/Make-your-Excel-spreadsheets-accessible-6CC05FC5-1314-48B5-8EB3-683E49B3E593?ui=en-US&rs=en-US&ad=US Microsoft guide to creating accessible Excel workbooks].
*Microsoft tool that allows you to check [https://support.office.com/en-us/article/Use-the-Accessibility-Checker-on-your-Windows-desktop-to-find-accessibility-issues-a16f6de0-2f39-4a2b-8bd8-5ad801426c7f?ui=en-US&rs=en-US&ad=US Excel workbooks for accessibility issues].
*Microsoft guide to creating [http://webaim.org/techniques/powerpoint/ accessible PowerPoint presentations].
*[http://webaim.org/techniques/powerpoint/ WebAIM’s guide to PowerPoint accessibility].

==UBC Platform Specific Accessibility Guidelines==

===Canvas===
*[https://community.canvaslms.com/docs/DOC-2061 Accessibility within Canvs]
*[https://community.canvaslms.com/groups/accessibility Canvas Accessibility Group]
*[https://community.canvaslms.com/groups/accessibility/blog/2018/05/08/how-to-fix-and-prevent-accessibility-issues-in-your-canvas-course How to Fix and Prevent Accessibility Issues in Your Canvas ]

===Edx===
*[http://edx.readthedocs.io/projects/edx-partner-course-staff/en/latest/accessibility/index.html Accessibility Best Practices Guidance for Content Providers]

===WordPress===
*[https://en.support.wordpress.com/accessibility/ Accessibility in WordPress]
*[http://khan.github.io/tota11y/ Tota11y] - a tool to check if your site is accessible or not. There is also a [https://chrome.google.com/webstore/detail/tota11y-plugin-from-khan/oedofneiplgibimfkccchnimiadcmhpe?hl=en chrome extension] available

===MediaWiki/UBC Wiki===
*[https://en.wikipedia.org/wiki/Wikipedia:Manual_of_Style/Accessibility Manual of Style- Accessibility]

===UBC Centre for Accessibility===
*[https://students.ubc.ca/about-student-services/centre-for-accessibility UBC Centre for Accessibility] (CfA) provides leadership on issues of accessibility for people with disabilities at UBC Vancouver, working in partnership with faculties to foster inclusive learning, living and working environments for students, faculty and staff. The Centre for Accessibility provides support and programming initiatives designed to remove barriers for students with disabilities and facilitates disability related accommodations for members of the UBC Vancouver community.

===UBC Centre for Workplace Accessibility===
*[https://hr.ubc.ca/health-and-wellbeing/workplace-accessibility/centre-workplace-accessibility The Centre for Workplace Accessibility] (CWA) is a hub for resources, tools, and programs that help remove barriers for faculty and staff with disabilities or ongoing medical conditions. It offers support to improve workplace accessibility using a trauma-informed, person-centred approach. Its initiatives also include projects and workshops designed to build disability inclusion literacy throughout the UBC community.

==Appendix: Checklist for OER Accessibility==

===Organizing Content===

☐ Contents is organized under headings and subheadings

☐ Headings and subheadings are used sequentially (e.g. Heading 1, heading 2, etc)

===Images===

☐ Images that convey information include Alternative Text (alt-text) descriptions of the image’s content or function.

☐ Graphs, Charts, and Maps also include contextual or supporting details in the text surrounding the image.

☐ Images do not rely on colour to convey information.

☐ Images that are purely decorative contain empty alternative text descriptions. (Descriptive text is unnecessary if the image doesn’t convey contextual content information).

===Tables===

☐ Tables include row and column headers.

☐ Table includes title or caption.

☐ Table does not have merged or split cells.

☐ Table has adequate cell padding.

===Weblinks===

☐ The weblink is meaningful in context, does not use generic text such as “click here” or “read more”.

☐ Weblinks do not open new windows or tabs.

☐ If weblink must open in a new window, a textual reference is included in the link information.

===Multimedia===

☐ A transcript has been made available for a multimedia resource that includes audio narration or instruction. Transcript includes:
:Speaker’s name
:All speech content
:Relevant descriptions of speech
:Descriptions of relevant non-speech audio

===Headings and subheadings===

☐ Captions of all speech content and relevant non-speech content are included in the multimedia resource that includes audio synchronized with a video presentation.

☐ Audio descriptions of contextual visuals (graphs, charts, etc) are included in the multimedia resource.

===Formulas===

☐ Formulas have been created using MathML.

☐ Formulas are images with alternative text descriptions, if MathML is not an option.

===Font Size===

☐ Font size is 12 point or higher for body text.

☐ Font size is 9 point for footnotes or end notes.

☐ Font size can be zoomed to 200%.

==Appendix: Accessibility 2-Page Handout==

[[File:Accessibility Handout Thumbnail.png|thumb|centre|400px|link=http://wiki.ubc.ca/images/5/5b/UBC_Accessibility_Handout.pdf|Click to Download PDF ]]

==Appendix: Additional OER Accessibility Resources==
*[https://accessibility.ctlt.ubc.ca/ UBC Accessibility 101] - A UBC resource that focuses on improving access to digital content for students with vision or hearing impairments and similar learning barriers.
*[https://blogs.ubc.ca/accessibleactivelearning/ Accessible Active Learning] - A resource designed for Instructional Skills Workshop (ISW) and TA Training facilitators at UBCV. It is meant as a resource to help them design activities with accessibility in-mind, to help make activities accessible to more students and participants.
*[https://equity.ubc.ca/resources/accessible-and-inclusive-event-planning/ UBC Accessible Event Planning Guide] - provides practical tools to help event organizers create inclusive and welcoming experiences for everyone, including particularly people with disabilities.
*[https://opentextbc.ca/accessibilitytoolkit/ BC Open Textbook Accessibility Toolkit] - (also in [https://opentextbc.ca/troussedoutildaccessibilite/ French]). See also the [https://cdn.collection.bccampus.ca/assets/B_Ccampus_Accessibility_Criteria_6b42ab8ce8.pdf BCcampus OER Accessibility Criteria checklist] and the [https://opentextbc.ca/accessibilitytoolkit/back-matter/inclusive-design-webinar-series/ BCcampus Inclusive Design Webinar Series].
*[https://students.ubc.ca/about-student-services/centre-for-accessibility UBC Centre for Accessibility] provides support and programming initiatives designed to remove barriers for students with disabilities and facilitates disability related accommodations for members of the UBC Vancouver community.
*[https://pressbooks.bccampus.ca/a11yondemand/ Digital Accessibility On-demand] - a resource by Luke McKnight designed as a just-in-time resource to guide creators to the step-by-step instructions they need to maximize accessibility and increase inclusivity.
*[https://pressbooks.bccampus.ca/accessibilityhandbook/ Accessibility Handbook for Teaching and Learning] - a guidebook by Luke McKnight and Briana Fraser to introduce concepts of digital accessibility and to provide detailed instructions to use the accessibility features of software such as Word and PowerPoint.
*[https://hr.ubc.ca/health-and-wellbeing/workplace-accessibility/centre-workplace-accessibility The Centre for Workplace Accessibility (CWA)] is a hub for resources, tools, and programs that help remove barriers for faculty and staff with disabilities or ongoing medical conditions. It offers support to improve workplace accessibility using a trauma-informed, person-centred approach.
*Inclusive Design Research Centre’s [http://floeproject.org/ Flexible Learning for Open Education]
*[http://www.udlcenter.org/implementation/postsecondary The National Center on Universal Design for Learning] provides a helpful overview on Universal Design for Learning.
*Portland Community College’s [http://www.pcc.edu/resources/instructional-support/access/ Accessibility for Online Course Content: A Guide for Instructors]
*[https://inclusive.microsoft.design/ Inclusive Design at Microsoft]
*[https://wiki.ubc.ca/images/0/02/Complex_Images_for_All_Learners.pdf Accessibility for Complex Images]: resource for making charts, graphs, figures, and other complex images accessible.
*[https://pressbooks.bccampus.ca/accessibilityhandbook/chapter/the-people-v-pdf/ The People v. PDF] - a semi-academic take on some of accessibility issues of PDFs
*The [https://bccampus.ca/wp-content/uploads/2023/04/OER-Equity-Rubric-1.pdf BCcampus OER Equity Rubric] is designed to help identify opportunities to adapt and improve the equity of open resources.

==References==
<references/>

==About this Toolkit==
[[File:CC-SA_button.png|left|CC by|100px]] The OER Accessibility Toolkit is licensed under a [https://creativecommons.org/licenses/by-sa/4.0/ Creative Commons Attribution-ShareAlike 4.0 International License], except where otherwise noted. Source files for this resource may be found on the [http://wiki.ubc.ca/Documentation:Open_UBC/Guide/OER_Accessibility_Toolkit UBC Wiki].

Content for this toolkit was adapted from the [https://opentextbc.ca/accessibilitytoolkit/ BC Open Textbook Accessibility Toolkit] by Amanda Coolidge, Sue Doner, and Tara Robertson. The [https://opentextbc.ca/accessibilitytoolkit/ BC Open Textbook Accessibility Toolkit] is licensed under a [https://creativecommons.org/licenses/by/4.0/ Creative Commons Attribution 4.0 International License], except where otherwise noted. Additional material has been adapted from the [http://edx.readthedocs.io/projects/edx-partner-course-staff/en/latest/accessibility/index.html edX Accessibility Best Practices for Developing Course Content] guidelines under a [https://creativecommons.org/licenses/by-sa/4.0/ Creative Commons Attribution Share Alike 4.0 International License].

[[Category:Open UBC]][[Category:Accessibility]] [[Category:Accessibility Toolkits]] [[Category:OER]] [[Category:Open Education]] [[Category:Universal Design]]

Documentation:Open UBC/Guide/OER Accessibility Toolkit

2026-05-29T16:49:49Z

WillEngle: /* Appendix: Additional OER Accessibility Resources */

==Accessibility for Open Education==

{{#widget:YouTube|id=KcvYG-rkO-Y|height=315|width=420}}

The focus of many open education projects is to provide access to education. But what does access mean? If the materials are not accessible for each and every student, do they fulfill the mandate to deliver fully open education? The open education movement has helped people in different parts of the world access content that they would otherwise not be able to view or interact with. Open education resources reduce costs for students and allow for greater flexibility for instructors. Accessibility can help push the movement even further forward.

The goal of the ''OER Accessibility Toolkit'' is to provide the needed resources to each content creator, instructor, instructional designer, educational technologist, librarian, administrator, and teaching assistant to create a truly open and accessible educational resource — one that is accessible for all students.

As you work through the content of the ''OER Accessibility Toolkit'', you will find that the suggestions provided are intended for the non-technical user. If you are looking for more technical descriptions of how to make your work accessible, we suggest you review the [https://www.w3.org/TR/WCAG20/ WCAG (Web Content Accessibility Guidelines)].

==Key Concepts: Universal Design and Personas==

Universal Design is the process of creating products (devices, environments, systems, and processes) that are usable by people with the widest possible range of abilities, operating within the widest possible range of situations (environments, conditions, and circumstances). Universal Design emerged from the slightly earlier concept of being barrier-free, the broader accessibility movement, and adaptive and assistive technology. It also seeks to blend aesthetics into these core considerations.

Let’s review some common definitions of Universal Design.

===Definition 1===

Universal Design or Universal Instructional Design (UID)
{| class="ambox ambox-notice"
| class="mbox-text" | <div>
"is an approach to teaching that consists of the proactive design and use of inclusive instructional and evaluation strategies. This approach provides academic access to a broad range of learners, including students with disabilities, while:
*maintaining academic standards […]
*reducing the need to having to retrofit after a course is already underway<ref>FAIR ([http://web2.uvcs.uvic.ca/fair/ Facilitating Accessible Instruction & Resources]). University of Victoria </ref>"

</div>
|}

===Definition 2===
{| class="ambox ambox-notice"
| class="mbox-text" | <div>
Universal Instructional Design (UID)

is an approach to designing course instruction, materials and content to benefit people of all learning styles without adaptation or retrofitting. UID provides equal access to learning, not simply equal access to information. UID allows the student to control the method of accessing information while the instructor monitors the learning process and initiates any beneficial methods. …It should be noted that UID does not remove academic challenges; it removes barriers to access.<ref>Universal Design for Learning. Ohio State University</ref>
</div>
|}

===Why Universal Design?===

For our purposes, we frame the practice of using Universal Design in a holistic and manageable way, and begin by addressing the barriers that are easy to anticipate and proactively re-mediate. This toolkit, therefore, will provide guidance to you if the answers to any of the following questions is “yes”:

*Do I have visual materials that present core concepts that not all students may be able to see or understand?
*Do I have multimedia (audio, video) materials that present core concepts that not all students may be able to be hear, see, or access?
*Do I have documents that present core concepts in a format that not all students may be able to access?

For the purpose of the ''OER Accessibility Toolkit'', we focus on an adjunct to Universal Design, that being Universal Design for Learning (UDL), which is a set of principles for curriculum development that gives all individuals equal opportunities to learn. UDL provides a blueprint for creating instructional goals, methods, materials, and assessments that work for everyone. Rather than a single, one-size-fits-all solution, it offers a flexible approach that can be customized and adjusted for individual needs.<ref>http://www.udlcenter.org/aboutudl/whatisudl ↵</ref>

The principles of Universal Design for Learning can be summarized by the following points.

*Present information and content in various ways.
*Provide more than one way for learners to express what they know.
*Stimulate interest and motivation for learning.

OER creators can apply these principles in course design by following several guidelines:

*Design resources and activities that can be accessed by learners in a variety of ways. For example, if there is a text component, provide the ability to enlarge the font size or change the text color. For images and diagrams, always provide an equivalent text description. For video, include text captions.
*Provide multiple ways for learners to engage with information and demonstrate their knowledge. This is particularly important to keep in mind as you design activities and assessments.
*Identify activities that require specific sensory or physical capability and for which it might be difficult or impossible to accommodate the accessibility needs of learners. For example, an activity that requires learners to identify objects by color might cause difficulties for learners with visual impairments. In these cases, consider whether there is a pedagogical justification for the activity being designed in that way. If there is a justification, communicate these requirements to prospective learners in the course description and establish a plan for responding to learners who encounter barriers.

===Persona===
{{#widget:YouTube|id=_YpNrOkW0Mw|height=315|width=420}}

This video shows a demonstration of students using accessibility softwares (ZoomText, JAWs and TextDragon) .

Designers use personas to represent the different types of people who may be accessing a website or product. Using a persona can be a helpful when you are designing an accessible open resources. Take a look at the personals from [http://uxmag.com/articles/book-excerpt-a-web-for-everyone Book Excerpt: A Web for Everyone] to get an idea on how your audiences navigate your course/resources.

==Best Practices 1: Online Content Organization and Weblinks==

HTML is a good format for creating accessible content. It is well supported and adaptable across browsers and devices. Also, the information in HTML markup helps assistive technologies, such as screen reader software, to provide information and functionality to people with vision impairments.

Organizing your html and online content so it has a logical flow just makes sense. Using headings, and subheadings to organize content allows students to clearly see how the main concepts are related. Headings are one of the main ways that students using a screen reader navigate through a webpage or online resource.

A weblink is a link from a file or document to another location (such as a website address) or file, typically activated by clicking on a highlighted word or image on the screen. Generally weblinks are included within content to provide the user with additional information that is available at a another location.

'''File types''': .html, .pdf, .doc, .xls

===Who Are You Doing This For?===

Everyone benefits from having content that’s clearly organized. In addition, well-organized content and descriptive weblinks support students who:

*Have a learning disability (For a example, a student with ADHD) - Having an organized content allow them to easily go back and find the important points.
*Are blind or have low vision - It gives them more control in navigating through different chapters.
*Have a form of cognitive disability
*Have a physical disability,
*Are deaf or hard of hearing

===What Do You Need to Do?===

====Content Organization====
Headings help to identify the hierarchical structure of a document (e.g., sections, sub-sections). Headings provide a visual cue that helps sighted readers quickly navigate through sections of a document, skimming through content until they find a section they are looking for. Similarly, headings create logical divisions in the content and allow a non-sighted user to navigate a page or document easily using a screen reader.

When it comes to using visual references to indicate the hierarchy and structure of a document, you may be accustomed to just changing the font, enlarging the type size, making it bold or underlined or italicized, creating the impression of a heading. This approach presents problems when creating material with accessibility in mind because screen readers won’t identify the text as a heading. Instead, a screen reader will just “read” through the text of a heading as if it were part of another paragraph of content, missing your intended cues about structure and organization.

[[File:Headings in wordpress.png|thumb|center|Headings in WordPress(UBC Blogs)]]
Keep the following guidelines in mind when you create online content.

*Use HTML tags to describe the meaning of content, rather than changing its appearance. For example, you should tag a section title with the appropriate heading level (such as <nowiki><h3></nowiki>) rather than making the text appear like a heading by applying visual elements such as bold text and a larger font size. Format list items into a list rather than using images of bullets or indents. Using HTML to describe your content’s meaning is valuable for learners who use screen readers, which, for example, can read through all headings of a specific level or announce the number of items in a list.
*Use HTML heading levels in sequential order to represent the structure of a document. Well-structured headings help learners and screen reader users to navigate a page and efficiently find what they are looking for.
*Use HTML list elements to group related items and make content easier to skim and read.

====Content Organization How tos====
*[https://en.support.wordpress.com/visual-editor/#styles How to create headings in WordPress(UBC Blogs)]
*[[Help:Formatting#Headers_.26_Lines|How to create headings in UBC Wiki]]
*[https://ccs.instructure.com/courses/1181412/pages/accessibility-basics-on-canvas-pages-headers-colors-and-tables?module_item_id=21897445 How to create headings in Canvas]
*[http://edx.readthedocs.io/projects/edx-partner-course-staff/en/latest/course_components/create_html_component.html#the-visual-editor How to create headings in EdX]

====Link Descriptions====

Ensure that all web pages and weblinks have titles that describe a topic or purpose. The purpose of the link can be determined by the text alone. That is, you don’t need to include additional information justifying the use of the link. You want the link to be meaningful in context. For example, do not use generic text such as “click here” or “read more” unless the purpose of the link can be determined by meaning in the surrounding content.<ref>https://www.webaccessibility.com/best_practices.php?best_practice_id=1301</ref>

Consider the following examples.

'''Example 1''' — unclear:

Click [http://open.ubc.ca here] for information on open at UBC.

'''Example 2''' — clear and accessible:

Information on [http://open.ubc.ca UBC Open education projects and resources] is available online.

====New Tabs/Windows====

In general, it is better if weblinks do not open new windows and tabs since they can be disorienting for people, especially people who have difficulty perceiving visual content.<ref>http://www.w3.org/TR/2014/NOTE-WCAG20-TECHS-20140916/G200</ref>. However, if a link must open in a new window, it is best practice to include a textual reference. For example, IInformation on [http://open.ubc.ca UBC Open education projects and resources (New Window)] is available online.<ref>http://accessibility.psu.edu/linkshtml</ref>

==Best Practices 2: Images==
In this section, we provide recommendations to guide your inclusion of accessible, image-based content.

===What Are Images?===

'''Images include''': photographs, diagrams, pictures, charts, graphs, maps

'''File types''': .gif, .jpg, .png

===Before You Begin===

====Why Are You Including the Images You Have Selected?====

Before you can determine what you need to do to make an image accessible, you first need to identify its purpose or value to your open resources. Consider the following questions:

#Does your image serve a functional purpose? In other words, is it conveying non-text content to students? If so, you should:
#*Provide a text alternative that serves the equivalent purpose of the non-text material<ref> Web Content Accessibility Guidelines (WCAG) 2.0, Guideline 1.1 Text Alternatives. Accessed from: http://www.w3.org/TR/WCAG20/#text-equiv </ref>
#*Not use colour as the only visual means of conveying information <ref> Web Content Accessibility Guidelines (WCAG) 2.0, Guideline 1.4.1 Use of Color. Accessed from: http://www.w3.org/TR/WCAG20/#visual-audio-contrast</ref>
#Does your image serve more of a decorative purpose? In other words, is it primarily a design element that does not convey content? If so, you should:
#*Avoid unnecessary text descriptions

====Who Are You Doing This For?====

This work supports students who:

*Are blind or have low vision
*Have poor contrast vision
*Are colour blind and cannot differentiate between certain colours
*Are using a device with monochrome display
*Have a form of cognitive disability

===What do you need to do? ===
====Functional Images and Alternative Text Description====
Consider what your content page would look like if the images didn’t load. Now try writing alternative text for each image that would work as a replacement and provide the same service as the image.

As you work on developing your alternative text descriptions, keep the following recommendations and guidelines in mind:
*Remember that alternative text must convey the content and functionality of an image and is rarely a literal description of the image (e.g., “photo of cat”). Rather than providing what the image looks like, alternative text should convey what the content of the image is and what it does. <ref>webAccess (2012). Adapted from: Top Ten Tips for making your website accessible. Accessed from: http://webaccess.berkeley.edu/developer-information/top-ten-tips/#alt </ref>
*For relatively simple images (e.g., photographs, illustrations), try to keep your text descriptions short. You should aim to create a brief alternative (one or two short sentences) that is an accurate and concise equivalent to the information in the image.
*For more complex images (e.g., detailed charts, graphs, maps), you will need to provide more than a one- to two-sentence description to ensure all users will benefit from the content or context you intended to provide. In these cases, you should either provide the details in the text surrounding the image or write a longer text description that students can link to on a separate page. You should still include a short text description (one to two sentences) that tells students where they can find the details you have provided in the longer description.
*Leave out any unnecessary information. For example, you do not need to include information like “image of…” or “photo of…”; assistive technologies will automatically identify the material as an image, so including that detail in your alternative description is superfluous.

Avoid redundancy of content in your alternative description. Don’t repeat the same information that already appears in text adjacent to the image.

=====Example 1: [https://opentextbc.ca/introductiontosociology/chapter/chapter20-population-urbanization-and-the-environment/ (from Introduction to Sociology)] =====

[[File:Rio-de-janeiro-and-london.png|thumb|center|Figure 20.11. The slum city and the global city: the Favéla Morro do Prazères in Rio de Janeiro and the London financial district show two sides of global urbanization (Photos courtesy of dany13/Flickr and Peter Pearson/Flickr). |alt="Figure 20.11 includes two photos. The first photo shows crowded buildings located on the hillside. They are small and shabby. The second photo shows magnificent buildings located by water."]]

This photograph could be described in this way:

{| class="ambox ambox-notice"
| class="mbox-text" | <div>
"Figure 20.11 includes two photos. The first photo shows crowded buildings located on the hillside. They are small and shabby. The second photo shows magnificent buildings located by water."
</div>
|}

=====Example 2 (Figure 18.1. Two-Atom, Double-Flask Diagram from [http://opentextbc.ca/introductorychemistry/chapter/entropy-and-the-second-law-of-thermodynamics/ Introductory Chemistry]): =====
[[File:Double flask gas atom diagram.png|center|thumb|(Figure 18.1. Two-Atom, Double-Flask Diagram from Introductory Chemistry) ]]
When the stopcock is opened between the flasks, the two atoms can distribute in four possible ways.

Figure 18.1 could be described as follows:
{| class="ambox ambox-notice"
| class="mbox-text" | <div>
"Figure 18.1 shows a diagram with five pairs of circles. All of these circles are open. The left one opens on the right and the right one opens on the left. They are connected with lines at their open points. One pair is located on the left and between their two connecting lines is a black dot with a red vertical line going across. The other four pairs arranged in a column are located on the right and between the connecting lines of each pair is a a small circle with a red horizontal line going through. A right arrow labelled Open Stopcock links the pair sitting on the left to the four pairs on the right. Each of these five pairs has two dots (green and blue) arranged in different patterns. For the pair on the left, the two dots, sitting obliquely, appear only in left circle. The green dot is at the left upper part of the circle and following it the blue dot is close to the bottom right. The first pair on the right has the similar situation. The only difference is that the green dot is at the right upper part of the circle and the blue dot is close the middle left. The second pair has a green dot in the centre of the left circle and a blue dot in the centre of the right circle. The third pair has a blue dot sitting at the left upper part of the left circle and a green dot sitting close to bottom right of the right circle. For the last pair, the two dots appear in oblique direction only in the right circle. A green dot is at the right upper part of the circle and a blue dot is close to bottom left.
"
</div>
|}

====Using Colour====
Consider what your images would look like if they only displayed in black and white. Would any necessary context or content be lost if the colour was “turned off”? Images should not rely on colour to convey information; if the point you are making depends on colour to be understood, you may need to edit your image or formatting so that concepts presented are not lost to those who are colour blind or who require high contrast between colours.

[[File:Colour-depend-1.jpg|thumb|center|In this example of a bar chart, colour is the sole means of communicating the data.]]

'''Example 1 - not accessible''':
In this basic bar chart, colour is the only means by which information is conveyed.

[[File:Colour-depend-2.jpg|thumb|center|This view of the same bar chart displays how the chart might appear to a student who is colour blind, or whose device does not display colour. All of the meaningful data is lost.]]

'''Example 2 — not accessible: '''
For a student who is colour blind or who has poor contrast vision, all of the relevant information is lost in a colour chart.

'''Example 3 — accessible:'''
Students who are colour blind can distinguish between high-contrast shades. In this example, contextual labels have been added to each bar at the bottom of the chart. Note that the chart will still require an [https://opentextbc.ca/accessibilitytoolkit/chapter/imageschartsgraphsmaps/#AltText alternative text description].
[[File:Colour-depend-3.jpg|thumb|center|In this view of the bar chart, high-contrast colours have been used so that shading differences will still display in grey scale. Text labels have also been added so that the data is not just being communicated with colour.]]

====Decorative Images====
If your image does not add meaning and is included for decorative or design purposes only, the space for the alternative text description should still be included with your image, but it should be left empty or blank. Assistive technologies will detect the image, and by leaving the alternative text description blank, you will signal to the student that there isn’t any contextual content embedded. Including alternative text descriptions for decorative images “simply slows the process down with no benefit because the screen-reading software vocalizes the content of the [alternative text description], whether that alternative text adds value or not.”<ref> webAccess (2012). Adapted from: Top Ten Tips for making your website accessible. Accessed from: http://webaccess.berkeley.edu/developer-information/top-ten-tips/#alt </ref>

====Complex Visuals====
Complex images refer to substantial information that may be challenging to describe in a short phrase or sentence. Learners may not
understand the images without a long description. Making complex images accessible for everyone can be challenging. It involves understanding the purpose, the content itself, the audiences, and the technology to create and access alternative formats.

{| class="ambox ambox-notice"
| class="mbox-text" | <div>
For strategies on how to make complex visuals such as graphs, tables, charts, and more accessible, see the following resource created by Supada Amornchat (CC BY-NC-SA): [https://www.pcc.edu/instructional-support/wp-content/uploads/sites/17/2017/11/complex-images.pdf Complex Images for All Learners: A Guide to Making Visual Content Accessible]</div>
|}

====How tos====
*[[Help:Adding_Media/Images_and_Pictures#Other_specific_options:|adding alt text on UBC Wiki]]
*[https://codex.wordpress.org/Inserting_Images_into_Posts_and_Pages#Step_4_.E2.80.93_Attachment_Details Adding image description in WordPress]
*[http://edx.readthedocs.io/projects/edx-developer-guide/en/latest/conventions/accessibility.html#make-images-accessible Edx Accessibility Guidelines - Make Images Accessible]
*[https://community.canvaslms.com/docs/DOC-2060#jive_content_id_Images Canvas General Accessibility Guidelines - Images]

==Best Practices 3: Tables==
In this section, we provide guidelines and recommendations for formatting tables.

===What Are Tables?===

'''Tables:''' In this context, we are referring to data tables, which are tables that include row and/or column header information to categorize content)

'''File types:''' .doc, .html, .pdf

===Are Your Tables Simple or Complex?===

A simple table includes a maximum of one header column and/or one header row. A complex table includes more than one header column and/or header row, and may include merged or split cells. <ref>AccessAbility: Accessibility and Usability at Penn State. Table Headers and Captions. Accessed from: http://accessibility.psu.edu/tables</ref>

We recommend you make every effort to keep data tables as simple in structure as possible. The more complex the design of a data table, the less accessible it will be for some students using screen-reading technology to access their textbook materials. Screen readers move left-to-right, top-to-bottom, one cell at a time, and because a screen reader does not repeat a cell, merging or splitting cells may affect the reading order of a table.

===Who Are You Doing This For?===

This work supports students who:
*Are blind or have low vision.
*Have a form of cognitive disability.

===What Do You Need To Do?===

In the same way that your [http://opentextbc.ca/accessibilitytoolkit/chapter/organizing-content/ content hierarchy needs true headings and structure], tables need a properly defined structure to be accessible. This means that you must add row and column headers to define the different sections of data. Screen readers read tables horizontally – cell by cell, row by row – and row and column headers help give the context of the data in each cell to students who are blind, have low vision, or have a cognitive disability.

===Creating Simple Tables===

A simple table includes:

#A table title or caption
#Maximum of one row of column headers and/or maximum of one column of row headers
#No merged or split cells
#Adequate cell padding for visual learners.

'''Example:'''

The table below is a simple table. Reviewed against the preceding requirements list, this table:

#Includes a '''title''' (Spring Blossoms)
#Has one row in which cells are tagged as '''column headers''' (Colour Family, Bulbs, Shrubs, Trees), and one column (beginning on the second row) in which the cells are tagged as '''row headers''' (Pink, Yellow)
#Contains no merged or split cells
#Has adequate '''cell padding''' to provide space buffering around the data in each cell. (Cell padding in this table is set at “3”).

{| border="1" cellspacing="0" cellpadding="3"
|-
!scope="col"| Colour Family
!scope="col"| Bulbs
!scope="col"| Shrubs
!scope="col"| Trees
|-
!scope="row"| Pink
| Tulips
| Flowering currant
|Ornamental plum
|-
!scope="row"| Yellow
| Daffodils
| Forsythia
|Star magnolia
|-
|}

For a student accessing the table through a screen reader, the first row of data will be presented along the lines of:
*Pink, Bulbs: Tulips
*Pink, Shrubs: Flowering currant
*Pink, Trees: Ornamental plum

===How tos===
*WordPress (UBC Blogs) - In order to add tables in UBC Blogs through visual editor, activate [http://support.cms.ubc.ca/cms-manual/adding-functionality/plugins/list-of-available-plugins/#MCE_Table_Buttons MCE Table Buttons]
*[[Help:Tables|Adding tables in UBC Wiki]]
*[https://community.canvaslms.com/docs/DOC-10346 Adding Tables in Canvas]

==Best Practices 4: Video and Multimedia==
Video and multimedia open resources can help to convey concepts and can bring information to life. In this section, we provide recommendations to guide your inclusion of accessible multimedia content.

===What Is Multimedia?===

'''Multimedia includes:''' videos, audio, animations, slideshows

'''File types:''' .mp3, .mp4, ppt., etc.

===Before You Begin===
'''What Type of Multimedia Are You Including?'''

Before you can determine what you need to do to make media materials accessible, you need to understand what is required for different types of multimedia. Consider the following questions:

1. Does your multimedia resource include audio narration or instruction? If so, you should: Provide a complete transcript of all speech content and relevant non-speech content in the resource.

2. Does your multimedia resource include audio that is synchronized with a video presentation? If so, you should: Provide captions of all speech content and relevant non-speech content in the resource.

3. Does your multimedia resource include contextual visuals (e.g., charts, graphs) that are not addressed in the spoken content? If so, you should: Provide audio descriptions of relevant visual materials in the resource.

===Who Are You Doing This For?===

This work supports students who:
*Are deaf or hard of hearing
*Are blind or have low vision
*Have a form of cognitive disability
*Are in a location where they cannot play or hear audio
*Are not native-English speakers and need written-word formats to support understanding

===What Do You Need To Do?===
====Transcripts====

Consider what your students would get out of your multimedia resource if they were not able to hear the audio portion, or if they had difficulty understanding your spoken word. A text transcript provides students with equivalent information to the audio content in a multimedia resource.<ref>Web Content Accessibility Guidelines (WCAG) 2.0, Guideline 1.2 Time-based Media: Provide alternatives for time-based media. Accessed from: http://www.w3.org/TR/WCAG20/#media-equiv</ref>

As you work on developing your text transcript, keep in mind the following recommendations about what to include:

#'''Speaker’s name'''
#'''All speech content:''' If there is speech that is not relevant, it is usually best to indicate that it has been excluded from the transcript. For example: “[A & B chatted while slides were loading].”'''
#'''Relevant descriptions about the speech: Descriptions that convey emotions, mood, etc. are usually provided in brackets. For example: “Don’t touch that! [shouted].”
#Descriptions of relevant non-speech audio: These are usually provided in brackets. For example: “[metal pipes crashing to concrete floor].” Background noise that isn’t relevant can be left out.
#'''Headings and sub-headings:''' Where they will make the transcript more usable or easy to navigate, headings and sub-headings can be helpful aids, especially when the transcript is long. When including these, put them in brackets to show that they were not part of the original audio. For example: [I

====Transcripts and third-party videos====

If you are not producing your own video resource but are planning to embed video materials from a third-party source (e.g., YouTube), be aware that not all third-party sources include transcripts. While services like YouTube technically support transcripts, not all contributors to YouTube include these. If you select a video resource that does not already have a transcript, you will need to produce one yourself.*

*''Copyright note:'' Producing your own transcript for a third-party video could infringe on copyright, depending on how the video has been licensed. Before you proceed with producing a transcript for media materials you did not create yourself, you should contact the copyright holder of that material to obtain permission to do so.

====Captions====

Timed text captions are essential to opening up a world of information for persons with hearing loss or literacy needs by making the readable equivalent of audio content available to them in a synchronized manner. Globally hearing loss affects about 10% of the population to some degree. It causes disability in 5% (360 to 538 million) and moderate to severe disability in 124 million people. Timed text captions also be helpful for learners whose native languages are languages other than the primary language of the media or who have cognitive conditions that benefit from visual.Captions are the text that is synchronized with the audio in a video presentation. Captions are important when people need to see what’s happening in the video and get the audio information in text at the same time.

The work you put into creating a text transcript for a video resource can be repurposed to provide the captions. Keep in mind the following recommendations about what to include in your captions:

#'''All speech content:''' If there is speech that is not relevant, it is usually best to indicate that it has been excluded from the captions. For example: “[A & B chatted while slides were loading].”
#'''Descriptions of relevant non-speech audio:''' These are usually provided in brackets. For example: “[metal pipes crashing to concrete floor]”; “[background music by XXX plays].” Background noise that isn’t relevant can be left out.

Text captions can be uploaded to YouTube and other platforms along with the video to create a timed text file in SubRip (SRT) format. Additional best practices for timed captions include:

*Each caption frame should not be on screen for less than three seconds.
*Each caption frame must not be on screen for less than two seconds.
*Each caption frame should not exceed more than 2 lines.
*Each caption frame must not exceed more than 3 lines.
*Each line should not exceed more than 32 characters
*All caption frames should be precisely time synched to the audio.
*When multiple speakers are present, it is sometimes helpful to identify who is speaking, especially when the video does not make this clear.
*Non-speech sounds like [MUSIC] or [LAUGHTER] should be added in square brackets.

====Downloadable Transcripts====
For both audio and video transcripts, consider including a text file that learners can download and review using tools such as word processing, screen reader, or literacy software. All learners can use transcripts of media-based learning materials for study and review.

====Audio Descriptions====

Consider what your students would get out of a multimedia resource if they were not able to see embedded visual materials critical for comprehension. Audio descriptions are helpful if visual content (e.g., a chart or a map) in a video or presentation provides important context that is not available through the audio alone.<ref>Web Content Accessibility Guidelines (WCAG) 2.0, Guideline 1.2.3 Audio Description or Media Alternative (Prerecorded). Accessed from: http://www.w3.org/TR/WCAG20/#media-equiv</ref> Actions that are only visible on screen without any audible equivalent are not accessible to learners who have visual impairments.

When describing visual elements in your multimedia resources, keep in mind the following recommendations and guidelines.

1. When contextual visual content on the screen is not described in the audio itself, you will need to provide an audio description that is an objective description of the visual element. ''Example:''

:::To help students fully grasp a concept that you are trying to convey in your video, you have included some contextual visual references (e.g., maps, charts, physical demonstrations of a process). However, you realize after making the video that the audio portion does not describe these visuals in enough detail for a student with visual impairments to be able to access all of the concepts you intended to convey.

::In this case, you would need to record an audio description of the visual material that provides enough detail to provide students like Jacob with the same content available to visual learners.

2. Whenever possible, avoid creating the need for audio descriptions in the first place by being proactive at the time of recording. If you pay attention to contextual visuals during the recording of the media piece, you may find opportunities to convey the visual content within the spoken material itself; you will not need to provide audio descriptions of the visual content after the fact. ''Example:''

::You are recording a video or presentation that includes a chart that tracks coal production in British Columbia, and as part of the presentation you want to focus attention on specific data in the chart. The narrator or presenter might point to sections on the chart and say:

:::“As you can see, metallurgical coal projection increased by 3 million tonnes over these two years.“

::In this case, audio descriptions would be necessary to provide the missing context to students with visual disabilities; these students cannot see the data on the chart that tells visual learners what the production figures are and for what dates. However, if the narrator or presenter instead says:

:::“This chart illustrates that metallurgical coal production in B.C. increased from 23 million tonnes in 1999 to 26 million tonnes in 2001,”

::the visual content is conveyed through the audio and no audio description will be necessary.

====Accessible Media Resources====

*[http://ncam.wgbh.org/invent_build/web_multimedia/accessible-digital-media-guide Accessible Digital Media Guidelines] provides detailed advice on creating online video and audio with accessibility in mind.
*[https://dcmp.org/public_content/ai/captioningkey/index.html Captioning Key by the National Association for the Deaf] provides excellent guidance on creating described and captioned media.

==Best Practices 5: Font size==

In this section, we review the two main concerns of font size on the web.

===What Is Font Size?===

'''Font size:''' The size of text visible on the screen.

===Who Are You Doing This For?===

This work supports students who:

*Are blind or have low vision
*Have a form of cognitive disability
*Are deaf or hard of hearing
*Have a physical disability

===What Do You Need To Do?===

There are two main concerns when working with font sizes.

# Ensuring that default font sizes are not too small.
# Ensuring that text can be expanded to 200% on websites<ref>http://sites.psu.edu/accessibility/fontsizehtml/ </ref>.

Keep in mind these recommendations and guidelines:

*'''12 point for body text''': For most documents, body text should be around 12 points. Small fonts may be illegible for some audiences.

*'''9 point for footnotes''': If a document contains footnotes or endnotes, the minimum size should be about 9 points

* '''200% zoom''': The Web Content Accessibility Guidelines (WCAG 2.0) recommend ensuring that text can be zoomed to 200%. As well, we recommend using liquid layouts that can accommodate 200% text. Liquid layout are layouts that are based on percentages of the current browser window's size. They flex with the size of the window, even if the current viewer changes their browser size as they're viewing the site. Liquid width layouts allow a very efficient use of the space provided by any given Web browser window or screen resolution.

==Best Practices 6: Colour Contrast==
In this section, we provide guidelines and recommendations about colour contrast in your open educational materials.

===What is Colour Contrast?===

'''Colour contrast includes''': hue, lightness and saturation of text, images, and background
'''File types''': .doc, .html, .pdf, .jpg, .gif

===What What Role Does Colour Play in the Delivery of Your Content?===

When documents or web pages do not provide enough contrast between foreground elements (e.g., text, images) and background elements (e.g., colour, watermark images), some students will have difficulty reading the content. Consider the following questions:

1. Have you presented text- or image-based content on a coloured or textured background? If so, you should:
*Confirm that there is sufficient contrast between your foreground content and the chosen background colour or texture.

2. Have you included links in your content? If so, you should:
*Confirm that the colour of your web links is distinct from both your background colour and the colour of the surrounding text.

3. Have you used colour to convey concepts or information? If so, you should:
*Confirm that you are not using colour alone to convey this information.

===Who Are You Doing This For?===

This work supports students who:

*Have low vision
*Have poor contrast vision
*Are colour blind and cannot differentiate between certain colours
*Are using a device with monochrome display

===What Do You Need To Do?===

====Contrast====

Students with low vision and/or a form of colour blindness may have difficulty reading text that does not contrast enough with the background colour you have selected. If the colour palette you have adopted is too subtle (e.g., white text on a pastel background; medium-grey text on a light-grey background), the contrast between your foreground and background is probably insufficient for some students.

Web Content Accessibility Guidelines (WCAG 2.0) require that “the visual presentation of text and images of text has a contrast ratio of at least 7:1.”<ref>Web Content Accessibility Guidelines (WCAG) 2.0, Guideline 1.4.6 Contrast (Enhanced). Accessed from: http://www.w3.org/TR/UNDERSTANDING-WCAG20/visual-audio-contrast7.html</ref> The image below presents four different foreground/background colour-contrast examples to illustrate insufficient and sufficient colour contrast ratios.
<br /><br />
[[File:Colour_Contrast.png|thumb|center|500px|Image displays four examples of foreground (text) colour against background colours; only the example on the far right presents combinations with sufficient colour contrast.]]
<br /><br />
{| class="ambox ambox-notice"
| class="mbox-text" | <div>
'''Not sure how to test your materials for colour contrast ratios?'''

There are many online and downloadable tools available to help you evaluate colour contrast ratios. Here are a few we have tried and like:
*'''WebAIM’s [http://webaim.org/resources/contrastchecker/ Color Contrast Checker]''': This web-based tool allows you to select or enter colour values to test and provides you with a “pass” or “fail” on your contrast ratio.
*'''ACART’s [http://www.contrastchecker.com/ Contrast Checker]''': This is a straightforward, web-based tool you can use to both check colour contrast and view your selections in grey scale. This tool also allows you to keep a history of the colour combinations you have tested.
*'''Giacomo Mazzocato’s [http://gmazzocato.altervista.org/colorwheel/wheel.php Accessibility Color Wheel]''': This web-based tool includes several options for testing your colour selections, including simulations of three types of colour blindness. You can also opt to test what your contrast ratio is when the foreground and background colour selections are inverted.
</div>
|}

====Weblink Colours====

Weblinks must be visually distinct from both the surrounding, non-linked text and background colour. If you do not underline your links (or provide some other non-colour cue), you must ensure that you provide both sufficient contrast between the link and background colours and between the link colour and that of the surrounding text.

Web Content Accessibility Guidelines (WCAG 2.0) require a:
*4.5:1 contrast between the link text color and the background
*3:1 contrast between the link text color and the surrounding non-link text color<ref>WebAIM (2015), WCAG 2.0 and Link Colors. Accessed from: http://webaim.org/blog/wcag-2-0-and-link-colors/ </ref>

====High-Contrast Mode====

Some students need to see light text on a dark background for it to be readable, while others require dark text on a light background. Students with low vision must be able to see content when it is displayed in high-contrast mode. This can be a subjective experience, based on individual student needs. We recommend that you try testing your text and image-based content as you go by using high-contrast mode on your own computer and making adjustments as needed.

All content items such as text, images, bullets, and table borders must be visible in both regular and high-contrast modes.

{| class="ambox ambox-notice"
| class="mbox-text" | <div>
'''Not sure how to test your content in high-contrast mode?
'''
To test the visibility of your content in this mode, turn on high contrast by simultaneously pressing the following keys on your (PC) keyboard:
::'''Left ALT + Left SHIFT + Print Screen.'''
To turn off high contrast mode, repeat this step.
</div>
|}

====Use of Colour====

You should not rely on colour as the sole means of conveying information and instruction. If the point you are making depends on colour to be understood, you will need to edit your materials so that concepts presented in the visuals are not lost to those who are colour blind or who require high contrast between colours.<ref>Web Content Accessibility Guidelines (WCAG) 2.0, Guideline 1.4.1 Use of Color. Accessed from: http://www.w3.org/TR/WCAG20/#visual-audio-contrast</ref>

==Best Practices 7: Formulas==

Math or Science formulas in open educational resources can be challenging to deliver in a way that is accessible to people with vision impairments. Non-scalable images of mathematical content cannot be sufficiently enlarged or navigated by low-vision users and are not accessible to blind users at all.

===What Are Formulas?===

'''Formulas include:''' Math equations or science formulas

'''File types:''' LaTex or MathType

===Before You Begin===
'''Who Are You Doing This For?'''

This work supports students who:

*Are blind or have low vision
*Have a form of cognitive disability,
*Have a physical disability

The following content is a derivative of Equations: Images vs. MathML from Accessibility and Usability at Penn State, http://accessibility.psu.edu/equations.

===What Do You Need to Do?===

There are several ways to handle equations from images with ALT tags to MathML. Having access to an equation editor such as MathType or MathMagic can streamline processing and converting equations considerably. These tools are similar to equation editors found in the ANGEL HTML Editor and Microsoft Office.

====MathML====

[http://accessibility.psu.edu/math/mathml/ Math ML] is a text-based XML markup language designed for math equations. Browsers that support MathML are able to translate the XML into a formatted equation. Since MathML with MathJax can be rendered in many systems, including HTML, Sites at Penn State, ANGEL and Drupal, it is considered the best choice for accessibility.

Information about [http://accessibility.psu.edu/math/mathml/ creating and viewing MathML] is available on that page.

MathML may vary from system to system and the content can change rapidly.

====Image with ALT tag====

A safe option to create an image of an equation (or export it from an equation editor) and then insert the image into a document with an ALT tag.

''Note:'' ALT tags can be written in Nemeth MathSpeak for students who have learned that system.

<math>
m = \frac{m_0}{\sqrt{1-\frac{v^2}{c^2}}}
</math>

View the ALT Tag

ALT= “m equals begin fraction m sub 0 over begin square root 1 minus begin fraction v sup 2 over c sup 2 end fraction end square root end fraction”

====LaTex====

LaTeX is a math markup language familiar to many in the science and math community, but unfortunately it is not currently supported by screen reader technology. However, it is fairly simple to convert LaTeX to an image or MathML in most equation editors.

For example, in the [http://wiki.ubc.ca UBC Wiki] you can insert a piece of LaTeX code using the <nowiki><math></nowiki> tag:
<pre>
<math>
m = \frac{m_0}{\sqrt{1-\frac{v^2}{c^2}}}
</math>
</pre>
The equation should appear fully formatted. Make minor adjustments as needed.

====Audio Files====
User testing with students have indicated that it would helpful to have an audio file of the formula or equation. The audio file would be placed beside the formula or equation and would allow the user to hear exactly how the formula or equation is interpreted.

====Audio Files====
User testing with students have indicated that it would helpful to have an audio file of the formula or equation. The audio file would be placed beside the formula or equation and would allow the user to hear exactly how the formula or equation is interpreted.
=====Example — equation with audio=====
[[File:MM0over.png|200px|center|math formular]]
[https://soundcloud.com/user-262382099-529580848/equation Listen to the audio file of this equation]:

===Additional Resources===

*In 2012, Portland Community College departments took a closer look at making math accessible to blind students. Read more about the math accessibility study on our website: http://www.pcc.edu/access.
*The [http://www.washington.edu/doit/are-there-guidelines-creating-accessible-math?465= DO-IT project from the University of Washington] provides guidance on creating accessible math content.
*The [http://www.washington.edu/doit/programs/accessstem/overview AccessSTEM] website provides guidance on creating accessible science, technology, engineering and math educational content.

==Best Practices 8: PDFs, Word Docs and Excel Files==
This section describes guidelines for creating accessible content in PDFs, Word documents, and Excel spreadsheets. Many of the same accessibility techniques and principles that apply to authoring in HTML also apply to creating document based OERs.

===PDFs===
Converting or publishing open resources as PDF documents can create accessibility barriers, particularly for learners with visual impairments. Accessibility issues are very common in PDF files that were scanned from printed sources or exported from a non-PDF document format. Scanned documents are simply images of text. To make scanned documents accessible, you must perform Optical Character Recognition (OCR) on these documents, and proofread the resulting text for accuracy before embedding it within the PDF file. You must also add semantic structure and other metadata (headings, links, alternative content for images, and so on) to the embedded text.

When you export documents to PDF from other formats, it is important to ensure that the source document contains all the required semantic structure and metadata before exporting. Unfortunately, some applications do not include this information when exporting and require the author to add or “tag” the document manually using PDF editing software. You should carefully consider whether exporting to PDF is necessary at all.

====Best Practices for Authoring Accessible PDF Documents====

*Explicitly define the language of the document so that screen readers know what language they should use to parse the document.
*Explicitly set the document title. When you export a file to PDF format, the document title usually defaults to the file name, not a human readable title.
*Verify that all images have alternative content defined or are marked as decorative only.
*Verify that the PDF file is “tagged”. Make sure the semantic structure from the source document has been correctly imported to the PDF file.
*Verify that a logical reading order is defined. This is especially important for documents that have atypical page layouts or structure.
*If your document includes tables, verify that table headers for rows and columns are properly defined.

====Accessible PDF Resources====
*[http://webaim.org/techniques/acrobat/ WebAIM's PDF Accessibility site] provides a detailed and illustrated guide on creating accessible PDFs.
*The [http://ncdae.org/resources/cheatsheets/ National Center of Disability and Access to Education has a collection of one-page “cheat sheets”] on accessible document authoring.
*Microsoft provides detailed [https://support.office.com/en-gb/article/Create-accessible-PDFs-064625e0-56ea-4e16-ad71-3aa33bb4b7ed?CorrelationId=9b8d28cf-aa96-4816-9536-b4aea195b51c&ui=en-US&rs=en-GB&ad=GB&ocmsassetID=HA102478227 guidance on generating accessible PDFs from Microsoft Office applications], including Word, Excel, and PowerPoint.
*Adobe provides [https://helpx.adobe.com/acrobat/using/create-verify-pdf-accessibility.html documentation on how to create and verify PDF accessibility].

===Word Documents===
Many of the same accessibility techniques and principles that apply to authoring one content also apply to creating Word documents. Keep formatting simple. Use headings, paragraphs, lists, images, and captions. Use tables for tabular data. Do not add unnecessary indents, rules, columns, blank lines, or typographic variation. Use standardized styles for formatting your text, such as Normal, Heading 1, and Heading 2, rather than manually formatting text using text styles and indents. Formatting text for its semantic meaning and not for its visual appearance allows users of assistive technology to consume and navigate documents effectively and efficiently.

Additional best practices include;

*Images must have descriptive text associated with them.
*Documents should be well structured.
*Hyperlinks should be meaningful and describe the destination.
*Tables should include properly defined column and row headers.
*Color combinations should be high contrast.
*Verify the accessibility of your document using [https://support.office.com/en-us/article/Use-the-Accessibility-Checker-on-your-Windows-desktop-to-find-accessibility-issues-a16f6de0-2f39-4a2b-8bd8-5ad801426c7f?ui=en-US&rs=en-US&ad=US Microsoft’s Accessibility Checker].

===Excel Spreadsheets===
Many of the same accessibility techniques and principles that apply to authoring data tables in HTML also apply to creating Excel spreadsheets. Microsoft has a [https://support.office.com/en-us/article/Make-your-Excel-spreadsheets-accessible-6CC05FC5-1314-48B5-8EB3-683E49B3E593?ui=en-US&rs=en-US&ad=US guide to creating accessible Excel workbooks].

*Images must have descriptive text associated with them.
*Column and row headings should be programmatically identified.
*Hyperlinks in spreadsheets should be meaningful and describe the destination.
*Use a unique and informative title for each worksheet tab.
*Do not use blank cells for formatting.
*Colour combinations should be high contrast.
*Verify the accessibility of your workbook using [https://support.office.com/en-us/article/Use-the-Accessibility-Checker-on-your-Windows-desktop-to-find-accessibility-issues-a16f6de0-2f39-4a2b-8bd8-5ad801426c7f?ui=en-US&rs=en-US&ad=US Microsoft’s Accessibility Checker].

===Additional Microsoft Accessibility Resources===
*[https://support.office.com/en-us/article/Make-your-Word-documents-accessible-D9BF3683-87AC-47EA-B91A-78DCACB3C66D?ui=en-US&rs=en-US&ad=US Microsoft guide to creating accessible Word documents.]
*[https://support.office.com/en-us/article/Use-the-Accessibility-Checker-on-your-Windows-desktop-to-find-accessibility-issues-a16f6de0-2f39-4a2b-8bd8-5ad801426c7f?ui=en-US&rs=en-US&ad=US Microsoft tool that allows you to check Word documents for accessibility issues.]
*Microsoft guide to creating [https://support.office.com/en-us/article/Make-your-PowerPoint-presentations-accessible-6F7772B2-2F33-4BD2-8CA7-DAE3B2B3EF25?ui=en-US&rs=en-US&ad=US accessible PowerPoint presentations].
*[https://support.office.com/en-us/article/Make-your-Excel-spreadsheets-accessible-6CC05FC5-1314-48B5-8EB3-683E49B3E593?ui=en-US&rs=en-US&ad=US Microsoft guide to creating accessible Excel workbooks].
*Microsoft tool that allows you to check [https://support.office.com/en-us/article/Use-the-Accessibility-Checker-on-your-Windows-desktop-to-find-accessibility-issues-a16f6de0-2f39-4a2b-8bd8-5ad801426c7f?ui=en-US&rs=en-US&ad=US Excel workbooks for accessibility issues].
*Microsoft guide to creating [http://webaim.org/techniques/powerpoint/ accessible PowerPoint presentations].
*[http://webaim.org/techniques/powerpoint/ WebAIM’s guide to PowerPoint accessibility].

==UBC Platform Specific Accessibility Guidelines==

===Canvas===
*[https://community.canvaslms.com/docs/DOC-2061 Accessibility within Canvs]
*[https://community.canvaslms.com/groups/accessibility Canvas Accessibility Group]
*[https://community.canvaslms.com/groups/accessibility/blog/2018/05/08/how-to-fix-and-prevent-accessibility-issues-in-your-canvas-course How to Fix and Prevent Accessibility Issues in Your Canvas ]

===Edx===
*[http://edx.readthedocs.io/projects/edx-partner-course-staff/en/latest/accessibility/index.html Accessibility Best Practices Guidance for Content Providers]

===WordPress===
*[https://en.support.wordpress.com/accessibility/ Accessibility in WordPress]
*[http://khan.github.io/tota11y/ Tota11y] - a tool to check if your site is accessible or not. There is also a [https://chrome.google.com/webstore/detail/tota11y-plugin-from-khan/oedofneiplgibimfkccchnimiadcmhpe?hl=en chrome extension] available

===MediaWiki/UBC Wiki===
*[https://en.wikipedia.org/wiki/Wikipedia:Manual_of_Style/Accessibility Manual of Style- Accessibility]

===UBC Centre for Accessibility===
*[https://students.ubc.ca/about-student-services/centre-for-accessibility UBC Centre for Accessibility] (CfA) provides leadership on issues of accessibility for people with disabilities at UBC Vancouver, working in partnership with faculties to foster inclusive learning, living and working environments for students, faculty and staff. The Centre for Accessibility provides support and programming initiatives designed to remove barriers for students with disabilities and facilitates disability related accommodations for members of the UBC Vancouver community.

===UBC Centre for Workplace Accessibility===
*[https://hr.ubc.ca/health-and-wellbeing/workplace-accessibility/centre-workplace-accessibility The Centre for Workplace Accessibility] (CWA) is a hub for resources, tools, and programs that help remove barriers for faculty and staff with disabilities or ongoing medical conditions. It offers support to improve workplace accessibility using a trauma-informed, person-centred approach. Its initiatives also include projects and workshops designed to build disability inclusion literacy throughout the UBC community.

==Appendix: Checklist for OER Accessibility==

===Organizing Content===

☐ Contents is organized under headings and subheadings

☐ Headings and subheadings are used sequentially (e.g. Heading 1, heading 2, etc)

===Images===

☐ Images that convey information include Alternative Text (alt-text) descriptions of the image’s content or function.

☐ Graphs, Charts, and Maps also include contextual or supporting details in the text surrounding the image.

☐ Images do not rely on colour to convey information.

☐ Images that are purely decorative contain empty alternative text descriptions. (Descriptive text is unnecessary if the image doesn’t convey contextual content information).

===Tables===

☐ Tables include row and column headers.

☐ Table includes title or caption.

☐ Table does not have merged or split cells.

☐ Table has adequate cell padding.

===Weblinks===

☐ The weblink is meaningful in context, does not use generic text such as “click here” or “read more”.

☐ Weblinks do not open new windows or tabs.

☐ If weblink must open in a new window, a textual reference is included in the link information.

===Multimedia===

☐ A transcript has been made available for a multimedia resource that includes audio narration or instruction. Transcript includes:
:Speaker’s name
:All speech content
:Relevant descriptions of speech
:Descriptions of relevant non-speech audio

===Headings and subheadings===

☐ Captions of all speech content and relevant non-speech content are included in the multimedia resource that includes audio synchronized with a video presentation.

☐ Audio descriptions of contextual visuals (graphs, charts, etc) are included in the multimedia resource.

===Formulas===

☐ Formulas have been created using MathML.

☐ Formulas are images with alternative text descriptions, if MathML is not an option.

===Font Size===

☐ Font size is 12 point or higher for body text.

☐ Font size is 9 point for footnotes or end notes.

☐ Font size can be zoomed to 200%.

==Appendix: Accessibility 2-Page Handout==

[[File:Accessibility Handout Thumbnail.png|thumb|centre|400px|link=http://wiki.ubc.ca/images/5/5b/UBC_Accessibility_Handout.pdf|Click to Download PDF ]]

==Appendix: Additional OER Accessibility Resources==
*[https://accessibility.ctlt.ubc.ca/ UBC Accessibility 101] - A UBC resource that focuses on improving access to digital content for students with vision or hearing impairments and similar learning barriers.
*[https://blogs.ubc.ca/accessibleactivelearning/ Accessible Active Learning] - A resource designed for Instructional Skills Workshop (ISW) and TA Training facilitators at UBCV. It is meant as a resource to help them design activities with accessibility in-mind, to help make activities accessible to more students and participants.
*[https://equity.ubc.ca/resources/accessible-and-inclusive-event-planning/ UBC Accessible Event Planning Guide] - provides practical tools to help event organizers create inclusive and welcoming experiences for everyone, including particularly people with disabilities.
*[https://opentextbc.ca/accessibilitytoolkit/ BC Open Textbook Accessibility Toolkit] - (also in [https://opentextbc.ca/troussedoutildaccessibilite/ French]). See also the [https://cdn.collection.bccampus.ca/assets/B_Ccampus_Accessibility_Criteria_6b42ab8ce8.pdf BCcampus OER Accessibility Criteria checklist] and the [https://opentextbc.ca/accessibilitytoolkit/back-matter/inclusive-design-webinar-series/ BCcampus Inclusive Design Webinar Series].
*[https://students.ubc.ca/about-student-services/centre-for-accessibility UBC Centre for Accessibility] provides support and programming initiatives designed to remove barriers for students with disabilities and facilitates disability related accommodations for members of the UBC Vancouver community.
*[https://pressbooks.bccampus.ca/a11yondemand/ Digital Accessibility On-demand] - a resource by Luke McKnight designed as a just-in-time resource to guide creators to the step-by-step instructions they need to maximize accessibility and increase inclusivity.
*[https://pressbooks.bccampus.ca/accessibilityhandbook/ Accessibility Handbook for Teaching and Learning] - a guidebook by Luke McKnight and Briana Fraser to introduce concepts of digital accessibility and to provide detailed instructions to use the accessibility features of software such as Word and PowerPoint.
*[https://hr.ubc.ca/health-and-wellbeing/workplace-accessibility/centre-workplace-accessibility The Centre for Workplace Accessibility (CWA)] is a hub for resources, tools, and programs that help remove barriers for faculty and staff with disabilities or ongoing medical conditions. It offers support to improve workplace accessibility using a trauma-informed, person-centred approach.
*Inclusive Design Research Centre’s [http://floeproject.org/ Flexible Learning for Open Education]
*[http://www.udlcenter.org/implementation/postsecondary The National Center on Universal Design for Learning] provides a helpful overview on Universal Design for Learning.
*Portland Community College’s [http://www.pcc.edu/resources/instructional-support/access/ Accessibility for Online Course Content: A Guide for Instructors]
*[https://inclusive.microsoft.design/ Inclusive Design at Microsoft]
*[https://wiki.ubc.ca/images/0/02/Complex_Images_for_All_Learners.pdf Accessibility for Complex Images]: resource for making charts, graphs, figures, and other complex images accessible.
*[https://pressbooks.bccampus.ca/accessibilityhandbook/chapter/the-people-v-pdf/ The People v. PDF] - a semi-academic take on some of accessibility issues of PDFs
*The [https://bccampus.ca/wp-content/uploads/2023/04/OER-Equity-Rubric-1.pdf BCcampus OER Equity Rubric] is designed to help identify opportunities to adapt and improve the equity of open resources.

==References==
<references/>

==About this Toolkit==
[[File:CC-SA_button.png|left|CC by|100px]] The OER Accessibility Toolkit is licensed under a [https://creativecommons.org/licenses/by-sa/4.0/ Creative Commons Attribution-ShareAlike 4.0 International License], except where otherwise noted. Source files for this resource may be found on the [http://wiki.ubc.ca/Documentation:Open_UBC/Guide/OER_Accessibility_Toolkit UBC Wiki].

Content for this toolkit was adapted from the [https://opentextbc.ca/accessibilitytoolkit/ BC Open Textbook Accessibility Toolkit] by Amanda Coolidge, Sue Doner, and Tara Robertson. The [https://opentextbc.ca/accessibilitytoolkit/ BC Open Textbook Accessibility Toolkit] is licensed under a [https://creativecommons.org/licenses/by/4.0/ Creative Commons Attribution 4.0 International License], except where otherwise noted. Additional material has been adapted from the [http://edx.readthedocs.io/projects/edx-partner-course-staff/en/latest/accessibility/index.html edX Accessibility Best Practices for Developing Course Content] guidelines under a [https://creativecommons.org/licenses/by-sa/4.0/ Creative Commons Attribution Share Alike 4.0 International License].

[[Category:Open UBC]][[Category:Accessibility]] [[Category:Accessibility Toolkits]] [[Category:OER]] [[Category:Open Education]] [[Category:Universal Design]]

Documentation:Open UBC/Guide/OER Accessibility Toolkit

2026-05-29T16:45:32Z

WillEngle: /* Appendix: Additional OER Accessibility Resources */

==Accessibility for Open Education==

{{#widget:YouTube|id=KcvYG-rkO-Y|height=315|width=420}}

The focus of many open education projects is to provide access to education. But what does access mean? If the materials are not accessible for each and every student, do they fulfill the mandate to deliver fully open education? The open education movement has helped people in different parts of the world access content that they would otherwise not be able to view or interact with. Open education resources reduce costs for students and allow for greater flexibility for instructors. Accessibility can help push the movement even further forward.

The goal of the ''OER Accessibility Toolkit'' is to provide the needed resources to each content creator, instructor, instructional designer, educational technologist, librarian, administrator, and teaching assistant to create a truly open and accessible educational resource — one that is accessible for all students.

As you work through the content of the ''OER Accessibility Toolkit'', you will find that the suggestions provided are intended for the non-technical user. If you are looking for more technical descriptions of how to make your work accessible, we suggest you review the [https://www.w3.org/TR/WCAG20/ WCAG (Web Content Accessibility Guidelines)].

==Key Concepts: Universal Design and Personas==

Universal Design is the process of creating products (devices, environments, systems, and processes) that are usable by people with the widest possible range of abilities, operating within the widest possible range of situations (environments, conditions, and circumstances). Universal Design emerged from the slightly earlier concept of being barrier-free, the broader accessibility movement, and adaptive and assistive technology. It also seeks to blend aesthetics into these core considerations.

Let’s review some common definitions of Universal Design.

===Definition 1===

Universal Design or Universal Instructional Design (UID)
{| class="ambox ambox-notice"
| class="mbox-text" | <div>
"is an approach to teaching that consists of the proactive design and use of inclusive instructional and evaluation strategies. This approach provides academic access to a broad range of learners, including students with disabilities, while:
*maintaining academic standards […]
*reducing the need to having to retrofit after a course is already underway<ref>FAIR ([http://web2.uvcs.uvic.ca/fair/ Facilitating Accessible Instruction & Resources]). University of Victoria </ref>"

</div>
|}

===Definition 2===
{| class="ambox ambox-notice"
| class="mbox-text" | <div>
Universal Instructional Design (UID)

is an approach to designing course instruction, materials and content to benefit people of all learning styles without adaptation or retrofitting. UID provides equal access to learning, not simply equal access to information. UID allows the student to control the method of accessing information while the instructor monitors the learning process and initiates any beneficial methods. …It should be noted that UID does not remove academic challenges; it removes barriers to access.<ref>Universal Design for Learning. Ohio State University</ref>
</div>
|}

===Why Universal Design?===

For our purposes, we frame the practice of using Universal Design in a holistic and manageable way, and begin by addressing the barriers that are easy to anticipate and proactively re-mediate. This toolkit, therefore, will provide guidance to you if the answers to any of the following questions is “yes”:

*Do I have visual materials that present core concepts that not all students may be able to see or understand?
*Do I have multimedia (audio, video) materials that present core concepts that not all students may be able to be hear, see, or access?
*Do I have documents that present core concepts in a format that not all students may be able to access?

For the purpose of the ''OER Accessibility Toolkit'', we focus on an adjunct to Universal Design, that being Universal Design for Learning (UDL), which is a set of principles for curriculum development that gives all individuals equal opportunities to learn. UDL provides a blueprint for creating instructional goals, methods, materials, and assessments that work for everyone. Rather than a single, one-size-fits-all solution, it offers a flexible approach that can be customized and adjusted for individual needs.<ref>http://www.udlcenter.org/aboutudl/whatisudl ↵</ref>

The principles of Universal Design for Learning can be summarized by the following points.

*Present information and content in various ways.
*Provide more than one way for learners to express what they know.
*Stimulate interest and motivation for learning.

OER creators can apply these principles in course design by following several guidelines:

*Design resources and activities that can be accessed by learners in a variety of ways. For example, if there is a text component, provide the ability to enlarge the font size or change the text color. For images and diagrams, always provide an equivalent text description. For video, include text captions.
*Provide multiple ways for learners to engage with information and demonstrate their knowledge. This is particularly important to keep in mind as you design activities and assessments.
*Identify activities that require specific sensory or physical capability and for which it might be difficult or impossible to accommodate the accessibility needs of learners. For example, an activity that requires learners to identify objects by color might cause difficulties for learners with visual impairments. In these cases, consider whether there is a pedagogical justification for the activity being designed in that way. If there is a justification, communicate these requirements to prospective learners in the course description and establish a plan for responding to learners who encounter barriers.

===Persona===
{{#widget:YouTube|id=_YpNrOkW0Mw|height=315|width=420}}

This video shows a demonstration of students using accessibility softwares (ZoomText, JAWs and TextDragon) .

Designers use personas to represent the different types of people who may be accessing a website or product. Using a persona can be a helpful when you are designing an accessible open resources. Take a look at the personals from [http://uxmag.com/articles/book-excerpt-a-web-for-everyone Book Excerpt: A Web for Everyone] to get an idea on how your audiences navigate your course/resources.

==Best Practices 1: Online Content Organization and Weblinks==

HTML is a good format for creating accessible content. It is well supported and adaptable across browsers and devices. Also, the information in HTML markup helps assistive technologies, such as screen reader software, to provide information and functionality to people with vision impairments.

Organizing your html and online content so it has a logical flow just makes sense. Using headings, and subheadings to organize content allows students to clearly see how the main concepts are related. Headings are one of the main ways that students using a screen reader navigate through a webpage or online resource.

A weblink is a link from a file or document to another location (such as a website address) or file, typically activated by clicking on a highlighted word or image on the screen. Generally weblinks are included within content to provide the user with additional information that is available at a another location.

'''File types''': .html, .pdf, .doc, .xls

===Who Are You Doing This For?===

Everyone benefits from having content that’s clearly organized. In addition, well-organized content and descriptive weblinks support students who:

*Have a learning disability (For a example, a student with ADHD) - Having an organized content allow them to easily go back and find the important points.
*Are blind or have low vision - It gives them more control in navigating through different chapters.
*Have a form of cognitive disability
*Have a physical disability,
*Are deaf or hard of hearing

===What Do You Need to Do?===

====Content Organization====
Headings help to identify the hierarchical structure of a document (e.g., sections, sub-sections). Headings provide a visual cue that helps sighted readers quickly navigate through sections of a document, skimming through content until they find a section they are looking for. Similarly, headings create logical divisions in the content and allow a non-sighted user to navigate a page or document easily using a screen reader.

When it comes to using visual references to indicate the hierarchy and structure of a document, you may be accustomed to just changing the font, enlarging the type size, making it bold or underlined or italicized, creating the impression of a heading. This approach presents problems when creating material with accessibility in mind because screen readers won’t identify the text as a heading. Instead, a screen reader will just “read” through the text of a heading as if it were part of another paragraph of content, missing your intended cues about structure and organization.

[[File:Headings in wordpress.png|thumb|center|Headings in WordPress(UBC Blogs)]]
Keep the following guidelines in mind when you create online content.

*Use HTML tags to describe the meaning of content, rather than changing its appearance. For example, you should tag a section title with the appropriate heading level (such as <nowiki><h3></nowiki>) rather than making the text appear like a heading by applying visual elements such as bold text and a larger font size. Format list items into a list rather than using images of bullets or indents. Using HTML to describe your content’s meaning is valuable for learners who use screen readers, which, for example, can read through all headings of a specific level or announce the number of items in a list.
*Use HTML heading levels in sequential order to represent the structure of a document. Well-structured headings help learners and screen reader users to navigate a page and efficiently find what they are looking for.
*Use HTML list elements to group related items and make content easier to skim and read.

====Content Organization How tos====
*[https://en.support.wordpress.com/visual-editor/#styles How to create headings in WordPress(UBC Blogs)]
*[[Help:Formatting#Headers_.26_Lines|How to create headings in UBC Wiki]]
*[https://ccs.instructure.com/courses/1181412/pages/accessibility-basics-on-canvas-pages-headers-colors-and-tables?module_item_id=21897445 How to create headings in Canvas]
*[http://edx.readthedocs.io/projects/edx-partner-course-staff/en/latest/course_components/create_html_component.html#the-visual-editor How to create headings in EdX]

====Link Descriptions====

Ensure that all web pages and weblinks have titles that describe a topic or purpose. The purpose of the link can be determined by the text alone. That is, you don’t need to include additional information justifying the use of the link. You want the link to be meaningful in context. For example, do not use generic text such as “click here” or “read more” unless the purpose of the link can be determined by meaning in the surrounding content.<ref>https://www.webaccessibility.com/best_practices.php?best_practice_id=1301</ref>

Consider the following examples.

'''Example 1''' — unclear:

Click [http://open.ubc.ca here] for information on open at UBC.

'''Example 2''' — clear and accessible:

Information on [http://open.ubc.ca UBC Open education projects and resources] is available online.

====New Tabs/Windows====

In general, it is better if weblinks do not open new windows and tabs since they can be disorienting for people, especially people who have difficulty perceiving visual content.<ref>http://www.w3.org/TR/2014/NOTE-WCAG20-TECHS-20140916/G200</ref>. However, if a link must open in a new window, it is best practice to include a textual reference. For example, IInformation on [http://open.ubc.ca UBC Open education projects and resources (New Window)] is available online.<ref>http://accessibility.psu.edu/linkshtml</ref>

==Best Practices 2: Images==
In this section, we provide recommendations to guide your inclusion of accessible, image-based content.

===What Are Images?===

'''Images include''': photographs, diagrams, pictures, charts, graphs, maps

'''File types''': .gif, .jpg, .png

===Before You Begin===

====Why Are You Including the Images You Have Selected?====

Before you can determine what you need to do to make an image accessible, you first need to identify its purpose or value to your open resources. Consider the following questions:

#Does your image serve a functional purpose? In other words, is it conveying non-text content to students? If so, you should:
#*Provide a text alternative that serves the equivalent purpose of the non-text material<ref> Web Content Accessibility Guidelines (WCAG) 2.0, Guideline 1.1 Text Alternatives. Accessed from: http://www.w3.org/TR/WCAG20/#text-equiv </ref>
#*Not use colour as the only visual means of conveying information <ref> Web Content Accessibility Guidelines (WCAG) 2.0, Guideline 1.4.1 Use of Color. Accessed from: http://www.w3.org/TR/WCAG20/#visual-audio-contrast</ref>
#Does your image serve more of a decorative purpose? In other words, is it primarily a design element that does not convey content? If so, you should:
#*Avoid unnecessary text descriptions

====Who Are You Doing This For?====

This work supports students who:

*Are blind or have low vision
*Have poor contrast vision
*Are colour blind and cannot differentiate between certain colours
*Are using a device with monochrome display
*Have a form of cognitive disability

===What do you need to do? ===
====Functional Images and Alternative Text Description====
Consider what your content page would look like if the images didn’t load. Now try writing alternative text for each image that would work as a replacement and provide the same service as the image.

As you work on developing your alternative text descriptions, keep the following recommendations and guidelines in mind:
*Remember that alternative text must convey the content and functionality of an image and is rarely a literal description of the image (e.g., “photo of cat”). Rather than providing what the image looks like, alternative text should convey what the content of the image is and what it does. <ref>webAccess (2012). Adapted from: Top Ten Tips for making your website accessible. Accessed from: http://webaccess.berkeley.edu/developer-information/top-ten-tips/#alt </ref>
*For relatively simple images (e.g., photographs, illustrations), try to keep your text descriptions short. You should aim to create a brief alternative (one or two short sentences) that is an accurate and concise equivalent to the information in the image.
*For more complex images (e.g., detailed charts, graphs, maps), you will need to provide more than a one- to two-sentence description to ensure all users will benefit from the content or context you intended to provide. In these cases, you should either provide the details in the text surrounding the image or write a longer text description that students can link to on a separate page. You should still include a short text description (one to two sentences) that tells students where they can find the details you have provided in the longer description.
*Leave out any unnecessary information. For example, you do not need to include information like “image of…” or “photo of…”; assistive technologies will automatically identify the material as an image, so including that detail in your alternative description is superfluous.

Avoid redundancy of content in your alternative description. Don’t repeat the same information that already appears in text adjacent to the image.

=====Example 1: [https://opentextbc.ca/introductiontosociology/chapter/chapter20-population-urbanization-and-the-environment/ (from Introduction to Sociology)] =====

[[File:Rio-de-janeiro-and-london.png|thumb|center|Figure 20.11. The slum city and the global city: the Favéla Morro do Prazères in Rio de Janeiro and the London financial district show two sides of global urbanization (Photos courtesy of dany13/Flickr and Peter Pearson/Flickr). |alt="Figure 20.11 includes two photos. The first photo shows crowded buildings located on the hillside. They are small and shabby. The second photo shows magnificent buildings located by water."]]

This photograph could be described in this way:

{| class="ambox ambox-notice"
| class="mbox-text" | <div>
"Figure 20.11 includes two photos. The first photo shows crowded buildings located on the hillside. They are small and shabby. The second photo shows magnificent buildings located by water."
</div>
|}

=====Example 2 (Figure 18.1. Two-Atom, Double-Flask Diagram from [http://opentextbc.ca/introductorychemistry/chapter/entropy-and-the-second-law-of-thermodynamics/ Introductory Chemistry]): =====
[[File:Double flask gas atom diagram.png|center|thumb|(Figure 18.1. Two-Atom, Double-Flask Diagram from Introductory Chemistry) ]]
When the stopcock is opened between the flasks, the two atoms can distribute in four possible ways.

Figure 18.1 could be described as follows:
{| class="ambox ambox-notice"
| class="mbox-text" | <div>
"Figure 18.1 shows a diagram with five pairs of circles. All of these circles are open. The left one opens on the right and the right one opens on the left. They are connected with lines at their open points. One pair is located on the left and between their two connecting lines is a black dot with a red vertical line going across. The other four pairs arranged in a column are located on the right and between the connecting lines of each pair is a a small circle with a red horizontal line going through. A right arrow labelled Open Stopcock links the pair sitting on the left to the four pairs on the right. Each of these five pairs has two dots (green and blue) arranged in different patterns. For the pair on the left, the two dots, sitting obliquely, appear only in left circle. The green dot is at the left upper part of the circle and following it the blue dot is close to the bottom right. The first pair on the right has the similar situation. The only difference is that the green dot is at the right upper part of the circle and the blue dot is close the middle left. The second pair has a green dot in the centre of the left circle and a blue dot in the centre of the right circle. The third pair has a blue dot sitting at the left upper part of the left circle and a green dot sitting close to bottom right of the right circle. For the last pair, the two dots appear in oblique direction only in the right circle. A green dot is at the right upper part of the circle and a blue dot is close to bottom left.
"
</div>
|}

====Using Colour====
Consider what your images would look like if they only displayed in black and white. Would any necessary context or content be lost if the colour was “turned off”? Images should not rely on colour to convey information; if the point you are making depends on colour to be understood, you may need to edit your image or formatting so that concepts presented are not lost to those who are colour blind or who require high contrast between colours.

[[File:Colour-depend-1.jpg|thumb|center|In this example of a bar chart, colour is the sole means of communicating the data.]]

'''Example 1 - not accessible''':
In this basic bar chart, colour is the only means by which information is conveyed.

[[File:Colour-depend-2.jpg|thumb|center|This view of the same bar chart displays how the chart might appear to a student who is colour blind, or whose device does not display colour. All of the meaningful data is lost.]]

'''Example 2 — not accessible: '''
For a student who is colour blind or who has poor contrast vision, all of the relevant information is lost in a colour chart.

'''Example 3 — accessible:'''
Students who are colour blind can distinguish between high-contrast shades. In this example, contextual labels have been added to each bar at the bottom of the chart. Note that the chart will still require an [https://opentextbc.ca/accessibilitytoolkit/chapter/imageschartsgraphsmaps/#AltText alternative text description].
[[File:Colour-depend-3.jpg|thumb|center|In this view of the bar chart, high-contrast colours have been used so that shading differences will still display in grey scale. Text labels have also been added so that the data is not just being communicated with colour.]]

====Decorative Images====
If your image does not add meaning and is included for decorative or design purposes only, the space for the alternative text description should still be included with your image, but it should be left empty or blank. Assistive technologies will detect the image, and by leaving the alternative text description blank, you will signal to the student that there isn’t any contextual content embedded. Including alternative text descriptions for decorative images “simply slows the process down with no benefit because the screen-reading software vocalizes the content of the [alternative text description], whether that alternative text adds value or not.”<ref> webAccess (2012). Adapted from: Top Ten Tips for making your website accessible. Accessed from: http://webaccess.berkeley.edu/developer-information/top-ten-tips/#alt </ref>

====Complex Visuals====
Complex images refer to substantial information that may be challenging to describe in a short phrase or sentence. Learners may not
understand the images without a long description. Making complex images accessible for everyone can be challenging. It involves understanding the purpose, the content itself, the audiences, and the technology to create and access alternative formats.

{| class="ambox ambox-notice"
| class="mbox-text" | <div>
For strategies on how to make complex visuals such as graphs, tables, charts, and more accessible, see the following resource created by Supada Amornchat (CC BY-NC-SA): [https://www.pcc.edu/instructional-support/wp-content/uploads/sites/17/2017/11/complex-images.pdf Complex Images for All Learners: A Guide to Making Visual Content Accessible]</div>
|}

====How tos====
*[[Help:Adding_Media/Images_and_Pictures#Other_specific_options:|adding alt text on UBC Wiki]]
*[https://codex.wordpress.org/Inserting_Images_into_Posts_and_Pages#Step_4_.E2.80.93_Attachment_Details Adding image description in WordPress]
*[http://edx.readthedocs.io/projects/edx-developer-guide/en/latest/conventions/accessibility.html#make-images-accessible Edx Accessibility Guidelines - Make Images Accessible]
*[https://community.canvaslms.com/docs/DOC-2060#jive_content_id_Images Canvas General Accessibility Guidelines - Images]

==Best Practices 3: Tables==
In this section, we provide guidelines and recommendations for formatting tables.

===What Are Tables?===

'''Tables:''' In this context, we are referring to data tables, which are tables that include row and/or column header information to categorize content)

'''File types:''' .doc, .html, .pdf

===Are Your Tables Simple or Complex?===

A simple table includes a maximum of one header column and/or one header row. A complex table includes more than one header column and/or header row, and may include merged or split cells. <ref>AccessAbility: Accessibility and Usability at Penn State. Table Headers and Captions. Accessed from: http://accessibility.psu.edu/tables</ref>

We recommend you make every effort to keep data tables as simple in structure as possible. The more complex the design of a data table, the less accessible it will be for some students using screen-reading technology to access their textbook materials. Screen readers move left-to-right, top-to-bottom, one cell at a time, and because a screen reader does not repeat a cell, merging or splitting cells may affect the reading order of a table.

===Who Are You Doing This For?===

This work supports students who:
*Are blind or have low vision.
*Have a form of cognitive disability.

===What Do You Need To Do?===

In the same way that your [http://opentextbc.ca/accessibilitytoolkit/chapter/organizing-content/ content hierarchy needs true headings and structure], tables need a properly defined structure to be accessible. This means that you must add row and column headers to define the different sections of data. Screen readers read tables horizontally – cell by cell, row by row – and row and column headers help give the context of the data in each cell to students who are blind, have low vision, or have a cognitive disability.

===Creating Simple Tables===

A simple table includes:

#A table title or caption
#Maximum of one row of column headers and/or maximum of one column of row headers
#No merged or split cells
#Adequate cell padding for visual learners.

'''Example:'''

The table below is a simple table. Reviewed against the preceding requirements list, this table:

#Includes a '''title''' (Spring Blossoms)
#Has one row in which cells are tagged as '''column headers''' (Colour Family, Bulbs, Shrubs, Trees), and one column (beginning on the second row) in which the cells are tagged as '''row headers''' (Pink, Yellow)
#Contains no merged or split cells
#Has adequate '''cell padding''' to provide space buffering around the data in each cell. (Cell padding in this table is set at “3”).

{| border="1" cellspacing="0" cellpadding="3"
|-
!scope="col"| Colour Family
!scope="col"| Bulbs
!scope="col"| Shrubs
!scope="col"| Trees
|-
!scope="row"| Pink
| Tulips
| Flowering currant
|Ornamental plum
|-
!scope="row"| Yellow
| Daffodils
| Forsythia
|Star magnolia
|-
|}

For a student accessing the table through a screen reader, the first row of data will be presented along the lines of:
*Pink, Bulbs: Tulips
*Pink, Shrubs: Flowering currant
*Pink, Trees: Ornamental plum

===How tos===
*WordPress (UBC Blogs) - In order to add tables in UBC Blogs through visual editor, activate [http://support.cms.ubc.ca/cms-manual/adding-functionality/plugins/list-of-available-plugins/#MCE_Table_Buttons MCE Table Buttons]
*[[Help:Tables|Adding tables in UBC Wiki]]
*[https://community.canvaslms.com/docs/DOC-10346 Adding Tables in Canvas]

==Best Practices 4: Video and Multimedia==
Video and multimedia open resources can help to convey concepts and can bring information to life. In this section, we provide recommendations to guide your inclusion of accessible multimedia content.

===What Is Multimedia?===

'''Multimedia includes:''' videos, audio, animations, slideshows

'''File types:''' .mp3, .mp4, ppt., etc.

===Before You Begin===
'''What Type of Multimedia Are You Including?'''

Before you can determine what you need to do to make media materials accessible, you need to understand what is required for different types of multimedia. Consider the following questions:

1. Does your multimedia resource include audio narration or instruction? If so, you should: Provide a complete transcript of all speech content and relevant non-speech content in the resource.

2. Does your multimedia resource include audio that is synchronized with a video presentation? If so, you should: Provide captions of all speech content and relevant non-speech content in the resource.

3. Does your multimedia resource include contextual visuals (e.g., charts, graphs) that are not addressed in the spoken content? If so, you should: Provide audio descriptions of relevant visual materials in the resource.

===Who Are You Doing This For?===

This work supports students who:
*Are deaf or hard of hearing
*Are blind or have low vision
*Have a form of cognitive disability
*Are in a location where they cannot play or hear audio
*Are not native-English speakers and need written-word formats to support understanding

===What Do You Need To Do?===
====Transcripts====

Consider what your students would get out of your multimedia resource if they were not able to hear the audio portion, or if they had difficulty understanding your spoken word. A text transcript provides students with equivalent information to the audio content in a multimedia resource.<ref>Web Content Accessibility Guidelines (WCAG) 2.0, Guideline 1.2 Time-based Media: Provide alternatives for time-based media. Accessed from: http://www.w3.org/TR/WCAG20/#media-equiv</ref>

As you work on developing your text transcript, keep in mind the following recommendations about what to include:

#'''Speaker’s name'''
#'''All speech content:''' If there is speech that is not relevant, it is usually best to indicate that it has been excluded from the transcript. For example: “[A & B chatted while slides were loading].”'''
#'''Relevant descriptions about the speech: Descriptions that convey emotions, mood, etc. are usually provided in brackets. For example: “Don’t touch that! [shouted].”
#Descriptions of relevant non-speech audio: These are usually provided in brackets. For example: “[metal pipes crashing to concrete floor].” Background noise that isn’t relevant can be left out.
#'''Headings and sub-headings:''' Where they will make the transcript more usable or easy to navigate, headings and sub-headings can be helpful aids, especially when the transcript is long. When including these, put them in brackets to show that they were not part of the original audio. For example: [I

====Transcripts and third-party videos====

If you are not producing your own video resource but are planning to embed video materials from a third-party source (e.g., YouTube), be aware that not all third-party sources include transcripts. While services like YouTube technically support transcripts, not all contributors to YouTube include these. If you select a video resource that does not already have a transcript, you will need to produce one yourself.*

*''Copyright note:'' Producing your own transcript for a third-party video could infringe on copyright, depending on how the video has been licensed. Before you proceed with producing a transcript for media materials you did not create yourself, you should contact the copyright holder of that material to obtain permission to do so.

====Captions====

Timed text captions are essential to opening up a world of information for persons with hearing loss or literacy needs by making the readable equivalent of audio content available to them in a synchronized manner. Globally hearing loss affects about 10% of the population to some degree. It causes disability in 5% (360 to 538 million) and moderate to severe disability in 124 million people. Timed text captions also be helpful for learners whose native languages are languages other than the primary language of the media or who have cognitive conditions that benefit from visual.Captions are the text that is synchronized with the audio in a video presentation. Captions are important when people need to see what’s happening in the video and get the audio information in text at the same time.

The work you put into creating a text transcript for a video resource can be repurposed to provide the captions. Keep in mind the following recommendations about what to include in your captions:

#'''All speech content:''' If there is speech that is not relevant, it is usually best to indicate that it has been excluded from the captions. For example: “[A & B chatted while slides were loading].”
#'''Descriptions of relevant non-speech audio:''' These are usually provided in brackets. For example: “[metal pipes crashing to concrete floor]”; “[background music by XXX plays].” Background noise that isn’t relevant can be left out.

Text captions can be uploaded to YouTube and other platforms along with the video to create a timed text file in SubRip (SRT) format. Additional best practices for timed captions include:

*Each caption frame should not be on screen for less than three seconds.
*Each caption frame must not be on screen for less than two seconds.
*Each caption frame should not exceed more than 2 lines.
*Each caption frame must not exceed more than 3 lines.
*Each line should not exceed more than 32 characters
*All caption frames should be precisely time synched to the audio.
*When multiple speakers are present, it is sometimes helpful to identify who is speaking, especially when the video does not make this clear.
*Non-speech sounds like [MUSIC] or [LAUGHTER] should be added in square brackets.

====Downloadable Transcripts====
For both audio and video transcripts, consider including a text file that learners can download and review using tools such as word processing, screen reader, or literacy software. All learners can use transcripts of media-based learning materials for study and review.

====Audio Descriptions====

Consider what your students would get out of a multimedia resource if they were not able to see embedded visual materials critical for comprehension. Audio descriptions are helpful if visual content (e.g., a chart or a map) in a video or presentation provides important context that is not available through the audio alone.<ref>Web Content Accessibility Guidelines (WCAG) 2.0, Guideline 1.2.3 Audio Description or Media Alternative (Prerecorded). Accessed from: http://www.w3.org/TR/WCAG20/#media-equiv</ref> Actions that are only visible on screen without any audible equivalent are not accessible to learners who have visual impairments.

When describing visual elements in your multimedia resources, keep in mind the following recommendations and guidelines.

1. When contextual visual content on the screen is not described in the audio itself, you will need to provide an audio description that is an objective description of the visual element. ''Example:''

:::To help students fully grasp a concept that you are trying to convey in your video, you have included some contextual visual references (e.g., maps, charts, physical demonstrations of a process). However, you realize after making the video that the audio portion does not describe these visuals in enough detail for a student with visual impairments to be able to access all of the concepts you intended to convey.

::In this case, you would need to record an audio description of the visual material that provides enough detail to provide students like Jacob with the same content available to visual learners.

2. Whenever possible, avoid creating the need for audio descriptions in the first place by being proactive at the time of recording. If you pay attention to contextual visuals during the recording of the media piece, you may find opportunities to convey the visual content within the spoken material itself; you will not need to provide audio descriptions of the visual content after the fact. ''Example:''

::You are recording a video or presentation that includes a chart that tracks coal production in British Columbia, and as part of the presentation you want to focus attention on specific data in the chart. The narrator or presenter might point to sections on the chart and say:

:::“As you can see, metallurgical coal projection increased by 3 million tonnes over these two years.“

::In this case, audio descriptions would be necessary to provide the missing context to students with visual disabilities; these students cannot see the data on the chart that tells visual learners what the production figures are and for what dates. However, if the narrator or presenter instead says:

:::“This chart illustrates that metallurgical coal production in B.C. increased from 23 million tonnes in 1999 to 26 million tonnes in 2001,”

::the visual content is conveyed through the audio and no audio description will be necessary.

====Accessible Media Resources====

*[http://ncam.wgbh.org/invent_build/web_multimedia/accessible-digital-media-guide Accessible Digital Media Guidelines] provides detailed advice on creating online video and audio with accessibility in mind.
*[https://dcmp.org/public_content/ai/captioningkey/index.html Captioning Key by the National Association for the Deaf] provides excellent guidance on creating described and captioned media.

==Best Practices 5: Font size==

In this section, we review the two main concerns of font size on the web.

===What Is Font Size?===

'''Font size:''' The size of text visible on the screen.

===Who Are You Doing This For?===

This work supports students who:

*Are blind or have low vision
*Have a form of cognitive disability
*Are deaf or hard of hearing
*Have a physical disability

===What Do You Need To Do?===

There are two main concerns when working with font sizes.

# Ensuring that default font sizes are not too small.
# Ensuring that text can be expanded to 200% on websites<ref>http://sites.psu.edu/accessibility/fontsizehtml/ </ref>.

Keep in mind these recommendations and guidelines:

*'''12 point for body text''': For most documents, body text should be around 12 points. Small fonts may be illegible for some audiences.

*'''9 point for footnotes''': If a document contains footnotes or endnotes, the minimum size should be about 9 points

* '''200% zoom''': The Web Content Accessibility Guidelines (WCAG 2.0) recommend ensuring that text can be zoomed to 200%. As well, we recommend using liquid layouts that can accommodate 200% text. Liquid layout are layouts that are based on percentages of the current browser window's size. They flex with the size of the window, even if the current viewer changes their browser size as they're viewing the site. Liquid width layouts allow a very efficient use of the space provided by any given Web browser window or screen resolution.

==Best Practices 6: Colour Contrast==
In this section, we provide guidelines and recommendations about colour contrast in your open educational materials.

===What is Colour Contrast?===

'''Colour contrast includes''': hue, lightness and saturation of text, images, and background
'''File types''': .doc, .html, .pdf, .jpg, .gif

===What What Role Does Colour Play in the Delivery of Your Content?===

When documents or web pages do not provide enough contrast between foreground elements (e.g., text, images) and background elements (e.g., colour, watermark images), some students will have difficulty reading the content. Consider the following questions:

1. Have you presented text- or image-based content on a coloured or textured background? If so, you should:
*Confirm that there is sufficient contrast between your foreground content and the chosen background colour or texture.

2. Have you included links in your content? If so, you should:
*Confirm that the colour of your web links is distinct from both your background colour and the colour of the surrounding text.

3. Have you used colour to convey concepts or information? If so, you should:
*Confirm that you are not using colour alone to convey this information.

===Who Are You Doing This For?===

This work supports students who:

*Have low vision
*Have poor contrast vision
*Are colour blind and cannot differentiate between certain colours
*Are using a device with monochrome display

===What Do You Need To Do?===

====Contrast====

Students with low vision and/or a form of colour blindness may have difficulty reading text that does not contrast enough with the background colour you have selected. If the colour palette you have adopted is too subtle (e.g., white text on a pastel background; medium-grey text on a light-grey background), the contrast between your foreground and background is probably insufficient for some students.

Web Content Accessibility Guidelines (WCAG 2.0) require that “the visual presentation of text and images of text has a contrast ratio of at least 7:1.”<ref>Web Content Accessibility Guidelines (WCAG) 2.0, Guideline 1.4.6 Contrast (Enhanced). Accessed from: http://www.w3.org/TR/UNDERSTANDING-WCAG20/visual-audio-contrast7.html</ref> The image below presents four different foreground/background colour-contrast examples to illustrate insufficient and sufficient colour contrast ratios.
<br /><br />
[[File:Colour_Contrast.png|thumb|center|500px|Image displays four examples of foreground (text) colour against background colours; only the example on the far right presents combinations with sufficient colour contrast.]]
<br /><br />
{| class="ambox ambox-notice"
| class="mbox-text" | <div>
'''Not sure how to test your materials for colour contrast ratios?'''

There are many online and downloadable tools available to help you evaluate colour contrast ratios. Here are a few we have tried and like:
*'''WebAIM’s [http://webaim.org/resources/contrastchecker/ Color Contrast Checker]''': This web-based tool allows you to select or enter colour values to test and provides you with a “pass” or “fail” on your contrast ratio.
*'''ACART’s [http://www.contrastchecker.com/ Contrast Checker]''': This is a straightforward, web-based tool you can use to both check colour contrast and view your selections in grey scale. This tool also allows you to keep a history of the colour combinations you have tested.
*'''Giacomo Mazzocato’s [http://gmazzocato.altervista.org/colorwheel/wheel.php Accessibility Color Wheel]''': This web-based tool includes several options for testing your colour selections, including simulations of three types of colour blindness. You can also opt to test what your contrast ratio is when the foreground and background colour selections are inverted.
</div>
|}

====Weblink Colours====

Weblinks must be visually distinct from both the surrounding, non-linked text and background colour. If you do not underline your links (or provide some other non-colour cue), you must ensure that you provide both sufficient contrast between the link and background colours and between the link colour and that of the surrounding text.

Web Content Accessibility Guidelines (WCAG 2.0) require a:
*4.5:1 contrast between the link text color and the background
*3:1 contrast between the link text color and the surrounding non-link text color<ref>WebAIM (2015), WCAG 2.0 and Link Colors. Accessed from: http://webaim.org/blog/wcag-2-0-and-link-colors/ </ref>

====High-Contrast Mode====

Some students need to see light text on a dark background for it to be readable, while others require dark text on a light background. Students with low vision must be able to see content when it is displayed in high-contrast mode. This can be a subjective experience, based on individual student needs. We recommend that you try testing your text and image-based content as you go by using high-contrast mode on your own computer and making adjustments as needed.

All content items such as text, images, bullets, and table borders must be visible in both regular and high-contrast modes.

{| class="ambox ambox-notice"
| class="mbox-text" | <div>
'''Not sure how to test your content in high-contrast mode?
'''
To test the visibility of your content in this mode, turn on high contrast by simultaneously pressing the following keys on your (PC) keyboard:
::'''Left ALT + Left SHIFT + Print Screen.'''
To turn off high contrast mode, repeat this step.
</div>
|}

====Use of Colour====

You should not rely on colour as the sole means of conveying information and instruction. If the point you are making depends on colour to be understood, you will need to edit your materials so that concepts presented in the visuals are not lost to those who are colour blind or who require high contrast between colours.<ref>Web Content Accessibility Guidelines (WCAG) 2.0, Guideline 1.4.1 Use of Color. Accessed from: http://www.w3.org/TR/WCAG20/#visual-audio-contrast</ref>

==Best Practices 7: Formulas==

Math or Science formulas in open educational resources can be challenging to deliver in a way that is accessible to people with vision impairments. Non-scalable images of mathematical content cannot be sufficiently enlarged or navigated by low-vision users and are not accessible to blind users at all.

===What Are Formulas?===

'''Formulas include:''' Math equations or science formulas

'''File types:''' LaTex or MathType

===Before You Begin===
'''Who Are You Doing This For?'''

This work supports students who:

*Are blind or have low vision
*Have a form of cognitive disability,
*Have a physical disability

The following content is a derivative of Equations: Images vs. MathML from Accessibility and Usability at Penn State, http://accessibility.psu.edu/equations.

===What Do You Need to Do?===

There are several ways to handle equations from images with ALT tags to MathML. Having access to an equation editor such as MathType or MathMagic can streamline processing and converting equations considerably. These tools are similar to equation editors found in the ANGEL HTML Editor and Microsoft Office.

====MathML====

[http://accessibility.psu.edu/math/mathml/ Math ML] is a text-based XML markup language designed for math equations. Browsers that support MathML are able to translate the XML into a formatted equation. Since MathML with MathJax can be rendered in many systems, including HTML, Sites at Penn State, ANGEL and Drupal, it is considered the best choice for accessibility.

Information about [http://accessibility.psu.edu/math/mathml/ creating and viewing MathML] is available on that page.

MathML may vary from system to system and the content can change rapidly.

====Image with ALT tag====

A safe option to create an image of an equation (or export it from an equation editor) and then insert the image into a document with an ALT tag.

''Note:'' ALT tags can be written in Nemeth MathSpeak for students who have learned that system.

<math>
m = \frac{m_0}{\sqrt{1-\frac{v^2}{c^2}}}
</math>

View the ALT Tag

ALT= “m equals begin fraction m sub 0 over begin square root 1 minus begin fraction v sup 2 over c sup 2 end fraction end square root end fraction”

====LaTex====

LaTeX is a math markup language familiar to many in the science and math community, but unfortunately it is not currently supported by screen reader technology. However, it is fairly simple to convert LaTeX to an image or MathML in most equation editors.

For example, in the [http://wiki.ubc.ca UBC Wiki] you can insert a piece of LaTeX code using the <nowiki><math></nowiki> tag:
<pre>
<math>
m = \frac{m_0}{\sqrt{1-\frac{v^2}{c^2}}}
</math>
</pre>
The equation should appear fully formatted. Make minor adjustments as needed.

====Audio Files====
User testing with students have indicated that it would helpful to have an audio file of the formula or equation. The audio file would be placed beside the formula or equation and would allow the user to hear exactly how the formula or equation is interpreted.

====Audio Files====
User testing with students have indicated that it would helpful to have an audio file of the formula or equation. The audio file would be placed beside the formula or equation and would allow the user to hear exactly how the formula or equation is interpreted.
=====Example — equation with audio=====
[[File:MM0over.png|200px|center|math formular]]
[https://soundcloud.com/user-262382099-529580848/equation Listen to the audio file of this equation]:

===Additional Resources===

*In 2012, Portland Community College departments took a closer look at making math accessible to blind students. Read more about the math accessibility study on our website: http://www.pcc.edu/access.
*The [http://www.washington.edu/doit/are-there-guidelines-creating-accessible-math?465= DO-IT project from the University of Washington] provides guidance on creating accessible math content.
*The [http://www.washington.edu/doit/programs/accessstem/overview AccessSTEM] website provides guidance on creating accessible science, technology, engineering and math educational content.

==Best Practices 8: PDFs, Word Docs and Excel Files==
This section describes guidelines for creating accessible content in PDFs, Word documents, and Excel spreadsheets. Many of the same accessibility techniques and principles that apply to authoring in HTML also apply to creating document based OERs.

===PDFs===
Converting or publishing open resources as PDF documents can create accessibility barriers, particularly for learners with visual impairments. Accessibility issues are very common in PDF files that were scanned from printed sources or exported from a non-PDF document format. Scanned documents are simply images of text. To make scanned documents accessible, you must perform Optical Character Recognition (OCR) on these documents, and proofread the resulting text for accuracy before embedding it within the PDF file. You must also add semantic structure and other metadata (headings, links, alternative content for images, and so on) to the embedded text.

When you export documents to PDF from other formats, it is important to ensure that the source document contains all the required semantic structure and metadata before exporting. Unfortunately, some applications do not include this information when exporting and require the author to add or “tag” the document manually using PDF editing software. You should carefully consider whether exporting to PDF is necessary at all.

====Best Practices for Authoring Accessible PDF Documents====

*Explicitly define the language of the document so that screen readers know what language they should use to parse the document.
*Explicitly set the document title. When you export a file to PDF format, the document title usually defaults to the file name, not a human readable title.
*Verify that all images have alternative content defined or are marked as decorative only.
*Verify that the PDF file is “tagged”. Make sure the semantic structure from the source document has been correctly imported to the PDF file.
*Verify that a logical reading order is defined. This is especially important for documents that have atypical page layouts or structure.
*If your document includes tables, verify that table headers for rows and columns are properly defined.

====Accessible PDF Resources====
*[http://webaim.org/techniques/acrobat/ WebAIM's PDF Accessibility site] provides a detailed and illustrated guide on creating accessible PDFs.
*The [http://ncdae.org/resources/cheatsheets/ National Center of Disability and Access to Education has a collection of one-page “cheat sheets”] on accessible document authoring.
*Microsoft provides detailed [https://support.office.com/en-gb/article/Create-accessible-PDFs-064625e0-56ea-4e16-ad71-3aa33bb4b7ed?CorrelationId=9b8d28cf-aa96-4816-9536-b4aea195b51c&ui=en-US&rs=en-GB&ad=GB&ocmsassetID=HA102478227 guidance on generating accessible PDFs from Microsoft Office applications], including Word, Excel, and PowerPoint.
*Adobe provides [https://helpx.adobe.com/acrobat/using/create-verify-pdf-accessibility.html documentation on how to create and verify PDF accessibility].

===Word Documents===
Many of the same accessibility techniques and principles that apply to authoring one content also apply to creating Word documents. Keep formatting simple. Use headings, paragraphs, lists, images, and captions. Use tables for tabular data. Do not add unnecessary indents, rules, columns, blank lines, or typographic variation. Use standardized styles for formatting your text, such as Normal, Heading 1, and Heading 2, rather than manually formatting text using text styles and indents. Formatting text for its semantic meaning and not for its visual appearance allows users of assistive technology to consume and navigate documents effectively and efficiently.

Additional best practices include;

*Images must have descriptive text associated with them.
*Documents should be well structured.
*Hyperlinks should be meaningful and describe the destination.
*Tables should include properly defined column and row headers.
*Color combinations should be high contrast.
*Verify the accessibility of your document using [https://support.office.com/en-us/article/Use-the-Accessibility-Checker-on-your-Windows-desktop-to-find-accessibility-issues-a16f6de0-2f39-4a2b-8bd8-5ad801426c7f?ui=en-US&rs=en-US&ad=US Microsoft’s Accessibility Checker].

===Excel Spreadsheets===
Many of the same accessibility techniques and principles that apply to authoring data tables in HTML also apply to creating Excel spreadsheets. Microsoft has a [https://support.office.com/en-us/article/Make-your-Excel-spreadsheets-accessible-6CC05FC5-1314-48B5-8EB3-683E49B3E593?ui=en-US&rs=en-US&ad=US guide to creating accessible Excel workbooks].

*Images must have descriptive text associated with them.
*Column and row headings should be programmatically identified.
*Hyperlinks in spreadsheets should be meaningful and describe the destination.
*Use a unique and informative title for each worksheet tab.
*Do not use blank cells for formatting.
*Colour combinations should be high contrast.
*Verify the accessibility of your workbook using [https://support.office.com/en-us/article/Use-the-Accessibility-Checker-on-your-Windows-desktop-to-find-accessibility-issues-a16f6de0-2f39-4a2b-8bd8-5ad801426c7f?ui=en-US&rs=en-US&ad=US Microsoft’s Accessibility Checker].

===Additional Microsoft Accessibility Resources===
*[https://support.office.com/en-us/article/Make-your-Word-documents-accessible-D9BF3683-87AC-47EA-B91A-78DCACB3C66D?ui=en-US&rs=en-US&ad=US Microsoft guide to creating accessible Word documents.]
*[https://support.office.com/en-us/article/Use-the-Accessibility-Checker-on-your-Windows-desktop-to-find-accessibility-issues-a16f6de0-2f39-4a2b-8bd8-5ad801426c7f?ui=en-US&rs=en-US&ad=US Microsoft tool that allows you to check Word documents for accessibility issues.]
*Microsoft guide to creating [https://support.office.com/en-us/article/Make-your-PowerPoint-presentations-accessible-6F7772B2-2F33-4BD2-8CA7-DAE3B2B3EF25?ui=en-US&rs=en-US&ad=US accessible PowerPoint presentations].
*[https://support.office.com/en-us/article/Make-your-Excel-spreadsheets-accessible-6CC05FC5-1314-48B5-8EB3-683E49B3E593?ui=en-US&rs=en-US&ad=US Microsoft guide to creating accessible Excel workbooks].
*Microsoft tool that allows you to check [https://support.office.com/en-us/article/Use-the-Accessibility-Checker-on-your-Windows-desktop-to-find-accessibility-issues-a16f6de0-2f39-4a2b-8bd8-5ad801426c7f?ui=en-US&rs=en-US&ad=US Excel workbooks for accessibility issues].
*Microsoft guide to creating [http://webaim.org/techniques/powerpoint/ accessible PowerPoint presentations].
*[http://webaim.org/techniques/powerpoint/ WebAIM’s guide to PowerPoint accessibility].

==UBC Platform Specific Accessibility Guidelines==

===Canvas===
*[https://community.canvaslms.com/docs/DOC-2061 Accessibility within Canvs]
*[https://community.canvaslms.com/groups/accessibility Canvas Accessibility Group]
*[https://community.canvaslms.com/groups/accessibility/blog/2018/05/08/how-to-fix-and-prevent-accessibility-issues-in-your-canvas-course How to Fix and Prevent Accessibility Issues in Your Canvas ]

===Edx===
*[http://edx.readthedocs.io/projects/edx-partner-course-staff/en/latest/accessibility/index.html Accessibility Best Practices Guidance for Content Providers]

===WordPress===
*[https://en.support.wordpress.com/accessibility/ Accessibility in WordPress]
*[http://khan.github.io/tota11y/ Tota11y] - a tool to check if your site is accessible or not. There is also a [https://chrome.google.com/webstore/detail/tota11y-plugin-from-khan/oedofneiplgibimfkccchnimiadcmhpe?hl=en chrome extension] available

===MediaWiki/UBC Wiki===
*[https://en.wikipedia.org/wiki/Wikipedia:Manual_of_Style/Accessibility Manual of Style- Accessibility]

===UBC Centre for Accessibility===
*[https://students.ubc.ca/about-student-services/centre-for-accessibility UBC Centre for Accessibility] (CfA) provides leadership on issues of accessibility for people with disabilities at UBC Vancouver, working in partnership with faculties to foster inclusive learning, living and working environments for students, faculty and staff. The Centre for Accessibility provides support and programming initiatives designed to remove barriers for students with disabilities and facilitates disability related accommodations for members of the UBC Vancouver community.

===UBC Centre for Workplace Accessibility===
*[https://hr.ubc.ca/health-and-wellbeing/workplace-accessibility/centre-workplace-accessibility The Centre for Workplace Accessibility] (CWA) is a hub for resources, tools, and programs that help remove barriers for faculty and staff with disabilities or ongoing medical conditions. It offers support to improve workplace accessibility using a trauma-informed, person-centred approach. Its initiatives also include projects and workshops designed to build disability inclusion literacy throughout the UBC community.

==Appendix: Checklist for OER Accessibility==

===Organizing Content===

☐ Contents is organized under headings and subheadings

☐ Headings and subheadings are used sequentially (e.g. Heading 1, heading 2, etc)

===Images===

☐ Images that convey information include Alternative Text (alt-text) descriptions of the image’s content or function.

☐ Graphs, Charts, and Maps also include contextual or supporting details in the text surrounding the image.

☐ Images do not rely on colour to convey information.

☐ Images that are purely decorative contain empty alternative text descriptions. (Descriptive text is unnecessary if the image doesn’t convey contextual content information).

===Tables===

☐ Tables include row and column headers.

☐ Table includes title or caption.

☐ Table does not have merged or split cells.

☐ Table has adequate cell padding.

===Weblinks===

☐ The weblink is meaningful in context, does not use generic text such as “click here” or “read more”.

☐ Weblinks do not open new windows or tabs.

☐ If weblink must open in a new window, a textual reference is included in the link information.

===Multimedia===

☐ A transcript has been made available for a multimedia resource that includes audio narration or instruction. Transcript includes:
:Speaker’s name
:All speech content
:Relevant descriptions of speech
:Descriptions of relevant non-speech audio

===Headings and subheadings===

☐ Captions of all speech content and relevant non-speech content are included in the multimedia resource that includes audio synchronized with a video presentation.

☐ Audio descriptions of contextual visuals (graphs, charts, etc) are included in the multimedia resource.

===Formulas===

☐ Formulas have been created using MathML.

☐ Formulas are images with alternative text descriptions, if MathML is not an option.

===Font Size===

☐ Font size is 12 point or higher for body text.

☐ Font size is 9 point for footnotes or end notes.

☐ Font size can be zoomed to 200%.

==Appendix: Accessibility 2-Page Handout==

[[File:Accessibility Handout Thumbnail.png|thumb|centre|400px|link=http://wiki.ubc.ca/images/5/5b/UBC_Accessibility_Handout.pdf|Click to Download PDF ]]

==Appendix: Additional OER Accessibility Resources==
*[https://accessibility.ctlt.ubc.ca/ UBC Accessibility 101] - A UBC resource that focuses on improving access to digital content for students with vision or hearing impairments and similar learning barriers.
*[https://blogs.ubc.ca/accessibleactivelearning/ Accessible Active Learning] - A resource designed for Instructional Skills Workshop (ISW) and TA Training facilitators at UBCV. It is meant as a resource to help them design activities with accessibility in-mind, to help make activities accessible to more students and participants.
*[https://equity.ubc.ca/resources/accessible-and-inclusive-event-planning/ UBC Accessible Event Planning Guide] - provides practical tools to help event organizers create inclusive and welcoming experiences for everyone, including particularly people with disabilities.
*[https://opentextbc.ca/accessibilitytoolkit/ BC Open Textbook Accessibility Toolkit] - (also in [https://opentextbc.ca/troussedoutildaccessibilite/ French]). See also the [https://cdn.collection.bccampus.ca/assets/B_Ccampus_Accessibility_Criteria_6b42ab8ce8.pdf BCcampus OER Accessibility Criteria checklist] and the [https://opentextbc.ca/accessibilitytoolkit/back-matter/inclusive-design-webinar-series/ BCcampus Inclusive Design Webinar Series].
*[https://students.ubc.ca/about-student-services/centre-for-accessibility UBC Centre for Accessibility] provides support and programming initiatives designed to remove barriers for students with disabilities and facilitates disability related accommodations for members of the UBC Vancouver community.
*[https://pressbooks.bccampus.ca/a11yondemand/ Digital Accessibility On-demand] - a resource by Luke McKnight designed as a just-in-time resource to guide creators to the step-by-step instructions they need to maximize accessibility and increase inclusivity.
*[https://pressbooks.bccampus.ca/accessibilityhandbook/ Accessibility Handbook for Teaching and Learning] - a guidebook by Luke McKnight and Briana Fraser to introduce concepts of digital accessibility and to provide detailed instructions to use the accessibility features of software such as Word and PowerPoint.
*[https://hr.ubc.ca/health-and-wellbeing/workplace-accessibility/centre-workplace-accessibility The Centre for Workplace Accessibility (CWA)] is a hub for resources, tools, and programs that help remove barriers for faculty and staff with disabilities or ongoing medical conditions. It offers support to improve workplace accessibility using a trauma-informed, person-centred approach.
*Inclusive Design Research Centre’s [http://floeproject.org/ Flexible Learning for Open Education]
*[http://www.udlcenter.org/implementation/postsecondary The National Center on Universal Design for Learning] provides a helpful overview on Universal Design for Learning.
*Portland Community College’s [http://www.pcc.edu/resources/instructional-support/access/ Accessibility for Online Course Content: A Guide for Instructors]
*[https://inclusive.microsoft.design/ Inclusive Design at Microsoft]
*[https://wiki.ubc.ca/images/0/02/Complex_Images_for_All_Learners.pdf Accessibility for Complex Images]: resource for making charts, graphs, figures, and other complex images accessible.
*[https://www.jisc.ac.uk/guides/supporting-an-inclusive-learner-experience-in-higher-education JISC guide to supporting an inclusive learner experience in higher education]
*The [https://bccampus.ca/wp-content/uploads/2023/04/OER-Equity-Rubric-1.pdf BCcampus OER Equity Rubric] is designed to help identify opportunities to adapt and improve the equity of open resources.

==References==
<references/>

==About this Toolkit==
[[File:CC-SA_button.png|left|CC by|100px]] The OER Accessibility Toolkit is licensed under a [https://creativecommons.org/licenses/by-sa/4.0/ Creative Commons Attribution-ShareAlike 4.0 International License], except where otherwise noted. Source files for this resource may be found on the [http://wiki.ubc.ca/Documentation:Open_UBC/Guide/OER_Accessibility_Toolkit UBC Wiki].

Content for this toolkit was adapted from the [https://opentextbc.ca/accessibilitytoolkit/ BC Open Textbook Accessibility Toolkit] by Amanda Coolidge, Sue Doner, and Tara Robertson. The [https://opentextbc.ca/accessibilitytoolkit/ BC Open Textbook Accessibility Toolkit] is licensed under a [https://creativecommons.org/licenses/by/4.0/ Creative Commons Attribution 4.0 International License], except where otherwise noted. Additional material has been adapted from the [http://edx.readthedocs.io/projects/edx-partner-course-staff/en/latest/accessibility/index.html edX Accessibility Best Practices for Developing Course Content] guidelines under a [https://creativecommons.org/licenses/by-sa/4.0/ Creative Commons Attribution Share Alike 4.0 International License].

[[Category:Open UBC]][[Category:Accessibility]] [[Category:Accessibility Toolkits]] [[Category:OER]] [[Category:Open Education]] [[Category:Universal Design]]

Documentation:Open UBC/Guide/OER Accessibility Toolkit

2026-05-29T16:41:23Z

WillEngle: /* Appendix: Additional OER Accessibility Resources */

==Accessibility for Open Education==

{{#widget:YouTube|id=KcvYG-rkO-Y|height=315|width=420}}

The focus of many open education projects is to provide access to education. But what does access mean? If the materials are not accessible for each and every student, do they fulfill the mandate to deliver fully open education? The open education movement has helped people in different parts of the world access content that they would otherwise not be able to view or interact with. Open education resources reduce costs for students and allow for greater flexibility for instructors. Accessibility can help push the movement even further forward.

The goal of the ''OER Accessibility Toolkit'' is to provide the needed resources to each content creator, instructor, instructional designer, educational technologist, librarian, administrator, and teaching assistant to create a truly open and accessible educational resource — one that is accessible for all students.

As you work through the content of the ''OER Accessibility Toolkit'', you will find that the suggestions provided are intended for the non-technical user. If you are looking for more technical descriptions of how to make your work accessible, we suggest you review the [https://www.w3.org/TR/WCAG20/ WCAG (Web Content Accessibility Guidelines)].

==Key Concepts: Universal Design and Personas==

Universal Design is the process of creating products (devices, environments, systems, and processes) that are usable by people with the widest possible range of abilities, operating within the widest possible range of situations (environments, conditions, and circumstances). Universal Design emerged from the slightly earlier concept of being barrier-free, the broader accessibility movement, and adaptive and assistive technology. It also seeks to blend aesthetics into these core considerations.

Let’s review some common definitions of Universal Design.

===Definition 1===

Universal Design or Universal Instructional Design (UID)
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"is an approach to teaching that consists of the proactive design and use of inclusive instructional and evaluation strategies. This approach provides academic access to a broad range of learners, including students with disabilities, while:
*maintaining academic standards […]
*reducing the need to having to retrofit after a course is already underway<ref>FAIR ([http://web2.uvcs.uvic.ca/fair/ Facilitating Accessible Instruction & Resources]). University of Victoria </ref>"

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===Definition 2===
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Universal Instructional Design (UID)

is an approach to designing course instruction, materials and content to benefit people of all learning styles without adaptation or retrofitting. UID provides equal access to learning, not simply equal access to information. UID allows the student to control the method of accessing information while the instructor monitors the learning process and initiates any beneficial methods. …It should be noted that UID does not remove academic challenges; it removes barriers to access.<ref>Universal Design for Learning. Ohio State University</ref>
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===Why Universal Design?===

For our purposes, we frame the practice of using Universal Design in a holistic and manageable way, and begin by addressing the barriers that are easy to anticipate and proactively re-mediate. This toolkit, therefore, will provide guidance to you if the answers to any of the following questions is “yes”:

*Do I have visual materials that present core concepts that not all students may be able to see or understand?
*Do I have multimedia (audio, video) materials that present core concepts that not all students may be able to be hear, see, or access?
*Do I have documents that present core concepts in a format that not all students may be able to access?

For the purpose of the ''OER Accessibility Toolkit'', we focus on an adjunct to Universal Design, that being Universal Design for Learning (UDL), which is a set of principles for curriculum development that gives all individuals equal opportunities to learn. UDL provides a blueprint for creating instructional goals, methods, materials, and assessments that work for everyone. Rather than a single, one-size-fits-all solution, it offers a flexible approach that can be customized and adjusted for individual needs.<ref>http://www.udlcenter.org/aboutudl/whatisudl ↵</ref>

The principles of Universal Design for Learning can be summarized by the following points.

*Present information and content in various ways.
*Provide more than one way for learners to express what they know.
*Stimulate interest and motivation for learning.

OER creators can apply these principles in course design by following several guidelines:

*Design resources and activities that can be accessed by learners in a variety of ways. For example, if there is a text component, provide the ability to enlarge the font size or change the text color. For images and diagrams, always provide an equivalent text description. For video, include text captions.
*Provide multiple ways for learners to engage with information and demonstrate their knowledge. This is particularly important to keep in mind as you design activities and assessments.
*Identify activities that require specific sensory or physical capability and for which it might be difficult or impossible to accommodate the accessibility needs of learners. For example, an activity that requires learners to identify objects by color might cause difficulties for learners with visual impairments. In these cases, consider whether there is a pedagogical justification for the activity being designed in that way. If there is a justification, communicate these requirements to prospective learners in the course description and establish a plan for responding to learners who encounter barriers.

===Persona===
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This video shows a demonstration of students using accessibility softwares (ZoomText, JAWs and TextDragon) .

Designers use personas to represent the different types of people who may be accessing a website or product. Using a persona can be a helpful when you are designing an accessible open resources. Take a look at the personals from [http://uxmag.com/articles/book-excerpt-a-web-for-everyone Book Excerpt: A Web for Everyone] to get an idea on how your audiences navigate your course/resources.

==Best Practices 1: Online Content Organization and Weblinks==

HTML is a good format for creating accessible content. It is well supported and adaptable across browsers and devices. Also, the information in HTML markup helps assistive technologies, such as screen reader software, to provide information and functionality to people with vision impairments.

Organizing your html and online content so it has a logical flow just makes sense. Using headings, and subheadings to organize content allows students to clearly see how the main concepts are related. Headings are one of the main ways that students using a screen reader navigate through a webpage or online resource.

A weblink is a link from a file or document to another location (such as a website address) or file, typically activated by clicking on a highlighted word or image on the screen. Generally weblinks are included within content to provide the user with additional information that is available at a another location.

'''File types''': .html, .pdf, .doc, .xls

===Who Are You Doing This For?===

Everyone benefits from having content that’s clearly organized. In addition, well-organized content and descriptive weblinks support students who:

*Have a learning disability (For a example, a student with ADHD) - Having an organized content allow them to easily go back and find the important points.
*Are blind or have low vision - It gives them more control in navigating through different chapters.
*Have a form of cognitive disability
*Have a physical disability,
*Are deaf or hard of hearing

===What Do You Need to Do?===

====Content Organization====
Headings help to identify the hierarchical structure of a document (e.g., sections, sub-sections). Headings provide a visual cue that helps sighted readers quickly navigate through sections of a document, skimming through content until they find a section they are looking for. Similarly, headings create logical divisions in the content and allow a non-sighted user to navigate a page or document easily using a screen reader.

When it comes to using visual references to indicate the hierarchy and structure of a document, you may be accustomed to just changing the font, enlarging the type size, making it bold or underlined or italicized, creating the impression of a heading. This approach presents problems when creating material with accessibility in mind because screen readers won’t identify the text as a heading. Instead, a screen reader will just “read” through the text of a heading as if it were part of another paragraph of content, missing your intended cues about structure and organization.

[[File:Headings in wordpress.png|thumb|center|Headings in WordPress(UBC Blogs)]]
Keep the following guidelines in mind when you create online content.

*Use HTML tags to describe the meaning of content, rather than changing its appearance. For example, you should tag a section title with the appropriate heading level (such as <nowiki><h3></nowiki>) rather than making the text appear like a heading by applying visual elements such as bold text and a larger font size. Format list items into a list rather than using images of bullets or indents. Using HTML to describe your content’s meaning is valuable for learners who use screen readers, which, for example, can read through all headings of a specific level or announce the number of items in a list.
*Use HTML heading levels in sequential order to represent the structure of a document. Well-structured headings help learners and screen reader users to navigate a page and efficiently find what they are looking for.
*Use HTML list elements to group related items and make content easier to skim and read.

====Content Organization How tos====
*[https://en.support.wordpress.com/visual-editor/#styles How to create headings in WordPress(UBC Blogs)]
*[[Help:Formatting#Headers_.26_Lines|How to create headings in UBC Wiki]]
*[https://ccs.instructure.com/courses/1181412/pages/accessibility-basics-on-canvas-pages-headers-colors-and-tables?module_item_id=21897445 How to create headings in Canvas]
*[http://edx.readthedocs.io/projects/edx-partner-course-staff/en/latest/course_components/create_html_component.html#the-visual-editor How to create headings in EdX]

====Link Descriptions====

Ensure that all web pages and weblinks have titles that describe a topic or purpose. The purpose of the link can be determined by the text alone. That is, you don’t need to include additional information justifying the use of the link. You want the link to be meaningful in context. For example, do not use generic text such as “click here” or “read more” unless the purpose of the link can be determined by meaning in the surrounding content.<ref>https://www.webaccessibility.com/best_practices.php?best_practice_id=1301</ref>

Consider the following examples.

'''Example 1''' — unclear:

Click [http://open.ubc.ca here] for information on open at UBC.

'''Example 2''' — clear and accessible:

Information on [http://open.ubc.ca UBC Open education projects and resources] is available online.

====New Tabs/Windows====

In general, it is better if weblinks do not open new windows and tabs since they can be disorienting for people, especially people who have difficulty perceiving visual content.<ref>http://www.w3.org/TR/2014/NOTE-WCAG20-TECHS-20140916/G200</ref>. However, if a link must open in a new window, it is best practice to include a textual reference. For example, IInformation on [http://open.ubc.ca UBC Open education projects and resources (New Window)] is available online.<ref>http://accessibility.psu.edu/linkshtml</ref>

==Best Practices 2: Images==
In this section, we provide recommendations to guide your inclusion of accessible, image-based content.

===What Are Images?===

'''Images include''': photographs, diagrams, pictures, charts, graphs, maps

'''File types''': .gif, .jpg, .png

===Before You Begin===

====Why Are You Including the Images You Have Selected?====

Before you can determine what you need to do to make an image accessible, you first need to identify its purpose or value to your open resources. Consider the following questions:

#Does your image serve a functional purpose? In other words, is it conveying non-text content to students? If so, you should:
#*Provide a text alternative that serves the equivalent purpose of the non-text material<ref> Web Content Accessibility Guidelines (WCAG) 2.0, Guideline 1.1 Text Alternatives. Accessed from: http://www.w3.org/TR/WCAG20/#text-equiv </ref>
#*Not use colour as the only visual means of conveying information <ref> Web Content Accessibility Guidelines (WCAG) 2.0, Guideline 1.4.1 Use of Color. Accessed from: http://www.w3.org/TR/WCAG20/#visual-audio-contrast</ref>
#Does your image serve more of a decorative purpose? In other words, is it primarily a design element that does not convey content? If so, you should:
#*Avoid unnecessary text descriptions

====Who Are You Doing This For?====

This work supports students who:

*Are blind or have low vision
*Have poor contrast vision
*Are colour blind and cannot differentiate between certain colours
*Are using a device with monochrome display
*Have a form of cognitive disability

===What do you need to do? ===
====Functional Images and Alternative Text Description====
Consider what your content page would look like if the images didn’t load. Now try writing alternative text for each image that would work as a replacement and provide the same service as the image.

As you work on developing your alternative text descriptions, keep the following recommendations and guidelines in mind:
*Remember that alternative text must convey the content and functionality of an image and is rarely a literal description of the image (e.g., “photo of cat”). Rather than providing what the image looks like, alternative text should convey what the content of the image is and what it does. <ref>webAccess (2012). Adapted from: Top Ten Tips for making your website accessible. Accessed from: http://webaccess.berkeley.edu/developer-information/top-ten-tips/#alt </ref>
*For relatively simple images (e.g., photographs, illustrations), try to keep your text descriptions short. You should aim to create a brief alternative (one or two short sentences) that is an accurate and concise equivalent to the information in the image.
*For more complex images (e.g., detailed charts, graphs, maps), you will need to provide more than a one- to two-sentence description to ensure all users will benefit from the content or context you intended to provide. In these cases, you should either provide the details in the text surrounding the image or write a longer text description that students can link to on a separate page. You should still include a short text description (one to two sentences) that tells students where they can find the details you have provided in the longer description.
*Leave out any unnecessary information. For example, you do not need to include information like “image of…” or “photo of…”; assistive technologies will automatically identify the material as an image, so including that detail in your alternative description is superfluous.

Avoid redundancy of content in your alternative description. Don’t repeat the same information that already appears in text adjacent to the image.

=====Example 1: [https://opentextbc.ca/introductiontosociology/chapter/chapter20-population-urbanization-and-the-environment/ (from Introduction to Sociology)] =====

[[File:Rio-de-janeiro-and-london.png|thumb|center|Figure 20.11. The slum city and the global city: the Favéla Morro do Prazères in Rio de Janeiro and the London financial district show two sides of global urbanization (Photos courtesy of dany13/Flickr and Peter Pearson/Flickr). |alt="Figure 20.11 includes two photos. The first photo shows crowded buildings located on the hillside. They are small and shabby. The second photo shows magnificent buildings located by water."]]

This photograph could be described in this way:

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"Figure 20.11 includes two photos. The first photo shows crowded buildings located on the hillside. They are small and shabby. The second photo shows magnificent buildings located by water."
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|}

=====Example 2 (Figure 18.1. Two-Atom, Double-Flask Diagram from [http://opentextbc.ca/introductorychemistry/chapter/entropy-and-the-second-law-of-thermodynamics/ Introductory Chemistry]): =====
[[File:Double flask gas atom diagram.png|center|thumb|(Figure 18.1. Two-Atom, Double-Flask Diagram from Introductory Chemistry) ]]
When the stopcock is opened between the flasks, the two atoms can distribute in four possible ways.

Figure 18.1 could be described as follows:
{| class="ambox ambox-notice"
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"Figure 18.1 shows a diagram with five pairs of circles. All of these circles are open. The left one opens on the right and the right one opens on the left. They are connected with lines at their open points. One pair is located on the left and between their two connecting lines is a black dot with a red vertical line going across. The other four pairs arranged in a column are located on the right and between the connecting lines of each pair is a a small circle with a red horizontal line going through. A right arrow labelled Open Stopcock links the pair sitting on the left to the four pairs on the right. Each of these five pairs has two dots (green and blue) arranged in different patterns. For the pair on the left, the two dots, sitting obliquely, appear only in left circle. The green dot is at the left upper part of the circle and following it the blue dot is close to the bottom right. The first pair on the right has the similar situation. The only difference is that the green dot is at the right upper part of the circle and the blue dot is close the middle left. The second pair has a green dot in the centre of the left circle and a blue dot in the centre of the right circle. The third pair has a blue dot sitting at the left upper part of the left circle and a green dot sitting close to bottom right of the right circle. For the last pair, the two dots appear in oblique direction only in the right circle. A green dot is at the right upper part of the circle and a blue dot is close to bottom left.
"
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====Using Colour====
Consider what your images would look like if they only displayed in black and white. Would any necessary context or content be lost if the colour was “turned off”? Images should not rely on colour to convey information; if the point you are making depends on colour to be understood, you may need to edit your image or formatting so that concepts presented are not lost to those who are colour blind or who require high contrast between colours.

[[File:Colour-depend-1.jpg|thumb|center|In this example of a bar chart, colour is the sole means of communicating the data.]]

'''Example 1 - not accessible''':
In this basic bar chart, colour is the only means by which information is conveyed.

[[File:Colour-depend-2.jpg|thumb|center|This view of the same bar chart displays how the chart might appear to a student who is colour blind, or whose device does not display colour. All of the meaningful data is lost.]]

'''Example 2 — not accessible: '''
For a student who is colour blind or who has poor contrast vision, all of the relevant information is lost in a colour chart.

'''Example 3 — accessible:'''
Students who are colour blind can distinguish between high-contrast shades. In this example, contextual labels have been added to each bar at the bottom of the chart. Note that the chart will still require an [https://opentextbc.ca/accessibilitytoolkit/chapter/imageschartsgraphsmaps/#AltText alternative text description].
[[File:Colour-depend-3.jpg|thumb|center|In this view of the bar chart, high-contrast colours have been used so that shading differences will still display in grey scale. Text labels have also been added so that the data is not just being communicated with colour.]]

====Decorative Images====
If your image does not add meaning and is included for decorative or design purposes only, the space for the alternative text description should still be included with your image, but it should be left empty or blank. Assistive technologies will detect the image, and by leaving the alternative text description blank, you will signal to the student that there isn’t any contextual content embedded. Including alternative text descriptions for decorative images “simply slows the process down with no benefit because the screen-reading software vocalizes the content of the [alternative text description], whether that alternative text adds value or not.”<ref> webAccess (2012). Adapted from: Top Ten Tips for making your website accessible. Accessed from: http://webaccess.berkeley.edu/developer-information/top-ten-tips/#alt </ref>

====Complex Visuals====
Complex images refer to substantial information that may be challenging to describe in a short phrase or sentence. Learners may not
understand the images without a long description. Making complex images accessible for everyone can be challenging. It involves understanding the purpose, the content itself, the audiences, and the technology to create and access alternative formats.

{| class="ambox ambox-notice"
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For strategies on how to make complex visuals such as graphs, tables, charts, and more accessible, see the following resource created by Supada Amornchat (CC BY-NC-SA): [https://www.pcc.edu/instructional-support/wp-content/uploads/sites/17/2017/11/complex-images.pdf Complex Images for All Learners: A Guide to Making Visual Content Accessible]</div>
|}

====How tos====
*[[Help:Adding_Media/Images_and_Pictures#Other_specific_options:|adding alt text on UBC Wiki]]
*[https://codex.wordpress.org/Inserting_Images_into_Posts_and_Pages#Step_4_.E2.80.93_Attachment_Details Adding image description in WordPress]
*[http://edx.readthedocs.io/projects/edx-developer-guide/en/latest/conventions/accessibility.html#make-images-accessible Edx Accessibility Guidelines - Make Images Accessible]
*[https://community.canvaslms.com/docs/DOC-2060#jive_content_id_Images Canvas General Accessibility Guidelines - Images]

==Best Practices 3: Tables==
In this section, we provide guidelines and recommendations for formatting tables.

===What Are Tables?===

'''Tables:''' In this context, we are referring to data tables, which are tables that include row and/or column header information to categorize content)

'''File types:''' .doc, .html, .pdf

===Are Your Tables Simple or Complex?===

A simple table includes a maximum of one header column and/or one header row. A complex table includes more than one header column and/or header row, and may include merged or split cells. <ref>AccessAbility: Accessibility and Usability at Penn State. Table Headers and Captions. Accessed from: http://accessibility.psu.edu/tables</ref>

We recommend you make every effort to keep data tables as simple in structure as possible. The more complex the design of a data table, the less accessible it will be for some students using screen-reading technology to access their textbook materials. Screen readers move left-to-right, top-to-bottom, one cell at a time, and because a screen reader does not repeat a cell, merging or splitting cells may affect the reading order of a table.

===Who Are You Doing This For?===

This work supports students who:
*Are blind or have low vision.
*Have a form of cognitive disability.

===What Do You Need To Do?===

In the same way that your [http://opentextbc.ca/accessibilitytoolkit/chapter/organizing-content/ content hierarchy needs true headings and structure], tables need a properly defined structure to be accessible. This means that you must add row and column headers to define the different sections of data. Screen readers read tables horizontally – cell by cell, row by row – and row and column headers help give the context of the data in each cell to students who are blind, have low vision, or have a cognitive disability.

===Creating Simple Tables===

A simple table includes:

#A table title or caption
#Maximum of one row of column headers and/or maximum of one column of row headers
#No merged or split cells
#Adequate cell padding for visual learners.

'''Example:'''

The table below is a simple table. Reviewed against the preceding requirements list, this table:

#Includes a '''title''' (Spring Blossoms)
#Has one row in which cells are tagged as '''column headers''' (Colour Family, Bulbs, Shrubs, Trees), and one column (beginning on the second row) in which the cells are tagged as '''row headers''' (Pink, Yellow)
#Contains no merged or split cells
#Has adequate '''cell padding''' to provide space buffering around the data in each cell. (Cell padding in this table is set at “3”).

{| border="1" cellspacing="0" cellpadding="3"
|-
!scope="col"| Colour Family
!scope="col"| Bulbs
!scope="col"| Shrubs
!scope="col"| Trees
|-
!scope="row"| Pink
| Tulips
| Flowering currant
|Ornamental plum
|-
!scope="row"| Yellow
| Daffodils
| Forsythia
|Star magnolia
|-
|}

For a student accessing the table through a screen reader, the first row of data will be presented along the lines of:
*Pink, Bulbs: Tulips
*Pink, Shrubs: Flowering currant
*Pink, Trees: Ornamental plum

===How tos===
*WordPress (UBC Blogs) - In order to add tables in UBC Blogs through visual editor, activate [http://support.cms.ubc.ca/cms-manual/adding-functionality/plugins/list-of-available-plugins/#MCE_Table_Buttons MCE Table Buttons]
*[[Help:Tables|Adding tables in UBC Wiki]]
*[https://community.canvaslms.com/docs/DOC-10346 Adding Tables in Canvas]

==Best Practices 4: Video and Multimedia==
Video and multimedia open resources can help to convey concepts and can bring information to life. In this section, we provide recommendations to guide your inclusion of accessible multimedia content.

===What Is Multimedia?===

'''Multimedia includes:''' videos, audio, animations, slideshows

'''File types:''' .mp3, .mp4, ppt., etc.

===Before You Begin===
'''What Type of Multimedia Are You Including?'''

Before you can determine what you need to do to make media materials accessible, you need to understand what is required for different types of multimedia. Consider the following questions:

1. Does your multimedia resource include audio narration or instruction? If so, you should: Provide a complete transcript of all speech content and relevant non-speech content in the resource.

2. Does your multimedia resource include audio that is synchronized with a video presentation? If so, you should: Provide captions of all speech content and relevant non-speech content in the resource.

3. Does your multimedia resource include contextual visuals (e.g., charts, graphs) that are not addressed in the spoken content? If so, you should: Provide audio descriptions of relevant visual materials in the resource.

===Who Are You Doing This For?===

This work supports students who:
*Are deaf or hard of hearing
*Are blind or have low vision
*Have a form of cognitive disability
*Are in a location where they cannot play or hear audio
*Are not native-English speakers and need written-word formats to support understanding

===What Do You Need To Do?===
====Transcripts====

Consider what your students would get out of your multimedia resource if they were not able to hear the audio portion, or if they had difficulty understanding your spoken word. A text transcript provides students with equivalent information to the audio content in a multimedia resource.<ref>Web Content Accessibility Guidelines (WCAG) 2.0, Guideline 1.2 Time-based Media: Provide alternatives for time-based media. Accessed from: http://www.w3.org/TR/WCAG20/#media-equiv</ref>

As you work on developing your text transcript, keep in mind the following recommendations about what to include:

#'''Speaker’s name'''
#'''All speech content:''' If there is speech that is not relevant, it is usually best to indicate that it has been excluded from the transcript. For example: “[A & B chatted while slides were loading].”'''
#'''Relevant descriptions about the speech: Descriptions that convey emotions, mood, etc. are usually provided in brackets. For example: “Don’t touch that! [shouted].”
#Descriptions of relevant non-speech audio: These are usually provided in brackets. For example: “[metal pipes crashing to concrete floor].” Background noise that isn’t relevant can be left out.
#'''Headings and sub-headings:''' Where they will make the transcript more usable or easy to navigate, headings and sub-headings can be helpful aids, especially when the transcript is long. When including these, put them in brackets to show that they were not part of the original audio. For example: [I

====Transcripts and third-party videos====

If you are not producing your own video resource but are planning to embed video materials from a third-party source (e.g., YouTube), be aware that not all third-party sources include transcripts. While services like YouTube technically support transcripts, not all contributors to YouTube include these. If you select a video resource that does not already have a transcript, you will need to produce one yourself.*

*''Copyright note:'' Producing your own transcript for a third-party video could infringe on copyright, depending on how the video has been licensed. Before you proceed with producing a transcript for media materials you did not create yourself, you should contact the copyright holder of that material to obtain permission to do so.

====Captions====

Timed text captions are essential to opening up a world of information for persons with hearing loss or literacy needs by making the readable equivalent of audio content available to them in a synchronized manner. Globally hearing loss affects about 10% of the population to some degree. It causes disability in 5% (360 to 538 million) and moderate to severe disability in 124 million people. Timed text captions also be helpful for learners whose native languages are languages other than the primary language of the media or who have cognitive conditions that benefit from visual.Captions are the text that is synchronized with the audio in a video presentation. Captions are important when people need to see what’s happening in the video and get the audio information in text at the same time.

The work you put into creating a text transcript for a video resource can be repurposed to provide the captions. Keep in mind the following recommendations about what to include in your captions:

#'''All speech content:''' If there is speech that is not relevant, it is usually best to indicate that it has been excluded from the captions. For example: “[A & B chatted while slides were loading].”
#'''Descriptions of relevant non-speech audio:''' These are usually provided in brackets. For example: “[metal pipes crashing to concrete floor]”; “[background music by XXX plays].” Background noise that isn’t relevant can be left out.

Text captions can be uploaded to YouTube and other platforms along with the video to create a timed text file in SubRip (SRT) format. Additional best practices for timed captions include:

*Each caption frame should not be on screen for less than three seconds.
*Each caption frame must not be on screen for less than two seconds.
*Each caption frame should not exceed more than 2 lines.
*Each caption frame must not exceed more than 3 lines.
*Each line should not exceed more than 32 characters
*All caption frames should be precisely time synched to the audio.
*When multiple speakers are present, it is sometimes helpful to identify who is speaking, especially when the video does not make this clear.
*Non-speech sounds like [MUSIC] or [LAUGHTER] should be added in square brackets.

====Downloadable Transcripts====
For both audio and video transcripts, consider including a text file that learners can download and review using tools such as word processing, screen reader, or literacy software. All learners can use transcripts of media-based learning materials for study and review.

====Audio Descriptions====

Consider what your students would get out of a multimedia resource if they were not able to see embedded visual materials critical for comprehension. Audio descriptions are helpful if visual content (e.g., a chart or a map) in a video or presentation provides important context that is not available through the audio alone.<ref>Web Content Accessibility Guidelines (WCAG) 2.0, Guideline 1.2.3 Audio Description or Media Alternative (Prerecorded). Accessed from: http://www.w3.org/TR/WCAG20/#media-equiv</ref> Actions that are only visible on screen without any audible equivalent are not accessible to learners who have visual impairments.

When describing visual elements in your multimedia resources, keep in mind the following recommendations and guidelines.

1. When contextual visual content on the screen is not described in the audio itself, you will need to provide an audio description that is an objective description of the visual element. ''Example:''

:::To help students fully grasp a concept that you are trying to convey in your video, you have included some contextual visual references (e.g., maps, charts, physical demonstrations of a process). However, you realize after making the video that the audio portion does not describe these visuals in enough detail for a student with visual impairments to be able to access all of the concepts you intended to convey.

::In this case, you would need to record an audio description of the visual material that provides enough detail to provide students like Jacob with the same content available to visual learners.

2. Whenever possible, avoid creating the need for audio descriptions in the first place by being proactive at the time of recording. If you pay attention to contextual visuals during the recording of the media piece, you may find opportunities to convey the visual content within the spoken material itself; you will not need to provide audio descriptions of the visual content after the fact. ''Example:''

::You are recording a video or presentation that includes a chart that tracks coal production in British Columbia, and as part of the presentation you want to focus attention on specific data in the chart. The narrator or presenter might point to sections on the chart and say:

:::“As you can see, metallurgical coal projection increased by 3 million tonnes over these two years.“

::In this case, audio descriptions would be necessary to provide the missing context to students with visual disabilities; these students cannot see the data on the chart that tells visual learners what the production figures are and for what dates. However, if the narrator or presenter instead says:

:::“This chart illustrates that metallurgical coal production in B.C. increased from 23 million tonnes in 1999 to 26 million tonnes in 2001,”

::the visual content is conveyed through the audio and no audio description will be necessary.

====Accessible Media Resources====

*[http://ncam.wgbh.org/invent_build/web_multimedia/accessible-digital-media-guide Accessible Digital Media Guidelines] provides detailed advice on creating online video and audio with accessibility in mind.
*[https://dcmp.org/public_content/ai/captioningkey/index.html Captioning Key by the National Association for the Deaf] provides excellent guidance on creating described and captioned media.

==Best Practices 5: Font size==

In this section, we review the two main concerns of font size on the web.

===What Is Font Size?===

'''Font size:''' The size of text visible on the screen.

===Who Are You Doing This For?===

This work supports students who:

*Are blind or have low vision
*Have a form of cognitive disability
*Are deaf or hard of hearing
*Have a physical disability

===What Do You Need To Do?===

There are two main concerns when working with font sizes.

# Ensuring that default font sizes are not too small.
# Ensuring that text can be expanded to 200% on websites<ref>http://sites.psu.edu/accessibility/fontsizehtml/ </ref>.

Keep in mind these recommendations and guidelines:

*'''12 point for body text''': For most documents, body text should be around 12 points. Small fonts may be illegible for some audiences.

*'''9 point for footnotes''': If a document contains footnotes or endnotes, the minimum size should be about 9 points

* '''200% zoom''': The Web Content Accessibility Guidelines (WCAG 2.0) recommend ensuring that text can be zoomed to 200%. As well, we recommend using liquid layouts that can accommodate 200% text. Liquid layout are layouts that are based on percentages of the current browser window's size. They flex with the size of the window, even if the current viewer changes their browser size as they're viewing the site. Liquid width layouts allow a very efficient use of the space provided by any given Web browser window or screen resolution.

==Best Practices 6: Colour Contrast==
In this section, we provide guidelines and recommendations about colour contrast in your open educational materials.

===What is Colour Contrast?===

'''Colour contrast includes''': hue, lightness and saturation of text, images, and background
'''File types''': .doc, .html, .pdf, .jpg, .gif

===What What Role Does Colour Play in the Delivery of Your Content?===

When documents or web pages do not provide enough contrast between foreground elements (e.g., text, images) and background elements (e.g., colour, watermark images), some students will have difficulty reading the content. Consider the following questions:

1. Have you presented text- or image-based content on a coloured or textured background? If so, you should:
*Confirm that there is sufficient contrast between your foreground content and the chosen background colour or texture.

2. Have you included links in your content? If so, you should:
*Confirm that the colour of your web links is distinct from both your background colour and the colour of the surrounding text.

3. Have you used colour to convey concepts or information? If so, you should:
*Confirm that you are not using colour alone to convey this information.

===Who Are You Doing This For?===

This work supports students who:

*Have low vision
*Have poor contrast vision
*Are colour blind and cannot differentiate between certain colours
*Are using a device with monochrome display

===What Do You Need To Do?===

====Contrast====

Students with low vision and/or a form of colour blindness may have difficulty reading text that does not contrast enough with the background colour you have selected. If the colour palette you have adopted is too subtle (e.g., white text on a pastel background; medium-grey text on a light-grey background), the contrast between your foreground and background is probably insufficient for some students.

Web Content Accessibility Guidelines (WCAG 2.0) require that “the visual presentation of text and images of text has a contrast ratio of at least 7:1.”<ref>Web Content Accessibility Guidelines (WCAG) 2.0, Guideline 1.4.6 Contrast (Enhanced). Accessed from: http://www.w3.org/TR/UNDERSTANDING-WCAG20/visual-audio-contrast7.html</ref> The image below presents four different foreground/background colour-contrast examples to illustrate insufficient and sufficient colour contrast ratios.
<br /><br />
[[File:Colour_Contrast.png|thumb|center|500px|Image displays four examples of foreground (text) colour against background colours; only the example on the far right presents combinations with sufficient colour contrast.]]
<br /><br />
{| class="ambox ambox-notice"
| class="mbox-text" | <div>
'''Not sure how to test your materials for colour contrast ratios?'''

There are many online and downloadable tools available to help you evaluate colour contrast ratios. Here are a few we have tried and like:
*'''WebAIM’s [http://webaim.org/resources/contrastchecker/ Color Contrast Checker]''': This web-based tool allows you to select or enter colour values to test and provides you with a “pass” or “fail” on your contrast ratio.
*'''ACART’s [http://www.contrastchecker.com/ Contrast Checker]''': This is a straightforward, web-based tool you can use to both check colour contrast and view your selections in grey scale. This tool also allows you to keep a history of the colour combinations you have tested.
*'''Giacomo Mazzocato’s [http://gmazzocato.altervista.org/colorwheel/wheel.php Accessibility Color Wheel]''': This web-based tool includes several options for testing your colour selections, including simulations of three types of colour blindness. You can also opt to test what your contrast ratio is when the foreground and background colour selections are inverted.
</div>
|}

====Weblink Colours====

Weblinks must be visually distinct from both the surrounding, non-linked text and background colour. If you do not underline your links (or provide some other non-colour cue), you must ensure that you provide both sufficient contrast between the link and background colours and between the link colour and that of the surrounding text.

Web Content Accessibility Guidelines (WCAG 2.0) require a:
*4.5:1 contrast between the link text color and the background
*3:1 contrast between the link text color and the surrounding non-link text color<ref>WebAIM (2015), WCAG 2.0 and Link Colors. Accessed from: http://webaim.org/blog/wcag-2-0-and-link-colors/ </ref>

====High-Contrast Mode====

Some students need to see light text on a dark background for it to be readable, while others require dark text on a light background. Students with low vision must be able to see content when it is displayed in high-contrast mode. This can be a subjective experience, based on individual student needs. We recommend that you try testing your text and image-based content as you go by using high-contrast mode on your own computer and making adjustments as needed.

All content items such as text, images, bullets, and table borders must be visible in both regular and high-contrast modes.

{| class="ambox ambox-notice"
| class="mbox-text" | <div>
'''Not sure how to test your content in high-contrast mode?
'''
To test the visibility of your content in this mode, turn on high contrast by simultaneously pressing the following keys on your (PC) keyboard:
::'''Left ALT + Left SHIFT + Print Screen.'''
To turn off high contrast mode, repeat this step.
</div>
|}

====Use of Colour====

You should not rely on colour as the sole means of conveying information and instruction. If the point you are making depends on colour to be understood, you will need to edit your materials so that concepts presented in the visuals are not lost to those who are colour blind or who require high contrast between colours.<ref>Web Content Accessibility Guidelines (WCAG) 2.0, Guideline 1.4.1 Use of Color. Accessed from: http://www.w3.org/TR/WCAG20/#visual-audio-contrast</ref>

==Best Practices 7: Formulas==

Math or Science formulas in open educational resources can be challenging to deliver in a way that is accessible to people with vision impairments. Non-scalable images of mathematical content cannot be sufficiently enlarged or navigated by low-vision users and are not accessible to blind users at all.

===What Are Formulas?===

'''Formulas include:''' Math equations or science formulas

'''File types:''' LaTex or MathType

===Before You Begin===
'''Who Are You Doing This For?'''

This work supports students who:

*Are blind or have low vision
*Have a form of cognitive disability,
*Have a physical disability

The following content is a derivative of Equations: Images vs. MathML from Accessibility and Usability at Penn State, http://accessibility.psu.edu/equations.

===What Do You Need to Do?===

There are several ways to handle equations from images with ALT tags to MathML. Having access to an equation editor such as MathType or MathMagic can streamline processing and converting equations considerably. These tools are similar to equation editors found in the ANGEL HTML Editor and Microsoft Office.

====MathML====

[http://accessibility.psu.edu/math/mathml/ Math ML] is a text-based XML markup language designed for math equations. Browsers that support MathML are able to translate the XML into a formatted equation. Since MathML with MathJax can be rendered in many systems, including HTML, Sites at Penn State, ANGEL and Drupal, it is considered the best choice for accessibility.

Information about [http://accessibility.psu.edu/math/mathml/ creating and viewing MathML] is available on that page.

MathML may vary from system to system and the content can change rapidly.

====Image with ALT tag====

A safe option to create an image of an equation (or export it from an equation editor) and then insert the image into a document with an ALT tag.

''Note:'' ALT tags can be written in Nemeth MathSpeak for students who have learned that system.

<math>
m = \frac{m_0}{\sqrt{1-\frac{v^2}{c^2}}}
</math>

View the ALT Tag

ALT= “m equals begin fraction m sub 0 over begin square root 1 minus begin fraction v sup 2 over c sup 2 end fraction end square root end fraction”

====LaTex====

LaTeX is a math markup language familiar to many in the science and math community, but unfortunately it is not currently supported by screen reader technology. However, it is fairly simple to convert LaTeX to an image or MathML in most equation editors.

For example, in the [http://wiki.ubc.ca UBC Wiki] you can insert a piece of LaTeX code using the <nowiki><math></nowiki> tag:
<pre>
<math>
m = \frac{m_0}{\sqrt{1-\frac{v^2}{c^2}}}
</math>
</pre>
The equation should appear fully formatted. Make minor adjustments as needed.

====Audio Files====
User testing with students have indicated that it would helpful to have an audio file of the formula or equation. The audio file would be placed beside the formula or equation and would allow the user to hear exactly how the formula or equation is interpreted.

====Audio Files====
User testing with students have indicated that it would helpful to have an audio file of the formula or equation. The audio file would be placed beside the formula or equation and would allow the user to hear exactly how the formula or equation is interpreted.
=====Example — equation with audio=====
[[File:MM0over.png|200px|center|math formular]]
[https://soundcloud.com/user-262382099-529580848/equation Listen to the audio file of this equation]:

===Additional Resources===

*In 2012, Portland Community College departments took a closer look at making math accessible to blind students. Read more about the math accessibility study on our website: http://www.pcc.edu/access.
*The [http://www.washington.edu/doit/are-there-guidelines-creating-accessible-math?465= DO-IT project from the University of Washington] provides guidance on creating accessible math content.
*The [http://www.washington.edu/doit/programs/accessstem/overview AccessSTEM] website provides guidance on creating accessible science, technology, engineering and math educational content.

==Best Practices 8: PDFs, Word Docs and Excel Files==
This section describes guidelines for creating accessible content in PDFs, Word documents, and Excel spreadsheets. Many of the same accessibility techniques and principles that apply to authoring in HTML also apply to creating document based OERs.

===PDFs===
Converting or publishing open resources as PDF documents can create accessibility barriers, particularly for learners with visual impairments. Accessibility issues are very common in PDF files that were scanned from printed sources or exported from a non-PDF document format. Scanned documents are simply images of text. To make scanned documents accessible, you must perform Optical Character Recognition (OCR) on these documents, and proofread the resulting text for accuracy before embedding it within the PDF file. You must also add semantic structure and other metadata (headings, links, alternative content for images, and so on) to the embedded text.

When you export documents to PDF from other formats, it is important to ensure that the source document contains all the required semantic structure and metadata before exporting. Unfortunately, some applications do not include this information when exporting and require the author to add or “tag” the document manually using PDF editing software. You should carefully consider whether exporting to PDF is necessary at all.

====Best Practices for Authoring Accessible PDF Documents====

*Explicitly define the language of the document so that screen readers know what language they should use to parse the document.
*Explicitly set the document title. When you export a file to PDF format, the document title usually defaults to the file name, not a human readable title.
*Verify that all images have alternative content defined or are marked as decorative only.
*Verify that the PDF file is “tagged”. Make sure the semantic structure from the source document has been correctly imported to the PDF file.
*Verify that a logical reading order is defined. This is especially important for documents that have atypical page layouts or structure.
*If your document includes tables, verify that table headers for rows and columns are properly defined.

====Accessible PDF Resources====
*[http://webaim.org/techniques/acrobat/ WebAIM's PDF Accessibility site] provides a detailed and illustrated guide on creating accessible PDFs.
*The [http://ncdae.org/resources/cheatsheets/ National Center of Disability and Access to Education has a collection of one-page “cheat sheets”] on accessible document authoring.
*Microsoft provides detailed [https://support.office.com/en-gb/article/Create-accessible-PDFs-064625e0-56ea-4e16-ad71-3aa33bb4b7ed?CorrelationId=9b8d28cf-aa96-4816-9536-b4aea195b51c&ui=en-US&rs=en-GB&ad=GB&ocmsassetID=HA102478227 guidance on generating accessible PDFs from Microsoft Office applications], including Word, Excel, and PowerPoint.
*Adobe provides [https://helpx.adobe.com/acrobat/using/create-verify-pdf-accessibility.html documentation on how to create and verify PDF accessibility].

===Word Documents===
Many of the same accessibility techniques and principles that apply to authoring one content also apply to creating Word documents. Keep formatting simple. Use headings, paragraphs, lists, images, and captions. Use tables for tabular data. Do not add unnecessary indents, rules, columns, blank lines, or typographic variation. Use standardized styles for formatting your text, such as Normal, Heading 1, and Heading 2, rather than manually formatting text using text styles and indents. Formatting text for its semantic meaning and not for its visual appearance allows users of assistive technology to consume and navigate documents effectively and efficiently.

Additional best practices include;

*Images must have descriptive text associated with them.
*Documents should be well structured.
*Hyperlinks should be meaningful and describe the destination.
*Tables should include properly defined column and row headers.
*Color combinations should be high contrast.
*Verify the accessibility of your document using [https://support.office.com/en-us/article/Use-the-Accessibility-Checker-on-your-Windows-desktop-to-find-accessibility-issues-a16f6de0-2f39-4a2b-8bd8-5ad801426c7f?ui=en-US&rs=en-US&ad=US Microsoft’s Accessibility Checker].

===Excel Spreadsheets===
Many of the same accessibility techniques and principles that apply to authoring data tables in HTML also apply to creating Excel spreadsheets. Microsoft has a [https://support.office.com/en-us/article/Make-your-Excel-spreadsheets-accessible-6CC05FC5-1314-48B5-8EB3-683E49B3E593?ui=en-US&rs=en-US&ad=US guide to creating accessible Excel workbooks].

*Images must have descriptive text associated with them.
*Column and row headings should be programmatically identified.
*Hyperlinks in spreadsheets should be meaningful and describe the destination.
*Use a unique and informative title for each worksheet tab.
*Do not use blank cells for formatting.
*Colour combinations should be high contrast.
*Verify the accessibility of your workbook using [https://support.office.com/en-us/article/Use-the-Accessibility-Checker-on-your-Windows-desktop-to-find-accessibility-issues-a16f6de0-2f39-4a2b-8bd8-5ad801426c7f?ui=en-US&rs=en-US&ad=US Microsoft’s Accessibility Checker].

===Additional Microsoft Accessibility Resources===
*[https://support.office.com/en-us/article/Make-your-Word-documents-accessible-D9BF3683-87AC-47EA-B91A-78DCACB3C66D?ui=en-US&rs=en-US&ad=US Microsoft guide to creating accessible Word documents.]
*[https://support.office.com/en-us/article/Use-the-Accessibility-Checker-on-your-Windows-desktop-to-find-accessibility-issues-a16f6de0-2f39-4a2b-8bd8-5ad801426c7f?ui=en-US&rs=en-US&ad=US Microsoft tool that allows you to check Word documents for accessibility issues.]
*Microsoft guide to creating [https://support.office.com/en-us/article/Make-your-PowerPoint-presentations-accessible-6F7772B2-2F33-4BD2-8CA7-DAE3B2B3EF25?ui=en-US&rs=en-US&ad=US accessible PowerPoint presentations].
*[https://support.office.com/en-us/article/Make-your-Excel-spreadsheets-accessible-6CC05FC5-1314-48B5-8EB3-683E49B3E593?ui=en-US&rs=en-US&ad=US Microsoft guide to creating accessible Excel workbooks].
*Microsoft tool that allows you to check [https://support.office.com/en-us/article/Use-the-Accessibility-Checker-on-your-Windows-desktop-to-find-accessibility-issues-a16f6de0-2f39-4a2b-8bd8-5ad801426c7f?ui=en-US&rs=en-US&ad=US Excel workbooks for accessibility issues].
*Microsoft guide to creating [http://webaim.org/techniques/powerpoint/ accessible PowerPoint presentations].
*[http://webaim.org/techniques/powerpoint/ WebAIM’s guide to PowerPoint accessibility].

==UBC Platform Specific Accessibility Guidelines==

===Canvas===
*[https://community.canvaslms.com/docs/DOC-2061 Accessibility within Canvs]
*[https://community.canvaslms.com/groups/accessibility Canvas Accessibility Group]
*[https://community.canvaslms.com/groups/accessibility/blog/2018/05/08/how-to-fix-and-prevent-accessibility-issues-in-your-canvas-course How to Fix and Prevent Accessibility Issues in Your Canvas ]

===Edx===
*[http://edx.readthedocs.io/projects/edx-partner-course-staff/en/latest/accessibility/index.html Accessibility Best Practices Guidance for Content Providers]

===WordPress===
*[https://en.support.wordpress.com/accessibility/ Accessibility in WordPress]
*[http://khan.github.io/tota11y/ Tota11y] - a tool to check if your site is accessible or not. There is also a [https://chrome.google.com/webstore/detail/tota11y-plugin-from-khan/oedofneiplgibimfkccchnimiadcmhpe?hl=en chrome extension] available

===MediaWiki/UBC Wiki===
*[https://en.wikipedia.org/wiki/Wikipedia:Manual_of_Style/Accessibility Manual of Style- Accessibility]

===UBC Centre for Accessibility===
*[https://students.ubc.ca/about-student-services/centre-for-accessibility UBC Centre for Accessibility] (CfA) provides leadership on issues of accessibility for people with disabilities at UBC Vancouver, working in partnership with faculties to foster inclusive learning, living and working environments for students, faculty and staff. The Centre for Accessibility provides support and programming initiatives designed to remove barriers for students with disabilities and facilitates disability related accommodations for members of the UBC Vancouver community.

===UBC Centre for Workplace Accessibility===
*[https://hr.ubc.ca/health-and-wellbeing/workplace-accessibility/centre-workplace-accessibility The Centre for Workplace Accessibility] (CWA) is a hub for resources, tools, and programs that help remove barriers for faculty and staff with disabilities or ongoing medical conditions. It offers support to improve workplace accessibility using a trauma-informed, person-centred approach. Its initiatives also include projects and workshops designed to build disability inclusion literacy throughout the UBC community.

==Appendix: Checklist for OER Accessibility==

===Organizing Content===

☐ Contents is organized under headings and subheadings

☐ Headings and subheadings are used sequentially (e.g. Heading 1, heading 2, etc)

===Images===

☐ Images that convey information include Alternative Text (alt-text) descriptions of the image’s content or function.

☐ Graphs, Charts, and Maps also include contextual or supporting details in the text surrounding the image.

☐ Images do not rely on colour to convey information.

☐ Images that are purely decorative contain empty alternative text descriptions. (Descriptive text is unnecessary if the image doesn’t convey contextual content information).

===Tables===

☐ Tables include row and column headers.

☐ Table includes title or caption.

☐ Table does not have merged or split cells.

☐ Table has adequate cell padding.

===Weblinks===

☐ The weblink is meaningful in context, does not use generic text such as “click here” or “read more”.

☐ Weblinks do not open new windows or tabs.

☐ If weblink must open in a new window, a textual reference is included in the link information.

===Multimedia===

☐ A transcript has been made available for a multimedia resource that includes audio narration or instruction. Transcript includes:
:Speaker’s name
:All speech content
:Relevant descriptions of speech
:Descriptions of relevant non-speech audio

===Headings and subheadings===

☐ Captions of all speech content and relevant non-speech content are included in the multimedia resource that includes audio synchronized with a video presentation.

☐ Audio descriptions of contextual visuals (graphs, charts, etc) are included in the multimedia resource.

===Formulas===

☐ Formulas have been created using MathML.

☐ Formulas are images with alternative text descriptions, if MathML is not an option.

===Font Size===

☐ Font size is 12 point or higher for body text.

☐ Font size is 9 point for footnotes or end notes.

☐ Font size can be zoomed to 200%.

==Appendix: Accessibility 2-Page Handout==

[[File:Accessibility Handout Thumbnail.png|thumb|centre|400px|link=http://wiki.ubc.ca/images/5/5b/UBC_Accessibility_Handout.pdf|Click to Download PDF ]]

==Appendix: Additional OER Accessibility Resources==
*[https://accessibility.ctlt.ubc.ca/ UBC Accessibility 101] - A UBC resource that focuses on improving access to digital content for students with vision or hearing impairments and similar learning barriers.
*[https://blogs.ubc.ca/accessibleactivelearning/ Accessible Active Learning] - A resource designed for Instructional Skills Workshop (ISW) and TA Training facilitators at UBCV. It is meant as a resource to help them design activities with accessibility in-mind, to help make activities accessible to more students and participants.
*[https://equity.ubc.ca/resources/accessible-and-inclusive-event-planning/ UBC Accessible Event Planning Guide] - provides practical tools to help event organizers create inclusive and welcoming experiences for everyone, including particularly people with disabilities.
*[https://opentextbc.ca/accessibilitytoolkit/ BC Open Textbook Accessibility Toolkit] - (also in [https://opentextbc.ca/troussedoutildaccessibilite/ French]). See also the [https://cdn.collection.bccampus.ca/assets/B_Ccampus_Accessibility_Criteria_6b42ab8ce8.pdf BCcampus OER Accessibility Criteria checklist] and the [https://opentextbc.ca/accessibilitytoolkit/back-matter/inclusive-design-webinar-series/ BCcampus Inclusive Design Webinar Series].
*[https://students.ubc.ca/about-student-services/centre-for-accessibility UBC Centre for Accessibility] provides support and programming initiatives designed to remove barriers for students with disabilities and facilitates disability related accommodations for members of the UBC Vancouver community.
*[https://pressbooks.bccampus.ca/a11yondemand/ Digital Accessibility On-demand] - a resource by Luke McKnight designed as a just-in-time resource to guide creators to the step-by-step instructions they need to maximize accessibility and increase inclusivity.
*[https://pressbooks.bccampus.ca/accessibilityhandbook/ Accessibility Handbook for Teaching and Learning] - a guidebook by Luke McKnight and Briana Fraser to introduce concepts of digital accessibility and to provide detailed instructions to use the accessibility features of software such as Word and PowerPoint.
*[https://hr.ubc.ca/health-and-wellbeing/workplace-accessibility/centre-workplace-accessibility The Centre for Workplace Accessibility (CWA)] is a hub for resources, tools, and programs that help remove barriers for faculty and staff with disabilities or ongoing medical conditions. It offers support to improve workplace accessibility using a trauma-informed, person-centred approach.
*Inclusive Design Research Centre’s [http://floeproject.org/ Flexible Learning for Open Education]
*[http://www.udlcenter.org/implementation/postsecondary The National Center on Universal Design for Learning] provides a helpful overview on Universal Design for Learning.
*Portland Community College’s [http://www.pcc.edu/resources/instructional-support/access/ Accessibility for Online Course Content: A Guide for Instructors]
*[https://inclusive.microsoft.design/ Inclusive Design at Microsoft]
*[https://wiki.ubc.ca/images/0/02/Complex_Images_for_All_Learners.pdf Accessibility for Complex Images]: resource for making charts, graphs, figures, and other complex images accessible.
*[https://www.jisc.ac.uk/guides/supporting-an-inclusive-learner-experience-in-higher-education JISC guide to supporting an inclusive learner experience in higher education]
*The [https://bccampus.ca/wp-content/uploads/2023/04/OER-Equity-Rubric-1.pdf BCcampus OER Equity Rubric] is designed to help identify opportunities to adapt and improve the equity of open resources.

==References==
<references/>

==About this Toolkit==
[[File:CC-SA_button.png|left|CC by|100px]] The OER Accessibility Toolkit is licensed under a [https://creativecommons.org/licenses/by-sa/4.0/ Creative Commons Attribution-ShareAlike 4.0 International License], except where otherwise noted. Source files for this resource may be found on the [http://wiki.ubc.ca/Documentation:Open_UBC/Guide/OER_Accessibility_Toolkit UBC Wiki].

Content for this toolkit was adapted from the [https://opentextbc.ca/accessibilitytoolkit/ BC Open Textbook Accessibility Toolkit] by Amanda Coolidge, Sue Doner, and Tara Robertson. The [https://opentextbc.ca/accessibilitytoolkit/ BC Open Textbook Accessibility Toolkit] is licensed under a [https://creativecommons.org/licenses/by/4.0/ Creative Commons Attribution 4.0 International License], except where otherwise noted. Additional material has been adapted from the [http://edx.readthedocs.io/projects/edx-partner-course-staff/en/latest/accessibility/index.html edX Accessibility Best Practices for Developing Course Content] guidelines under a [https://creativecommons.org/licenses/by-sa/4.0/ Creative Commons Attribution Share Alike 4.0 International License].

[[Category:Open UBC]][[Category:Accessibility]] [[Category:Accessibility Toolkits]] [[Category:OER]] [[Category:Open Education]] [[Category:Universal Design]]

Documentation:Open UBC/Guide/OER Accessibility Toolkit

2026-05-29T16:40:43Z

WillEngle: /* Appendix: Additional OER Accessibility Resources */

==Accessibility for Open Education==

{{#widget:YouTube|id=KcvYG-rkO-Y|height=315|width=420}}

The focus of many open education projects is to provide access to education. But what does access mean? If the materials are not accessible for each and every student, do they fulfill the mandate to deliver fully open education? The open education movement has helped people in different parts of the world access content that they would otherwise not be able to view or interact with. Open education resources reduce costs for students and allow for greater flexibility for instructors. Accessibility can help push the movement even further forward.

The goal of the ''OER Accessibility Toolkit'' is to provide the needed resources to each content creator, instructor, instructional designer, educational technologist, librarian, administrator, and teaching assistant to create a truly open and accessible educational resource — one that is accessible for all students.

As you work through the content of the ''OER Accessibility Toolkit'', you will find that the suggestions provided are intended for the non-technical user. If you are looking for more technical descriptions of how to make your work accessible, we suggest you review the [https://www.w3.org/TR/WCAG20/ WCAG (Web Content Accessibility Guidelines)].

==Key Concepts: Universal Design and Personas==

Universal Design is the process of creating products (devices, environments, systems, and processes) that are usable by people with the widest possible range of abilities, operating within the widest possible range of situations (environments, conditions, and circumstances). Universal Design emerged from the slightly earlier concept of being barrier-free, the broader accessibility movement, and adaptive and assistive technology. It also seeks to blend aesthetics into these core considerations.

Let’s review some common definitions of Universal Design.

===Definition 1===

Universal Design or Universal Instructional Design (UID)
{| class="ambox ambox-notice"
| class="mbox-text" | <div>
"is an approach to teaching that consists of the proactive design and use of inclusive instructional and evaluation strategies. This approach provides academic access to a broad range of learners, including students with disabilities, while:
*maintaining academic standards […]
*reducing the need to having to retrofit after a course is already underway<ref>FAIR ([http://web2.uvcs.uvic.ca/fair/ Facilitating Accessible Instruction & Resources]). University of Victoria </ref>"

</div>
|}

===Definition 2===
{| class="ambox ambox-notice"
| class="mbox-text" | <div>
Universal Instructional Design (UID)

is an approach to designing course instruction, materials and content to benefit people of all learning styles without adaptation or retrofitting. UID provides equal access to learning, not simply equal access to information. UID allows the student to control the method of accessing information while the instructor monitors the learning process and initiates any beneficial methods. …It should be noted that UID does not remove academic challenges; it removes barriers to access.<ref>Universal Design for Learning. Ohio State University</ref>
</div>
|}

===Why Universal Design?===

For our purposes, we frame the practice of using Universal Design in a holistic and manageable way, and begin by addressing the barriers that are easy to anticipate and proactively re-mediate. This toolkit, therefore, will provide guidance to you if the answers to any of the following questions is “yes”:

*Do I have visual materials that present core concepts that not all students may be able to see or understand?
*Do I have multimedia (audio, video) materials that present core concepts that not all students may be able to be hear, see, or access?
*Do I have documents that present core concepts in a format that not all students may be able to access?

For the purpose of the ''OER Accessibility Toolkit'', we focus on an adjunct to Universal Design, that being Universal Design for Learning (UDL), which is a set of principles for curriculum development that gives all individuals equal opportunities to learn. UDL provides a blueprint for creating instructional goals, methods, materials, and assessments that work for everyone. Rather than a single, one-size-fits-all solution, it offers a flexible approach that can be customized and adjusted for individual needs.<ref>http://www.udlcenter.org/aboutudl/whatisudl ↵</ref>

The principles of Universal Design for Learning can be summarized by the following points.

*Present information and content in various ways.
*Provide more than one way for learners to express what they know.
*Stimulate interest and motivation for learning.

OER creators can apply these principles in course design by following several guidelines:

*Design resources and activities that can be accessed by learners in a variety of ways. For example, if there is a text component, provide the ability to enlarge the font size or change the text color. For images and diagrams, always provide an equivalent text description. For video, include text captions.
*Provide multiple ways for learners to engage with information and demonstrate their knowledge. This is particularly important to keep in mind as you design activities and assessments.
*Identify activities that require specific sensory or physical capability and for which it might be difficult or impossible to accommodate the accessibility needs of learners. For example, an activity that requires learners to identify objects by color might cause difficulties for learners with visual impairments. In these cases, consider whether there is a pedagogical justification for the activity being designed in that way. If there is a justification, communicate these requirements to prospective learners in the course description and establish a plan for responding to learners who encounter barriers.

===Persona===
{{#widget:YouTube|id=_YpNrOkW0Mw|height=315|width=420}}

This video shows a demonstration of students using accessibility softwares (ZoomText, JAWs and TextDragon) .

Designers use personas to represent the different types of people who may be accessing a website or product. Using a persona can be a helpful when you are designing an accessible open resources. Take a look at the personals from [http://uxmag.com/articles/book-excerpt-a-web-for-everyone Book Excerpt: A Web for Everyone] to get an idea on how your audiences navigate your course/resources.

==Best Practices 1: Online Content Organization and Weblinks==

HTML is a good format for creating accessible content. It is well supported and adaptable across browsers and devices. Also, the information in HTML markup helps assistive technologies, such as screen reader software, to provide information and functionality to people with vision impairments.

Organizing your html and online content so it has a logical flow just makes sense. Using headings, and subheadings to organize content allows students to clearly see how the main concepts are related. Headings are one of the main ways that students using a screen reader navigate through a webpage or online resource.

A weblink is a link from a file or document to another location (such as a website address) or file, typically activated by clicking on a highlighted word or image on the screen. Generally weblinks are included within content to provide the user with additional information that is available at a another location.

'''File types''': .html, .pdf, .doc, .xls

===Who Are You Doing This For?===

Everyone benefits from having content that’s clearly organized. In addition, well-organized content and descriptive weblinks support students who:

*Have a learning disability (For a example, a student with ADHD) - Having an organized content allow them to easily go back and find the important points.
*Are blind or have low vision - It gives them more control in navigating through different chapters.
*Have a form of cognitive disability
*Have a physical disability,
*Are deaf or hard of hearing

===What Do You Need to Do?===

====Content Organization====
Headings help to identify the hierarchical structure of a document (e.g., sections, sub-sections). Headings provide a visual cue that helps sighted readers quickly navigate through sections of a document, skimming through content until they find a section they are looking for. Similarly, headings create logical divisions in the content and allow a non-sighted user to navigate a page or document easily using a screen reader.

When it comes to using visual references to indicate the hierarchy and structure of a document, you may be accustomed to just changing the font, enlarging the type size, making it bold or underlined or italicized, creating the impression of a heading. This approach presents problems when creating material with accessibility in mind because screen readers won’t identify the text as a heading. Instead, a screen reader will just “read” through the text of a heading as if it were part of another paragraph of content, missing your intended cues about structure and organization.

[[File:Headings in wordpress.png|thumb|center|Headings in WordPress(UBC Blogs)]]
Keep the following guidelines in mind when you create online content.

*Use HTML tags to describe the meaning of content, rather than changing its appearance. For example, you should tag a section title with the appropriate heading level (such as <nowiki><h3></nowiki>) rather than making the text appear like a heading by applying visual elements such as bold text and a larger font size. Format list items into a list rather than using images of bullets or indents. Using HTML to describe your content’s meaning is valuable for learners who use screen readers, which, for example, can read through all headings of a specific level or announce the number of items in a list.
*Use HTML heading levels in sequential order to represent the structure of a document. Well-structured headings help learners and screen reader users to navigate a page and efficiently find what they are looking for.
*Use HTML list elements to group related items and make content easier to skim and read.

====Content Organization How tos====
*[https://en.support.wordpress.com/visual-editor/#styles How to create headings in WordPress(UBC Blogs)]
*[[Help:Formatting#Headers_.26_Lines|How to create headings in UBC Wiki]]
*[https://ccs.instructure.com/courses/1181412/pages/accessibility-basics-on-canvas-pages-headers-colors-and-tables?module_item_id=21897445 How to create headings in Canvas]
*[http://edx.readthedocs.io/projects/edx-partner-course-staff/en/latest/course_components/create_html_component.html#the-visual-editor How to create headings in EdX]

====Link Descriptions====

Ensure that all web pages and weblinks have titles that describe a topic or purpose. The purpose of the link can be determined by the text alone. That is, you don’t need to include additional information justifying the use of the link. You want the link to be meaningful in context. For example, do not use generic text such as “click here” or “read more” unless the purpose of the link can be determined by meaning in the surrounding content.<ref>https://www.webaccessibility.com/best_practices.php?best_practice_id=1301</ref>

Consider the following examples.

'''Example 1''' — unclear:

Click [http://open.ubc.ca here] for information on open at UBC.

'''Example 2''' — clear and accessible:

Information on [http://open.ubc.ca UBC Open education projects and resources] is available online.

====New Tabs/Windows====

In general, it is better if weblinks do not open new windows and tabs since they can be disorienting for people, especially people who have difficulty perceiving visual content.<ref>http://www.w3.org/TR/2014/NOTE-WCAG20-TECHS-20140916/G200</ref>. However, if a link must open in a new window, it is best practice to include a textual reference. For example, IInformation on [http://open.ubc.ca UBC Open education projects and resources (New Window)] is available online.<ref>http://accessibility.psu.edu/linkshtml</ref>

==Best Practices 2: Images==
In this section, we provide recommendations to guide your inclusion of accessible, image-based content.

===What Are Images?===

'''Images include''': photographs, diagrams, pictures, charts, graphs, maps

'''File types''': .gif, .jpg, .png

===Before You Begin===

====Why Are You Including the Images You Have Selected?====

Before you can determine what you need to do to make an image accessible, you first need to identify its purpose or value to your open resources. Consider the following questions:

#Does your image serve a functional purpose? In other words, is it conveying non-text content to students? If so, you should:
#*Provide a text alternative that serves the equivalent purpose of the non-text material<ref> Web Content Accessibility Guidelines (WCAG) 2.0, Guideline 1.1 Text Alternatives. Accessed from: http://www.w3.org/TR/WCAG20/#text-equiv </ref>
#*Not use colour as the only visual means of conveying information <ref> Web Content Accessibility Guidelines (WCAG) 2.0, Guideline 1.4.1 Use of Color. Accessed from: http://www.w3.org/TR/WCAG20/#visual-audio-contrast</ref>
#Does your image serve more of a decorative purpose? In other words, is it primarily a design element that does not convey content? If so, you should:
#*Avoid unnecessary text descriptions

====Who Are You Doing This For?====

This work supports students who:

*Are blind or have low vision
*Have poor contrast vision
*Are colour blind and cannot differentiate between certain colours
*Are using a device with monochrome display
*Have a form of cognitive disability

===What do you need to do? ===
====Functional Images and Alternative Text Description====
Consider what your content page would look like if the images didn’t load. Now try writing alternative text for each image that would work as a replacement and provide the same service as the image.

As you work on developing your alternative text descriptions, keep the following recommendations and guidelines in mind:
*Remember that alternative text must convey the content and functionality of an image and is rarely a literal description of the image (e.g., “photo of cat”). Rather than providing what the image looks like, alternative text should convey what the content of the image is and what it does. <ref>webAccess (2012). Adapted from: Top Ten Tips for making your website accessible. Accessed from: http://webaccess.berkeley.edu/developer-information/top-ten-tips/#alt </ref>
*For relatively simple images (e.g., photographs, illustrations), try to keep your text descriptions short. You should aim to create a brief alternative (one or two short sentences) that is an accurate and concise equivalent to the information in the image.
*For more complex images (e.g., detailed charts, graphs, maps), you will need to provide more than a one- to two-sentence description to ensure all users will benefit from the content or context you intended to provide. In these cases, you should either provide the details in the text surrounding the image or write a longer text description that students can link to on a separate page. You should still include a short text description (one to two sentences) that tells students where they can find the details you have provided in the longer description.
*Leave out any unnecessary information. For example, you do not need to include information like “image of…” or “photo of…”; assistive technologies will automatically identify the material as an image, so including that detail in your alternative description is superfluous.

Avoid redundancy of content in your alternative description. Don’t repeat the same information that already appears in text adjacent to the image.

=====Example 1: [https://opentextbc.ca/introductiontosociology/chapter/chapter20-population-urbanization-and-the-environment/ (from Introduction to Sociology)] =====

[[File:Rio-de-janeiro-and-london.png|thumb|center|Figure 20.11. The slum city and the global city: the Favéla Morro do Prazères in Rio de Janeiro and the London financial district show two sides of global urbanization (Photos courtesy of dany13/Flickr and Peter Pearson/Flickr). |alt="Figure 20.11 includes two photos. The first photo shows crowded buildings located on the hillside. They are small and shabby. The second photo shows magnificent buildings located by water."]]

This photograph could be described in this way:

{| class="ambox ambox-notice"
| class="mbox-text" | <div>
"Figure 20.11 includes two photos. The first photo shows crowded buildings located on the hillside. They are small and shabby. The second photo shows magnificent buildings located by water."
</div>
|}

=====Example 2 (Figure 18.1. Two-Atom, Double-Flask Diagram from [http://opentextbc.ca/introductorychemistry/chapter/entropy-and-the-second-law-of-thermodynamics/ Introductory Chemistry]): =====
[[File:Double flask gas atom diagram.png|center|thumb|(Figure 18.1. Two-Atom, Double-Flask Diagram from Introductory Chemistry) ]]
When the stopcock is opened between the flasks, the two atoms can distribute in four possible ways.

Figure 18.1 could be described as follows:
{| class="ambox ambox-notice"
| class="mbox-text" | <div>
"Figure 18.1 shows a diagram with five pairs of circles. All of these circles are open. The left one opens on the right and the right one opens on the left. They are connected with lines at their open points. One pair is located on the left and between their two connecting lines is a black dot with a red vertical line going across. The other four pairs arranged in a column are located on the right and between the connecting lines of each pair is a a small circle with a red horizontal line going through. A right arrow labelled Open Stopcock links the pair sitting on the left to the four pairs on the right. Each of these five pairs has two dots (green and blue) arranged in different patterns. For the pair on the left, the two dots, sitting obliquely, appear only in left circle. The green dot is at the left upper part of the circle and following it the blue dot is close to the bottom right. The first pair on the right has the similar situation. The only difference is that the green dot is at the right upper part of the circle and the blue dot is close the middle left. The second pair has a green dot in the centre of the left circle and a blue dot in the centre of the right circle. The third pair has a blue dot sitting at the left upper part of the left circle and a green dot sitting close to bottom right of the right circle. For the last pair, the two dots appear in oblique direction only in the right circle. A green dot is at the right upper part of the circle and a blue dot is close to bottom left.
"
</div>
|}

====Using Colour====
Consider what your images would look like if they only displayed in black and white. Would any necessary context or content be lost if the colour was “turned off”? Images should not rely on colour to convey information; if the point you are making depends on colour to be understood, you may need to edit your image or formatting so that concepts presented are not lost to those who are colour blind or who require high contrast between colours.

[[File:Colour-depend-1.jpg|thumb|center|In this example of a bar chart, colour is the sole means of communicating the data.]]

'''Example 1 - not accessible''':
In this basic bar chart, colour is the only means by which information is conveyed.

[[File:Colour-depend-2.jpg|thumb|center|This view of the same bar chart displays how the chart might appear to a student who is colour blind, or whose device does not display colour. All of the meaningful data is lost.]]

'''Example 2 — not accessible: '''
For a student who is colour blind or who has poor contrast vision, all of the relevant information is lost in a colour chart.

'''Example 3 — accessible:'''
Students who are colour blind can distinguish between high-contrast shades. In this example, contextual labels have been added to each bar at the bottom of the chart. Note that the chart will still require an [https://opentextbc.ca/accessibilitytoolkit/chapter/imageschartsgraphsmaps/#AltText alternative text description].
[[File:Colour-depend-3.jpg|thumb|center|In this view of the bar chart, high-contrast colours have been used so that shading differences will still display in grey scale. Text labels have also been added so that the data is not just being communicated with colour.]]

====Decorative Images====
If your image does not add meaning and is included for decorative or design purposes only, the space for the alternative text description should still be included with your image, but it should be left empty or blank. Assistive technologies will detect the image, and by leaving the alternative text description blank, you will signal to the student that there isn’t any contextual content embedded. Including alternative text descriptions for decorative images “simply slows the process down with no benefit because the screen-reading software vocalizes the content of the [alternative text description], whether that alternative text adds value or not.”<ref> webAccess (2012). Adapted from: Top Ten Tips for making your website accessible. Accessed from: http://webaccess.berkeley.edu/developer-information/top-ten-tips/#alt </ref>

====Complex Visuals====
Complex images refer to substantial information that may be challenging to describe in a short phrase or sentence. Learners may not
understand the images without a long description. Making complex images accessible for everyone can be challenging. It involves understanding the purpose, the content itself, the audiences, and the technology to create and access alternative formats.

{| class="ambox ambox-notice"
| class="mbox-text" | <div>
For strategies on how to make complex visuals such as graphs, tables, charts, and more accessible, see the following resource created by Supada Amornchat (CC BY-NC-SA): [https://www.pcc.edu/instructional-support/wp-content/uploads/sites/17/2017/11/complex-images.pdf Complex Images for All Learners: A Guide to Making Visual Content Accessible]</div>
|}

====How tos====
*[[Help:Adding_Media/Images_and_Pictures#Other_specific_options:|adding alt text on UBC Wiki]]
*[https://codex.wordpress.org/Inserting_Images_into_Posts_and_Pages#Step_4_.E2.80.93_Attachment_Details Adding image description in WordPress]
*[http://edx.readthedocs.io/projects/edx-developer-guide/en/latest/conventions/accessibility.html#make-images-accessible Edx Accessibility Guidelines - Make Images Accessible]
*[https://community.canvaslms.com/docs/DOC-2060#jive_content_id_Images Canvas General Accessibility Guidelines - Images]

==Best Practices 3: Tables==
In this section, we provide guidelines and recommendations for formatting tables.

===What Are Tables?===

'''Tables:''' In this context, we are referring to data tables, which are tables that include row and/or column header information to categorize content)

'''File types:''' .doc, .html, .pdf

===Are Your Tables Simple or Complex?===

A simple table includes a maximum of one header column and/or one header row. A complex table includes more than one header column and/or header row, and may include merged or split cells. <ref>AccessAbility: Accessibility and Usability at Penn State. Table Headers and Captions. Accessed from: http://accessibility.psu.edu/tables</ref>

We recommend you make every effort to keep data tables as simple in structure as possible. The more complex the design of a data table, the less accessible it will be for some students using screen-reading technology to access their textbook materials. Screen readers move left-to-right, top-to-bottom, one cell at a time, and because a screen reader does not repeat a cell, merging or splitting cells may affect the reading order of a table.

===Who Are You Doing This For?===

This work supports students who:
*Are blind or have low vision.
*Have a form of cognitive disability.

===What Do You Need To Do?===

In the same way that your [http://opentextbc.ca/accessibilitytoolkit/chapter/organizing-content/ content hierarchy needs true headings and structure], tables need a properly defined structure to be accessible. This means that you must add row and column headers to define the different sections of data. Screen readers read tables horizontally – cell by cell, row by row – and row and column headers help give the context of the data in each cell to students who are blind, have low vision, or have a cognitive disability.

===Creating Simple Tables===

A simple table includes:

#A table title or caption
#Maximum of one row of column headers and/or maximum of one column of row headers
#No merged or split cells
#Adequate cell padding for visual learners.

'''Example:'''

The table below is a simple table. Reviewed against the preceding requirements list, this table:

#Includes a '''title''' (Spring Blossoms)
#Has one row in which cells are tagged as '''column headers''' (Colour Family, Bulbs, Shrubs, Trees), and one column (beginning on the second row) in which the cells are tagged as '''row headers''' (Pink, Yellow)
#Contains no merged or split cells
#Has adequate '''cell padding''' to provide space buffering around the data in each cell. (Cell padding in this table is set at “3”).

{| border="1" cellspacing="0" cellpadding="3"
|-
!scope="col"| Colour Family
!scope="col"| Bulbs
!scope="col"| Shrubs
!scope="col"| Trees
|-
!scope="row"| Pink
| Tulips
| Flowering currant
|Ornamental plum
|-
!scope="row"| Yellow
| Daffodils
| Forsythia
|Star magnolia
|-
|}

For a student accessing the table through a screen reader, the first row of data will be presented along the lines of:
*Pink, Bulbs: Tulips
*Pink, Shrubs: Flowering currant
*Pink, Trees: Ornamental plum

===How tos===
*WordPress (UBC Blogs) - In order to add tables in UBC Blogs through visual editor, activate [http://support.cms.ubc.ca/cms-manual/adding-functionality/plugins/list-of-available-plugins/#MCE_Table_Buttons MCE Table Buttons]
*[[Help:Tables|Adding tables in UBC Wiki]]
*[https://community.canvaslms.com/docs/DOC-10346 Adding Tables in Canvas]

==Best Practices 4: Video and Multimedia==
Video and multimedia open resources can help to convey concepts and can bring information to life. In this section, we provide recommendations to guide your inclusion of accessible multimedia content.

===What Is Multimedia?===

'''Multimedia includes:''' videos, audio, animations, slideshows

'''File types:''' .mp3, .mp4, ppt., etc.

===Before You Begin===
'''What Type of Multimedia Are You Including?'''

Before you can determine what you need to do to make media materials accessible, you need to understand what is required for different types of multimedia. Consider the following questions:

1. Does your multimedia resource include audio narration or instruction? If so, you should: Provide a complete transcript of all speech content and relevant non-speech content in the resource.

2. Does your multimedia resource include audio that is synchronized with a video presentation? If so, you should: Provide captions of all speech content and relevant non-speech content in the resource.

3. Does your multimedia resource include contextual visuals (e.g., charts, graphs) that are not addressed in the spoken content? If so, you should: Provide audio descriptions of relevant visual materials in the resource.

===Who Are You Doing This For?===

This work supports students who:
*Are deaf or hard of hearing
*Are blind or have low vision
*Have a form of cognitive disability
*Are in a location where they cannot play or hear audio
*Are not native-English speakers and need written-word formats to support understanding

===What Do You Need To Do?===
====Transcripts====

Consider what your students would get out of your multimedia resource if they were not able to hear the audio portion, or if they had difficulty understanding your spoken word. A text transcript provides students with equivalent information to the audio content in a multimedia resource.<ref>Web Content Accessibility Guidelines (WCAG) 2.0, Guideline 1.2 Time-based Media: Provide alternatives for time-based media. Accessed from: http://www.w3.org/TR/WCAG20/#media-equiv</ref>

As you work on developing your text transcript, keep in mind the following recommendations about what to include:

#'''Speaker’s name'''
#'''All speech content:''' If there is speech that is not relevant, it is usually best to indicate that it has been excluded from the transcript. For example: “[A & B chatted while slides were loading].”'''
#'''Relevant descriptions about the speech: Descriptions that convey emotions, mood, etc. are usually provided in brackets. For example: “Don’t touch that! [shouted].”
#Descriptions of relevant non-speech audio: These are usually provided in brackets. For example: “[metal pipes crashing to concrete floor].” Background noise that isn’t relevant can be left out.
#'''Headings and sub-headings:''' Where they will make the transcript more usable or easy to navigate, headings and sub-headings can be helpful aids, especially when the transcript is long. When including these, put them in brackets to show that they were not part of the original audio. For example: [I

====Transcripts and third-party videos====

If you are not producing your own video resource but are planning to embed video materials from a third-party source (e.g., YouTube), be aware that not all third-party sources include transcripts. While services like YouTube technically support transcripts, not all contributors to YouTube include these. If you select a video resource that does not already have a transcript, you will need to produce one yourself.*

*''Copyright note:'' Producing your own transcript for a third-party video could infringe on copyright, depending on how the video has been licensed. Before you proceed with producing a transcript for media materials you did not create yourself, you should contact the copyright holder of that material to obtain permission to do so.

====Captions====

Timed text captions are essential to opening up a world of information for persons with hearing loss or literacy needs by making the readable equivalent of audio content available to them in a synchronized manner. Globally hearing loss affects about 10% of the population to some degree. It causes disability in 5% (360 to 538 million) and moderate to severe disability in 124 million people. Timed text captions also be helpful for learners whose native languages are languages other than the primary language of the media or who have cognitive conditions that benefit from visual.Captions are the text that is synchronized with the audio in a video presentation. Captions are important when people need to see what’s happening in the video and get the audio information in text at the same time.

The work you put into creating a text transcript for a video resource can be repurposed to provide the captions. Keep in mind the following recommendations about what to include in your captions:

#'''All speech content:''' If there is speech that is not relevant, it is usually best to indicate that it has been excluded from the captions. For example: “[A & B chatted while slides were loading].”
#'''Descriptions of relevant non-speech audio:''' These are usually provided in brackets. For example: “[metal pipes crashing to concrete floor]”; “[background music by XXX plays].” Background noise that isn’t relevant can be left out.

Text captions can be uploaded to YouTube and other platforms along with the video to create a timed text file in SubRip (SRT) format. Additional best practices for timed captions include:

*Each caption frame should not be on screen for less than three seconds.
*Each caption frame must not be on screen for less than two seconds.
*Each caption frame should not exceed more than 2 lines.
*Each caption frame must not exceed more than 3 lines.
*Each line should not exceed more than 32 characters
*All caption frames should be precisely time synched to the audio.
*When multiple speakers are present, it is sometimes helpful to identify who is speaking, especially when the video does not make this clear.
*Non-speech sounds like [MUSIC] or [LAUGHTER] should be added in square brackets.

====Downloadable Transcripts====
For both audio and video transcripts, consider including a text file that learners can download and review using tools such as word processing, screen reader, or literacy software. All learners can use transcripts of media-based learning materials for study and review.

====Audio Descriptions====

Consider what your students would get out of a multimedia resource if they were not able to see embedded visual materials critical for comprehension. Audio descriptions are helpful if visual content (e.g., a chart or a map) in a video or presentation provides important context that is not available through the audio alone.<ref>Web Content Accessibility Guidelines (WCAG) 2.0, Guideline 1.2.3 Audio Description or Media Alternative (Prerecorded). Accessed from: http://www.w3.org/TR/WCAG20/#media-equiv</ref> Actions that are only visible on screen without any audible equivalent are not accessible to learners who have visual impairments.

When describing visual elements in your multimedia resources, keep in mind the following recommendations and guidelines.

1. When contextual visual content on the screen is not described in the audio itself, you will need to provide an audio description that is an objective description of the visual element. ''Example:''

:::To help students fully grasp a concept that you are trying to convey in your video, you have included some contextual visual references (e.g., maps, charts, physical demonstrations of a process). However, you realize after making the video that the audio portion does not describe these visuals in enough detail for a student with visual impairments to be able to access all of the concepts you intended to convey.

::In this case, you would need to record an audio description of the visual material that provides enough detail to provide students like Jacob with the same content available to visual learners.

2. Whenever possible, avoid creating the need for audio descriptions in the first place by being proactive at the time of recording. If you pay attention to contextual visuals during the recording of the media piece, you may find opportunities to convey the visual content within the spoken material itself; you will not need to provide audio descriptions of the visual content after the fact. ''Example:''

::You are recording a video or presentation that includes a chart that tracks coal production in British Columbia, and as part of the presentation you want to focus attention on specific data in the chart. The narrator or presenter might point to sections on the chart and say:

:::“As you can see, metallurgical coal projection increased by 3 million tonnes over these two years.“

::In this case, audio descriptions would be necessary to provide the missing context to students with visual disabilities; these students cannot see the data on the chart that tells visual learners what the production figures are and for what dates. However, if the narrator or presenter instead says:

:::“This chart illustrates that metallurgical coal production in B.C. increased from 23 million tonnes in 1999 to 26 million tonnes in 2001,”

::the visual content is conveyed through the audio and no audio description will be necessary.

====Accessible Media Resources====

*[http://ncam.wgbh.org/invent_build/web_multimedia/accessible-digital-media-guide Accessible Digital Media Guidelines] provides detailed advice on creating online video and audio with accessibility in mind.
*[https://dcmp.org/public_content/ai/captioningkey/index.html Captioning Key by the National Association for the Deaf] provides excellent guidance on creating described and captioned media.

==Best Practices 5: Font size==

In this section, we review the two main concerns of font size on the web.

===What Is Font Size?===

'''Font size:''' The size of text visible on the screen.

===Who Are You Doing This For?===

This work supports students who:

*Are blind or have low vision
*Have a form of cognitive disability
*Are deaf or hard of hearing
*Have a physical disability

===What Do You Need To Do?===

There are two main concerns when working with font sizes.

# Ensuring that default font sizes are not too small.
# Ensuring that text can be expanded to 200% on websites<ref>http://sites.psu.edu/accessibility/fontsizehtml/ </ref>.

Keep in mind these recommendations and guidelines:

*'''12 point for body text''': For most documents, body text should be around 12 points. Small fonts may be illegible for some audiences.

*'''9 point for footnotes''': If a document contains footnotes or endnotes, the minimum size should be about 9 points

* '''200% zoom''': The Web Content Accessibility Guidelines (WCAG 2.0) recommend ensuring that text can be zoomed to 200%. As well, we recommend using liquid layouts that can accommodate 200% text. Liquid layout are layouts that are based on percentages of the current browser window's size. They flex with the size of the window, even if the current viewer changes their browser size as they're viewing the site. Liquid width layouts allow a very efficient use of the space provided by any given Web browser window or screen resolution.

==Best Practices 6: Colour Contrast==
In this section, we provide guidelines and recommendations about colour contrast in your open educational materials.

===What is Colour Contrast?===

'''Colour contrast includes''': hue, lightness and saturation of text, images, and background
'''File types''': .doc, .html, .pdf, .jpg, .gif

===What What Role Does Colour Play in the Delivery of Your Content?===

When documents or web pages do not provide enough contrast between foreground elements (e.g., text, images) and background elements (e.g., colour, watermark images), some students will have difficulty reading the content. Consider the following questions:

1. Have you presented text- or image-based content on a coloured or textured background? If so, you should:
*Confirm that there is sufficient contrast between your foreground content and the chosen background colour or texture.

2. Have you included links in your content? If so, you should:
*Confirm that the colour of your web links is distinct from both your background colour and the colour of the surrounding text.

3. Have you used colour to convey concepts or information? If so, you should:
*Confirm that you are not using colour alone to convey this information.

===Who Are You Doing This For?===

This work supports students who:

*Have low vision
*Have poor contrast vision
*Are colour blind and cannot differentiate between certain colours
*Are using a device with monochrome display

===What Do You Need To Do?===

====Contrast====

Students with low vision and/or a form of colour blindness may have difficulty reading text that does not contrast enough with the background colour you have selected. If the colour palette you have adopted is too subtle (e.g., white text on a pastel background; medium-grey text on a light-grey background), the contrast between your foreground and background is probably insufficient for some students.

Web Content Accessibility Guidelines (WCAG 2.0) require that “the visual presentation of text and images of text has a contrast ratio of at least 7:1.”<ref>Web Content Accessibility Guidelines (WCAG) 2.0, Guideline 1.4.6 Contrast (Enhanced). Accessed from: http://www.w3.org/TR/UNDERSTANDING-WCAG20/visual-audio-contrast7.html</ref> The image below presents four different foreground/background colour-contrast examples to illustrate insufficient and sufficient colour contrast ratios.
<br /><br />
[[File:Colour_Contrast.png|thumb|center|500px|Image displays four examples of foreground (text) colour against background colours; only the example on the far right presents combinations with sufficient colour contrast.]]
<br /><br />
{| class="ambox ambox-notice"
| class="mbox-text" | <div>
'''Not sure how to test your materials for colour contrast ratios?'''

There are many online and downloadable tools available to help you evaluate colour contrast ratios. Here are a few we have tried and like:
*'''WebAIM’s [http://webaim.org/resources/contrastchecker/ Color Contrast Checker]''': This web-based tool allows you to select or enter colour values to test and provides you with a “pass” or “fail” on your contrast ratio.
*'''ACART’s [http://www.contrastchecker.com/ Contrast Checker]''': This is a straightforward, web-based tool you can use to both check colour contrast and view your selections in grey scale. This tool also allows you to keep a history of the colour combinations you have tested.
*'''Giacomo Mazzocato’s [http://gmazzocato.altervista.org/colorwheel/wheel.php Accessibility Color Wheel]''': This web-based tool includes several options for testing your colour selections, including simulations of three types of colour blindness. You can also opt to test what your contrast ratio is when the foreground and background colour selections are inverted.
</div>
|}

====Weblink Colours====

Weblinks must be visually distinct from both the surrounding, non-linked text and background colour. If you do not underline your links (or provide some other non-colour cue), you must ensure that you provide both sufficient contrast between the link and background colours and between the link colour and that of the surrounding text.

Web Content Accessibility Guidelines (WCAG 2.0) require a:
*4.5:1 contrast between the link text color and the background
*3:1 contrast between the link text color and the surrounding non-link text color<ref>WebAIM (2015), WCAG 2.0 and Link Colors. Accessed from: http://webaim.org/blog/wcag-2-0-and-link-colors/ </ref>

====High-Contrast Mode====

Some students need to see light text on a dark background for it to be readable, while others require dark text on a light background. Students with low vision must be able to see content when it is displayed in high-contrast mode. This can be a subjective experience, based on individual student needs. We recommend that you try testing your text and image-based content as you go by using high-contrast mode on your own computer and making adjustments as needed.

All content items such as text, images, bullets, and table borders must be visible in both regular and high-contrast modes.

{| class="ambox ambox-notice"
| class="mbox-text" | <div>
'''Not sure how to test your content in high-contrast mode?
'''
To test the visibility of your content in this mode, turn on high contrast by simultaneously pressing the following keys on your (PC) keyboard:
::'''Left ALT + Left SHIFT + Print Screen.'''
To turn off high contrast mode, repeat this step.
</div>
|}

====Use of Colour====

You should not rely on colour as the sole means of conveying information and instruction. If the point you are making depends on colour to be understood, you will need to edit your materials so that concepts presented in the visuals are not lost to those who are colour blind or who require high contrast between colours.<ref>Web Content Accessibility Guidelines (WCAG) 2.0, Guideline 1.4.1 Use of Color. Accessed from: http://www.w3.org/TR/WCAG20/#visual-audio-contrast</ref>

==Best Practices 7: Formulas==

Math or Science formulas in open educational resources can be challenging to deliver in a way that is accessible to people with vision impairments. Non-scalable images of mathematical content cannot be sufficiently enlarged or navigated by low-vision users and are not accessible to blind users at all.

===What Are Formulas?===

'''Formulas include:''' Math equations or science formulas

'''File types:''' LaTex or MathType

===Before You Begin===
'''Who Are You Doing This For?'''

This work supports students who:

*Are blind or have low vision
*Have a form of cognitive disability,
*Have a physical disability

The following content is a derivative of Equations: Images vs. MathML from Accessibility and Usability at Penn State, http://accessibility.psu.edu/equations.

===What Do You Need to Do?===

There are several ways to handle equations from images with ALT tags to MathML. Having access to an equation editor such as MathType or MathMagic can streamline processing and converting equations considerably. These tools are similar to equation editors found in the ANGEL HTML Editor and Microsoft Office.

====MathML====

[http://accessibility.psu.edu/math/mathml/ Math ML] is a text-based XML markup language designed for math equations. Browsers that support MathML are able to translate the XML into a formatted equation. Since MathML with MathJax can be rendered in many systems, including HTML, Sites at Penn State, ANGEL and Drupal, it is considered the best choice for accessibility.

Information about [http://accessibility.psu.edu/math/mathml/ creating and viewing MathML] is available on that page.

MathML may vary from system to system and the content can change rapidly.

====Image with ALT tag====

A safe option to create an image of an equation (or export it from an equation editor) and then insert the image into a document with an ALT tag.

''Note:'' ALT tags can be written in Nemeth MathSpeak for students who have learned that system.

<math>
m = \frac{m_0}{\sqrt{1-\frac{v^2}{c^2}}}
</math>

View the ALT Tag

ALT= “m equals begin fraction m sub 0 over begin square root 1 minus begin fraction v sup 2 over c sup 2 end fraction end square root end fraction”

====LaTex====

LaTeX is a math markup language familiar to many in the science and math community, but unfortunately it is not currently supported by screen reader technology. However, it is fairly simple to convert LaTeX to an image or MathML in most equation editors.

For example, in the [http://wiki.ubc.ca UBC Wiki] you can insert a piece of LaTeX code using the <nowiki><math></nowiki> tag:
<pre>
<math>
m = \frac{m_0}{\sqrt{1-\frac{v^2}{c^2}}}
</math>
</pre>
The equation should appear fully formatted. Make minor adjustments as needed.

====Audio Files====
User testing with students have indicated that it would helpful to have an audio file of the formula or equation. The audio file would be placed beside the formula or equation and would allow the user to hear exactly how the formula or equation is interpreted.

====Audio Files====
User testing with students have indicated that it would helpful to have an audio file of the formula or equation. The audio file would be placed beside the formula or equation and would allow the user to hear exactly how the formula or equation is interpreted.
=====Example — equation with audio=====
[[File:MM0over.png|200px|center|math formular]]
[https://soundcloud.com/user-262382099-529580848/equation Listen to the audio file of this equation]:

===Additional Resources===

*In 2012, Portland Community College departments took a closer look at making math accessible to blind students. Read more about the math accessibility study on our website: http://www.pcc.edu/access.
*The [http://www.washington.edu/doit/are-there-guidelines-creating-accessible-math?465= DO-IT project from the University of Washington] provides guidance on creating accessible math content.
*The [http://www.washington.edu/doit/programs/accessstem/overview AccessSTEM] website provides guidance on creating accessible science, technology, engineering and math educational content.

==Best Practices 8: PDFs, Word Docs and Excel Files==
This section describes guidelines for creating accessible content in PDFs, Word documents, and Excel spreadsheets. Many of the same accessibility techniques and principles that apply to authoring in HTML also apply to creating document based OERs.

===PDFs===
Converting or publishing open resources as PDF documents can create accessibility barriers, particularly for learners with visual impairments. Accessibility issues are very common in PDF files that were scanned from printed sources or exported from a non-PDF document format. Scanned documents are simply images of text. To make scanned documents accessible, you must perform Optical Character Recognition (OCR) on these documents, and proofread the resulting text for accuracy before embedding it within the PDF file. You must also add semantic structure and other metadata (headings, links, alternative content for images, and so on) to the embedded text.

When you export documents to PDF from other formats, it is important to ensure that the source document contains all the required semantic structure and metadata before exporting. Unfortunately, some applications do not include this information when exporting and require the author to add or “tag” the document manually using PDF editing software. You should carefully consider whether exporting to PDF is necessary at all.

====Best Practices for Authoring Accessible PDF Documents====

*Explicitly define the language of the document so that screen readers know what language they should use to parse the document.
*Explicitly set the document title. When you export a file to PDF format, the document title usually defaults to the file name, not a human readable title.
*Verify that all images have alternative content defined or are marked as decorative only.
*Verify that the PDF file is “tagged”. Make sure the semantic structure from the source document has been correctly imported to the PDF file.
*Verify that a logical reading order is defined. This is especially important for documents that have atypical page layouts or structure.
*If your document includes tables, verify that table headers for rows and columns are properly defined.

====Accessible PDF Resources====
*[http://webaim.org/techniques/acrobat/ WebAIM's PDF Accessibility site] provides a detailed and illustrated guide on creating accessible PDFs.
*The [http://ncdae.org/resources/cheatsheets/ National Center of Disability and Access to Education has a collection of one-page “cheat sheets”] on accessible document authoring.
*Microsoft provides detailed [https://support.office.com/en-gb/article/Create-accessible-PDFs-064625e0-56ea-4e16-ad71-3aa33bb4b7ed?CorrelationId=9b8d28cf-aa96-4816-9536-b4aea195b51c&ui=en-US&rs=en-GB&ad=GB&ocmsassetID=HA102478227 guidance on generating accessible PDFs from Microsoft Office applications], including Word, Excel, and PowerPoint.
*Adobe provides [https://helpx.adobe.com/acrobat/using/create-verify-pdf-accessibility.html documentation on how to create and verify PDF accessibility].

===Word Documents===
Many of the same accessibility techniques and principles that apply to authoring one content also apply to creating Word documents. Keep formatting simple. Use headings, paragraphs, lists, images, and captions. Use tables for tabular data. Do not add unnecessary indents, rules, columns, blank lines, or typographic variation. Use standardized styles for formatting your text, such as Normal, Heading 1, and Heading 2, rather than manually formatting text using text styles and indents. Formatting text for its semantic meaning and not for its visual appearance allows users of assistive technology to consume and navigate documents effectively and efficiently.

Additional best practices include;

*Images must have descriptive text associated with them.
*Documents should be well structured.
*Hyperlinks should be meaningful and describe the destination.
*Tables should include properly defined column and row headers.
*Color combinations should be high contrast.
*Verify the accessibility of your document using [https://support.office.com/en-us/article/Use-the-Accessibility-Checker-on-your-Windows-desktop-to-find-accessibility-issues-a16f6de0-2f39-4a2b-8bd8-5ad801426c7f?ui=en-US&rs=en-US&ad=US Microsoft’s Accessibility Checker].

===Excel Spreadsheets===
Many of the same accessibility techniques and principles that apply to authoring data tables in HTML also apply to creating Excel spreadsheets. Microsoft has a [https://support.office.com/en-us/article/Make-your-Excel-spreadsheets-accessible-6CC05FC5-1314-48B5-8EB3-683E49B3E593?ui=en-US&rs=en-US&ad=US guide to creating accessible Excel workbooks].

*Images must have descriptive text associated with them.
*Column and row headings should be programmatically identified.
*Hyperlinks in spreadsheets should be meaningful and describe the destination.
*Use a unique and informative title for each worksheet tab.
*Do not use blank cells for formatting.
*Colour combinations should be high contrast.
*Verify the accessibility of your workbook using [https://support.office.com/en-us/article/Use-the-Accessibility-Checker-on-your-Windows-desktop-to-find-accessibility-issues-a16f6de0-2f39-4a2b-8bd8-5ad801426c7f?ui=en-US&rs=en-US&ad=US Microsoft’s Accessibility Checker].

===Additional Microsoft Accessibility Resources===
*[https://support.office.com/en-us/article/Make-your-Word-documents-accessible-D9BF3683-87AC-47EA-B91A-78DCACB3C66D?ui=en-US&rs=en-US&ad=US Microsoft guide to creating accessible Word documents.]
*[https://support.office.com/en-us/article/Use-the-Accessibility-Checker-on-your-Windows-desktop-to-find-accessibility-issues-a16f6de0-2f39-4a2b-8bd8-5ad801426c7f?ui=en-US&rs=en-US&ad=US Microsoft tool that allows you to check Word documents for accessibility issues.]
*Microsoft guide to creating [https://support.office.com/en-us/article/Make-your-PowerPoint-presentations-accessible-6F7772B2-2F33-4BD2-8CA7-DAE3B2B3EF25?ui=en-US&rs=en-US&ad=US accessible PowerPoint presentations].
*[https://support.office.com/en-us/article/Make-your-Excel-spreadsheets-accessible-6CC05FC5-1314-48B5-8EB3-683E49B3E593?ui=en-US&rs=en-US&ad=US Microsoft guide to creating accessible Excel workbooks].
*Microsoft tool that allows you to check [https://support.office.com/en-us/article/Use-the-Accessibility-Checker-on-your-Windows-desktop-to-find-accessibility-issues-a16f6de0-2f39-4a2b-8bd8-5ad801426c7f?ui=en-US&rs=en-US&ad=US Excel workbooks for accessibility issues].
*Microsoft guide to creating [http://webaim.org/techniques/powerpoint/ accessible PowerPoint presentations].
*[http://webaim.org/techniques/powerpoint/ WebAIM’s guide to PowerPoint accessibility].

==UBC Platform Specific Accessibility Guidelines==

===Canvas===
*[https://community.canvaslms.com/docs/DOC-2061 Accessibility within Canvs]
*[https://community.canvaslms.com/groups/accessibility Canvas Accessibility Group]
*[https://community.canvaslms.com/groups/accessibility/blog/2018/05/08/how-to-fix-and-prevent-accessibility-issues-in-your-canvas-course How to Fix and Prevent Accessibility Issues in Your Canvas ]

===Edx===
*[http://edx.readthedocs.io/projects/edx-partner-course-staff/en/latest/accessibility/index.html Accessibility Best Practices Guidance for Content Providers]

===WordPress===
*[https://en.support.wordpress.com/accessibility/ Accessibility in WordPress]
*[http://khan.github.io/tota11y/ Tota11y] - a tool to check if your site is accessible or not. There is also a [https://chrome.google.com/webstore/detail/tota11y-plugin-from-khan/oedofneiplgibimfkccchnimiadcmhpe?hl=en chrome extension] available

===MediaWiki/UBC Wiki===
*[https://en.wikipedia.org/wiki/Wikipedia:Manual_of_Style/Accessibility Manual of Style- Accessibility]

===UBC Centre for Accessibility===
*[https://students.ubc.ca/about-student-services/centre-for-accessibility UBC Centre for Accessibility] (CfA) provides leadership on issues of accessibility for people with disabilities at UBC Vancouver, working in partnership with faculties to foster inclusive learning, living and working environments for students, faculty and staff. The Centre for Accessibility provides support and programming initiatives designed to remove barriers for students with disabilities and facilitates disability related accommodations for members of the UBC Vancouver community.

===UBC Centre for Workplace Accessibility===
*[https://hr.ubc.ca/health-and-wellbeing/workplace-accessibility/centre-workplace-accessibility The Centre for Workplace Accessibility] (CWA) is a hub for resources, tools, and programs that help remove barriers for faculty and staff with disabilities or ongoing medical conditions. It offers support to improve workplace accessibility using a trauma-informed, person-centred approach. Its initiatives also include projects and workshops designed to build disability inclusion literacy throughout the UBC community.

==Appendix: Checklist for OER Accessibility==

===Organizing Content===

☐ Contents is organized under headings and subheadings

☐ Headings and subheadings are used sequentially (e.g. Heading 1, heading 2, etc)

===Images===

☐ Images that convey information include Alternative Text (alt-text) descriptions of the image’s content or function.

☐ Graphs, Charts, and Maps also include contextual or supporting details in the text surrounding the image.

☐ Images do not rely on colour to convey information.

☐ Images that are purely decorative contain empty alternative text descriptions. (Descriptive text is unnecessary if the image doesn’t convey contextual content information).

===Tables===

☐ Tables include row and column headers.

☐ Table includes title or caption.

☐ Table does not have merged or split cells.

☐ Table has adequate cell padding.

===Weblinks===

☐ The weblink is meaningful in context, does not use generic text such as “click here” or “read more”.

☐ Weblinks do not open new windows or tabs.

☐ If weblink must open in a new window, a textual reference is included in the link information.

===Multimedia===

☐ A transcript has been made available for a multimedia resource that includes audio narration or instruction. Transcript includes:
:Speaker’s name
:All speech content
:Relevant descriptions of speech
:Descriptions of relevant non-speech audio

===Headings and subheadings===

☐ Captions of all speech content and relevant non-speech content are included in the multimedia resource that includes audio synchronized with a video presentation.

☐ Audio descriptions of contextual visuals (graphs, charts, etc) are included in the multimedia resource.

===Formulas===

☐ Formulas have been created using MathML.

☐ Formulas are images with alternative text descriptions, if MathML is not an option.

===Font Size===

☐ Font size is 12 point or higher for body text.

☐ Font size is 9 point for footnotes or end notes.

☐ Font size can be zoomed to 200%.

==Appendix: Accessibility 2-Page Handout==

[[File:Accessibility Handout Thumbnail.png|thumb|centre|400px|link=http://wiki.ubc.ca/images/5/5b/UBC_Accessibility_Handout.pdf|Click to Download PDF ]]

==Appendix: Additional OER Accessibility Resources==
*[https://accessibility.ctlt.ubc.ca/ UBC Accessibility 101] - A UBC resource that focuses on improving access to digital content for students with vision or hearing impairments and similar learning barriers.
*[https://blogs.ubc.ca/accessibleactivelearning/ Accessible Active Learning] - A resource designed for Instructional Skills Workshop (ISW) and TA Training facilitators at UBCV. It is meant as a resource to help them design activities with accessibility in-mind, to help make activities accessible to more students and participants.
*[https://equity.ubc.ca/resources/accessible-and-inclusive-event-planning/ UBC Accessible Event Planning Guide] - provides practical tools to help event organizers create inclusive and welcoming experiences for everyone, including particularly people with disabilities.
*[https://opentextbc.ca/accessibilitytoolkit/ BC Open Textbook Accessibility Toolkit] - (also in [https://opentextbc.ca/troussedoutildaccessibilite/ French]). See also the [https://cdn.collection.bccampus.ca/assets/B_Ccampus_Accessibility_Criteria_6b42ab8ce8.pdf BCcampus OER Accessibility Criteria checklist] and the [https://opentextbc.ca/accessibilitytoolkit/back-matter/inclusive-design-webinar-series/ BCcampus Inclusive Design Webinar Series].
*[https://students.ubc.ca/about-student-services/centre-for-accessibility UBC Centre for Accessibility] provides support and programming initiatives designed to remove barriers for students with disabilities and facilitates disability related accommodations for members of the UBC Vancouver community.
*[https://pressbooks.bccampus.ca/a11yondemand/ Digital Accessibility On-demand] - a resource by Luke McKnight designed as a just-in-time resource to guide creators to the step-by-step instructions they need to maximize accessibility and increase inclusivity.
*[https://pressbooks.bccampus.ca/accessibilityhandbook/ https://pressbooks.bccampus.ca/accessibilityhandbook/] - a guidebook by Luke McKnight and Briana Fraser to introduce concepts of digital accessibility and to provide detailed instructions to use the accessibility features of software such as Word and PowerPoint.
*[https://hr.ubc.ca/health-and-wellbeing/workplace-accessibility/centre-workplace-accessibility The Centre for Workplace Accessibility (CWA)] is a hub for resources, tools, and programs that help remove barriers for faculty and staff with disabilities or ongoing medical conditions. It offers support to improve workplace accessibility using a trauma-informed, person-centred approach.
*Inclusive Design Research Centre’s [http://floeproject.org/ Flexible Learning for Open Education]
*[http://www.udlcenter.org/implementation/postsecondary The National Center on Universal Design for Learning] provides a helpful overview on Universal Design for Learning.
*Portland Community College’s [http://www.pcc.edu/resources/instructional-support/access/ Accessibility for Online Course Content: A Guide for Instructors]
*[https://inclusive.microsoft.design/ Inclusive Design at Microsoft]
*[https://wiki.ubc.ca/images/0/02/Complex_Images_for_All_Learners.pdf Accessibility for Complex Images]: resource for making charts, graphs, figures, and other complex images accessible.
*[https://www.jisc.ac.uk/guides/supporting-an-inclusive-learner-experience-in-higher-education JISC guide to supporting an inclusive learner experience in higher education]
*The [https://bccampus.ca/wp-content/uploads/2023/04/OER-Equity-Rubric-1.pdf BCcampus OER Equity Rubric] is designed to help identify opportunities to adapt and improve the equity of open resources.

==References==
<references/>

==About this Toolkit==
[[File:CC-SA_button.png|left|CC by|100px]] The OER Accessibility Toolkit is licensed under a [https://creativecommons.org/licenses/by-sa/4.0/ Creative Commons Attribution-ShareAlike 4.0 International License], except where otherwise noted. Source files for this resource may be found on the [http://wiki.ubc.ca/Documentation:Open_UBC/Guide/OER_Accessibility_Toolkit UBC Wiki].

Content for this toolkit was adapted from the [https://opentextbc.ca/accessibilitytoolkit/ BC Open Textbook Accessibility Toolkit] by Amanda Coolidge, Sue Doner, and Tara Robertson. The [https://opentextbc.ca/accessibilitytoolkit/ BC Open Textbook Accessibility Toolkit] is licensed under a [https://creativecommons.org/licenses/by/4.0/ Creative Commons Attribution 4.0 International License], except where otherwise noted. Additional material has been adapted from the [http://edx.readthedocs.io/projects/edx-partner-course-staff/en/latest/accessibility/index.html edX Accessibility Best Practices for Developing Course Content] guidelines under a [https://creativecommons.org/licenses/by-sa/4.0/ Creative Commons Attribution Share Alike 4.0 International License].

[[Category:Open UBC]][[Category:Accessibility]] [[Category:Accessibility Toolkits]] [[Category:OER]] [[Category:Open Education]] [[Category:Universal Design]]

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This is a second fact.<ref name=":0">Engle. W. (2025). ''Will's Second Book''. etc. </ref>

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This is a second fact.<ref name=":0">Engle. W. (2025). ''Will's Second Book''. etc. </ref>

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This is a fact.<ref>{{Cite book|title=Will's Book|last=Engle|first=Engle|publisher=UBC|year=2021|location=Vancouver, BC|pages=102-103}}</ref>

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This is a second fact.<ref name=":0">Engle. W. (2025). ''Will's Second Book''. etc. </ref>

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This is a fact.<ref>{{Cite book|title=Will's Book|last=Engle|first=Engle|publisher=UBC|year=2021|location=Vancouver, BC|pages=102-103}}</ref>

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This is a fact.<ref>{{Cite book|title=Will's Book|last=Engle|first=Engle|publisher=UBC|year=2021|location=Vancouver, BC|pages=102-103}}</ref>

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Course:EOSC311/2026/Will and Rie's demo project

2026-05-25T20:33:04Z

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This is a fact.<ref>{{Cite book|title=Will's Book|last=Engle|first=Engle|publisher=UBC|year=2021|location=Vancouver, BC|pages=102-103}}</ref> This is a second fact.<ref name=":0">Engle. W. (2025). ''Will's Second Book''. etc. </ref>

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This is a third fact.<ref name=":0" /> [[File:Canada British Columbia location map Okanagan.svg|thumb|Map Example]]

==Conclusion / Your Evaluation of the Connections==

==References==
<references />

{{Projectbox_EOSC311}}
[[Category:EOSC311]]

Course:EOSC311/2026/Will and Rie's demo project

2026-05-25T20:32:36Z

WillEngle:

Add Summary Here

test1...

This is a fact.<ref>{{Cite book|title=Will's Book|last=Engle|first=Engle|publisher=UBC|year=2021|location=Vancouver, BC|pages=102-103}}</ref> This is a second fact.<ref>Engle. W. (2025). ''Will's Second Book''. etc. </ref>

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==References==
<references />

{{Projectbox_EOSC311}}
[[Category:EOSC311]]

Course:EOSC311/2026/Will and Rie's demo project

2026-05-25T20:31:26Z

WillEngle:

Add Summary Here

test1...

This is a fact.<ref>{{Cite book|title=Will's Book|last=Engle|first=Engle|publisher=UBC|year=2021|location=Vancouver, BC|pages=102-103}}</ref> This is a second fact.

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This is a third fact. [[File:Canada British Columbia location map Okanagan.svg|thumb|Map Example]]

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EOSC 311

2026-05-25T19:42:36Z

WillEngle: Redirected page to Course:EOSC311

#REDIRECT [[Course:EOSC311]]

Documentation:Funding Proposal - Theory of Change, Logical Framework, and Narrative to Address Primary Forest Deforestation in the State of Sarawak, Malaysia

2026-05-15T20:53:25Z

WillEngle: /* References */

== '''Ivan Egirait-Situation analysis, problem tree, and stakeholder analysis''' ==
Malaysia, located in Southeast Asia (WorldData.info, 2026), comprises of approximately 18.88 million hectares of forest<ref>The country is comprised of 13 states and three Federal Territories. Eleven of these states and two Federal Territories are situated in Peninsular Malaysia, with the states of Sabah and Sarawak situated on the island of Borneo, separated by the South China Sea (WorldData.info, 2026).</ref>, with Sarawak contributing the largest share (FAO, 2025; Koh et al., 2023). It accounts for roughly 43% of Malaysia’s total remaining forest cover; however, only 11% are fully protected<ref>About 1.09 million hectares of primary forest persist nationwide, of which just 13.32% falls within protected areas (FAO, 2025; UNEP-WCMC & IUCN, n.d.).</ref>(Koh et al., 2023).

The palm oil sector is particularly dominant wherein palm oil surpassed crude petroleum as the Sarawak’s leading export in 2023, generating approximately USD 3.1 billion<sup>'''[3]'''</sup> (UKAS, 2025). Oil palm plantations cover approximately 5.65 million hectares of Malaysia’s land area, of which Sarawak hosts ~1.62 million hectares (ISIS Malaysia & UPM, 2024a). See figure 1 below for state level distribution.

=== '''Figure 1: State-Level Share of Oil Palm Plantation Area in Malaysia (2023)''' ===
[[File:State-Level_Share_of_Oil_Palm_Plantation_Area_in_Malaysia.png|thumb|Source: Ministry of Plantation and Commodities (2024)|center]]
Source: Ministry of Plantation and Commodities (2024)

Estimates suggest that nearly 90% of the Sarawak’s primary forest has been lost to deforestation over the past five decades (Merriman, 2025; Sasada, 2025). This has been driven primarily by conversion of forests to large-scale oil palm plantations (ISIS Malaysia & UPM, 2024a). Additional drivers include timber and rubber plantations, legal and illegal logging, mining activities, and major infrastructure projects (Koh et al., 2023).

Underlying these drivers include weak land-tenure frameworks, inadequate recognition of Native Customary Rights (NCR), corruption and vested political–economic interests tied to timber and plantation concessions<sup>'''[4]'''</sup> (Koh et al., 2023). Strong global demand for palm oil and pulp, coupled with government incentives such as subsidies and expansion targets, have further reinforced pressure on forested land (ISIS Malaysia & UPM, 2024a, 2024b).

The consequences of this primary forest deforestation have been multidimensional, encompassing biodiversity loss, increased greenhouse gas emissions, environmental degradation, social conflict, and long-term economic vulnerabilities (Human Rights Watch, 2025; Koh et al., 2023). See annex 2 for problem tree diagram.

In terms of stakeholders, at state level, the Ministry of Urban Development and Natural Resources (MUDeNR) provides policy oversight, with implementation undertaken by specialized agencies. The Forest Department Sarawak is responsible for forest management planning, while the Sarawak Forestry Corporation oversees conservation and protection functions<sup>'''[5]'''</sup> (Forest Department Sarawak, 2026; Ministry of Natural Resources and Urban Development, 2026; World Resources Institute, 2024).

Land governance, including the adjudication of NCR, falls under the jurisdiction of the Land and Survey Department with the federal Ministry of Plantation and Commodities influencing the sector through regulatory standards developed by the Malaysian Palm Oil Board<sup>'''[6]'''</sup> (Malay Mail, 2024). Plantation companies and smallholder associations, primarily those represented by the Sarawak Oil Palm Plantation Owners Association (SOPPOA), exert considerable influence reinforced by market incentives, whereas Indigenous communities often possess limited political leverage despite their legally recognized NCR claims and forest dependence over the decades (Kiu, 2024; Ho, 2025). NGOs, and certification schemes such as the Malaysian Sustainable Palm Oil standard (MSPO), as well as sustainability commitments by global buyers continue to exert growing, though still uneven, influence in shaping forest governance outcomes (Human Rights Watch, 2025; ISIS Malaysia & UPM, 2024a; Koh et al., 2023).

== '''Theory of change, Logical framework and narrative''' ==
To address primary forest deforestation, the proposed theory of change (TOC) articulates an overarching impact statement which stipulates that IF Sarawak strengthens forest governance, secures Native Customary Rights tenure, and transitions priority palm oil supply chains toward deforestation-free production systems, THEN primary forest loss will decline by 70% by 2040, BECAUSE land-use decisions will shift from politically driven forest conversion toward transparent, community-inclusive, and climate-aligned management supported by sustainable palm oil markets. See Annex 3 for theory of change diagram.

This projection is considered achievable, as evidenced by Brazil’s integrated approach between 2004 and 2012, which combined robust forest monitoring, stringent policy enforcement, advocacy, market interventions, and international financing, achieving over 70% reduction in deforestation during that period (Andrade, 2026).

The TOC rests on several key assumptions that underlie the likelihood of success. First, it assumes that Sarawak’s Forest Department and Land & Survey Department will prioritize forest monitoring and compliance with the MSPO certification framework (Forest Department Sarawak, 2026; Malay Mail, 2024). This expectation is reinforced by mounting international pressure from the EU, NGOs, consumer brands, and local communities, under the EUDR, which aims to reduce deforestation linked to commodities entering the EU market, a major destination for Malaysian palm oil<sup>'''[7]'''</sup> (The Borneo Project, 2025a, 2025b).

Second, the TOC presumes that the Sarawak Land Code will continue progressing toward consistent legal recognition of NCR rights across Indigenous and local communities (Malay Mail, 2024). Despite some inconsistency in application, existing pathways for improved legal recognition are anticipated to reduce land tenure disputes among stakeholders (Awang Mahmood, 2026).

Third, it is expected that the SOPPOA will uphold its commitments to market-based incentives promoting compliance with sustainable practices (Kiu, 2024). Degraded Permanent Forest Estates for restoration are also anticipated to possess viable soil conditions and strong community buy-in, fostering greater engagement in sustainable forest management (Minggu, 2026)

Barriers are anticipated to challenge implementation. Weak enforcement capacity may constrain forest managers and frontline officers in regulating companies and addressing illegal activities (Koh et al., 2023). This could impede activities such as developing satellite-based deforestation monitoring systems, training agencies for data-sharing, and establishing multi-stakeholder land governance platforms (ISIS Malaysia & UPM, 2024a, 2024b).

Political and economic pressure on state policymakers and rural communities to prioritize plantation expansion over long-term forest protection may hinder activities like implementing community-based forest restoration projects, supporting agroforestry initiatives, strengthening protected area management, and promoting adoption of sustainable palm oil certification systems (Human Rights Watch, 2025; Koh et al., 2023).

Inconsistent recognition of Indigenous land tenure may undermine government accountability slowing activities such as participatory mapping of Indigenous territories, provision of legal assistance for NCR recognition, and the establishment of conflict-resolution mechanisms between communities and plantation companies (ISIS Malaysia & UPM, 2024a; 2024b)

Political influence exerted by vested interests in timber and oil palm plantation industries may weaken transparency and accountability in land-use decisions, thereby diminishing the effectiveness of capacity-building programs and traceability system implementation (Kiu, 2024; Koh et al., 2023).

A comprehensive package of activities is delivered. Developing satellite-based deforestation monitoring systems, training government agencies in data-sharing and forest surveillance and establishing multi-stakeholder land governance platforms are projected to produce the output of improved forest monitoring and governance systems, leading to the outcome of strengthened forest governance and enforcement capacity. The associated co-benefit from this process will be enhanced livelihoods and reduced conflict through more reliable and equitable forest management structures<sup>'''[8]'''</sup>. In Indonesia, Indigenous communities have used satellite data to monitor and report illegal logging activities, while in Suriname, deforestation data has been instrumental in exposing threats to the Saamaka people’s land rights. In both cases this significantly reduced deforestation (Reytar et al., 2023).

The implementation of community-based forest restoration projects, support for agroforestry initiatives, and reinforced management of protected areas are expected to yield the output of forest restoration and conservation initiatives. This, in turn, will result in the outcome of climate-resilient and restored forest landscapes. Community-based forest management programs have been effective in Nepal, Bangladesh, Bhutan, and Sri Lanka, resulting in increased forest cover, biodiversity preservation, and reduced deforestation while providing local communities with income-generating opportunities that advance economic well-being<sup>'''[9]'''</sup> (Bhusal et al., 2024).

Participatory mapping of Indigenous territories, providing legal assistance for NCR recognition, and setting up conflict-resolution platforms, are projected to yield the output of strengthened recognition and mapping of NCR lands. The corresponding outcome will be secure recognition and protection of NCR to land, with the co-benefit of improved livelihoods and reduced conflict through reduced disputes and equitable access to forest resources. In Suriname’s Amazon rainforest, the Saamaka community in efforts to reduce deforestation, have been successful in utilizing spatial data and mapping tools from LandMark to document illegal deforestation and land degradation on their territories<sup>'''[10]'''</sup> (World Resources Institute, 2026).

Training stakeholders in sustainable practices, supporting adoption of the MSPO certification, and developing traceability systems for deforestation-free palm oil supply chains is anticipated to generate the output of sustainable palm oil certification and landscape management, facilitating the outcome of deforestation-free palm oil production in supply chains. The co-benefit will be enhanced biodiversity conservation across agro-industrial landscapes. Progress in this regard has been evident in Indonesia through its mandatory national certification scheme, the Indonesian Sustainable Palm Oil standard, supported by forest-use restrictions, audits, and updated supply-chain traceability requirements (Sarmiento et al., 2024). Traceability was improved by requiring certified operators to identify the origin of fresh fruit bunches and disclosure of supplier and buyer linkages across the value chain<sup>'''[11]'''</sup> (Sarmiento et al., 2024).

== '''Gender analysis''' ==
Disparities continue to shape women's roles in Sarawak's forest and palm oil sectors (aus der Beek, 2026). Adult literacy rates lag for women (72%) compared to men (96.8%) and national averages (Borneo Post, 2017; Statbase, 2026), potentially constraining NCR claims and MSPO certification access. Labour force participation within the forestry sector is similarly gendered, with men disproportionately represented in formal employment (15.3% compared to 7.9%) (Lim, 2019; Meng, 2009).

Division of labor reflects gendered norms wherein women handle intensive forest gathering amid mobility/time constraints, yet hold limited decision-making power (Bitzer et al., 2024). Women's ethnobotanical expertise too complemented men's, supporting restoration and livelihoods (Faridah Aini et al., 2017). Climate change further intensifies these inequalities, as deforestation disproportionately increases women’s household responsibilities, undermining their adaptive capacity, primarily in relation to food and water security (Dasgupta, 2024; Alam et al., 2025).

To address these gaps, the project proposes gender quotas ensuring at least 40% female participation in governance platforms, gender sensitive NCR mapping, and agroforestry initiatives. Complementary measures, including flexible training schedules and gender-disaggregated monitoring are anticipated to enhance equitable access to MSPO certification, leadership opportunities, and livelihood benefits across project phases (Guillaume, 2017; aus der Beek, 2026).

== '''Risk analysis''' ==
Risks are anticipated across activities. Political changes in land‑use policies present a high‑likelihood, high‑impact threat that could weaken reform commitments, disrupting implementation. Mitigation will include sustained stakeholder engagement, policy advocacy, transparency, and alignment with institutional frameworks (Sarmiento et al., 2024). If this risk occurs, adaptive programming and stronger partnerships with stakeholders will be employed to sustain momentum (Sanz & Perea Blazquez, 2025).

Climate shocks pose a moderate‑likelihood, high‑impact risk, for restoration and agroforestry efforts. Mitigation will emphasize climate‑resilient species selection and adaptive land management drawing on proven practices from India and Nepal (Dhyani et al., 2021). Mitigation will include recovery and livelihood support strategies to relieve pressure on forests.

Stakeholder conflict represents a moderate‑likelihood, moderate‑to‑high‑impact risk that could delay participatory mapping and NCR recognition. Mitigation will involve inclusive engagement, proactive conflict‑resolution mechanisms, and stakeholder mapping (Wiati et al., 2018; Sarmiento et al., 2024). If disputes arise, mediation platforms will be intensified to rebuild trust.

Market volatility in palm oil prices presents a moderate‑likelihood, moderate‑impact risk affecting primarily smallholders<sup>'''[12]'''</sup> (Reich & Musshoff, 2025). Mitigation will include long‑term market incentives and certification benefits, while response efforts will focus on strengthening value chain partnerships and income diversification (Sarmiento et al., 2024).

== '''Appendices''' ==
'''Annex 1: Map Showing the location of Sarawak.'''

'''Source: Human Rights Watch, 2025'''

'''Annex 2: Problem Tree for Sarawak illustrating the core problem of primary forest deforestation due to oil palm conversion of forests in Sarawak, its causes and effects'''

[[File:Problem_Tree_for_Sarawak_illustrating_the_core_problem_of_primary_forest_deforestation_due_to_oil_palm_conversion_of_forests_in_Sarawak,_its_causes_and_effects.png|center|thumb]]
'''Biodiversity loss''' (orangutans, hornbills and many endemic species lose habitat)

'''Greenhouse gas emissions''' (From peatland drainage under oil palms)

'''Environmental impacts''' (soil erosion, sedimentation of rivers and altered water cycles)

'''Social impacts''' (displacement of Indigenous and rural communities, conflict over land, communities report losing access to hunting, fishing and traditional lands)

'''Economic vulnerabilities''' (overreliance on a boom‑bust commodity).

'''Conversion of natural primary forests to oil palm plantations'''.

'''Global market demand''' for palm oil (food, cosmetics, biofuel, animal feed)

'''National/state policies and incentives''' promoting plantation agriculture (e.g. land concessions, zoning of forest for agriculture, targets for palm output).

'''Land-tenure and governance gaps''' (vague title deeds, weak enforcement, overlapping laws in Sarawak)

'''Economic pressures''' (poverty reduction goals, desire for export revenue) that prioritize plantation development over conservation.

'''Source: Secondary data, 2026'''

'''Annex 3: Theory of Change Diagram'''
[[File:Theory_of_Change_Diagram.jpg|thumb|Ivan Egirait Updated Theory of Change Diagram|center]]
'''Source: Secondary data, 2026'''

== '''References''' ==

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* Andrade, R. (2026). The reduction of deforestation in Brazil 2004–2012: What happens next? <nowiki>https://www.ricardoandrade.org/index.php/publications/reduction-deforestation</nowiki>
* aus der Beek, R. (2026, March 31). ''From consultation to leadership: Advancing gender equality and social inclusion in social forestry''. RECOFTC. <nowiki>https://www.recoftc.org/regional/stories/consultation-leadership-advancing-gender-equality-and-social-inclusion-social-forestry</nowiki>
* Awang Mahmood, A. Z. B. (2026, April 4). NCR basics. Land and Survey Department Sarawak. <nowiki>https://landsurvey.sarawak.gov.my/web/subpage/webpage_view/614</nowiki>
* Bhusal, A., Dhungel, N., Chhetri, P., Bhattarai, S., Giri, S., Pathak, T. R., & Khanal, A. (2024). Status of community-based forest management in selected South Asian countries: Benefits, challenges, and key lessons. Journal of Sustainability and Environmental Management, 3(4), 225–236. <nowiki>https://www.nepjol.info/index.php/josem</nowiki>
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* Koh, J., Johari, S., Shuib, A., Siow, M. L., & Matthew, N. K. (2023). Malaysia’s Forest Pledges and The Bornean State of Sarawak: A Policy Perspective. Sustainability, 15(2), 1385. <nowiki>https://doi.org/10.3390/su15021385</nowiki>
* Kumaran, S., Chew, J. S., & Nambiappan, B. (2021). ''Moving forward with mandatory MSPO certification standards''. ''Oil Palm Industry Economic Journal, 21''(1), 1–12. <nowiki>https://doi.org/10.21894/opiej.2021.01</nowiki>
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* Meng, L. (2009). ''The relevance and impact of gender issues on the outlook for forestry to 2020 in North Asia''. Food and Agriculture Organization of the United Nations, Regional Office for Asia and the Pacific. <nowiki>https://www.fao.org/4/am257e/am257e00.pdf</nowiki>
* Merriman, J. (2025, January 7). ''The promise of “no deforestation”: Sarawak’s forests tell a different story''. The Borneo Project. <nowiki>https://borneoproject.org/the-promise-of-no-deforestation-sarawaks-forests-tell-a-different-story/</nowiki>
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* Minggu, K. (2026, March 31). Deputy Premier: Growing PFE hectarage proof of commitment to sustainable forest management. The Borneo Post. <nowiki>https://www.theborneopost.com/2026/03/31/deputy-premier-growing-pfe-hectarage-proof-of-commitment-to-sustainable-forest-management/</nowiki>
* Ministry of Plantation and Commodities. (2024). ''Agricommodity pocket stats 2023''. <nowiki>https://www.kpk.gov.my/kpk/images/mpi_statistik/Pocket_Stats/2023/poket-stats-2023full/index.html#page/1</nowiki>
* Proforest. (2025). ''Options to broaden smallholder inclusivity in legal and deforestation-free palm oil supply chains in Malaysia''. European Forest Institute. <nowiki>https://efi.int/sites/default/files/files/flegtredd/KAMI/Resources/smallholder_inclusivity_report.pdf</nowiki>
* Reich, C., & Musshoff, O. (2025). Oil palm smallholders and the road to certification: Insights from Indonesia. Journal of Environmental Management, 375, 124303. <nowiki>https://doi.org/10.1016/j.jenvman.2025.124303</nowiki>
* Reytar, K., Webb, J., & Veit, P. (2023, November 20). Indigenous peoples and local communities are using satellite data to fight deforestation. World Resources Institute. <nowiki>https://www.wri.org/insights/indigenous-peoples-local-communities-use-satellite-data-deforestation</nowiki>
* Sanz, M. J., & Perea Blazquez, A. K. (2025). Analysis of international climate change governance for the agriculture, forest and land use sector: Gaps and recommendations for future improvement. Earth System Governance, 25, 100278. <nowiki>https://doi.org/10.1016/j.esg.2025.100278</nowiki>
* Sarmiento, F., Larrea, C., Oeschger, A., & Jose, R. (2024, February 21). ''Measures to enhance forest conservation and reduce deforestation: Viewpoints and lessons from producing countries''. International Institute for Sustainable Development. <nowiki>https://www.iisd.org/ssi/publications/measures-enhance-forest-conservation-reduce-deforestation/</nowiki>
* Sasada, I. (2025, August 8). ''Maps offer hope of saving a rainforest in Malaysian Borneo’s Sarawak''. Al Jazeera. <nowiki>https://www.aljazeera.com/news/2025/8/8/maps-offer-hope-to-save-threatened-rainforest-in-malaysian-borneos-sarawak</nowiki>
* Statbase. (2026). ''Literacy rate, by gender | Malaysia | Male''. <nowiki>https://statbase.org/data/mys-literacy-rate-by-gender/</nowiki>
* The Borneo Project. (2025a, January 10). ''Deforestation alert: Ulu Belaga''. <nowiki>https://borneoproject.org/deforestation-alert-ulu-belaga/</nowiki>
* The Borneo Project. (2025b, October 30). ''Victory for Indigenous communities in Sarawak as Urun Plantations halts forest clearing''. <nowiki>https://borneoproject.org/victory-for-indigenous-communities-in-sarawak-as-urun-plantations-halts-forest-clearing/</nowiki>
* UKAS. (2025, September 19). ''Palm oil overtakes crude petroleum as Sarawak’s leading export''. Premier of Sarawak Department. <nowiki>https://premierdept.sarawak.gov.my/web/subpage/news_view/25115/UKAS</nowiki>
* UNEP-WCMC & IUCN. (n.d.). Malaysia country profile. ProtectedPlanet. <nowiki>https://www.protectedplanet.net/country/MYS</nowiki>
* Wiati, C. B., Indriyanti, S. Y., Maharani, R. N., & Subarudi. (2018). Conflict resolution efforts through stakeholder mapping in Labanan Research Forest, Berau, East Kalimantan, Indonesia. IOP Conference Series: Earth and Environmental Science, 144(1), 012063. <nowiki>https://doi.org/10.1088/1755-1315/144/1/012063</nowiki>
* World Resources Institute. (2026). LandMark: A global data platform of Indigenous and community lands to help communities protect their land rights and secure tenure. <nowiki>https://www.wri.org/initiatives/landmark</nowiki>
* World Resources Institute. (2024). ''Malaysia''. Forest Legality Risk Tool. <nowiki>https://forestpolicy.org/risk-tool/country/malaysia</nowiki>
* worlddata.info. (2026, January). ''Malaysia – Federal parliamentary monarchy, Southeast Asia, surface area, capital''. <nowiki>https://www.worlddata.info/asia/malaysia/index.php</nowiki>
* Yasmin, N., van Rijn, M., & Hojas Gascon, L. (2026). Réduction des émissions provenant du déboisement et de la dégradation des forêts REDD+. Food and Agriculture Organization of the United Nations. <nowiki>https://www.fao.org/redd/news/detail/fr/c/1667812/</nowiki>

== Footnote ==
<sup>[1]</sup> The country is comprised of 13 states and three Federal Territories. Eleven of these states and two Federal Territories are situated in Peninsular Malaysia, with the states of Sabah and Sarawak situated on the island of Borneo, separated by the South China Sea (WorldData.info, 2026).

<sup>[2]</sup> About 1.09 million hectares of primary forest persist nationwide, of which just 13.32% falls within protected areas (FAO, 2025; UNEP-WCMC & IUCN, n.d.).

<sup>[3]</sup> Palm oil and related products contribute nearly 9.9% of exports, around 6% of national GDP (ISIS Malaysia & UPM, 2024).

<sup>[4]</sup> Although Malaysia adopted a No New Deforestation pledge for oil palm in 2018, forest clearance within plantation areas in Sarawak has continued (Merriman, 2025).

<sup>[5]</sup> The Sarawak Premier authorizes major land and plantation concessions, while the MUDeNR Permanent Secretary chairs certification-related committees. Environmental compliance and regulatory oversight on the other hand are administered by the Natural Resources and Environment Board (Forest Department Sarawak, 2026; Ho, 2025; Kiu, 2024).

<sup>[6]</sup> Other federal institutions such as the Malaysian Palm Oil Council, Ministry of Investment, Trade and Industry and the Malaysian Timber Industry Board, influence the broader economic and regulatory environment through export policy, trade negotiations, and sustainability certification systems (ISIS Malaysia & UPM, 2024a, 2024b; Kumaran et al., 2021)

<sup>[7]</sup> The EU ranks as the third-largest market for oil palm from Malaysia, after India and China. In 2023, palm oil exports accounted for 7.1% of the Malaysia’s overall palm oil exports (Proforest, 2025).

<sup>[8]</sup> Cambodia has effectively implemented deforestation monitoring systems across four provinces bordering Thailand with positive outcomes from the pilot phase prompting incorporation of near–real-time monitoring into the national action plan for 2024–2027 (Yasmin et al., 2026).

<sup>[9]</sup> Rwanda too, reduced deforestation by combining policy reform, landscape restoration, agroforestry, tree-planting campaigns, multi-stakeholder coordination, and strong monitoring, all supported by financing and public participation, moving from about 10.7% forest cover in 2010 to 30.4% in 2022 (Sarmiento et al., 2024).

<sup>[10]</sup> Similarly, in Indonesia’s Lebak District, the Kasepuhan Karang community have employed participatory mapping to delineate key land uses, serving as a critical instrument for formal recognition of their land rights (International Land Coalition, 2026).

<sup>[11]</sup> Companies such as Musim Mas achieved full traceability to plantation for managed mills by 2020 with 93% traceability for third-party mills by 2021, enabling proactive monitoring across 9.2 million hectares of production areas in Indonesia (Fripp et al., 2023).

<sup>[12]</sup> Smallholder farmers face high financial and structural constraints which could limit their capacity, hence risking their exclusion from vital supply chains (Jong, 2023).

Documentation:Sarawak’s Forest Governance under the European Union Deforestation Regulation: Policy Options for the Premier of the State of Sarawak, Malaysia

2026-05-15T20:52:26Z

WillEngle:

Oil palm and timber plantations expansion have been noted as the primary drivers of deforestation in Sarawak<ref>By 2024, Sarawak had lost 1.7 million hectares of humid primary forest, a 23% decline in its overall primary forest area (Global Forest Watch, n.d.).</ref> (Sarawak Report, 2024). This has created a significant governance challenge under the European Union Deforestation Regulation (EUDR) which came into force on 29<sup>th</sup> June 2023 requiring commodities entering the EU market to be deforestation-free and legally produced with a post-2020 deforestation cutoff<ref>Continued forest loss and land-rights disputes risk “high-risk” classification, which could threaten Sarawak’s EU market access (Funds for NGOs, 2024). </ref> (The Borneo Project, 2024).

= List of Abbreviations =

'''EUDR - European Union Deforestation Regulation'''

'''FPIC - Free, Prior and Informed Consent'''

'''ISIS - Institute of Strategic and International Studies'''

'''ISPO - Indonesian Sustainable Palm Oil'''

'''MSPO - Malaysian Sustainable Palm Oil'''

'''NCR - Native Customary Rights'''

'''UPM - Universiti Putra Malaysia'''

'''WTO - World Trade Organisation'''

== Background ==
The EUDR has increased pressure on producers with compliance depending on strict plot-level geolocation and supply-chain traceability requirements, limiting the scope for diverting commodities to alternative markets (Human Rights Watch, 2024).

Malaysia has challenged the EUDR, framing it as a form of disguised protectionism and a trade barrier that places disproportionate burdens on smallholders in its formal complaint to the WTO, this has introduced further uncertainty (Brasier, 2024; Teja, 2024).

Malaysia has relied on the Malaysian Sustainable Palm Oil (MSPO) certification scheme, alongside existing legal frameworks under the Land Code and Forest Ordinance, to address raised sustainability concerns (ISIS Malaysia & UPM, 2024a, 2024b). The EU has recognised the scheme as a credible certification framework that could support compliance with the EUDR, due to the incorporation of digital traceability tools that strengthen supply-chain transparency (Reuters, 2025).

However, despite these policy advancements, forest loss remains significant, with approximately 85,100 hectares cleared in 2023<ref>This has contributed to a cumulative decline of about 1.04 million acres between 2019 and 2023. Furthermore, associated analysis suggests that logging and oil palm expansion continue to threaten extensive areas of naturally regenerating forest (Keeton-Olsen, 2024).</ref> (Funds for NGOs, 2024) See figure 1 below for extent of plantation expansion. This has been intensified by the state’s target of one million hectares of timber plantations, requiring the clearance of over 400,000 hectares of natural forest (The Borneo Project, 2024).

'''Figure 1: Extent of Plantation Concessions in Sarawak'''

Local tensions too, have escalated with Long Urun recording over 40,000 satellite‑detected deforestation alerts, with nearly 500 hectares of forest lost. This triggered petitions and blockades after official avenues failed. International pressure later prompted a temporary moratorium (Keeton‑Olsen, 2025; The Borneo Project, 2025a, 2025b). (See figure 2 below, for extent).

'''Figure 2: Land Clearing Captured in Long Urun on September 24, 2025'''

Furthermore, Sarawak’s Land Code has been criticized for limiting the legal recognition of Indigenous Native Customary Rights (NCR) lands while enabling commercial access to forested areas through state-issued leases<ref>Additionally, although the legal framework requires the voluntary surrender or termination of customary land and compensation prior to commercial allocation, implementation has been noted to be inconsistent in practice (Human Rights Watch, 2024).</ref> (The Borneo Project, 2025a, 2025b).

These governance challenges have strengthened calls by civil society organisations urging the EU to classify Sarawak as a high-risk jurisdiction which would increase regulatory scrutiny of exports to EU markets (Keeton-Olsen, 2024). Given the importance of European markets for Malaysia’s palm oil<ref>The EU represents a key destination for Malaysian palm oil, ranking as the third-largest market after India and China. In 2023, palm oil exports from Malaysia to the EU totaled 1.07 million tonnes, accounting for 7.1% of the country’s overall palm oil exports (Proforest, 2025).</ref> and timber sectors<ref>EU countries are significant importers of Malaysian forestry goods, with the Netherlands and Germany ranking as the second- and third-largest purchasers of nationally certified timber from Malaysia in 2022(Keeton-Olsen, 2024).</ref>, strengthening forest governance and ensuring compliance are paramount (Human Rights Watch, 2024).

== Key Actors ==
At the international level, EU institutions act as external regulators through EUDR requirements, shaping market access and compliance expectations. International NGOs and consumer brands exert influence through supply chain pressure, exemplified by the sourcing suspensions linked to plantation expansion in Long Urun (The Borneo Project, 2025a, 2025b).

At the national level, federal institutions such as the Malaysian Palm Oil Council, Ministry of Investment, Trade and Industry, Ministry of Plantation and Commodities, Malaysian Timber Industry Board, influence the broader economic and regulatory environment through export policy, trade negotiations, and sustainability certification systems, while engaging directly with the EU on EUDR compliance (ISIS Malaysia & UPM, 2024a, 2024b; Kumaran et al., 2021; Reuters, 2025). They continue to lead Malaysia’s challenge to the EUDR at the WTO (Brasier, 2024; Teja, 2024).

At the sub-national level, the Sarawak state government holds primary authority over land allocation, forest classification, and plantation licensing through the Sarawak Ministry of Natural Resources and Urban Development<ref>Operational authority is implemented through several key agencies. The Sarawak Forest Department oversees forest classification, management, and the issuance of timber licences, while the Sarawak Land and Survey Department is responsible for land allocation, land registration, and matters related to NCR land. In parallel, the Sarawak Forestry Corporation is mandated to manage conservation efforts, including protected areas and biodiversity (Forest Department Sarawak, 2026; Land and Survey Department Sarawak, 2026; Sarawak Forestry Corporation, 2026).</ref> (Ministry of Urban Development and Natural Resources, 2026). This enables it to approve timber concessions and oil palm expansion<ref>Power at this level remains closely aligned with major corporations, whose political and economic influence continue to shape development priorities and regulatory enforcement (Tan et al., 2023; Koh et al., 2023). </ref> (Keeton-Olsen, 2021; Mohammad et al., 2022).

At the local level, Indigenous communities alongside forest-dependent households, smallholders, and plantation workers, are most directly affected by these governance dynamics<ref>It has been observed that smallholder farmers are more unlikely to satisfy the legality and sustainability requirements stipulated by the EUDR, as financial and structural constraints could limit their capacity to comply, thereby risking their exclusion from this vital global supply chain (Jong, 2023).</ref>. They rely on NCR lands for livelihoods and cultural continuity but face persistent barriers to formal recognition under Sarawak’s Land Code (Human Rights Watch, 2024). Forest conversion threatens their subsistence resources, fuels local conflicts, exposing smallholders and labourers to economic risks<ref>Compliance with the EUDR will therefore require significant financial, technical, and institutional support from government and industry stakeholders (Proforest, 2025).</ref> (Funds for NGOs, 2024).

== Policy options ==

=== '''Option 1: Status Quo''' ===
Herein, enforcement would continue through current state mechanisms under the Land Code and Forest Ordinance alongside the MSPO certification framework. This approach preserves current development trajectories centred on oil palm and timber expansion<ref>This option largely reflects existing approaches, which have not fully curbed deforestation or addressed persistent traceability and enforcement gaps (The Borneo Project, 2024).</ref> (Human Rights Watch, 2024; UKAS, 2025a).

Continued forest loss would likely persist, reinforcing international scrutiny from regulators, civil society organisations, and consumer brands concerned (Funds for NGOs, 2024; The Borneo Project, 2024). Sarawak could face heightened due-diligence requirements or potential classification as a “high-risk” jurisdiction, increasing transaction costs (ISIS Malaysia & UPM, 2024a, 2024b). See figure 3 below for due-diligence requirements.

Figure 3: Due Diligence Requirements Under Articles 9, 10 and 11 of the EUDR
[[File:Due_Diligence_Requirements_Under_Articles_9,_10_and_11_of_the_EUDR.png|center|thumb|Due Diligence Requirements Under Articles 9, 10 and 11 of the EUDR; Source: ISIS Malaysia, & UPM, 2024b|500x500px]]

The main benefit of this would be that plantation expansion proceeds without disruption, industry actors avoid new compliance costs, while state revenues linked to land-based development would remain stable in the near term (Koh et al., 2023; Tan et al., 2023).

Authority over routine enforcement priorities, administrative coordination, and public communication would be retained while avoiding initiating legislative or regulatory reforms (Forests Ordinance, 2015). This would favour plantation and timber interests while minimising confrontation with powerful industry actors. Winners would include large agribusiness firms and political actors aligned with expansion, while losers would include forest-dependent communities, environmentally oriented exporters, and stakeholders seeking stronger sustainability compliance (Human Rights Watch, 2024; The Borneo Project, 2024).

=== '''Option 2: Compliance and Traceability Strategy''' ===
This would strengthen supply-chain transparency and traceability systems while allowing continued land conversion within existing regulatory limits as seen in Indonesia which was able to achieve compliance and traceability through its mandatory national certification system, the Indonesian Sustainable Palm Oil (ISPO) scheme, paired with forest-use restrictions, audits, and traceability rules for the palm oil supply chain<ref>ISPO made compliance a legal requirement rather than a purely voluntary market choice with traceability being strengthened by requiring certified operators to identify the source of fresh fruit bunches and disclosure of supplier and buyer relationships within the value chain (Sarmiento et al., 2024).</ref> (Sarmiento et al., 2024).

Measures would include improving geolocation data, integrating plantation licensing databases, strengthening MSPO 2.0 implementation, and supporting smallholders in meeting certification requirements<ref>This will be critical given the EUDR’s post-2020 cutoff, as traceability systems must be capable of distinguishing between compliant and non-compliant production areas. This could reduce the feasibility of simply redirecting exports to alternative markets, reinforcing the need for system-wide transparency (The Borneo Project, 2024).</ref> (ISIS Malaysia & UPM, 2024a, 2024b; Reuters, 2025).

Strengthening digital monitoring systems, verification mechanisms, and compliance support programmes would require public funding and institutional coordination (Forests Ordinance, 2015). Smallholders may face additional reporting burdens, while some companies may resist transparency requirements. Reforms may also remain procedural rather than substantive if underlying drivers of deforestation remain unchanged (The Borneo Project, 2024).

Enhanced traceability and compliance systems would demonstrate legality and supply-chain transparency to EU regulators and international buyers with export-oriented producers gaining more secure access to European markets, while improved governance systems could increase investor confidence, reducing trade disruptions (Ross, 2026).

Exercising of direct control over monitoring systems, enforcement transparency, and state-level compliance infrastructure would be facilitated but would require coordination with federal agencies responsible for certification and export promotion as well as cabinet support for budget allocations and inter-agency mandates (Forests Ordinance, 2015). This would appeal to export-oriented firms and federal trade authorities while avoiding major restrictions on plantation expansion. Winners would include compliant exporters and supported smallholders, while non-compliant operators would face greater scrutiny (Human Rights Watch, 2024).

=== '''Option 3: Forest Protection and Land Governance Reform''' ===
This would ensure stronger land-use regulation and governance reform. Measures will include a moratorium on new plantations in natural forests and peatlands, expansion of protected forest areas, stricter enforcement of land-conversion rules, and improved recognition of Indigenous NCR alongside Free, Prior and Informed Consent (FPIC) requirements for development projects (Human Rights Watch, 2024; The Borneo Project, 2024).

Stricter land-use controls could slow plantation expansion, potentially reducing short-term revenue from land-based development with enforcement capacity needing strengthening. Compensation or renegotiation of existing concessions would also need to be carried out to minimize legal disputes as well as boost investor confidence (Koh et al., 2023; Tan et al., 2023). Peru was able to achieve similar structural reforms by pairing land and forest formalization with clearer rules, stronger institutions, and incentives that brought informal actors into the legal system <ref>This involved moving from informal, insecure land use to formal, contract-based forest access through the creation of Agroforestry Concessions and reorganization of land into forest-use zones. The reform worked by giving smallholders a legal path into the system instead of leaving them invisible to the state (Sarmiento et al., 2024).</ref>(Sarmiento et al., 2024).

Stronger forest protection would result, reducing deforestation, improving biodiversity conservation, while decreasing land-rights conflicts with Indigenous communities (Sarmiento et al., 2024). Alignment with the EUDR would also strengthen Sarawak’s credibility (Tang, 2025; Reuters, 2025).

Control of enforcement priorities and administrative measures would be enabled. However, major reforms focusing on land-law amendments and protected-area designations would require approval from the State Legislative Assembly and coordination with federal authorities (Forests Ordinance, 2015). This option may face resistance from agribusiness interests but would gain support from civil society, Indigenous communities, and international partners. Winners would include forest-dependent communities, sustainable producers, and long-term exporters, while firms reliant on expansion and land-conversion revenues may incur losses (ISIS Malaysia & UPM, 2024a, 2024b; Mohammad et al., 2022).

== Recommended Policy option ==
A hybrid strategy would be the most viable approach, beginning with Option 2 and transitioning toward Option 3. Strengthening traceability, MSPO 2.0 implementation, and monitoring systems would provide immediate protection of EU market access, which is critical given Sarawak’s export dependence and exposure to EUDR requirements (Sarmiento et al., 2024; UKAS, 2025). This approach is politically feasible, avoids abrupt disruption, while building on the required administrative capacity for deeper reforms (Sarmiento et al., 2024).

However, compliance alone may not address the underlying deforestation drivers. A phased transition towards stronger land-use regulation and recognition of NCR and FPIC is necessary for long-term sustainability (Sarmiento et al., 2024; The Borneo Project, 2024). This would counter the state–corporate bias by empowering Indigenous voices via NCR/FPIC, while using traceability to appease exporters (Human Rights Watch, 2024). While Malaysia’s WTO challenge may reshape future obligations, it does not eliminate the immediate need for compliance (Brasier, 2024; Teja, 2024). This combined approach balances short-term trade imperatives with longer-term governance reform.

== Decision Timeline, Next Steps, and Key Milestones ==
The approach should be adopted by 30 March 2026 to allow sufficient lead time for implementation before the EUDR takes effect. It will apply from 30 December 2026 for large operators and traders, and from 30 June 2027 for micro- and small enterprises (European Commission, 2024). In addition, the EU’s risk benchmarking review, expected in May 2026, may shape Malaysia’s classification as high or standard risk, making early preparation paramount (Meridia, 2025).

Implementation should proceed in phases. In April 2026, an inter-agency taskforce should be convened to coordinate traceability mapping. In May 2026, Cabinet should decide on budget allocations and whether Land Code amendments will be pursued. June 2026 should mark the launch of smallholder support pilots and stakeholder forums, followed by quarterly deforestation monitoring reports. In Q2 2026, legislative reforms could be considered during the State Assembly session, while a federal MSPO audit is expected in Q3 2026. Large-firm pilots should begin in December 2026, with scale-up decisions made in late 2026 ahead of April 2027 compliance checks.

= References =

* Brasier, P.-J. S. (2024, September 18). ''Heated debates about the EUDR are missing the bigger picture''. Fern. <nowiki>https://www.fern.org/pt/publications-insight/article/heated-debates-about-the-eudr-are-missing-the-bigger-picture/</nowiki>
* Erickson-Davis, M. (2018, March 12). ''Sarawak makes 80% forest preservation commitment, but some have doubts''. Mongabay. <nowiki>https://news.mongabay.com/2018/03/sarawak-makes-80-forest-preservation-commitment-but-some-have-doubts/</nowiki>
* European Union. (2025, September 5). ''EU and Malaysia agree to strengthen their partnership and continue their joint efforts against deforestation''. <nowiki>https://www.eeas.europa.eu/delegations/malaysia/eu-and-malaysia-agree-strengthen-their-partnership-and-continue-their-joint-efforts-against_en</nowiki>
* Forest Department Sarawak. (2026, March 27). ''Forest Department Sarawak''. <nowiki>https://forestry.sarawak.gov.my/web/home/index/</nowiki>
* Forests Ordinance, 2015, c. 71 (Sarawak). (2015). ''Laws of Sarawak''. <nowiki>https://lawnet.sarawak.gov.my/lawnet_file/Ordinance/ORD_Watermark.pdf</nowiki>
* Funds for NGOs. (2024, October 15). ''NGOs urge EU to designate Sarawak as “high risk” for timber and palm oil''. <nowiki>https://news.fundsforngos.org/2024/10/15/ngos-urge-eu-to-designate-sarawak-as-high-risk-for-timber-and-palm-oil/</nowiki>
* Global Forest Watch. (n.d.). ''Malaysia''. <nowiki>https://www.globalforestwatch.org/dashboards/country/MYS/14/</nowiki>
* Human Rights Watch. (2024, September 23). ''EU: Address Indigenous rights violations in Malaysian imports: Designate Sarawak as “high risk” under new anti-deforestation law''. <nowiki>https://www.hrw.org/news/2024/09/23/eu-address-indigenous-rights-violations-malaysian-imports</nowiki>
* Institute of Strategic and International Studies Malaysia (ISIS Malaysia), & Universiti Putra Malaysia (UPM). (2024a). ''Availability of EU deforestation regulation relevant information for the palm oil sector in Malaysia'' (Policy Brief No. 2). <nowiki>https://www.isis.org.my/wp-content/uploads/2024/11/Policy-brief-2-Malaysia-data-readiness-for-EUDR_layout2.pdf</nowiki>
* Institute of Strategic and International Studies Malaysia (ISIS Malaysia), & Universiti Putra Malaysia (UPM). (2024b). ''Reinforcing deforestation‑free palm oil supply chains: Options for Malaysia in the context of EU and global legislation''. European Forest Institute. <nowiki>https://efi.int/sites/default/files/files/flegtredd/KAMI/Resources/Deforestation_free_supply_chains_for_palm_oil_2.pdf</nowiki>
* Jong, H. N. (2023, September 1). ''Palm oil giants Indonesia, Malaysia start talks with EU over deforestation rule''. Mongabay. <nowiki>https://news.mongabay.com/2023/09/palm-oil-giants-indonesia-malaysia-start-talks-with-eu-over-deforestation-rule/</nowiki>
* Keeton-Olsen, D. (2021, February 18). ''In Malaysian Borneo’s rainforests, powerful state governments set their own rules''. Mongabay. <nowiki>https://news.mongabay.com/2021/02/in-malaysian-borneos-rainforests-powerful-state-government-set-their-own-rules/</nowiki>
* Keeton-Olsen, D. (2024, October 9). ''NGOs push EU to label Sarawak as “high risk” source of timber, palm oil''. Mongabay. <nowiki>https://news.mongabay.com/2024/10/ngos-push-eu-to-label-sarawak-as-high-risk-source-of-timber-palm-oil/</nowiki>
* Keeton-Olsen, D. (2025, November 11). ''Cautious win for Indigenous groups in Malaysia as palm oil firm pauses forest clearing''. Mongabay. <nowiki>https://news.mongabay.com/2025/11/cautious-win-for-indigenous-groups-in-malaysia-as-palm-oil-firm-pauses-forest-clearing/</nowiki>
* Koh, J., Johari, S., Shuib, A., Siow, M. L., & Matthew, N. K. (2023). Malaysia’s forest pledges and the Bornean state of Sarawak: A policy perspective. ''Sustainability, 15''(2), 1385. <nowiki>https://doi.org/10.3390/su15021385</nowiki>
* Kumaran, S., Chew, J. S., & Nambiappan, B. (2021). ''Moving forward with mandatory MSPO certification standards''. ''Oil Palm Industry Economic Journal, 21''(1), 1–12. <nowiki>https://doi.org/10.21894/opiej.2021.01</nowiki>
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* Meridia. (2025, May 28). ''EUDR benchmarking and risk categories explained: A simple guide''. <nowiki>https://www.meridia.land/blog/eudr-benchmarking-and-risk-categories-explained-a-simple-guide</nowiki>
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* Mohammad, H. H., Ripot, S., Alek, R. J., Cluny, W., & Kader, W. A. (2022). ''Sustainable forest management: Sarawak’s perspective''. Forest Department Sarawak. <nowiki>https://www.forestry.gov.my/images/pengumuman/2022/MFC/MFC2024/paperwork/Paper_2_Sustainable_Forest_Management_Sarawaks_Perspective.pdf</nowiki>
* Proforest. (2025). ''Options to broaden smallholder inclusivity in legal and deforestation-free palm oil supply chains in Malaysia''. European Forest Institute. <nowiki>https://efi.int/sites/default/files/files/flegtredd/KAMI/Resources/smallholder_inclusivity_report.pdf</nowiki>
* Reuters. (2025, September 10). ''EU clears Malaysia's palm oil certification for new deforestation rule''. <nowiki>https://www.reuters.com/markets/commodities/eu-clears-malaysias-palm-oil-certification-new-deforestation-rule-2025-09-10/</nowiki>
* Ross, J. (2026, March 3). Malaysia warns CITES push on tropical timber is self‑interest, not science. Wood Central. <nowiki>https://woodcentral.com.au/malaysia-warns-cites-push-on-tropical-timber-is-self-interest-not-science/</nowiki>
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* Sarmiento, F., Larrea, C., Oeschger, A., & Jose, R. (2024, February 21). ''Measures to enhance forest conservation and reduce deforestation: Viewpoints and lessons from producing countries''. International Institute for Sustainable Development. <nowiki>https://www.iisd.org/ssi/publications/measures-enhance-forest-conservation-reduce-deforestation/</nowiki>
* Tan, L. C., Toh, M. L., Looi, K. S., Tan, W. V., Ujang, M. U., Thoo, A. C., Azri, N. S. b., & Kathitasapathy, S. A. L. (2023). Towards “good” Native land governance: An evaluation in Sarawak, Malaysia. ''The International Indigenous Policy Journal, 14''(1). <nowiki>https://doi.org/10.18584/iipj.2023.14.1.13873</nowiki>
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* Teja, N. (2024, February 8). ''EU deforestation regulation dubbed a ‘double-edged sword’ for global palm oil markets''. Sustainable Views. <nowiki>https://www.sustainableviews.com/eu-deforestation-regulation-dubbed-a-double-edged-sword-for-global-palm-oil-markets/</nowiki>
* The Borneo Project. (2024, September 26). ''Why Sarawak should be high risk under the new EU deforestation rules''. <nowiki>https://borneoproject.org/why-sarawak-should-be-high-risk-under-the-new-eu-deforestation-rules/</nowiki>
* The Borneo Project. (2025a, January 10). ''Deforestation alert: Ulu Belaga''. <nowiki>https://borneoproject.org/deforestation-alert-ulu-belaga/</nowiki>
* The Borneo Project. (2025b, October 30). ''Victory for Indigenous communities in Sarawak as Urun Plantations halts forest clearing''. <nowiki>https://borneoproject.org/victory-for-indigenous-communities-in-sarawak-as-urun-plantations-halts-forest-clearing/</nowiki>
* UKAS. (2025a, September 19). ''Palm oil overtakes crude petroleum as Sarawak’s leading export''. Premier of Sarawak Department. <nowiki>https://premierdept.sarawak.gov.my/web/subpage/news_view/25115/UKAS</nowiki>
* UKAS. (2025b, January 17). ''Sarawak Cabinet works collectively for the well-being of the people''. Government of Sarawak. <nowiki>https://premierdept.sarawak.gov.my/web/subpage/news_view/11717/UKAS#:~:text=%E2%80%9COur%20cabinet%20operates%20on%20a%20collective%20system,economy%2C%20and%20that%20is%20the%20result%20of</nowiki>

== Notes ==
[[Category:Forestry]]

Documentation:Sarawak’s Forest Governance under the European Union Deforestation Regulation: Policy Options for the Premier of the State of Sarawak, Malaysia

2026-05-15T20:51:54Z

WillEngle: /* Background */

Documentation:Sarawak’s Forest Governance under the European Union Deforestation Regulation: Policy Options for the Premier of the State of Sarawak, Malaysia

2026-05-15T20:48:45Z

WillEngle: /* Background */

Oil palm and timber plantations expansion have been noted as the primary drivers of deforestation in Sarawak<ref>By 2024, Sarawak had lost 1.7 million hectares of humid primary forest, a 23% decline in its overall primary forest area (Global Forest Watch, n.d.).</ref> (Sarawak Report, 2024). This has created a significant governance challenge under the European Union Deforestation Regulation (EUDR) which came into force on 29<sup>th</sup> June 2023 requiring commodities entering the EU market to be deforestation-free and legally produced with a post-2020 deforestation cutoff<ref>Continued forest loss and land-rights disputes risk “high-risk” classification, which could threaten Sarawak’s EU market access (Funds for NGOs, 2024). </ref> (The Borneo Project, 2024).

= List of Abbreviations =

'''EUDR - European Union Deforestation Regulation'''

'''FPIC - Free, Prior and Informed Consent'''

'''ISIS - Institute of Strategic and International Studies'''

'''ISPO - Indonesian Sustainable Palm Oil'''

'''MSPO - Malaysian Sustainable Palm Oil'''

'''NCR - Native Customary Rights'''

'''UPM - Universiti Putra Malaysia'''

'''WTO - World Trade Organisation'''

== Background ==
The EUDR has increased pressure on producers with compliance depending on strict plot-level geolocation and supply-chain traceability requirements, limiting the scope for diverting commodities to alternative markets (Human Rights Watch, 2024).

Malaysia has challenged the EUDR, framing it as a form of disguised protectionism and a trade barrier that places disproportionate burdens on smallholders in its formal complaint to the WTO, this has introduced further uncertainty (Brasier, 2024; Teja, 2024).

Malaysia has relied on the Malaysian Sustainable Palm Oil (MSPO) certification scheme, alongside existing legal frameworks under the Land Code and Forest Ordinance, to address raised sustainability concerns (ISIS Malaysia & UPM, 2024a, 2024b). The EU has recognised the scheme as a credible certification framework that could support compliance with the EUDR, due to the incorporation of digital traceability tools that strengthen supply-chain transparency (Reuters, 2025).

However, despite these policy advancements, forest loss remains significant, with approximately 85,100 hectares cleared in 2023<ref>This has contributed to a cumulative decline of about 1.04 million acres between 2019 and 2023. Furthermore, associated analysis suggests that logging and oil palm expansion continue to threaten extensive areas of naturally regenerating forest (Keeton-Olsen, 2024).</ref> (Funds for NGOs, 2024) See figure 1 below for extent of plantation expansion. This has been intensified by the state’s target of one million hectares of timber plantations, requiring the clearance of over 400,000 hectares of natural forest (The Borneo Project, 2024).

'''Figure 1: Extent of Plantation Concessions in Sarawak'''
[[File:Extent_of_Plantation_Concessions_in_Sarawak.png|center|thumb|Extent of Plantation Concessions in Sarawak; Source: Erickson-Davis (2018)|500x500px]]

Local tensions too, have escalated with Long Urun recording over 40,000 satellite‑detected deforestation alerts, with nearly 500 hectares of forest lost. This triggered petitions and blockades after official avenues failed. International pressure later prompted a temporary moratorium (Keeton‑Olsen, 2025; The Borneo Project, 2025a, 2025b). (See figure 2 below, for extent).

'''Figure 2: Land Clearing Captured in Long Urun on September 24, 2025'''
[[File:Land_Clearing_Captured_in_Long_Urun.png|center|thumb|Land Clearing Captured in Long Urun; Source: Keeton-Olsen (2025)|500x500px]]Furthermore, Sarawak’s Land Code has been criticized for limiting the legal recognition of Indigenous Native Customary Rights (NCR) lands while enabling commercial access to forested areas through state-issued leases<ref>Additionally, although the legal framework requires the voluntary surrender or termination of customary land and compensation prior to commercial allocation, implementation has been noted to be inconsistent in practice (Human Rights Watch, 2024).</ref> (The Borneo Project, 2025a, 2025b).

These governance challenges have strengthened calls by civil society organisations urging the EU to classify Sarawak as a high-risk jurisdiction which would increase regulatory scrutiny of exports to EU markets (Keeton-Olsen, 2024). Given the importance of European markets for Malaysia’s palm oil<ref>The EU represents a key destination for Malaysian palm oil, ranking as the third-largest market after India and China. In 2023, palm oil exports from Malaysia to the EU totaled 1.07 million tonnes, accounting for 7.1% of the country’s overall palm oil exports (Proforest, 2025).</ref> and timber sectors<ref>EU countries are significant importers of Malaysian forestry goods, with the Netherlands and Germany ranking as the second- and third-largest purchasers of nationally certified timber from Malaysia in 2022(Keeton-Olsen, 2024).</ref>, strengthening forest governance and ensuring compliance are paramount (Human Rights Watch, 2024).

== Key Actors ==
At the international level, EU institutions act as external regulators through EUDR requirements, shaping market access and compliance expectations. International NGOs and consumer brands exert influence through supply chain pressure, exemplified by the sourcing suspensions linked to plantation expansion in Long Urun (The Borneo Project, 2025a, 2025b).

At the national level, federal institutions such as the Malaysian Palm Oil Council, Ministry of Investment, Trade and Industry, Ministry of Plantation and Commodities, Malaysian Timber Industry Board, influence the broader economic and regulatory environment through export policy, trade negotiations, and sustainability certification systems, while engaging directly with the EU on EUDR compliance (ISIS Malaysia & UPM, 2024a, 2024b; Kumaran et al., 2021; Reuters, 2025). They continue to lead Malaysia’s challenge to the EUDR at the WTO (Brasier, 2024; Teja, 2024).

At the sub-national level, the Sarawak state government holds primary authority over land allocation, forest classification, and plantation licensing through the Sarawak Ministry of Natural Resources and Urban Development<ref>Operational authority is implemented through several key agencies. The Sarawak Forest Department oversees forest classification, management, and the issuance of timber licences, while the Sarawak Land and Survey Department is responsible for land allocation, land registration, and matters related to NCR land. In parallel, the Sarawak Forestry Corporation is mandated to manage conservation efforts, including protected areas and biodiversity (Forest Department Sarawak, 2026; Land and Survey Department Sarawak, 2026; Sarawak Forestry Corporation, 2026).</ref> (Ministry of Urban Development and Natural Resources, 2026). This enables it to approve timber concessions and oil palm expansion<ref>Power at this level remains closely aligned with major corporations, whose political and economic influence continue to shape development priorities and regulatory enforcement (Tan et al., 2023; Koh et al., 2023). </ref> (Keeton-Olsen, 2021; Mohammad et al., 2022).

At the local level, Indigenous communities alongside forest-dependent households, smallholders, and plantation workers, are most directly affected by these governance dynamics<ref>It has been observed that smallholder farmers are more unlikely to satisfy the legality and sustainability requirements stipulated by the EUDR, as financial and structural constraints could limit their capacity to comply, thereby risking their exclusion from this vital global supply chain (Jong, 2023).</ref>. They rely on NCR lands for livelihoods and cultural continuity but face persistent barriers to formal recognition under Sarawak’s Land Code (Human Rights Watch, 2024). Forest conversion threatens their subsistence resources, fuels local conflicts, exposing smallholders and labourers to economic risks<ref>Compliance with the EUDR will therefore require significant financial, technical, and institutional support from government and industry stakeholders (Proforest, 2025).</ref> (Funds for NGOs, 2024).

== Policy options ==

=== '''Option 1: Status Quo''' ===
Herein, enforcement would continue through current state mechanisms under the Land Code and Forest Ordinance alongside the MSPO certification framework. This approach preserves current development trajectories centred on oil palm and timber expansion<ref>This option largely reflects existing approaches, which have not fully curbed deforestation or addressed persistent traceability and enforcement gaps (The Borneo Project, 2024).</ref> (Human Rights Watch, 2024; UKAS, 2025a).

Continued forest loss would likely persist, reinforcing international scrutiny from regulators, civil society organisations, and consumer brands concerned (Funds for NGOs, 2024; The Borneo Project, 2024). Sarawak could face heightened due-diligence requirements or potential classification as a “high-risk” jurisdiction, increasing transaction costs (ISIS Malaysia & UPM, 2024a, 2024b). See figure 3 below for due-diligence requirements.

Figure 3: Due Diligence Requirements Under Articles 9, 10 and 11 of the EUDR
[[File:Due_Diligence_Requirements_Under_Articles_9,_10_and_11_of_the_EUDR.png|center|thumb|Due Diligence Requirements Under Articles 9, 10 and 11 of the EUDR; Source: ISIS Malaysia, & UPM, 2024b|500x500px]]

The main benefit of this would be that plantation expansion proceeds without disruption, industry actors avoid new compliance costs, while state revenues linked to land-based development would remain stable in the near term (Koh et al., 2023; Tan et al., 2023).

Authority over routine enforcement priorities, administrative coordination, and public communication would be retained while avoiding initiating legislative or regulatory reforms (Forests Ordinance, 2015). This would favour plantation and timber interests while minimising confrontation with powerful industry actors. Winners would include large agribusiness firms and political actors aligned with expansion, while losers would include forest-dependent communities, environmentally oriented exporters, and stakeholders seeking stronger sustainability compliance (Human Rights Watch, 2024; The Borneo Project, 2024).

=== '''Option 2: Compliance and Traceability Strategy''' ===
This would strengthen supply-chain transparency and traceability systems while allowing continued land conversion within existing regulatory limits as seen in Indonesia which was able to achieve compliance and traceability through its mandatory national certification system, the Indonesian Sustainable Palm Oil (ISPO) scheme, paired with forest-use restrictions, audits, and traceability rules for the palm oil supply chain<ref>ISPO made compliance a legal requirement rather than a purely voluntary market choice with traceability being strengthened by requiring certified operators to identify the source of fresh fruit bunches and disclosure of supplier and buyer relationships within the value chain (Sarmiento et al., 2024).</ref> (Sarmiento et al., 2024).

Measures would include improving geolocation data, integrating plantation licensing databases, strengthening MSPO 2.0 implementation, and supporting smallholders in meeting certification requirements<ref>This will be critical given the EUDR’s post-2020 cutoff, as traceability systems must be capable of distinguishing between compliant and non-compliant production areas. This could reduce the feasibility of simply redirecting exports to alternative markets, reinforcing the need for system-wide transparency (The Borneo Project, 2024).</ref> (ISIS Malaysia & UPM, 2024a, 2024b; Reuters, 2025).

Strengthening digital monitoring systems, verification mechanisms, and compliance support programmes would require public funding and institutional coordination (Forests Ordinance, 2015). Smallholders may face additional reporting burdens, while some companies may resist transparency requirements. Reforms may also remain procedural rather than substantive if underlying drivers of deforestation remain unchanged (The Borneo Project, 2024).

Enhanced traceability and compliance systems would demonstrate legality and supply-chain transparency to EU regulators and international buyers with export-oriented producers gaining more secure access to European markets, while improved governance systems could increase investor confidence, reducing trade disruptions (Ross, 2026).

Exercising of direct control over monitoring systems, enforcement transparency, and state-level compliance infrastructure would be facilitated but would require coordination with federal agencies responsible for certification and export promotion as well as cabinet support for budget allocations and inter-agency mandates (Forests Ordinance, 2015). This would appeal to export-oriented firms and federal trade authorities while avoiding major restrictions on plantation expansion. Winners would include compliant exporters and supported smallholders, while non-compliant operators would face greater scrutiny (Human Rights Watch, 2024).

=== '''Option 3: Forest Protection and Land Governance Reform''' ===
This would ensure stronger land-use regulation and governance reform. Measures will include a moratorium on new plantations in natural forests and peatlands, expansion of protected forest areas, stricter enforcement of land-conversion rules, and improved recognition of Indigenous NCR alongside Free, Prior and Informed Consent (FPIC) requirements for development projects (Human Rights Watch, 2024; The Borneo Project, 2024).

Stricter land-use controls could slow plantation expansion, potentially reducing short-term revenue from land-based development with enforcement capacity needing strengthening. Compensation or renegotiation of existing concessions would also need to be carried out to minimize legal disputes as well as boost investor confidence (Koh et al., 2023; Tan et al., 2023). Peru was able to achieve similar structural reforms by pairing land and forest formalization with clearer rules, stronger institutions, and incentives that brought informal actors into the legal system <ref>This involved moving from informal, insecure land use to formal, contract-based forest access through the creation of Agroforestry Concessions and reorganization of land into forest-use zones. The reform worked by giving smallholders a legal path into the system instead of leaving them invisible to the state (Sarmiento et al., 2024).</ref>(Sarmiento et al., 2024).

Stronger forest protection would result, reducing deforestation, improving biodiversity conservation, while decreasing land-rights conflicts with Indigenous communities (Sarmiento et al., 2024). Alignment with the EUDR would also strengthen Sarawak’s credibility (Tang, 2025; Reuters, 2025).

Control of enforcement priorities and administrative measures would be enabled. However, major reforms focusing on land-law amendments and protected-area designations would require approval from the State Legislative Assembly and coordination with federal authorities (Forests Ordinance, 2015). This option may face resistance from agribusiness interests but would gain support from civil society, Indigenous communities, and international partners. Winners would include forest-dependent communities, sustainable producers, and long-term exporters, while firms reliant on expansion and land-conversion revenues may incur losses (ISIS Malaysia & UPM, 2024a, 2024b; Mohammad et al., 2022).

== Recommended Policy option ==
A hybrid strategy would be the most viable approach, beginning with Option 2 and transitioning toward Option 3. Strengthening traceability, MSPO 2.0 implementation, and monitoring systems would provide immediate protection of EU market access, which is critical given Sarawak’s export dependence and exposure to EUDR requirements (Sarmiento et al., 2024; UKAS, 2025). This approach is politically feasible, avoids abrupt disruption, while building on the required administrative capacity for deeper reforms (Sarmiento et al., 2024).

However, compliance alone may not address the underlying deforestation drivers. A phased transition towards stronger land-use regulation and recognition of NCR and FPIC is necessary for long-term sustainability (Sarmiento et al., 2024; The Borneo Project, 2024). This would counter the state–corporate bias by empowering Indigenous voices via NCR/FPIC, while using traceability to appease exporters (Human Rights Watch, 2024). While Malaysia’s WTO challenge may reshape future obligations, it does not eliminate the immediate need for compliance (Brasier, 2024; Teja, 2024). This combined approach balances short-term trade imperatives with longer-term governance reform.

== Decision Timeline, Next Steps, and Key Milestones ==
The approach should be adopted by 30 March 2026 to allow sufficient lead time for implementation before the EUDR takes effect. It will apply from 30 December 2026 for large operators and traders, and from 30 June 2027 for micro- and small enterprises (European Commission, 2024). In addition, the EU’s risk benchmarking review, expected in May 2026, may shape Malaysia’s classification as high or standard risk, making early preparation paramount (Meridia, 2025).

Implementation should proceed in phases. In April 2026, an inter-agency taskforce should be convened to coordinate traceability mapping. In May 2026, Cabinet should decide on budget allocations and whether Land Code amendments will be pursued. June 2026 should mark the launch of smallholder support pilots and stakeholder forums, followed by quarterly deforestation monitoring reports. In Q2 2026, legislative reforms could be considered during the State Assembly session, while a federal MSPO audit is expected in Q3 2026. Large-firm pilots should begin in December 2026, with scale-up decisions made in late 2026 ahead of April 2027 compliance checks.

= References =

* Brasier, P.-J. S. (2024, September 18). ''Heated debates about the EUDR are missing the bigger picture''. Fern. <nowiki>https://www.fern.org/pt/publications-insight/article/heated-debates-about-the-eudr-are-missing-the-bigger-picture/</nowiki>
* Erickson-Davis, M. (2018, March 12). ''Sarawak makes 80% forest preservation commitment, but some have doubts''. Mongabay. <nowiki>https://news.mongabay.com/2018/03/sarawak-makes-80-forest-preservation-commitment-but-some-have-doubts/</nowiki>
* European Union. (2025, September 5). ''EU and Malaysia agree to strengthen their partnership and continue their joint efforts against deforestation''. <nowiki>https://www.eeas.europa.eu/delegations/malaysia/eu-and-malaysia-agree-strengthen-their-partnership-and-continue-their-joint-efforts-against_en</nowiki>
* Forest Department Sarawak. (2026, March 27). ''Forest Department Sarawak''. <nowiki>https://forestry.sarawak.gov.my/web/home/index/</nowiki>
* Forests Ordinance, 2015, c. 71 (Sarawak). (2015). ''Laws of Sarawak''. <nowiki>https://lawnet.sarawak.gov.my/lawnet_file/Ordinance/ORD_Watermark.pdf</nowiki>
* Funds for NGOs. (2024, October 15). ''NGOs urge EU to designate Sarawak as “high risk” for timber and palm oil''. <nowiki>https://news.fundsforngos.org/2024/10/15/ngos-urge-eu-to-designate-sarawak-as-high-risk-for-timber-and-palm-oil/</nowiki>
* Global Forest Watch. (n.d.). ''Malaysia''. <nowiki>https://www.globalforestwatch.org/dashboards/country/MYS/14/</nowiki>
* Human Rights Watch. (2024, September 23). ''EU: Address Indigenous rights violations in Malaysian imports: Designate Sarawak as “high risk” under new anti-deforestation law''. <nowiki>https://www.hrw.org/news/2024/09/23/eu-address-indigenous-rights-violations-malaysian-imports</nowiki>
* Institute of Strategic and International Studies Malaysia (ISIS Malaysia), & Universiti Putra Malaysia (UPM). (2024a). ''Availability of EU deforestation regulation relevant information for the palm oil sector in Malaysia'' (Policy Brief No. 2). <nowiki>https://www.isis.org.my/wp-content/uploads/2024/11/Policy-brief-2-Malaysia-data-readiness-for-EUDR_layout2.pdf</nowiki>
* Institute of Strategic and International Studies Malaysia (ISIS Malaysia), & Universiti Putra Malaysia (UPM). (2024b). ''Reinforcing deforestation‑free palm oil supply chains: Options for Malaysia in the context of EU and global legislation''. European Forest Institute. <nowiki>https://efi.int/sites/default/files/files/flegtredd/KAMI/Resources/Deforestation_free_supply_chains_for_palm_oil_2.pdf</nowiki>
* Jong, H. N. (2023, September 1). ''Palm oil giants Indonesia, Malaysia start talks with EU over deforestation rule''. Mongabay. <nowiki>https://news.mongabay.com/2023/09/palm-oil-giants-indonesia-malaysia-start-talks-with-eu-over-deforestation-rule/</nowiki>
* Keeton-Olsen, D. (2021, February 18). ''In Malaysian Borneo’s rainforests, powerful state governments set their own rules''. Mongabay. <nowiki>https://news.mongabay.com/2021/02/in-malaysian-borneos-rainforests-powerful-state-government-set-their-own-rules/</nowiki>
* Keeton-Olsen, D. (2024, October 9). ''NGOs push EU to label Sarawak as “high risk” source of timber, palm oil''. Mongabay. <nowiki>https://news.mongabay.com/2024/10/ngos-push-eu-to-label-sarawak-as-high-risk-source-of-timber-palm-oil/</nowiki>
* Keeton-Olsen, D. (2025, November 11). ''Cautious win for Indigenous groups in Malaysia as palm oil firm pauses forest clearing''. Mongabay. <nowiki>https://news.mongabay.com/2025/11/cautious-win-for-indigenous-groups-in-malaysia-as-palm-oil-firm-pauses-forest-clearing/</nowiki>
* Koh, J., Johari, S., Shuib, A., Siow, M. L., & Matthew, N. K. (2023). Malaysia’s forest pledges and the Bornean state of Sarawak: A policy perspective. ''Sustainability, 15''(2), 1385. <nowiki>https://doi.org/10.3390/su15021385</nowiki>
* Kumaran, S., Chew, J. S., & Nambiappan, B. (2021). ''Moving forward with mandatory MSPO certification standards''. ''Oil Palm Industry Economic Journal, 21''(1), 1–12. <nowiki>https://doi.org/10.21894/opiej.2021.01</nowiki>
* Land and Survey Department Sarawak. (2026, March 27). ''Land and Survey Department Sarawak''. <nowiki>https://landsurvey.sarawak.gov.my/web/home/index/</nowiki>
* Low, C. C. (2024, July 4). ''Timber grab: The truth behind Pahang oil palm plantations in Malaysia''. Asian Dispatch. <nowiki>https://www.asiandispatch.net/timber-grab-the-truth-behind-pahang-oil-palm-plantations-in-malaysia</nowiki>
* Meridia. (2025, May 28). ''EUDR benchmarking and risk categories explained: A simple guide''. <nowiki>https://www.meridia.land/blog/eudr-benchmarking-and-risk-categories-explained-a-simple-guide</nowiki>
* Ministry of Urban Development and Natural Resources. (2026, March 20). ''MUDeNR – Sarawak''. <nowiki>https://mudenr.sarawak.gov.my/web/home/index/</nowiki>
* Mohammad, H. H., Ripot, S., Alek, R. J., Cluny, W., & Kader, W. A. (2022). ''Sustainable forest management: Sarawak’s perspective''. Forest Department Sarawak. <nowiki>https://www.forestry.gov.my/images/pengumuman/2022/MFC/MFC2024/paperwork/Paper_2_Sustainable_Forest_Management_Sarawaks_Perspective.pdf</nowiki>
* Proforest. (2025). ''Options to broaden smallholder inclusivity in legal and deforestation-free palm oil supply chains in Malaysia''. European Forest Institute. <nowiki>https://efi.int/sites/default/files/files/flegtredd/KAMI/Resources/smallholder_inclusivity_report.pdf</nowiki>
* Reuters. (2025, September 10). ''EU clears Malaysia's palm oil certification for new deforestation rule''. <nowiki>https://www.reuters.com/markets/commodities/eu-clears-malaysias-palm-oil-certification-new-deforestation-rule-2025-09-10/</nowiki>
* Ross, J. (2026, March 3). Malaysia warns CITES push on tropical timber is self‑interest, not science. Wood Central. <nowiki>https://woodcentral.com.au/malaysia-warns-cites-push-on-tropical-timber-is-self-interest-not-science/</nowiki>
* Sarawak Forestry Corporation. (2026, March 20). ''Sarawak Forestry Corporation''. <nowiki>https://sfc.sarawak.gov.my/web/home/index/</nowiki>
* Sarawak Report. (2024, June 2). ''Malaysia’s rainforest threat is focused on Sarawak''. <nowiki>https://www.sarawakreport.org/2024/06/malaysias-rainforest-threat-is-focused-on-sarawak/</nowiki>
* Sarmiento, F., Larrea, C., Oeschger, A., & Jose, R. (2024, February 21). ''Measures to enhance forest conservation and reduce deforestation: Viewpoints and lessons from producing countries''. International Institute for Sustainable Development. <nowiki>https://www.iisd.org/ssi/publications/measures-enhance-forest-conservation-reduce-deforestation/</nowiki>
* Tan, L. C., Toh, M. L., Looi, K. S., Tan, W. V., Ujang, M. U., Thoo, A. C., Azri, N. S. b., & Kathitasapathy, S. A. L. (2023). Towards “good” Native land governance: An evaluation in Sarawak, Malaysia. ''The International Indigenous Policy Journal, 14''(1). <nowiki>https://doi.org/10.18584/iipj.2023.14.1.13873</nowiki>
* Tang, A. (2025, October 8). ''EU delays deforestation rule to Dec 2026''. ''Sarawak Tribune''. <nowiki>https://www.sarawaktribune.com/eu-delays-deforestation-rule-to-december-2026/</nowiki>
* Teja, N. (2024, February 8). ''EU deforestation regulation dubbed a ‘double-edged sword’ for global palm oil markets''. Sustainable Views. <nowiki>https://www.sustainableviews.com/eu-deforestation-regulation-dubbed-a-double-edged-sword-for-global-palm-oil-markets/</nowiki>
* The Borneo Project. (2024, September 26). ''Why Sarawak should be high risk under the new EU deforestation rules''. <nowiki>https://borneoproject.org/why-sarawak-should-be-high-risk-under-the-new-eu-deforestation-rules/</nowiki>
* The Borneo Project. (2025a, January 10). ''Deforestation alert: Ulu Belaga''. <nowiki>https://borneoproject.org/deforestation-alert-ulu-belaga/</nowiki>
* The Borneo Project. (2025b, October 30). ''Victory for Indigenous communities in Sarawak as Urun Plantations halts forest clearing''. <nowiki>https://borneoproject.org/victory-for-indigenous-communities-in-sarawak-as-urun-plantations-halts-forest-clearing/</nowiki>
* UKAS. (2025a, September 19). ''Palm oil overtakes crude petroleum as Sarawak’s leading export''. Premier of Sarawak Department. <nowiki>https://premierdept.sarawak.gov.my/web/subpage/news_view/25115/UKAS</nowiki>
* UKAS. (2025b, January 17). ''Sarawak Cabinet works collectively for the well-being of the people''. Government of Sarawak. <nowiki>https://premierdept.sarawak.gov.my/web/subpage/news_view/11717/UKAS#:~:text=%E2%80%9COur%20cabinet%20operates%20on%20a%20collective%20system,economy%2C%20and%20that%20is%20the%20result%20of</nowiki>

== Notes ==
[[Category:Forestry]]

Documentation:Sarawak’s Forest Governance under the European Union Deforestation Regulation: Policy Options for the Premier of the State of Sarawak, Malaysia

2026-05-15T20:47:26Z

WillEngle: /* Background */

Oil palm and timber plantations expansion have been noted as the primary drivers of deforestation in Sarawak<ref>By 2024, Sarawak had lost 1.7 million hectares of humid primary forest, a 23% decline in its overall primary forest area (Global Forest Watch, n.d.).</ref> (Sarawak Report, 2024). This has created a significant governance challenge under the European Union Deforestation Regulation (EUDR) which came into force on 29<sup>th</sup> June 2023 requiring commodities entering the EU market to be deforestation-free and legally produced with a post-2020 deforestation cutoff<ref>Continued forest loss and land-rights disputes risk “high-risk” classification, which could threaten Sarawak’s EU market access (Funds for NGOs, 2024). </ref> (The Borneo Project, 2024).

= List of Abbreviations =

'''EUDR - European Union Deforestation Regulation'''

'''FPIC - Free, Prior and Informed Consent'''

'''ISIS - Institute of Strategic and International Studies'''

'''ISPO - Indonesian Sustainable Palm Oil'''

'''MSPO - Malaysian Sustainable Palm Oil'''

'''NCR - Native Customary Rights'''

'''UPM - Universiti Putra Malaysia'''

'''WTO - World Trade Organisation'''

== Background ==
The EUDR has increased pressure on producers with compliance depending on strict plot-level geolocation and supply-chain traceability requirements, limiting the scope for diverting commodities to alternative markets (Human Rights Watch, 2024).

Malaysia has challenged the EUDR, framing it as a form of disguised protectionism and a trade barrier that places disproportionate burdens on smallholders in its formal complaint to the WTO, this has introduced further uncertainty (Brasier, 2024; Teja, 2024).

Malaysia has relied on the Malaysian Sustainable Palm Oil (MSPO) certification scheme, alongside existing legal frameworks under the Land Code and Forest Ordinance, to address raised sustainability concerns (ISIS Malaysia & UPM, 2024a, 2024b). The EU has recognised the scheme as a credible certification framework that could support compliance with the EUDR, due to the incorporation of digital traceability tools that strengthen supply-chain transparency (Reuters, 2025).

However, despite these policy advancements, forest loss remains significant, with approximately 85,100 hectares cleared in 2023<ref>This has contributed to a cumulative decline of about 1.04 million acres between 2019 and 2023. Furthermore, associated analysis suggests that logging and oil palm expansion continue to threaten extensive areas of naturally regenerating forest (Keeton-Olsen, 2024).</ref> (Funds for NGOs, 2024) See figure 1 below for extent of plantation expansion. This has been intensified by the state’s target of one million hectares of timber plantations, requiring the clearance of over 400,000 hectares of natural forest (The Borneo Project, 2024).

'''Figure 1: Extent of Plantation Concessions in Sarawak'''
[[File:Extent_of_Plantation_Concessions_in_Sarawak.png|center|thumb|Extent of Plantation Concessions in Sarawak|500x500px]]

Source: Erickson-Davis (2018)

Local tensions too, have escalated with Long Urun recording over 40,000 satellite‑detected deforestation alerts, with nearly 500 hectares of forest lost. This triggered petitions and blockades after official avenues failed. International pressure later prompted a temporary moratorium (Keeton‑Olsen, 2025; The Borneo Project, 2025a, 2025b). (See figure 2 below, for extent).

'''Figure 2: Land Clearing Captured in Long Urun on September 24, 2025'''
[[File:Land_Clearing_Captured_in_Long_Urun.png|center|thumb|Land Clearing Captured in Long Urun|500x500px]]

Source: Keeton-Olsen (2025)

Furthermore, Sarawak’s Land Code has been criticized for limiting the legal recognition of Indigenous Native Customary Rights (NCR) lands while enabling commercial access to forested areas through state-issued leases<ref>Additionally, although the legal framework requires the voluntary surrender or termination of customary land and compensation prior to commercial allocation, implementation has been noted to be inconsistent in practice (Human Rights Watch, 2024).</ref> (The Borneo Project, 2025a, 2025b).

These governance challenges have strengthened calls by civil society organisations urging the EU to classify Sarawak as a high-risk jurisdiction which would increase regulatory scrutiny of exports to EU markets (Keeton-Olsen, 2024). Given the importance of European markets for Malaysia’s palm oil<ref>The EU represents a key destination for Malaysian palm oil, ranking as the third-largest market after India and China. In 2023, palm oil exports from Malaysia to the EU totaled 1.07 million tonnes, accounting for 7.1% of the country’s overall palm oil exports (Proforest, 2025).</ref> and timber sectors<ref>EU countries are significant importers of Malaysian forestry goods, with the Netherlands and Germany ranking as the second- and third-largest purchasers of nationally certified timber from Malaysia in 2022(Keeton-Olsen, 2024).</ref>, strengthening forest governance and ensuring compliance are paramount (Human Rights Watch, 2024).

== Key Actors ==
At the international level, EU institutions act as external regulators through EUDR requirements, shaping market access and compliance expectations. International NGOs and consumer brands exert influence through supply chain pressure, exemplified by the sourcing suspensions linked to plantation expansion in Long Urun (The Borneo Project, 2025a, 2025b).

At the national level, federal institutions such as the Malaysian Palm Oil Council, Ministry of Investment, Trade and Industry, Ministry of Plantation and Commodities, Malaysian Timber Industry Board, influence the broader economic and regulatory environment through export policy, trade negotiations, and sustainability certification systems, while engaging directly with the EU on EUDR compliance (ISIS Malaysia & UPM, 2024a, 2024b; Kumaran et al., 2021; Reuters, 2025). They continue to lead Malaysia’s challenge to the EUDR at the WTO (Brasier, 2024; Teja, 2024).

At the sub-national level, the Sarawak state government holds primary authority over land allocation, forest classification, and plantation licensing through the Sarawak Ministry of Natural Resources and Urban Development<ref>Operational authority is implemented through several key agencies. The Sarawak Forest Department oversees forest classification, management, and the issuance of timber licences, while the Sarawak Land and Survey Department is responsible for land allocation, land registration, and matters related to NCR land. In parallel, the Sarawak Forestry Corporation is mandated to manage conservation efforts, including protected areas and biodiversity (Forest Department Sarawak, 2026; Land and Survey Department Sarawak, 2026; Sarawak Forestry Corporation, 2026).</ref> (Ministry of Urban Development and Natural Resources, 2026). This enables it to approve timber concessions and oil palm expansion<ref>Power at this level remains closely aligned with major corporations, whose political and economic influence continue to shape development priorities and regulatory enforcement (Tan et al., 2023; Koh et al., 2023). </ref> (Keeton-Olsen, 2021; Mohammad et al., 2022).

At the local level, Indigenous communities alongside forest-dependent households, smallholders, and plantation workers, are most directly affected by these governance dynamics<ref>It has been observed that smallholder farmers are more unlikely to satisfy the legality and sustainability requirements stipulated by the EUDR, as financial and structural constraints could limit their capacity to comply, thereby risking their exclusion from this vital global supply chain (Jong, 2023).</ref>. They rely on NCR lands for livelihoods and cultural continuity but face persistent barriers to formal recognition under Sarawak’s Land Code (Human Rights Watch, 2024). Forest conversion threatens their subsistence resources, fuels local conflicts, exposing smallholders and labourers to economic risks<ref>Compliance with the EUDR will therefore require significant financial, technical, and institutional support from government and industry stakeholders (Proforest, 2025).</ref> (Funds for NGOs, 2024).

== Policy options ==

=== '''Option 1: Status Quo''' ===
Herein, enforcement would continue through current state mechanisms under the Land Code and Forest Ordinance alongside the MSPO certification framework. This approach preserves current development trajectories centred on oil palm and timber expansion<ref>This option largely reflects existing approaches, which have not fully curbed deforestation or addressed persistent traceability and enforcement gaps (The Borneo Project, 2024).</ref> (Human Rights Watch, 2024; UKAS, 2025a).

Continued forest loss would likely persist, reinforcing international scrutiny from regulators, civil society organisations, and consumer brands concerned (Funds for NGOs, 2024; The Borneo Project, 2024). Sarawak could face heightened due-diligence requirements or potential classification as a “high-risk” jurisdiction, increasing transaction costs (ISIS Malaysia & UPM, 2024a, 2024b). See figure 3 below for due-diligence requirements.

Figure 3: Due Diligence Requirements Under Articles 9, 10 and 11 of the EUDR
[[File:Due_Diligence_Requirements_Under_Articles_9,_10_and_11_of_the_EUDR.png|center|thumb|Due Diligence Requirements Under Articles 9, 10 and 11 of the EUDR|500x500px]]

Source: ISIS Malaysia, & UPM, 2024b

The main benefit of this would be that plantation expansion proceeds without disruption, industry actors avoid new compliance costs, while state revenues linked to land-based development would remain stable in the near term (Koh et al., 2023; Tan et al., 2023).

Authority over routine enforcement priorities, administrative coordination, and public communication would be retained while avoiding initiating legislative or regulatory reforms (Forests Ordinance, 2015). This would favour plantation and timber interests while minimising confrontation with powerful industry actors. Winners would include large agribusiness firms and political actors aligned with expansion, while losers would include forest-dependent communities, environmentally oriented exporters, and stakeholders seeking stronger sustainability compliance (Human Rights Watch, 2024; The Borneo Project, 2024).

=== '''Option 2: Compliance and Traceability Strategy''' ===
This would strengthen supply-chain transparency and traceability systems while allowing continued land conversion within existing regulatory limits as seen in Indonesia which was able to achieve compliance and traceability through its mandatory national certification system, the Indonesian Sustainable Palm Oil (ISPO) scheme, paired with forest-use restrictions, audits, and traceability rules for the palm oil supply chain<ref>ISPO made compliance a legal requirement rather than a purely voluntary market choice with traceability being strengthened by requiring certified operators to identify the source of fresh fruit bunches and disclosure of supplier and buyer relationships within the value chain (Sarmiento et al., 2024).</ref> (Sarmiento et al., 2024).

Measures would include improving geolocation data, integrating plantation licensing databases, strengthening MSPO 2.0 implementation, and supporting smallholders in meeting certification requirements<ref>This will be critical given the EUDR’s post-2020 cutoff, as traceability systems must be capable of distinguishing between compliant and non-compliant production areas. This could reduce the feasibility of simply redirecting exports to alternative markets, reinforcing the need for system-wide transparency (The Borneo Project, 2024).</ref> (ISIS Malaysia & UPM, 2024a, 2024b; Reuters, 2025).

Strengthening digital monitoring systems, verification mechanisms, and compliance support programmes would require public funding and institutional coordination (Forests Ordinance, 2015). Smallholders may face additional reporting burdens, while some companies may resist transparency requirements. Reforms may also remain procedural rather than substantive if underlying drivers of deforestation remain unchanged (The Borneo Project, 2024).

Enhanced traceability and compliance systems would demonstrate legality and supply-chain transparency to EU regulators and international buyers with export-oriented producers gaining more secure access to European markets, while improved governance systems could increase investor confidence, reducing trade disruptions (Ross, 2026).

Exercising of direct control over monitoring systems, enforcement transparency, and state-level compliance infrastructure would be facilitated but would require coordination with federal agencies responsible for certification and export promotion as well as cabinet support for budget allocations and inter-agency mandates (Forests Ordinance, 2015). This would appeal to export-oriented firms and federal trade authorities while avoiding major restrictions on plantation expansion. Winners would include compliant exporters and supported smallholders, while non-compliant operators would face greater scrutiny (Human Rights Watch, 2024).

=== '''Option 3: Forest Protection and Land Governance Reform''' ===
This would ensure stronger land-use regulation and governance reform. Measures will include a moratorium on new plantations in natural forests and peatlands, expansion of protected forest areas, stricter enforcement of land-conversion rules, and improved recognition of Indigenous NCR alongside Free, Prior and Informed Consent (FPIC) requirements for development projects (Human Rights Watch, 2024; The Borneo Project, 2024).

Stricter land-use controls could slow plantation expansion, potentially reducing short-term revenue from land-based development with enforcement capacity needing strengthening. Compensation or renegotiation of existing concessions would also need to be carried out to minimize legal disputes as well as boost investor confidence (Koh et al., 2023; Tan et al., 2023). Peru was able to achieve similar structural reforms by pairing land and forest formalization with clearer rules, stronger institutions, and incentives that brought informal actors into the legal system <ref>This involved moving from informal, insecure land use to formal, contract-based forest access through the creation of Agroforestry Concessions and reorganization of land into forest-use zones. The reform worked by giving smallholders a legal path into the system instead of leaving them invisible to the state (Sarmiento et al., 2024).</ref>(Sarmiento et al., 2024).

Stronger forest protection would result, reducing deforestation, improving biodiversity conservation, while decreasing land-rights conflicts with Indigenous communities (Sarmiento et al., 2024). Alignment with the EUDR would also strengthen Sarawak’s credibility (Tang, 2025; Reuters, 2025).

Control of enforcement priorities and administrative measures would be enabled. However, major reforms focusing on land-law amendments and protected-area designations would require approval from the State Legislative Assembly and coordination with federal authorities (Forests Ordinance, 2015). This option may face resistance from agribusiness interests but would gain support from civil society, Indigenous communities, and international partners. Winners would include forest-dependent communities, sustainable producers, and long-term exporters, while firms reliant on expansion and land-conversion revenues may incur losses (ISIS Malaysia & UPM, 2024a, 2024b; Mohammad et al., 2022).

== Recommended Policy option ==
A hybrid strategy would be the most viable approach, beginning with Option 2 and transitioning toward Option 3. Strengthening traceability, MSPO 2.0 implementation, and monitoring systems would provide immediate protection of EU market access, which is critical given Sarawak’s export dependence and exposure to EUDR requirements (Sarmiento et al., 2024; UKAS, 2025). This approach is politically feasible, avoids abrupt disruption, while building on the required administrative capacity for deeper reforms (Sarmiento et al., 2024).

However, compliance alone may not address the underlying deforestation drivers. A phased transition towards stronger land-use regulation and recognition of NCR and FPIC is necessary for long-term sustainability (Sarmiento et al., 2024; The Borneo Project, 2024). This would counter the state–corporate bias by empowering Indigenous voices via NCR/FPIC, while using traceability to appease exporters (Human Rights Watch, 2024). While Malaysia’s WTO challenge may reshape future obligations, it does not eliminate the immediate need for compliance (Brasier, 2024; Teja, 2024). This combined approach balances short-term trade imperatives with longer-term governance reform.

== Decision Timeline, Next Steps, and Key Milestones ==
The approach should be adopted by 30 March 2026 to allow sufficient lead time for implementation before the EUDR takes effect. It will apply from 30 December 2026 for large operators and traders, and from 30 June 2027 for micro- and small enterprises (European Commission, 2024). In addition, the EU’s risk benchmarking review, expected in May 2026, may shape Malaysia’s classification as high or standard risk, making early preparation paramount (Meridia, 2025).

Implementation should proceed in phases. In April 2026, an inter-agency taskforce should be convened to coordinate traceability mapping. In May 2026, Cabinet should decide on budget allocations and whether Land Code amendments will be pursued. June 2026 should mark the launch of smallholder support pilots and stakeholder forums, followed by quarterly deforestation monitoring reports. In Q2 2026, legislative reforms could be considered during the State Assembly session, while a federal MSPO audit is expected in Q3 2026. Large-firm pilots should begin in December 2026, with scale-up decisions made in late 2026 ahead of April 2027 compliance checks.

= References =

* Brasier, P.-J. S. (2024, September 18). ''Heated debates about the EUDR are missing the bigger picture''. Fern. <nowiki>https://www.fern.org/pt/publications-insight/article/heated-debates-about-the-eudr-are-missing-the-bigger-picture/</nowiki>
* Erickson-Davis, M. (2018, March 12). ''Sarawak makes 80% forest preservation commitment, but some have doubts''. Mongabay. <nowiki>https://news.mongabay.com/2018/03/sarawak-makes-80-forest-preservation-commitment-but-some-have-doubts/</nowiki>
* European Union. (2025, September 5). ''EU and Malaysia agree to strengthen their partnership and continue their joint efforts against deforestation''. <nowiki>https://www.eeas.europa.eu/delegations/malaysia/eu-and-malaysia-agree-strengthen-their-partnership-and-continue-their-joint-efforts-against_en</nowiki>
* Forest Department Sarawak. (2026, March 27). ''Forest Department Sarawak''. <nowiki>https://forestry.sarawak.gov.my/web/home/index/</nowiki>
* Forests Ordinance, 2015, c. 71 (Sarawak). (2015). ''Laws of Sarawak''. <nowiki>https://lawnet.sarawak.gov.my/lawnet_file/Ordinance/ORD_Watermark.pdf</nowiki>
* Funds for NGOs. (2024, October 15). ''NGOs urge EU to designate Sarawak as “high risk” for timber and palm oil''. <nowiki>https://news.fundsforngos.org/2024/10/15/ngos-urge-eu-to-designate-sarawak-as-high-risk-for-timber-and-palm-oil/</nowiki>
* Global Forest Watch. (n.d.). ''Malaysia''. <nowiki>https://www.globalforestwatch.org/dashboards/country/MYS/14/</nowiki>
* Human Rights Watch. (2024, September 23). ''EU: Address Indigenous rights violations in Malaysian imports: Designate Sarawak as “high risk” under new anti-deforestation law''. <nowiki>https://www.hrw.org/news/2024/09/23/eu-address-indigenous-rights-violations-malaysian-imports</nowiki>
* Institute of Strategic and International Studies Malaysia (ISIS Malaysia), & Universiti Putra Malaysia (UPM). (2024a). ''Availability of EU deforestation regulation relevant information for the palm oil sector in Malaysia'' (Policy Brief No. 2). <nowiki>https://www.isis.org.my/wp-content/uploads/2024/11/Policy-brief-2-Malaysia-data-readiness-for-EUDR_layout2.pdf</nowiki>
* Institute of Strategic and International Studies Malaysia (ISIS Malaysia), & Universiti Putra Malaysia (UPM). (2024b). ''Reinforcing deforestation‑free palm oil supply chains: Options for Malaysia in the context of EU and global legislation''. European Forest Institute. <nowiki>https://efi.int/sites/default/files/files/flegtredd/KAMI/Resources/Deforestation_free_supply_chains_for_palm_oil_2.pdf</nowiki>
* Jong, H. N. (2023, September 1). ''Palm oil giants Indonesia, Malaysia start talks with EU over deforestation rule''. Mongabay. <nowiki>https://news.mongabay.com/2023/09/palm-oil-giants-indonesia-malaysia-start-talks-with-eu-over-deforestation-rule/</nowiki>
* Keeton-Olsen, D. (2021, February 18). ''In Malaysian Borneo’s rainforests, powerful state governments set their own rules''. Mongabay. <nowiki>https://news.mongabay.com/2021/02/in-malaysian-borneos-rainforests-powerful-state-government-set-their-own-rules/</nowiki>
* Keeton-Olsen, D. (2024, October 9). ''NGOs push EU to label Sarawak as “high risk” source of timber, palm oil''. Mongabay. <nowiki>https://news.mongabay.com/2024/10/ngos-push-eu-to-label-sarawak-as-high-risk-source-of-timber-palm-oil/</nowiki>
* Keeton-Olsen, D. (2025, November 11). ''Cautious win for Indigenous groups in Malaysia as palm oil firm pauses forest clearing''. Mongabay. <nowiki>https://news.mongabay.com/2025/11/cautious-win-for-indigenous-groups-in-malaysia-as-palm-oil-firm-pauses-forest-clearing/</nowiki>
* Koh, J., Johari, S., Shuib, A., Siow, M. L., & Matthew, N. K. (2023). Malaysia’s forest pledges and the Bornean state of Sarawak: A policy perspective. ''Sustainability, 15''(2), 1385. <nowiki>https://doi.org/10.3390/su15021385</nowiki>
* Kumaran, S., Chew, J. S., & Nambiappan, B. (2021). ''Moving forward with mandatory MSPO certification standards''. ''Oil Palm Industry Economic Journal, 21''(1), 1–12. <nowiki>https://doi.org/10.21894/opiej.2021.01</nowiki>
* Land and Survey Department Sarawak. (2026, March 27). ''Land and Survey Department Sarawak''. <nowiki>https://landsurvey.sarawak.gov.my/web/home/index/</nowiki>
* Low, C. C. (2024, July 4). ''Timber grab: The truth behind Pahang oil palm plantations in Malaysia''. Asian Dispatch. <nowiki>https://www.asiandispatch.net/timber-grab-the-truth-behind-pahang-oil-palm-plantations-in-malaysia</nowiki>
* Meridia. (2025, May 28). ''EUDR benchmarking and risk categories explained: A simple guide''. <nowiki>https://www.meridia.land/blog/eudr-benchmarking-and-risk-categories-explained-a-simple-guide</nowiki>
* Ministry of Urban Development and Natural Resources. (2026, March 20). ''MUDeNR – Sarawak''. <nowiki>https://mudenr.sarawak.gov.my/web/home/index/</nowiki>
* Mohammad, H. H., Ripot, S., Alek, R. J., Cluny, W., & Kader, W. A. (2022). ''Sustainable forest management: Sarawak’s perspective''. Forest Department Sarawak. <nowiki>https://www.forestry.gov.my/images/pengumuman/2022/MFC/MFC2024/paperwork/Paper_2_Sustainable_Forest_Management_Sarawaks_Perspective.pdf</nowiki>
* Proforest. (2025). ''Options to broaden smallholder inclusivity in legal and deforestation-free palm oil supply chains in Malaysia''. European Forest Institute. <nowiki>https://efi.int/sites/default/files/files/flegtredd/KAMI/Resources/smallholder_inclusivity_report.pdf</nowiki>
* Reuters. (2025, September 10). ''EU clears Malaysia's palm oil certification for new deforestation rule''. <nowiki>https://www.reuters.com/markets/commodities/eu-clears-malaysias-palm-oil-certification-new-deforestation-rule-2025-09-10/</nowiki>
* Ross, J. (2026, March 3). Malaysia warns CITES push on tropical timber is self‑interest, not science. Wood Central. <nowiki>https://woodcentral.com.au/malaysia-warns-cites-push-on-tropical-timber-is-self-interest-not-science/</nowiki>
* Sarawak Forestry Corporation. (2026, March 20). ''Sarawak Forestry Corporation''. <nowiki>https://sfc.sarawak.gov.my/web/home/index/</nowiki>
* Sarawak Report. (2024, June 2). ''Malaysia’s rainforest threat is focused on Sarawak''. <nowiki>https://www.sarawakreport.org/2024/06/malaysias-rainforest-threat-is-focused-on-sarawak/</nowiki>
* Sarmiento, F., Larrea, C., Oeschger, A., & Jose, R. (2024, February 21). ''Measures to enhance forest conservation and reduce deforestation: Viewpoints and lessons from producing countries''. International Institute for Sustainable Development. <nowiki>https://www.iisd.org/ssi/publications/measures-enhance-forest-conservation-reduce-deforestation/</nowiki>
* Tan, L. C., Toh, M. L., Looi, K. S., Tan, W. V., Ujang, M. U., Thoo, A. C., Azri, N. S. b., & Kathitasapathy, S. A. L. (2023). Towards “good” Native land governance: An evaluation in Sarawak, Malaysia. ''The International Indigenous Policy Journal, 14''(1). <nowiki>https://doi.org/10.18584/iipj.2023.14.1.13873</nowiki>
* Tang, A. (2025, October 8). ''EU delays deforestation rule to Dec 2026''. ''Sarawak Tribune''. <nowiki>https://www.sarawaktribune.com/eu-delays-deforestation-rule-to-december-2026/</nowiki>
* Teja, N. (2024, February 8). ''EU deforestation regulation dubbed a ‘double-edged sword’ for global palm oil markets''. Sustainable Views. <nowiki>https://www.sustainableviews.com/eu-deforestation-regulation-dubbed-a-double-edged-sword-for-global-palm-oil-markets/</nowiki>
* The Borneo Project. (2024, September 26). ''Why Sarawak should be high risk under the new EU deforestation rules''. <nowiki>https://borneoproject.org/why-sarawak-should-be-high-risk-under-the-new-eu-deforestation-rules/</nowiki>
* The Borneo Project. (2025a, January 10). ''Deforestation alert: Ulu Belaga''. <nowiki>https://borneoproject.org/deforestation-alert-ulu-belaga/</nowiki>
* The Borneo Project. (2025b, October 30). ''Victory for Indigenous communities in Sarawak as Urun Plantations halts forest clearing''. <nowiki>https://borneoproject.org/victory-for-indigenous-communities-in-sarawak-as-urun-plantations-halts-forest-clearing/</nowiki>
* UKAS. (2025a, September 19). ''Palm oil overtakes crude petroleum as Sarawak’s leading export''. Premier of Sarawak Department. <nowiki>https://premierdept.sarawak.gov.my/web/subpage/news_view/25115/UKAS</nowiki>
* UKAS. (2025b, January 17). ''Sarawak Cabinet works collectively for the well-being of the people''. Government of Sarawak. <nowiki>https://premierdept.sarawak.gov.my/web/subpage/news_view/11717/UKAS#:~:text=%E2%80%9COur%20cabinet%20operates%20on%20a%20collective%20system,economy%2C%20and%20that%20is%20the%20result%20of</nowiki>

== Notes ==
[[Category:Forestry]]

File:Due Diligence Requirements Under Articles 9, 10 and 11 of the EUDR.png

2026-05-15T20:46:22Z

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2026-05-15T20:46:09Z

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|source=ISIS Malaysia, & UPM, 2024b
|author=Institute of Strategic and International Studies Malaysia (ISIS Malaysia), & Universiti Putra Malaysia (UPM). (2024b). Reinforcing deforestation free palm oil supply chains: Options for Malaysia in the context of EU and global legislation. European Forest Institute.
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WillEngle:

Documentation:Sarawak’s Forest Governance under the European Union Deforestation Regulation: Policy Options for the Premier of the State of Sarawak, Malaysia

2026-05-15T20:40:19Z

WillEngle: /* Background */

Oil palm and timber plantations expansion have been noted as the primary drivers of deforestation in Sarawak<ref>By 2024, Sarawak had lost 1.7 million hectares of humid primary forest, a 23% decline in its overall primary forest area (Global Forest Watch, n.d.).</ref> (Sarawak Report, 2024). This has created a significant governance challenge under the European Union Deforestation Regulation (EUDR) which came into force on 29<sup>th</sup> June 2023 requiring commodities entering the EU market to be deforestation-free and legally produced with a post-2020 deforestation cutoff<ref>Continued forest loss and land-rights disputes risk “high-risk” classification, which could threaten Sarawak’s EU market access (Funds for NGOs, 2024). </ref> (The Borneo Project, 2024).

= List of Abbreviations =

'''EUDR - European Union Deforestation Regulation'''

'''FPIC - Free, Prior and Informed Consent'''

'''ISIS - Institute of Strategic and International Studies'''

'''ISPO - Indonesian Sustainable Palm Oil'''

'''MSPO - Malaysian Sustainable Palm Oil'''

'''NCR - Native Customary Rights'''

'''UPM - Universiti Putra Malaysia'''

'''WTO - World Trade Organisation'''

== Background ==
The EUDR has increased pressure on producers with compliance depending on strict plot-level geolocation and supply-chain traceability requirements, limiting the scope for diverting commodities to alternative markets (Human Rights Watch, 2024).

Malaysia has challenged the EUDR, framing it as a form of disguised protectionism and a trade barrier that places disproportionate burdens on smallholders in its formal complaint to the WTO, this has introduced further uncertainty (Brasier, 2024; Teja, 2024).

Malaysia has relied on the Malaysian Sustainable Palm Oil (MSPO) certification scheme, alongside existing legal frameworks under the Land Code and Forest Ordinance, to address raised sustainability concerns (ISIS Malaysia & UPM, 2024a, 2024b). The EU has recognised the scheme as a credible certification framework that could support compliance with the EUDR, due to the incorporation of digital traceability tools that strengthen supply-chain transparency (Reuters, 2025).

However, despite these policy advancements, forest loss remains significant, with approximately 85,100 hectares cleared in 2023<ref>This has contributed to a cumulative decline of about 1.04 million acres between 2019 and 2023. Furthermore, associated analysis suggests that logging and oil palm expansion continue to threaten extensive areas of naturally regenerating forest (Keeton-Olsen, 2024).</ref> (Funds for NGOs, 2024) See figure 1 below for extent of plantation expansion. This has been intensified by the state’s target of one million hectares of timber plantations, requiring the clearance of over 400,000 hectares of natural forest (The Borneo Project, 2024).

'''Figure 1: Extent of Plantation Concessions in Sarawak'''
[[File:Extent_of_Plantation_Concessions_in_Sarawak.png|center|thumb|Extent of Plantation Concessions in Sarawak]]

Source: Erickson-Davis (2018)

Local tensions too, have escalated with Long Urun recording over 40,000 satellite‑detected deforestation alerts, with nearly 500 hectares of forest lost. This triggered petitions and blockades after official avenues failed. International pressure later prompted a temporary moratorium (Keeton‑Olsen, 2025; The Borneo Project, 2025a, 2025b). (See figure 2 below, for extent).

'''Figure 2: Land Clearing Captured in Long Urun on September 24, 2025'''
[[File:Land_Clearing_Captured_in_Long_Urun.png|center|thumb|Land Clearing Captured in Long Urun]]

Source: Keeton-Olsen (2025)

Furthermore, Sarawak’s Land Code has been criticized for limiting the legal recognition of Indigenous Native Customary Rights (NCR) lands while enabling commercial access to forested areas through state-issued leases<ref>Additionally, although the legal framework requires the voluntary surrender or termination of customary land and compensation prior to commercial allocation, implementation has been noted to be inconsistent in practice (Human Rights Watch, 2024).</ref> (The Borneo Project, 2025a, 2025b).

These governance challenges have strengthened calls by civil society organisations urging the EU to classify Sarawak as a high-risk jurisdiction which would increase regulatory scrutiny of exports to EU markets (Keeton-Olsen, 2024). Given the importance of European markets for Malaysia’s palm oil<ref>The EU represents a key destination for Malaysian palm oil, ranking as the third-largest market after India and China. In 2023, palm oil exports from Malaysia to the EU totaled 1.07 million tonnes, accounting for 7.1% of the country’s overall palm oil exports (Proforest, 2025).</ref> and timber sectors<ref>EU countries are significant importers of Malaysian forestry goods, with the Netherlands and Germany ranking as the second- and third-largest purchasers of nationally certified timber from Malaysia in 2022(Keeton-Olsen, 2024).</ref>, strengthening forest governance and ensuring compliance are paramount (Human Rights Watch, 2024).

== Key Actors ==
At the international level, EU institutions act as external regulators through EUDR requirements, shaping market access and compliance expectations. International NGOs and consumer brands exert influence through supply chain pressure, exemplified by the sourcing suspensions linked to plantation expansion in Long Urun (The Borneo Project, 2025a, 2025b).

At the national level, federal institutions such as the Malaysian Palm Oil Council, Ministry of Investment, Trade and Industry, Ministry of Plantation and Commodities, Malaysian Timber Industry Board, influence the broader economic and regulatory environment through export policy, trade negotiations, and sustainability certification systems, while engaging directly with the EU on EUDR compliance (ISIS Malaysia & UPM, 2024a, 2024b; Kumaran et al., 2021; Reuters, 2025). They continue to lead Malaysia’s challenge to the EUDR at the WTO (Brasier, 2024; Teja, 2024).

At the sub-national level, the Sarawak state government holds primary authority over land allocation, forest classification, and plantation licensing through the Sarawak Ministry of Natural Resources and Urban Development<ref>Operational authority is implemented through several key agencies. The Sarawak Forest Department oversees forest classification, management, and the issuance of timber licences, while the Sarawak Land and Survey Department is responsible for land allocation, land registration, and matters related to NCR land. In parallel, the Sarawak Forestry Corporation is mandated to manage conservation efforts, including protected areas and biodiversity (Forest Department Sarawak, 2026; Land and Survey Department Sarawak, 2026; Sarawak Forestry Corporation, 2026).</ref> (Ministry of Urban Development and Natural Resources, 2026). This enables it to approve timber concessions and oil palm expansion<ref>Power at this level remains closely aligned with major corporations, whose political and economic influence continue to shape development priorities and regulatory enforcement (Tan et al., 2023; Koh et al., 2023). </ref> (Keeton-Olsen, 2021; Mohammad et al., 2022).

At the local level, Indigenous communities alongside forest-dependent households, smallholders, and plantation workers, are most directly affected by these governance dynamics<ref>It has been observed that smallholder farmers are more unlikely to satisfy the legality and sustainability requirements stipulated by the EUDR, as financial and structural constraints could limit their capacity to comply, thereby risking their exclusion from this vital global supply chain (Jong, 2023).</ref>. They rely on NCR lands for livelihoods and cultural continuity but face persistent barriers to formal recognition under Sarawak’s Land Code (Human Rights Watch, 2024). Forest conversion threatens their subsistence resources, fuels local conflicts, exposing smallholders and labourers to economic risks<ref>Compliance with the EUDR will therefore require significant financial, technical, and institutional support from government and industry stakeholders (Proforest, 2025).</ref> (Funds for NGOs, 2024).

== Policy options ==

=== '''Option 1: Status Quo''' ===
Herein, enforcement would continue through current state mechanisms under the Land Code and Forest Ordinance alongside the MSPO certification framework. This approach preserves current development trajectories centred on oil palm and timber expansion<ref>This option largely reflects existing approaches, which have not fully curbed deforestation or addressed persistent traceability and enforcement gaps (The Borneo Project, 2024).</ref> (Human Rights Watch, 2024; UKAS, 2025a).

Continued forest loss would likely persist, reinforcing international scrutiny from regulators, civil society organisations, and consumer brands concerned (Funds for NGOs, 2024; The Borneo Project, 2024). Sarawak could face heightened due-diligence requirements or potential classification as a “high-risk” jurisdiction, increasing transaction costs (ISIS Malaysia & UPM, 2024a, 2024b). See figure 3 below for due-diligence requirements.

Figure 3: Due Diligence Requirements Under Articles 9, 10 and 11 of the EUDR
[[File:Due_Diligence_Requirements_Under_Articles_9,_10_and_11_of_the_EUDR.png|center|thumb|Due Diligence Requirements Under Articles 9, 10 and 11 of the EUDR]]

Source: ISIS Malaysia, & UPM, 2024b

The main benefit of this would be that plantation expansion proceeds without disruption, industry actors avoid new compliance costs, while state revenues linked to land-based development would remain stable in the near term (Koh et al., 2023; Tan et al., 2023).

Authority over routine enforcement priorities, administrative coordination, and public communication would be retained while avoiding initiating legislative or regulatory reforms (Forests Ordinance, 2015). This would favour plantation and timber interests while minimising confrontation with powerful industry actors. Winners would include large agribusiness firms and political actors aligned with expansion, while losers would include forest-dependent communities, environmentally oriented exporters, and stakeholders seeking stronger sustainability compliance (Human Rights Watch, 2024; The Borneo Project, 2024).

=== '''Option 2: Compliance and Traceability Strategy''' ===
This would strengthen supply-chain transparency and traceability systems while allowing continued land conversion within existing regulatory limits as seen in Indonesia which was able to achieve compliance and traceability through its mandatory national certification system, the Indonesian Sustainable Palm Oil (ISPO) scheme, paired with forest-use restrictions, audits, and traceability rules for the palm oil supply chain<ref>ISPO made compliance a legal requirement rather than a purely voluntary market choice with traceability being strengthened by requiring certified operators to identify the source of fresh fruit bunches and disclosure of supplier and buyer relationships within the value chain (Sarmiento et al., 2024).</ref> (Sarmiento et al., 2024).

Measures would include improving geolocation data, integrating plantation licensing databases, strengthening MSPO 2.0 implementation, and supporting smallholders in meeting certification requirements<ref>This will be critical given the EUDR’s post-2020 cutoff, as traceability systems must be capable of distinguishing between compliant and non-compliant production areas. This could reduce the feasibility of simply redirecting exports to alternative markets, reinforcing the need for system-wide transparency (The Borneo Project, 2024).</ref> (ISIS Malaysia & UPM, 2024a, 2024b; Reuters, 2025).

Strengthening digital monitoring systems, verification mechanisms, and compliance support programmes would require public funding and institutional coordination (Forests Ordinance, 2015). Smallholders may face additional reporting burdens, while some companies may resist transparency requirements. Reforms may also remain procedural rather than substantive if underlying drivers of deforestation remain unchanged (The Borneo Project, 2024).

Enhanced traceability and compliance systems would demonstrate legality and supply-chain transparency to EU regulators and international buyers with export-oriented producers gaining more secure access to European markets, while improved governance systems could increase investor confidence, reducing trade disruptions (Ross, 2026).

Exercising of direct control over monitoring systems, enforcement transparency, and state-level compliance infrastructure would be facilitated but would require coordination with federal agencies responsible for certification and export promotion as well as cabinet support for budget allocations and inter-agency mandates (Forests Ordinance, 2015). This would appeal to export-oriented firms and federal trade authorities while avoiding major restrictions on plantation expansion. Winners would include compliant exporters and supported smallholders, while non-compliant operators would face greater scrutiny (Human Rights Watch, 2024).

=== '''Option 3: Forest Protection and Land Governance Reform''' ===
This would ensure stronger land-use regulation and governance reform. Measures will include a moratorium on new plantations in natural forests and peatlands, expansion of protected forest areas, stricter enforcement of land-conversion rules, and improved recognition of Indigenous NCR alongside Free, Prior and Informed Consent (FPIC) requirements for development projects (Human Rights Watch, 2024; The Borneo Project, 2024).

Stricter land-use controls could slow plantation expansion, potentially reducing short-term revenue from land-based development with enforcement capacity needing strengthening. Compensation or renegotiation of existing concessions would also need to be carried out to minimize legal disputes as well as boost investor confidence (Koh et al., 2023; Tan et al., 2023). Peru was able to achieve similar structural reforms by pairing land and forest formalization with clearer rules, stronger institutions, and incentives that brought informal actors into the legal system <ref>This involved moving from informal, insecure land use to formal, contract-based forest access through the creation of Agroforestry Concessions and reorganization of land into forest-use zones. The reform worked by giving smallholders a legal path into the system instead of leaving them invisible to the state (Sarmiento et al., 2024).</ref>(Sarmiento et al., 2024).

Stronger forest protection would result, reducing deforestation, improving biodiversity conservation, while decreasing land-rights conflicts with Indigenous communities (Sarmiento et al., 2024). Alignment with the EUDR would also strengthen Sarawak’s credibility (Tang, 2025; Reuters, 2025).

Control of enforcement priorities and administrative measures would be enabled. However, major reforms focusing on land-law amendments and protected-area designations would require approval from the State Legislative Assembly and coordination with federal authorities (Forests Ordinance, 2015). This option may face resistance from agribusiness interests but would gain support from civil society, Indigenous communities, and international partners. Winners would include forest-dependent communities, sustainable producers, and long-term exporters, while firms reliant on expansion and land-conversion revenues may incur losses (ISIS Malaysia & UPM, 2024a, 2024b; Mohammad et al., 2022).

== Recommended Policy option ==
A hybrid strategy would be the most viable approach, beginning with Option 2 and transitioning toward Option 3. Strengthening traceability, MSPO 2.0 implementation, and monitoring systems would provide immediate protection of EU market access, which is critical given Sarawak’s export dependence and exposure to EUDR requirements (Sarmiento et al., 2024; UKAS, 2025). This approach is politically feasible, avoids abrupt disruption, while building on the required administrative capacity for deeper reforms (Sarmiento et al., 2024).

However, compliance alone may not address the underlying deforestation drivers. A phased transition towards stronger land-use regulation and recognition of NCR and FPIC is necessary for long-term sustainability (Sarmiento et al., 2024; The Borneo Project, 2024). This would counter the state–corporate bias by empowering Indigenous voices via NCR/FPIC, while using traceability to appease exporters (Human Rights Watch, 2024). While Malaysia’s WTO challenge may reshape future obligations, it does not eliminate the immediate need for compliance (Brasier, 2024; Teja, 2024). This combined approach balances short-term trade imperatives with longer-term governance reform.

== Decision Timeline, Next Steps, and Key Milestones ==
The approach should be adopted by 30 March 2026 to allow sufficient lead time for implementation before the EUDR takes effect. It will apply from 30 December 2026 for large operators and traders, and from 30 June 2027 for micro- and small enterprises (European Commission, 2024). In addition, the EU’s risk benchmarking review, expected in May 2026, may shape Malaysia’s classification as high or standard risk, making early preparation paramount (Meridia, 2025).

Implementation should proceed in phases. In April 2026, an inter-agency taskforce should be convened to coordinate traceability mapping. In May 2026, Cabinet should decide on budget allocations and whether Land Code amendments will be pursued. June 2026 should mark the launch of smallholder support pilots and stakeholder forums, followed by quarterly deforestation monitoring reports. In Q2 2026, legislative reforms could be considered during the State Assembly session, while a federal MSPO audit is expected in Q3 2026. Large-firm pilots should begin in December 2026, with scale-up decisions made in late 2026 ahead of April 2027 compliance checks.

= References =

* Brasier, P.-J. S. (2024, September 18). ''Heated debates about the EUDR are missing the bigger picture''. Fern. <nowiki>https://www.fern.org/pt/publications-insight/article/heated-debates-about-the-eudr-are-missing-the-bigger-picture/</nowiki>
* Erickson-Davis, M. (2018, March 12). ''Sarawak makes 80% forest preservation commitment, but some have doubts''. Mongabay. <nowiki>https://news.mongabay.com/2018/03/sarawak-makes-80-forest-preservation-commitment-but-some-have-doubts/</nowiki>
* European Union. (2025, September 5). ''EU and Malaysia agree to strengthen their partnership and continue their joint efforts against deforestation''. <nowiki>https://www.eeas.europa.eu/delegations/malaysia/eu-and-malaysia-agree-strengthen-their-partnership-and-continue-their-joint-efforts-against_en</nowiki>
* Forest Department Sarawak. (2026, March 27). ''Forest Department Sarawak''. <nowiki>https://forestry.sarawak.gov.my/web/home/index/</nowiki>
* Forests Ordinance, 2015, c. 71 (Sarawak). (2015). ''Laws of Sarawak''. <nowiki>https://lawnet.sarawak.gov.my/lawnet_file/Ordinance/ORD_Watermark.pdf</nowiki>
* Funds for NGOs. (2024, October 15). ''NGOs urge EU to designate Sarawak as “high risk” for timber and palm oil''. <nowiki>https://news.fundsforngos.org/2024/10/15/ngos-urge-eu-to-designate-sarawak-as-high-risk-for-timber-and-palm-oil/</nowiki>
* Global Forest Watch. (n.d.). ''Malaysia''. <nowiki>https://www.globalforestwatch.org/dashboards/country/MYS/14/</nowiki>
* Human Rights Watch. (2024, September 23). ''EU: Address Indigenous rights violations in Malaysian imports: Designate Sarawak as “high risk” under new anti-deforestation law''. <nowiki>https://www.hrw.org/news/2024/09/23/eu-address-indigenous-rights-violations-malaysian-imports</nowiki>
* Institute of Strategic and International Studies Malaysia (ISIS Malaysia), & Universiti Putra Malaysia (UPM). (2024a). ''Availability of EU deforestation regulation relevant information for the palm oil sector in Malaysia'' (Policy Brief No. 2). <nowiki>https://www.isis.org.my/wp-content/uploads/2024/11/Policy-brief-2-Malaysia-data-readiness-for-EUDR_layout2.pdf</nowiki>
* Institute of Strategic and International Studies Malaysia (ISIS Malaysia), & Universiti Putra Malaysia (UPM). (2024b). ''Reinforcing deforestation‑free palm oil supply chains: Options for Malaysia in the context of EU and global legislation''. European Forest Institute. <nowiki>https://efi.int/sites/default/files/files/flegtredd/KAMI/Resources/Deforestation_free_supply_chains_for_palm_oil_2.pdf</nowiki>
* Jong, H. N. (2023, September 1). ''Palm oil giants Indonesia, Malaysia start talks with EU over deforestation rule''. Mongabay. <nowiki>https://news.mongabay.com/2023/09/palm-oil-giants-indonesia-malaysia-start-talks-with-eu-over-deforestation-rule/</nowiki>
* Keeton-Olsen, D. (2021, February 18). ''In Malaysian Borneo’s rainforests, powerful state governments set their own rules''. Mongabay. <nowiki>https://news.mongabay.com/2021/02/in-malaysian-borneos-rainforests-powerful-state-government-set-their-own-rules/</nowiki>
* Keeton-Olsen, D. (2024, October 9). ''NGOs push EU to label Sarawak as “high risk” source of timber, palm oil''. Mongabay. <nowiki>https://news.mongabay.com/2024/10/ngos-push-eu-to-label-sarawak-as-high-risk-source-of-timber-palm-oil/</nowiki>
* Keeton-Olsen, D. (2025, November 11). ''Cautious win for Indigenous groups in Malaysia as palm oil firm pauses forest clearing''. Mongabay. <nowiki>https://news.mongabay.com/2025/11/cautious-win-for-indigenous-groups-in-malaysia-as-palm-oil-firm-pauses-forest-clearing/</nowiki>
* Koh, J., Johari, S., Shuib, A., Siow, M. L., & Matthew, N. K. (2023). Malaysia’s forest pledges and the Bornean state of Sarawak: A policy perspective. ''Sustainability, 15''(2), 1385. <nowiki>https://doi.org/10.3390/su15021385</nowiki>
* Kumaran, S., Chew, J. S., & Nambiappan, B. (2021). ''Moving forward with mandatory MSPO certification standards''. ''Oil Palm Industry Economic Journal, 21''(1), 1–12. <nowiki>https://doi.org/10.21894/opiej.2021.01</nowiki>
* Land and Survey Department Sarawak. (2026, March 27). ''Land and Survey Department Sarawak''. <nowiki>https://landsurvey.sarawak.gov.my/web/home/index/</nowiki>
* Low, C. C. (2024, July 4). ''Timber grab: The truth behind Pahang oil palm plantations in Malaysia''. Asian Dispatch. <nowiki>https://www.asiandispatch.net/timber-grab-the-truth-behind-pahang-oil-palm-plantations-in-malaysia</nowiki>
* Meridia. (2025, May 28). ''EUDR benchmarking and risk categories explained: A simple guide''. <nowiki>https://www.meridia.land/blog/eudr-benchmarking-and-risk-categories-explained-a-simple-guide</nowiki>
* Ministry of Urban Development and Natural Resources. (2026, March 20). ''MUDeNR – Sarawak''. <nowiki>https://mudenr.sarawak.gov.my/web/home/index/</nowiki>
* Mohammad, H. H., Ripot, S., Alek, R. J., Cluny, W., & Kader, W. A. (2022). ''Sustainable forest management: Sarawak’s perspective''. Forest Department Sarawak. <nowiki>https://www.forestry.gov.my/images/pengumuman/2022/MFC/MFC2024/paperwork/Paper_2_Sustainable_Forest_Management_Sarawaks_Perspective.pdf</nowiki>
* Proforest. (2025). ''Options to broaden smallholder inclusivity in legal and deforestation-free palm oil supply chains in Malaysia''. European Forest Institute. <nowiki>https://efi.int/sites/default/files/files/flegtredd/KAMI/Resources/smallholder_inclusivity_report.pdf</nowiki>
* Reuters. (2025, September 10). ''EU clears Malaysia's palm oil certification for new deforestation rule''. <nowiki>https://www.reuters.com/markets/commodities/eu-clears-malaysias-palm-oil-certification-new-deforestation-rule-2025-09-10/</nowiki>
* Ross, J. (2026, March 3). Malaysia warns CITES push on tropical timber is self‑interest, not science. Wood Central. <nowiki>https://woodcentral.com.au/malaysia-warns-cites-push-on-tropical-timber-is-self-interest-not-science/</nowiki>
* Sarawak Forestry Corporation. (2026, March 20). ''Sarawak Forestry Corporation''. <nowiki>https://sfc.sarawak.gov.my/web/home/index/</nowiki>
* Sarawak Report. (2024, June 2). ''Malaysia’s rainforest threat is focused on Sarawak''. <nowiki>https://www.sarawakreport.org/2024/06/malaysias-rainforest-threat-is-focused-on-sarawak/</nowiki>
* Sarmiento, F., Larrea, C., Oeschger, A., & Jose, R. (2024, February 21). ''Measures to enhance forest conservation and reduce deforestation: Viewpoints and lessons from producing countries''. International Institute for Sustainable Development. <nowiki>https://www.iisd.org/ssi/publications/measures-enhance-forest-conservation-reduce-deforestation/</nowiki>
* Tan, L. C., Toh, M. L., Looi, K. S., Tan, W. V., Ujang, M. U., Thoo, A. C., Azri, N. S. b., & Kathitasapathy, S. A. L. (2023). Towards “good” Native land governance: An evaluation in Sarawak, Malaysia. ''The International Indigenous Policy Journal, 14''(1). <nowiki>https://doi.org/10.18584/iipj.2023.14.1.13873</nowiki>
* Tang, A. (2025, October 8). ''EU delays deforestation rule to Dec 2026''. ''Sarawak Tribune''. <nowiki>https://www.sarawaktribune.com/eu-delays-deforestation-rule-to-december-2026/</nowiki>
* Teja, N. (2024, February 8). ''EU deforestation regulation dubbed a ‘double-edged sword’ for global palm oil markets''. Sustainable Views. <nowiki>https://www.sustainableviews.com/eu-deforestation-regulation-dubbed-a-double-edged-sword-for-global-palm-oil-markets/</nowiki>
* The Borneo Project. (2024, September 26). ''Why Sarawak should be high risk under the new EU deforestation rules''. <nowiki>https://borneoproject.org/why-sarawak-should-be-high-risk-under-the-new-eu-deforestation-rules/</nowiki>
* The Borneo Project. (2025a, January 10). ''Deforestation alert: Ulu Belaga''. <nowiki>https://borneoproject.org/deforestation-alert-ulu-belaga/</nowiki>
* The Borneo Project. (2025b, October 30). ''Victory for Indigenous communities in Sarawak as Urun Plantations halts forest clearing''. <nowiki>https://borneoproject.org/victory-for-indigenous-communities-in-sarawak-as-urun-plantations-halts-forest-clearing/</nowiki>
* UKAS. (2025a, September 19). ''Palm oil overtakes crude petroleum as Sarawak’s leading export''. Premier of Sarawak Department. <nowiki>https://premierdept.sarawak.gov.my/web/subpage/news_view/25115/UKAS</nowiki>
* UKAS. (2025b, January 17). ''Sarawak Cabinet works collectively for the well-being of the people''. Government of Sarawak. <nowiki>https://premierdept.sarawak.gov.my/web/subpage/news_view/11717/UKAS#:~:text=%E2%80%9COur%20cabinet%20operates%20on%20a%20collective%20system,economy%2C%20and%20that%20is%20the%20result%20of</nowiki>

== Notes ==
[[Category:Forestry]]

File:Due Diligence Requirements Under Articles 9, 10 and 11 of the EUDR.png

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Documentation:Sarawak’s Forest Governance under the European Union Deforestation Regulation: Policy Options for the Premier of the State of Sarawak, Malaysia

2026-05-15T20:29:16Z

WillEngle: /* References */

Oil palm and timber plantations expansion have been noted as the primary drivers of deforestation in Sarawak<ref>By 2024, Sarawak had lost 1.7 million hectares of humid primary forest, a 23% decline in its overall primary forest area (Global Forest Watch, n.d.).</ref> (Sarawak Report, 2024). This has created a significant governance challenge under the European Union Deforestation Regulation (EUDR) which came into force on 29<sup>th</sup> June 2023 requiring commodities entering the EU market to be deforestation-free and legally produced with a post-2020 deforestation cutoff<ref>Continued forest loss and land-rights disputes risk “high-risk” classification, which could threaten Sarawak’s EU market access (Funds for NGOs, 2024). </ref> (The Borneo Project, 2024).

= List of Abbreviations =

'''EUDR - European Union Deforestation Regulation'''

'''FPIC - Free, Prior and Informed Consent'''

'''ISIS - Institute of Strategic and International Studies'''

'''ISPO - Indonesian Sustainable Palm Oil'''

'''MSPO - Malaysian Sustainable Palm Oil'''

'''NCR - Native Customary Rights'''

'''UPM - Universiti Putra Malaysia'''

'''WTO - World Trade Organisation'''

== Background ==
The EUDR has increased pressure on producers with compliance depending on strict plot-level geolocation and supply-chain traceability requirements, limiting the scope for diverting commodities to alternative markets (Human Rights Watch, 2024).

Malaysia has challenged the EUDR, framing it as a form of disguised protectionism and a trade barrier that places disproportionate burdens on smallholders in its formal complaint to the WTO, this has introduced further uncertainty (Brasier, 2024; Teja, 2024).

Malaysia has relied on the Malaysian Sustainable Palm Oil (MSPO) certification scheme, alongside existing legal frameworks under the Land Code and Forest Ordinance, to address raised sustainability concerns (ISIS Malaysia & UPM, 2024a, 2024b). The EU has recognised the scheme as a credible certification framework that could support compliance with the EUDR, due to the incorporation of digital traceability tools that strengthen supply-chain transparency (Reuters, 2025).

However, despite these policy advancements, forest loss remains significant, with approximately 85,100 hectares cleared in 2023<ref>This has contributed to a cumulative decline of about 1.04 million acres between 2019 and 2023. Furthermore, associated analysis suggests that logging and oil palm expansion continue to threaten extensive areas of naturally regenerating forest (Keeton-Olsen, 2024).</ref> (Funds for NGOs, 2024) See figure 1 below for extent of plantation expansion. This has been intensified by the state’s target of one million hectares of timber plantations, requiring the clearance of over 400,000 hectares of natural forest (The Borneo Project, 2024).

'''Figure 1: Extent of Plantation Concessions in Sarawak'''

Source: Erickson-Davis (2018)

Local tensions too, have escalated with Long Urun recording over 40,000 satellite‑detected deforestation alerts, with nearly 500 hectares of forest lost. This triggered petitions and blockades after official avenues failed. International pressure later prompted a temporary moratorium (Keeton‑Olsen, 2025; The Borneo Project, 2025a, 2025b). (See figure 2 below, for extent).

'''Figure 2: Land Clearing Captured in Long Urun on September 24, 2025'''

Source: Keeton-Olsen (2025)

Furthermore, Sarawak’s Land Code has been criticized for limiting the legal recognition of Indigenous Native Customary Rights (NCR) lands while enabling commercial access to forested areas through state-issued leases<ref>Additionally, although the legal framework requires the voluntary surrender or termination of customary land and compensation prior to commercial allocation, implementation has been noted to be inconsistent in practice (Human Rights Watch, 2024).</ref> (The Borneo Project, 2025a, 2025b).

These governance challenges have strengthened calls by civil society organisations urging the EU to classify Sarawak as a high-risk jurisdiction which would increase regulatory scrutiny of exports to EU markets (Keeton-Olsen, 2024). Given the importance of European markets for Malaysia’s palm oil<ref>The EU represents a key destination for Malaysian palm oil, ranking as the third-largest market after India and China. In 2023, palm oil exports from Malaysia to the EU totaled 1.07 million tonnes, accounting for 7.1% of the country’s overall palm oil exports (Proforest, 2025).</ref> and timber sectors<ref>EU countries are significant importers of Malaysian forestry goods, with the Netherlands and Germany ranking as the second- and third-largest purchasers of nationally certified timber from Malaysia in 2022(Keeton-Olsen, 2024).</ref>, strengthening forest governance and ensuring compliance are paramount (Human Rights Watch, 2024).

== Key Actors ==
At the international level, EU institutions act as external regulators through EUDR requirements, shaping market access and compliance expectations. International NGOs and consumer brands exert influence through supply chain pressure, exemplified by the sourcing suspensions linked to plantation expansion in Long Urun (The Borneo Project, 2025a, 2025b).

At the national level, federal institutions such as the Malaysian Palm Oil Council, Ministry of Investment, Trade and Industry, Ministry of Plantation and Commodities, Malaysian Timber Industry Board, influence the broader economic and regulatory environment through export policy, trade negotiations, and sustainability certification systems, while engaging directly with the EU on EUDR compliance (ISIS Malaysia & UPM, 2024a, 2024b; Kumaran et al., 2021; Reuters, 2025). They continue to lead Malaysia’s challenge to the EUDR at the WTO (Brasier, 2024; Teja, 2024).

At the sub-national level, the Sarawak state government holds primary authority over land allocation, forest classification, and plantation licensing through the Sarawak Ministry of Natural Resources and Urban Development<ref>Operational authority is implemented through several key agencies. The Sarawak Forest Department oversees forest classification, management, and the issuance of timber licences, while the Sarawak Land and Survey Department is responsible for land allocation, land registration, and matters related to NCR land. In parallel, the Sarawak Forestry Corporation is mandated to manage conservation efforts, including protected areas and biodiversity (Forest Department Sarawak, 2026; Land and Survey Department Sarawak, 2026; Sarawak Forestry Corporation, 2026).</ref> (Ministry of Urban Development and Natural Resources, 2026). This enables it to approve timber concessions and oil palm expansion<ref>Power at this level remains closely aligned with major corporations, whose political and economic influence continue to shape development priorities and regulatory enforcement (Tan et al., 2023; Koh et al., 2023). </ref> (Keeton-Olsen, 2021; Mohammad et al., 2022).

At the local level, Indigenous communities alongside forest-dependent households, smallholders, and plantation workers, are most directly affected by these governance dynamics<ref>It has been observed that smallholder farmers are more unlikely to satisfy the legality and sustainability requirements stipulated by the EUDR, as financial and structural constraints could limit their capacity to comply, thereby risking their exclusion from this vital global supply chain (Jong, 2023).</ref>. They rely on NCR lands for livelihoods and cultural continuity but face persistent barriers to formal recognition under Sarawak’s Land Code (Human Rights Watch, 2024). Forest conversion threatens their subsistence resources, fuels local conflicts, exposing smallholders and labourers to economic risks<ref>Compliance with the EUDR will therefore require significant financial, technical, and institutional support from government and industry stakeholders (Proforest, 2025).</ref> (Funds for NGOs, 2024).

== Policy options ==

=== '''Option 1: Status Quo''' ===
Herein, enforcement would continue through current state mechanisms under the Land Code and Forest Ordinance alongside the MSPO certification framework. This approach preserves current development trajectories centred on oil palm and timber expansion<ref>This option largely reflects existing approaches, which have not fully curbed deforestation or addressed persistent traceability and enforcement gaps (The Borneo Project, 2024).</ref> (Human Rights Watch, 2024; UKAS, 2025a).

Continued forest loss would likely persist, reinforcing international scrutiny from regulators, civil society organisations, and consumer brands concerned (Funds for NGOs, 2024; The Borneo Project, 2024). Sarawak could face heightened due-diligence requirements or potential classification as a “high-risk” jurisdiction, increasing transaction costs (ISIS Malaysia & UPM, 2024a, 2024b). See figure 3 below for due-diligence requirements.

Figure 3: Due Diligence Requirements Under Articles 9, 10 and 11 of the EUDR

Source: ISIS Malaysia, & UPM, 2024b

The main benefit of this would be that plantation expansion proceeds without disruption, industry actors avoid new compliance costs, while state revenues linked to land-based development would remain stable in the near term (Koh et al., 2023; Tan et al., 2023).

Authority over routine enforcement priorities, administrative coordination, and public communication would be retained while avoiding initiating legislative or regulatory reforms (Forests Ordinance, 2015). This would favour plantation and timber interests while minimising confrontation with powerful industry actors. Winners would include large agribusiness firms and political actors aligned with expansion, while losers would include forest-dependent communities, environmentally oriented exporters, and stakeholders seeking stronger sustainability compliance (Human Rights Watch, 2024; The Borneo Project, 2024).

=== '''Option 2: Compliance and Traceability Strategy''' ===
This would strengthen supply-chain transparency and traceability systems while allowing continued land conversion within existing regulatory limits as seen in Indonesia which was able to achieve compliance and traceability through its mandatory national certification system, the Indonesian Sustainable Palm Oil (ISPO) scheme, paired with forest-use restrictions, audits, and traceability rules for the palm oil supply chain<ref>ISPO made compliance a legal requirement rather than a purely voluntary market choice with traceability being strengthened by requiring certified operators to identify the source of fresh fruit bunches and disclosure of supplier and buyer relationships within the value chain (Sarmiento et al., 2024).</ref> (Sarmiento et al., 2024).

Measures would include improving geolocation data, integrating plantation licensing databases, strengthening MSPO 2.0 implementation, and supporting smallholders in meeting certification requirements<ref>This will be critical given the EUDR’s post-2020 cutoff, as traceability systems must be capable of distinguishing between compliant and non-compliant production areas. This could reduce the feasibility of simply redirecting exports to alternative markets, reinforcing the need for system-wide transparency (The Borneo Project, 2024).</ref> (ISIS Malaysia & UPM, 2024a, 2024b; Reuters, 2025).

Strengthening digital monitoring systems, verification mechanisms, and compliance support programmes would require public funding and institutional coordination (Forests Ordinance, 2015). Smallholders may face additional reporting burdens, while some companies may resist transparency requirements. Reforms may also remain procedural rather than substantive if underlying drivers of deforestation remain unchanged (The Borneo Project, 2024).

Enhanced traceability and compliance systems would demonstrate legality and supply-chain transparency to EU regulators and international buyers with export-oriented producers gaining more secure access to European markets, while improved governance systems could increase investor confidence, reducing trade disruptions (Ross, 2026).

Exercising of direct control over monitoring systems, enforcement transparency, and state-level compliance infrastructure would be facilitated but would require coordination with federal agencies responsible for certification and export promotion as well as cabinet support for budget allocations and inter-agency mandates (Forests Ordinance, 2015). This would appeal to export-oriented firms and federal trade authorities while avoiding major restrictions on plantation expansion. Winners would include compliant exporters and supported smallholders, while non-compliant operators would face greater scrutiny (Human Rights Watch, 2024).

=== '''Option 3: Forest Protection and Land Governance Reform''' ===
This would ensure stronger land-use regulation and governance reform. Measures will include a moratorium on new plantations in natural forests and peatlands, expansion of protected forest areas, stricter enforcement of land-conversion rules, and improved recognition of Indigenous NCR alongside Free, Prior and Informed Consent (FPIC) requirements for development projects (Human Rights Watch, 2024; The Borneo Project, 2024).

Stricter land-use controls could slow plantation expansion, potentially reducing short-term revenue from land-based development with enforcement capacity needing strengthening. Compensation or renegotiation of existing concessions would also need to be carried out to minimize legal disputes as well as boost investor confidence (Koh et al., 2023; Tan et al., 2023). Peru was able to achieve similar structural reforms by pairing land and forest formalization with clearer rules, stronger institutions, and incentives that brought informal actors into the legal system <ref>This involved moving from informal, insecure land use to formal, contract-based forest access through the creation of Agroforestry Concessions and reorganization of land into forest-use zones. The reform worked by giving smallholders a legal path into the system instead of leaving them invisible to the state (Sarmiento et al., 2024).</ref>(Sarmiento et al., 2024).

Stronger forest protection would result, reducing deforestation, improving biodiversity conservation, while decreasing land-rights conflicts with Indigenous communities (Sarmiento et al., 2024). Alignment with the EUDR would also strengthen Sarawak’s credibility (Tang, 2025; Reuters, 2025).

Control of enforcement priorities and administrative measures would be enabled. However, major reforms focusing on land-law amendments and protected-area designations would require approval from the State Legislative Assembly and coordination with federal authorities (Forests Ordinance, 2015). This option may face resistance from agribusiness interests but would gain support from civil society, Indigenous communities, and international partners. Winners would include forest-dependent communities, sustainable producers, and long-term exporters, while firms reliant on expansion and land-conversion revenues may incur losses (ISIS Malaysia & UPM, 2024a, 2024b; Mohammad et al., 2022).

== Recommended Policy option ==
A hybrid strategy would be the most viable approach, beginning with Option 2 and transitioning toward Option 3. Strengthening traceability, MSPO 2.0 implementation, and monitoring systems would provide immediate protection of EU market access, which is critical given Sarawak’s export dependence and exposure to EUDR requirements (Sarmiento et al., 2024; UKAS, 2025). This approach is politically feasible, avoids abrupt disruption, while building on the required administrative capacity for deeper reforms (Sarmiento et al., 2024).

However, compliance alone may not address the underlying deforestation drivers. A phased transition towards stronger land-use regulation and recognition of NCR and FPIC is necessary for long-term sustainability (Sarmiento et al., 2024; The Borneo Project, 2024). This would counter the state–corporate bias by empowering Indigenous voices via NCR/FPIC, while using traceability to appease exporters (Human Rights Watch, 2024). While Malaysia’s WTO challenge may reshape future obligations, it does not eliminate the immediate need for compliance (Brasier, 2024; Teja, 2024). This combined approach balances short-term trade imperatives with longer-term governance reform.

== Decision Timeline, Next Steps, and Key Milestones ==
The approach should be adopted by 30 March 2026 to allow sufficient lead time for implementation before the EUDR takes effect. It will apply from 30 December 2026 for large operators and traders, and from 30 June 2027 for micro- and small enterprises (European Commission, 2024). In addition, the EU’s risk benchmarking review, expected in May 2026, may shape Malaysia’s classification as high or standard risk, making early preparation paramount (Meridia, 2025).

Implementation should proceed in phases. In April 2026, an inter-agency taskforce should be convened to coordinate traceability mapping. In May 2026, Cabinet should decide on budget allocations and whether Land Code amendments will be pursued. June 2026 should mark the launch of smallholder support pilots and stakeholder forums, followed by quarterly deforestation monitoring reports. In Q2 2026, legislative reforms could be considered during the State Assembly session, while a federal MSPO audit is expected in Q3 2026. Large-firm pilots should begin in December 2026, with scale-up decisions made in late 2026 ahead of April 2027 compliance checks.

= References =

* Brasier, P.-J. S. (2024, September 18). ''Heated debates about the EUDR are missing the bigger picture''. Fern. <nowiki>https://www.fern.org/pt/publications-insight/article/heated-debates-about-the-eudr-are-missing-the-bigger-picture/</nowiki>
* Erickson-Davis, M. (2018, March 12). ''Sarawak makes 80% forest preservation commitment, but some have doubts''. Mongabay. <nowiki>https://news.mongabay.com/2018/03/sarawak-makes-80-forest-preservation-commitment-but-some-have-doubts/</nowiki>
* European Union. (2025, September 5). ''EU and Malaysia agree to strengthen their partnership and continue their joint efforts against deforestation''. <nowiki>https://www.eeas.europa.eu/delegations/malaysia/eu-and-malaysia-agree-strengthen-their-partnership-and-continue-their-joint-efforts-against_en</nowiki>
* Forest Department Sarawak. (2026, March 27). ''Forest Department Sarawak''. <nowiki>https://forestry.sarawak.gov.my/web/home/index/</nowiki>
* Forests Ordinance, 2015, c. 71 (Sarawak). (2015). ''Laws of Sarawak''. <nowiki>https://lawnet.sarawak.gov.my/lawnet_file/Ordinance/ORD_Watermark.pdf</nowiki>
* Funds for NGOs. (2024, October 15). ''NGOs urge EU to designate Sarawak as “high risk” for timber and palm oil''. <nowiki>https://news.fundsforngos.org/2024/10/15/ngos-urge-eu-to-designate-sarawak-as-high-risk-for-timber-and-palm-oil/</nowiki>
* Global Forest Watch. (n.d.). ''Malaysia''. <nowiki>https://www.globalforestwatch.org/dashboards/country/MYS/14/</nowiki>
* Human Rights Watch. (2024, September 23). ''EU: Address Indigenous rights violations in Malaysian imports: Designate Sarawak as “high risk” under new anti-deforestation law''. <nowiki>https://www.hrw.org/news/2024/09/23/eu-address-indigenous-rights-violations-malaysian-imports</nowiki>
* Institute of Strategic and International Studies Malaysia (ISIS Malaysia), & Universiti Putra Malaysia (UPM). (2024a). ''Availability of EU deforestation regulation relevant information for the palm oil sector in Malaysia'' (Policy Brief No. 2). <nowiki>https://www.isis.org.my/wp-content/uploads/2024/11/Policy-brief-2-Malaysia-data-readiness-for-EUDR_layout2.pdf</nowiki>
* Institute of Strategic and International Studies Malaysia (ISIS Malaysia), & Universiti Putra Malaysia (UPM). (2024b). ''Reinforcing deforestation‑free palm oil supply chains: Options for Malaysia in the context of EU and global legislation''. European Forest Institute. <nowiki>https://efi.int/sites/default/files/files/flegtredd/KAMI/Resources/Deforestation_free_supply_chains_for_palm_oil_2.pdf</nowiki>
* Jong, H. N. (2023, September 1). ''Palm oil giants Indonesia, Malaysia start talks with EU over deforestation rule''. Mongabay. <nowiki>https://news.mongabay.com/2023/09/palm-oil-giants-indonesia-malaysia-start-talks-with-eu-over-deforestation-rule/</nowiki>
* Keeton-Olsen, D. (2021, February 18). ''In Malaysian Borneo’s rainforests, powerful state governments set their own rules''. Mongabay. <nowiki>https://news.mongabay.com/2021/02/in-malaysian-borneos-rainforests-powerful-state-government-set-their-own-rules/</nowiki>
* Keeton-Olsen, D. (2024, October 9). ''NGOs push EU to label Sarawak as “high risk” source of timber, palm oil''. Mongabay. <nowiki>https://news.mongabay.com/2024/10/ngos-push-eu-to-label-sarawak-as-high-risk-source-of-timber-palm-oil/</nowiki>
* Keeton-Olsen, D. (2025, November 11). ''Cautious win for Indigenous groups in Malaysia as palm oil firm pauses forest clearing''. Mongabay. <nowiki>https://news.mongabay.com/2025/11/cautious-win-for-indigenous-groups-in-malaysia-as-palm-oil-firm-pauses-forest-clearing/</nowiki>
* Koh, J., Johari, S., Shuib, A., Siow, M. L., & Matthew, N. K. (2023). Malaysia’s forest pledges and the Bornean state of Sarawak: A policy perspective. ''Sustainability, 15''(2), 1385. <nowiki>https://doi.org/10.3390/su15021385</nowiki>
* Kumaran, S., Chew, J. S., & Nambiappan, B. (2021). ''Moving forward with mandatory MSPO certification standards''. ''Oil Palm Industry Economic Journal, 21''(1), 1–12. <nowiki>https://doi.org/10.21894/opiej.2021.01</nowiki>
* Land and Survey Department Sarawak. (2026, March 27). ''Land and Survey Department Sarawak''. <nowiki>https://landsurvey.sarawak.gov.my/web/home/index/</nowiki>
* Low, C. C. (2024, July 4). ''Timber grab: The truth behind Pahang oil palm plantations in Malaysia''. Asian Dispatch. <nowiki>https://www.asiandispatch.net/timber-grab-the-truth-behind-pahang-oil-palm-plantations-in-malaysia</nowiki>
* Meridia. (2025, May 28). ''EUDR benchmarking and risk categories explained: A simple guide''. <nowiki>https://www.meridia.land/blog/eudr-benchmarking-and-risk-categories-explained-a-simple-guide</nowiki>
* Ministry of Urban Development and Natural Resources. (2026, March 20). ''MUDeNR – Sarawak''. <nowiki>https://mudenr.sarawak.gov.my/web/home/index/</nowiki>
* Mohammad, H. H., Ripot, S., Alek, R. J., Cluny, W., & Kader, W. A. (2022). ''Sustainable forest management: Sarawak’s perspective''. Forest Department Sarawak. <nowiki>https://www.forestry.gov.my/images/pengumuman/2022/MFC/MFC2024/paperwork/Paper_2_Sustainable_Forest_Management_Sarawaks_Perspective.pdf</nowiki>
* Proforest. (2025). ''Options to broaden smallholder inclusivity in legal and deforestation-free palm oil supply chains in Malaysia''. European Forest Institute. <nowiki>https://efi.int/sites/default/files/files/flegtredd/KAMI/Resources/smallholder_inclusivity_report.pdf</nowiki>
* Reuters. (2025, September 10). ''EU clears Malaysia's palm oil certification for new deforestation rule''. <nowiki>https://www.reuters.com/markets/commodities/eu-clears-malaysias-palm-oil-certification-new-deforestation-rule-2025-09-10/</nowiki>
* Ross, J. (2026, March 3). Malaysia warns CITES push on tropical timber is self‑interest, not science. Wood Central. <nowiki>https://woodcentral.com.au/malaysia-warns-cites-push-on-tropical-timber-is-self-interest-not-science/</nowiki>
* Sarawak Forestry Corporation. (2026, March 20). ''Sarawak Forestry Corporation''. <nowiki>https://sfc.sarawak.gov.my/web/home/index/</nowiki>
* Sarawak Report. (2024, June 2). ''Malaysia’s rainforest threat is focused on Sarawak''. <nowiki>https://www.sarawakreport.org/2024/06/malaysias-rainforest-threat-is-focused-on-sarawak/</nowiki>
* Sarmiento, F., Larrea, C., Oeschger, A., & Jose, R. (2024, February 21). ''Measures to enhance forest conservation and reduce deforestation: Viewpoints and lessons from producing countries''. International Institute for Sustainable Development. <nowiki>https://www.iisd.org/ssi/publications/measures-enhance-forest-conservation-reduce-deforestation/</nowiki>
* Tan, L. C., Toh, M. L., Looi, K. S., Tan, W. V., Ujang, M. U., Thoo, A. C., Azri, N. S. b., & Kathitasapathy, S. A. L. (2023). Towards “good” Native land governance: An evaluation in Sarawak, Malaysia. ''The International Indigenous Policy Journal, 14''(1). <nowiki>https://doi.org/10.18584/iipj.2023.14.1.13873</nowiki>
* Tang, A. (2025, October 8). ''EU delays deforestation rule to Dec 2026''. ''Sarawak Tribune''. <nowiki>https://www.sarawaktribune.com/eu-delays-deforestation-rule-to-december-2026/</nowiki>
* Teja, N. (2024, February 8). ''EU deforestation regulation dubbed a ‘double-edged sword’ for global palm oil markets''. Sustainable Views. <nowiki>https://www.sustainableviews.com/eu-deforestation-regulation-dubbed-a-double-edged-sword-for-global-palm-oil-markets/</nowiki>
* The Borneo Project. (2024, September 26). ''Why Sarawak should be high risk under the new EU deforestation rules''. <nowiki>https://borneoproject.org/why-sarawak-should-be-high-risk-under-the-new-eu-deforestation-rules/</nowiki>
* The Borneo Project. (2025a, January 10). ''Deforestation alert: Ulu Belaga''. <nowiki>https://borneoproject.org/deforestation-alert-ulu-belaga/</nowiki>
* The Borneo Project. (2025b, October 30). ''Victory for Indigenous communities in Sarawak as Urun Plantations halts forest clearing''. <nowiki>https://borneoproject.org/victory-for-indigenous-communities-in-sarawak-as-urun-plantations-halts-forest-clearing/</nowiki>
* UKAS. (2025a, September 19). ''Palm oil overtakes crude petroleum as Sarawak’s leading export''. Premier of Sarawak Department. <nowiki>https://premierdept.sarawak.gov.my/web/subpage/news_view/25115/UKAS</nowiki>
* UKAS. (2025b, January 17). ''Sarawak Cabinet works collectively for the well-being of the people''. Government of Sarawak. <nowiki>https://premierdept.sarawak.gov.my/web/subpage/news_view/11717/UKAS#:~:text=%E2%80%9COur%20cabinet%20operates%20on%20a%20collective%20system,economy%2C%20and%20that%20is%20the%20result%20of</nowiki>

== Notes ==
[[Category:Forestry]]

Documentation:Sarawak’s Forest Governance under the European Union Deforestation Regulation: Policy Options for the Premier of the State of Sarawak, Malaysia

2026-05-15T20:28:49Z

WillEngle:

Oil palm and timber plantations expansion have been noted as the primary drivers of deforestation in Sarawak<ref>By 2024, Sarawak had lost 1.7 million hectares of humid primary forest, a 23% decline in its overall primary forest area (Global Forest Watch, n.d.).</ref> (Sarawak Report, 2024). This has created a significant governance challenge under the European Union Deforestation Regulation (EUDR) which came into force on 29<sup>th</sup> June 2023 requiring commodities entering the EU market to be deforestation-free and legally produced with a post-2020 deforestation cutoff<ref>Continued forest loss and land-rights disputes risk “high-risk” classification, which could threaten Sarawak’s EU market access (Funds for NGOs, 2024). </ref> (The Borneo Project, 2024).

= List of Abbreviations =

'''EUDR - European Union Deforestation Regulation'''

'''FPIC - Free, Prior and Informed Consent'''

'''ISIS - Institute of Strategic and International Studies'''

'''ISPO - Indonesian Sustainable Palm Oil'''

'''MSPO - Malaysian Sustainable Palm Oil'''

'''NCR - Native Customary Rights'''

'''UPM - Universiti Putra Malaysia'''

'''WTO - World Trade Organisation'''

== Background ==
The EUDR has increased pressure on producers with compliance depending on strict plot-level geolocation and supply-chain traceability requirements, limiting the scope for diverting commodities to alternative markets (Human Rights Watch, 2024).

Malaysia has challenged the EUDR, framing it as a form of disguised protectionism and a trade barrier that places disproportionate burdens on smallholders in its formal complaint to the WTO, this has introduced further uncertainty (Brasier, 2024; Teja, 2024).

Malaysia has relied on the Malaysian Sustainable Palm Oil (MSPO) certification scheme, alongside existing legal frameworks under the Land Code and Forest Ordinance, to address raised sustainability concerns (ISIS Malaysia & UPM, 2024a, 2024b). The EU has recognised the scheme as a credible certification framework that could support compliance with the EUDR, due to the incorporation of digital traceability tools that strengthen supply-chain transparency (Reuters, 2025).

However, despite these policy advancements, forest loss remains significant, with approximately 85,100 hectares cleared in 2023<ref>This has contributed to a cumulative decline of about 1.04 million acres between 2019 and 2023. Furthermore, associated analysis suggests that logging and oil palm expansion continue to threaten extensive areas of naturally regenerating forest (Keeton-Olsen, 2024).</ref> (Funds for NGOs, 2024) See figure 1 below for extent of plantation expansion. This has been intensified by the state’s target of one million hectares of timber plantations, requiring the clearance of over 400,000 hectares of natural forest (The Borneo Project, 2024).

'''Figure 1: Extent of Plantation Concessions in Sarawak'''

Source: Erickson-Davis (2018)

Local tensions too, have escalated with Long Urun recording over 40,000 satellite‑detected deforestation alerts, with nearly 500 hectares of forest lost. This triggered petitions and blockades after official avenues failed. International pressure later prompted a temporary moratorium (Keeton‑Olsen, 2025; The Borneo Project, 2025a, 2025b). (See figure 2 below, for extent).

'''Figure 2: Land Clearing Captured in Long Urun on September 24, 2025'''

Source: Keeton-Olsen (2025)

Furthermore, Sarawak’s Land Code has been criticized for limiting the legal recognition of Indigenous Native Customary Rights (NCR) lands while enabling commercial access to forested areas through state-issued leases<ref>Additionally, although the legal framework requires the voluntary surrender or termination of customary land and compensation prior to commercial allocation, implementation has been noted to be inconsistent in practice (Human Rights Watch, 2024).</ref> (The Borneo Project, 2025a, 2025b).

These governance challenges have strengthened calls by civil society organisations urging the EU to classify Sarawak as a high-risk jurisdiction which would increase regulatory scrutiny of exports to EU markets (Keeton-Olsen, 2024). Given the importance of European markets for Malaysia’s palm oil<ref>The EU represents a key destination for Malaysian palm oil, ranking as the third-largest market after India and China. In 2023, palm oil exports from Malaysia to the EU totaled 1.07 million tonnes, accounting for 7.1% of the country’s overall palm oil exports (Proforest, 2025).</ref> and timber sectors<ref>EU countries are significant importers of Malaysian forestry goods, with the Netherlands and Germany ranking as the second- and third-largest purchasers of nationally certified timber from Malaysia in 2022(Keeton-Olsen, 2024).</ref>, strengthening forest governance and ensuring compliance are paramount (Human Rights Watch, 2024).

== Key Actors ==
At the international level, EU institutions act as external regulators through EUDR requirements, shaping market access and compliance expectations. International NGOs and consumer brands exert influence through supply chain pressure, exemplified by the sourcing suspensions linked to plantation expansion in Long Urun (The Borneo Project, 2025a, 2025b).

At the national level, federal institutions such as the Malaysian Palm Oil Council, Ministry of Investment, Trade and Industry, Ministry of Plantation and Commodities, Malaysian Timber Industry Board, influence the broader economic and regulatory environment through export policy, trade negotiations, and sustainability certification systems, while engaging directly with the EU on EUDR compliance (ISIS Malaysia & UPM, 2024a, 2024b; Kumaran et al., 2021; Reuters, 2025). They continue to lead Malaysia’s challenge to the EUDR at the WTO (Brasier, 2024; Teja, 2024).

At the sub-national level, the Sarawak state government holds primary authority over land allocation, forest classification, and plantation licensing through the Sarawak Ministry of Natural Resources and Urban Development<ref>Operational authority is implemented through several key agencies. The Sarawak Forest Department oversees forest classification, management, and the issuance of timber licences, while the Sarawak Land and Survey Department is responsible for land allocation, land registration, and matters related to NCR land. In parallel, the Sarawak Forestry Corporation is mandated to manage conservation efforts, including protected areas and biodiversity (Forest Department Sarawak, 2026; Land and Survey Department Sarawak, 2026; Sarawak Forestry Corporation, 2026).</ref> (Ministry of Urban Development and Natural Resources, 2026). This enables it to approve timber concessions and oil palm expansion<ref>Power at this level remains closely aligned with major corporations, whose political and economic influence continue to shape development priorities and regulatory enforcement (Tan et al., 2023; Koh et al., 2023). </ref> (Keeton-Olsen, 2021; Mohammad et al., 2022).

At the local level, Indigenous communities alongside forest-dependent households, smallholders, and plantation workers, are most directly affected by these governance dynamics<ref>It has been observed that smallholder farmers are more unlikely to satisfy the legality and sustainability requirements stipulated by the EUDR, as financial and structural constraints could limit their capacity to comply, thereby risking their exclusion from this vital global supply chain (Jong, 2023).</ref>. They rely on NCR lands for livelihoods and cultural continuity but face persistent barriers to formal recognition under Sarawak’s Land Code (Human Rights Watch, 2024). Forest conversion threatens their subsistence resources, fuels local conflicts, exposing smallholders and labourers to economic risks<ref>Compliance with the EUDR will therefore require significant financial, technical, and institutional support from government and industry stakeholders (Proforest, 2025).</ref> (Funds for NGOs, 2024).

== Policy options ==

=== '''Option 1: Status Quo''' ===
Herein, enforcement would continue through current state mechanisms under the Land Code and Forest Ordinance alongside the MSPO certification framework. This approach preserves current development trajectories centred on oil palm and timber expansion<ref>This option largely reflects existing approaches, which have not fully curbed deforestation or addressed persistent traceability and enforcement gaps (The Borneo Project, 2024).</ref> (Human Rights Watch, 2024; UKAS, 2025a).

Continued forest loss would likely persist, reinforcing international scrutiny from regulators, civil society organisations, and consumer brands concerned (Funds for NGOs, 2024; The Borneo Project, 2024). Sarawak could face heightened due-diligence requirements or potential classification as a “high-risk” jurisdiction, increasing transaction costs (ISIS Malaysia & UPM, 2024a, 2024b). See figure 3 below for due-diligence requirements.

Figure 3: Due Diligence Requirements Under Articles 9, 10 and 11 of the EUDR

Source: ISIS Malaysia, & UPM, 2024b

The main benefit of this would be that plantation expansion proceeds without disruption, industry actors avoid new compliance costs, while state revenues linked to land-based development would remain stable in the near term (Koh et al., 2023; Tan et al., 2023).

Authority over routine enforcement priorities, administrative coordination, and public communication would be retained while avoiding initiating legislative or regulatory reforms (Forests Ordinance, 2015). This would favour plantation and timber interests while minimising confrontation with powerful industry actors. Winners would include large agribusiness firms and political actors aligned with expansion, while losers would include forest-dependent communities, environmentally oriented exporters, and stakeholders seeking stronger sustainability compliance (Human Rights Watch, 2024; The Borneo Project, 2024).

=== '''Option 2: Compliance and Traceability Strategy''' ===
This would strengthen supply-chain transparency and traceability systems while allowing continued land conversion within existing regulatory limits as seen in Indonesia which was able to achieve compliance and traceability through its mandatory national certification system, the Indonesian Sustainable Palm Oil (ISPO) scheme, paired with forest-use restrictions, audits, and traceability rules for the palm oil supply chain<ref>ISPO made compliance a legal requirement rather than a purely voluntary market choice with traceability being strengthened by requiring certified operators to identify the source of fresh fruit bunches and disclosure of supplier and buyer relationships within the value chain (Sarmiento et al., 2024).</ref> (Sarmiento et al., 2024).

Measures would include improving geolocation data, integrating plantation licensing databases, strengthening MSPO 2.0 implementation, and supporting smallholders in meeting certification requirements<ref>This will be critical given the EUDR’s post-2020 cutoff, as traceability systems must be capable of distinguishing between compliant and non-compliant production areas. This could reduce the feasibility of simply redirecting exports to alternative markets, reinforcing the need for system-wide transparency (The Borneo Project, 2024).</ref> (ISIS Malaysia & UPM, 2024a, 2024b; Reuters, 2025).

Strengthening digital monitoring systems, verification mechanisms, and compliance support programmes would require public funding and institutional coordination (Forests Ordinance, 2015). Smallholders may face additional reporting burdens, while some companies may resist transparency requirements. Reforms may also remain procedural rather than substantive if underlying drivers of deforestation remain unchanged (The Borneo Project, 2024).

Enhanced traceability and compliance systems would demonstrate legality and supply-chain transparency to EU regulators and international buyers with export-oriented producers gaining more secure access to European markets, while improved governance systems could increase investor confidence, reducing trade disruptions (Ross, 2026).

Exercising of direct control over monitoring systems, enforcement transparency, and state-level compliance infrastructure would be facilitated but would require coordination with federal agencies responsible for certification and export promotion as well as cabinet support for budget allocations and inter-agency mandates (Forests Ordinance, 2015). This would appeal to export-oriented firms and federal trade authorities while avoiding major restrictions on plantation expansion. Winners would include compliant exporters and supported smallholders, while non-compliant operators would face greater scrutiny (Human Rights Watch, 2024).

=== '''Option 3: Forest Protection and Land Governance Reform''' ===
This would ensure stronger land-use regulation and governance reform. Measures will include a moratorium on new plantations in natural forests and peatlands, expansion of protected forest areas, stricter enforcement of land-conversion rules, and improved recognition of Indigenous NCR alongside Free, Prior and Informed Consent (FPIC) requirements for development projects (Human Rights Watch, 2024; The Borneo Project, 2024).

Stricter land-use controls could slow plantation expansion, potentially reducing short-term revenue from land-based development with enforcement capacity needing strengthening. Compensation or renegotiation of existing concessions would also need to be carried out to minimize legal disputes as well as boost investor confidence (Koh et al., 2023; Tan et al., 2023). Peru was able to achieve similar structural reforms by pairing land and forest formalization with clearer rules, stronger institutions, and incentives that brought informal actors into the legal system <ref>This involved moving from informal, insecure land use to formal, contract-based forest access through the creation of Agroforestry Concessions and reorganization of land into forest-use zones. The reform worked by giving smallholders a legal path into the system instead of leaving them invisible to the state (Sarmiento et al., 2024).</ref>(Sarmiento et al., 2024).

Stronger forest protection would result, reducing deforestation, improving biodiversity conservation, while decreasing land-rights conflicts with Indigenous communities (Sarmiento et al., 2024). Alignment with the EUDR would also strengthen Sarawak’s credibility (Tang, 2025; Reuters, 2025).

Control of enforcement priorities and administrative measures would be enabled. However, major reforms focusing on land-law amendments and protected-area designations would require approval from the State Legislative Assembly and coordination with federal authorities (Forests Ordinance, 2015). This option may face resistance from agribusiness interests but would gain support from civil society, Indigenous communities, and international partners. Winners would include forest-dependent communities, sustainable producers, and long-term exporters, while firms reliant on expansion and land-conversion revenues may incur losses (ISIS Malaysia & UPM, 2024a, 2024b; Mohammad et al., 2022).

== Recommended Policy option ==
A hybrid strategy would be the most viable approach, beginning with Option 2 and transitioning toward Option 3. Strengthening traceability, MSPO 2.0 implementation, and monitoring systems would provide immediate protection of EU market access, which is critical given Sarawak’s export dependence and exposure to EUDR requirements (Sarmiento et al., 2024; UKAS, 2025). This approach is politically feasible, avoids abrupt disruption, while building on the required administrative capacity for deeper reforms (Sarmiento et al., 2024).

However, compliance alone may not address the underlying deforestation drivers. A phased transition towards stronger land-use regulation and recognition of NCR and FPIC is necessary for long-term sustainability (Sarmiento et al., 2024; The Borneo Project, 2024). This would counter the state–corporate bias by empowering Indigenous voices via NCR/FPIC, while using traceability to appease exporters (Human Rights Watch, 2024). While Malaysia’s WTO challenge may reshape future obligations, it does not eliminate the immediate need for compliance (Brasier, 2024; Teja, 2024). This combined approach balances short-term trade imperatives with longer-term governance reform.

== Decision Timeline, Next Steps, and Key Milestones ==
The approach should be adopted by 30 March 2026 to allow sufficient lead time for implementation before the EUDR takes effect. It will apply from 30 December 2026 for large operators and traders, and from 30 June 2027 for micro- and small enterprises (European Commission, 2024). In addition, the EU’s risk benchmarking review, expected in May 2026, may shape Malaysia’s classification as high or standard risk, making early preparation paramount (Meridia, 2025).

Implementation should proceed in phases. In April 2026, an inter-agency taskforce should be convened to coordinate traceability mapping. In May 2026, Cabinet should decide on budget allocations and whether Land Code amendments will be pursued. June 2026 should mark the launch of smallholder support pilots and stakeholder forums, followed by quarterly deforestation monitoring reports. In Q2 2026, legislative reforms could be considered during the State Assembly session, while a federal MSPO audit is expected in Q3 2026. Large-firm pilots should begin in December 2026, with scale-up decisions made in late 2026 ahead of April 2027 compliance checks.

= References =
Brasier, P.-J. S. (2024, September 18). ''Heated debates about the EUDR are missing the bigger picture''. Fern. <nowiki>https://www.fern.org/pt/publications-insight/article/heated-debates-about-the-eudr-are-missing-the-bigger-picture/</nowiki>

Erickson-Davis, M. (2018, March 12). ''Sarawak makes 80% forest preservation commitment, but some have doubts''. Mongabay. <nowiki>https://news.mongabay.com/2018/03/sarawak-makes-80-forest-preservation-commitment-but-some-have-doubts/</nowiki>

European Union. (2025, September 5). ''EU and Malaysia agree to strengthen their partnership and continue their joint efforts against deforestation''. <nowiki>https://www.eeas.europa.eu/delegations/malaysia/eu-and-malaysia-agree-strengthen-their-partnership-and-continue-their-joint-efforts-against_en</nowiki>

Forest Department Sarawak. (2026, March 27). ''Forest Department Sarawak''. <nowiki>https://forestry.sarawak.gov.my/web/home/index/</nowiki>

Forests Ordinance, 2015, c. 71 (Sarawak). (2015). ''Laws of Sarawak''. <nowiki>https://lawnet.sarawak.gov.my/lawnet_file/Ordinance/ORD_Watermark.pdf</nowiki>

Funds for NGOs. (2024, October 15). ''NGOs urge EU to designate Sarawak as “high risk” for timber and palm oil''. <nowiki>https://news.fundsforngos.org/2024/10/15/ngos-urge-eu-to-designate-sarawak-as-high-risk-for-timber-and-palm-oil/</nowiki>

Global Forest Watch. (n.d.). ''Malaysia''. <nowiki>https://www.globalforestwatch.org/dashboards/country/MYS/14/</nowiki>

Human Rights Watch. (2024, September 23). ''EU: Address Indigenous rights violations in Malaysian imports: Designate Sarawak as “high risk” under new anti-deforestation law''. <nowiki>https://www.hrw.org/news/2024/09/23/eu-address-indigenous-rights-violations-malaysian-imports</nowiki>

Institute of Strategic and International Studies Malaysia (ISIS Malaysia), & Universiti Putra Malaysia (UPM). (2024a). ''Availability of EU deforestation regulation relevant information for the palm oil sector in Malaysia'' (Policy Brief No. 2). <nowiki>https://www.isis.org.my/wp-content/uploads/2024/11/Policy-brief-2-Malaysia-data-readiness-for-EUDR_layout2.pdf</nowiki>

Institute of Strategic and International Studies Malaysia (ISIS Malaysia), & Universiti Putra Malaysia (UPM). (2024b). ''Reinforcing deforestation‑free palm oil supply chains: Options for Malaysia in the context of EU and global legislation''. European Forest Institute. <nowiki>https://efi.int/sites/default/files/files/flegtredd/KAMI/Resources/Deforestation_free_supply_chains_for_palm_oil_2.pdf</nowiki>

Jong, H. N. (2023, September 1). ''Palm oil giants Indonesia, Malaysia start talks with EU over deforestation rule''. Mongabay. <nowiki>https://news.mongabay.com/2023/09/palm-oil-giants-indonesia-malaysia-start-talks-with-eu-over-deforestation-rule/</nowiki>

Keeton-Olsen, D. (2021, February 18). ''In Malaysian Borneo’s rainforests, powerful state governments set their own rules''. Mongabay. <nowiki>https://news.mongabay.com/2021/02/in-malaysian-borneos-rainforests-powerful-state-government-set-their-own-rules/</nowiki>

Keeton-Olsen, D. (2024, October 9). ''NGOs push EU to label Sarawak as “high risk” source of timber, palm oil''. Mongabay. <nowiki>https://news.mongabay.com/2024/10/ngos-push-eu-to-label-sarawak-as-high-risk-source-of-timber-palm-oil/</nowiki>

Keeton-Olsen, D. (2025, November 11). ''Cautious win for Indigenous groups in Malaysia as palm oil firm pauses forest clearing''. Mongabay. <nowiki>https://news.mongabay.com/2025/11/cautious-win-for-indigenous-groups-in-malaysia-as-palm-oil-firm-pauses-forest-clearing/</nowiki>

Koh, J., Johari, S., Shuib, A., Siow, M. L., & Matthew, N. K. (2023). Malaysia’s forest pledges and the Bornean state of Sarawak: A policy perspective. ''Sustainability, 15''(2), 1385. <nowiki>https://doi.org/10.3390/su15021385</nowiki>

Kumaran, S., Chew, J. S., & Nambiappan, B. (2021). ''Moving forward with mandatory MSPO certification standards''. ''Oil Palm Industry Economic Journal, 21''(1), 1–12. <nowiki>https://doi.org/10.21894/opiej.2021.01</nowiki>

Land and Survey Department Sarawak. (2026, March 27). ''Land and Survey Department Sarawak''. <nowiki>https://landsurvey.sarawak.gov.my/web/home/index/</nowiki>

Low, C. C. (2024, July 4). ''Timber grab: The truth behind Pahang oil palm plantations in Malaysia''. Asian Dispatch. <nowiki>https://www.asiandispatch.net/timber-grab-the-truth-behind-pahang-oil-palm-plantations-in-malaysia</nowiki>

Meridia. (2025, May 28). ''EUDR benchmarking and risk categories explained: A simple guide''. <nowiki>https://www.meridia.land/blog/eudr-benchmarking-and-risk-categories-explained-a-simple-guide</nowiki>

Ministry of Urban Development and Natural Resources. (2026, March 20). ''MUDeNR – Sarawak''. <nowiki>https://mudenr.sarawak.gov.my/web/home/index/</nowiki>

Mohammad, H. H., Ripot, S., Alek, R. J., Cluny, W., & Kader, W. A. (2022). ''Sustainable forest management: Sarawak’s perspective''. Forest Department Sarawak. <nowiki>https://www.forestry.gov.my/images/pengumuman/2022/MFC/MFC2024/paperwork/Paper_2_Sustainable_Forest_Management_Sarawaks_Perspective.pdf</nowiki>

Proforest. (2025). ''Options to broaden smallholder inclusivity in legal and deforestation-free palm oil supply chains in Malaysia''. European Forest Institute. <nowiki>https://efi.int/sites/default/files/files/flegtredd/KAMI/Resources/smallholder_inclusivity_report.pdf</nowiki>

Reuters. (2025, September 10). ''EU clears Malaysia's palm oil certification for new deforestation rule''. <nowiki>https://www.reuters.com/markets/commodities/eu-clears-malaysias-palm-oil-certification-new-deforestation-rule-2025-09-10/</nowiki>

Ross, J. (2026, March 3). Malaysia warns CITES push on tropical timber is self‑interest, not science. Wood Central. <nowiki>https://woodcentral.com.au/malaysia-warns-cites-push-on-tropical-timber-is-self-interest-not-science/</nowiki>

Sarawak Forestry Corporation. (2026, March 20). ''Sarawak Forestry Corporation''. <nowiki>https://sfc.sarawak.gov.my/web/home/index/</nowiki>

Sarawak Report. (2024, June 2). ''Malaysia’s rainforest threat is focused on Sarawak''. <nowiki>https://www.sarawakreport.org/2024/06/malaysias-rainforest-threat-is-focused-on-sarawak/</nowiki>

Sarmiento, F., Larrea, C., Oeschger, A., & Jose, R. (2024, February 21). ''Measures to enhance forest conservation and reduce deforestation: Viewpoints and lessons from producing countries''. International Institute for Sustainable Development. <nowiki>https://www.iisd.org/ssi/publications/measures-enhance-forest-conservation-reduce-deforestation/</nowiki>

Tan, L. C., Toh, M. L., Looi, K. S., Tan, W. V., Ujang, M. U., Thoo, A. C., Azri, N. S. b., & Kathitasapathy, S. A. L. (2023). Towards “good” Native land governance: An evaluation in Sarawak, Malaysia. ''The International Indigenous Policy Journal, 14''(1). <nowiki>https://doi.org/10.18584/iipj.2023.14.1.13873</nowiki>

Tang, A. (2025, October 8). ''EU delays deforestation rule to Dec 2026''. ''Sarawak Tribune''. <nowiki>https://www.sarawaktribune.com/eu-delays-deforestation-rule-to-december-2026/</nowiki>

Teja, N. (2024, February 8). ''EU deforestation regulation dubbed a ‘double-edged sword’ for global palm oil markets''. Sustainable Views. <nowiki>https://www.sustainableviews.com/eu-deforestation-regulation-dubbed-a-double-edged-sword-for-global-palm-oil-markets/</nowiki>

The Borneo Project. (2024, September 26). ''Why Sarawak should be high risk under the new EU deforestation rules''. <nowiki>https://borneoproject.org/why-sarawak-should-be-high-risk-under-the-new-eu-deforestation-rules/</nowiki>

The Borneo Project. (2025a, January 10). ''Deforestation alert: Ulu Belaga''. <nowiki>https://borneoproject.org/deforestation-alert-ulu-belaga/</nowiki>

The Borneo Project. (2025b, October 30). ''Victory for Indigenous communities in Sarawak as Urun Plantations halts forest clearing''. <nowiki>https://borneoproject.org/victory-for-indigenous-communities-in-sarawak-as-urun-plantations-halts-forest-clearing/</nowiki>

UKAS. (2025a, September 19). ''Palm oil overtakes crude petroleum as Sarawak’s leading export''. Premier of Sarawak Department. <nowiki>https://premierdept.sarawak.gov.my/web/subpage/news_view/25115/UKAS</nowiki>

UKAS. (2025b, January 17). ''Sarawak Cabinet works collectively for the well-being of the people''. Government of Sarawak. <nowiki>https://premierdept.sarawak.gov.my/web/subpage/news_view/11717/UKAS#:~:text=%E2%80%9COur%20cabinet%20operates%20on%20a%20collective%20system,economy%2C%20and%20that%20is%20the%20result%20of</nowiki>

== Notes ==
[[Category:Forestry]]

Documentation:Sarawak’s Forest Governance under the European Union Deforestation Regulation: Policy Options for the Premier of the State of Sarawak, Malaysia

2026-05-15T20:28:04Z

WillEngle: /* Option 1: Status Quo */

Oil palm and timber plantations expansion have been noted as the primary drivers of deforestation in Sarawak<ref>By 2024, Sarawak had lost 1.7 million hectares of humid primary forest, a 23% decline in its overall primary forest area (Global Forest Watch, n.d.).</ref> (Sarawak Report, 2024). This has created a significant governance challenge under the European Union Deforestation Regulation (EUDR) which came into force on 29<sup>th</sup> June 2023 requiring commodities entering the EU market to be deforestation-free and legally produced with a post-2020 deforestation cutoff<ref>Continued forest loss and land-rights disputes risk “high-risk” classification, which could threaten Sarawak’s EU market access (Funds for NGOs, 2024). </ref> (The Borneo Project, 2024).

= List of Abbreviations =

'''EUDR - European Union Deforestation Regulation'''

'''FPIC - Free, Prior and Informed Consent'''

'''ISIS - Institute of Strategic and International Studies'''

'''ISPO - Indonesian Sustainable Palm Oil'''

'''MSPO - Malaysian Sustainable Palm Oil'''

'''NCR - Native Customary Rights'''

'''UPM - Universiti Putra Malaysia'''

'''WTO - World Trade Organisation'''

== Background ==
The EUDR has increased pressure on producers with compliance depending on strict plot-level geolocation and supply-chain traceability requirements, limiting the scope for diverting commodities to alternative markets (Human Rights Watch, 2024).

Malaysia has challenged the EUDR, framing it as a form of disguised protectionism and a trade barrier that places disproportionate burdens on smallholders in its formal complaint to the WTO, this has introduced further uncertainty (Brasier, 2024; Teja, 2024).

Malaysia has relied on the Malaysian Sustainable Palm Oil (MSPO) certification scheme, alongside existing legal frameworks under the Land Code and Forest Ordinance, to address raised sustainability concerns (ISIS Malaysia & UPM, 2024a, 2024b). The EU has recognised the scheme as a credible certification framework that could support compliance with the EUDR, due to the incorporation of digital traceability tools that strengthen supply-chain transparency (Reuters, 2025).

However, despite these policy advancements, forest loss remains significant, with approximately 85,100 hectares cleared in 2023<ref>This has contributed to a cumulative decline of about 1.04 million acres between 2019 and 2023. Furthermore, associated analysis suggests that logging and oil palm expansion continue to threaten extensive areas of naturally regenerating forest (Keeton-Olsen, 2024).</ref> (Funds for NGOs, 2024) See figure 1 below for extent of plantation expansion. This has been intensified by the state’s target of one million hectares of timber plantations, requiring the clearance of over 400,000 hectares of natural forest (The Borneo Project, 2024).

'''Figure 1: Extent of Plantation Concessions in Sarawak'''

Source: Erickson-Davis (2018)

Local tensions too, have escalated with Long Urun recording over 40,000 satellite‑detected deforestation alerts, with nearly 500 hectares of forest lost. This triggered petitions and blockades after official avenues failed. International pressure later prompted a temporary moratorium (Keeton‑Olsen, 2025; The Borneo Project, 2025a, 2025b). (See figure 2 below, for extent).

'''Figure 2: Land Clearing Captured in Long Urun on September 24, 2025'''

Source: Keeton-Olsen (2025)

Furthermore, Sarawak’s Land Code has been criticized for limiting the legal recognition of Indigenous Native Customary Rights (NCR) lands while enabling commercial access to forested areas through state-issued leases<ref>Additionally, although the legal framework requires the voluntary surrender or termination of customary land and compensation prior to commercial allocation, implementation has been noted to be inconsistent in practice (Human Rights Watch, 2024).</ref> (The Borneo Project, 2025a, 2025b).

These governance challenges have strengthened calls by civil society organisations urging the EU to classify Sarawak as a high-risk jurisdiction which would increase regulatory scrutiny of exports to EU markets (Keeton-Olsen, 2024). Given the importance of European markets for Malaysia’s palm oil<ref>The EU represents a key destination for Malaysian palm oil, ranking as the third-largest market after India and China. In 2023, palm oil exports from Malaysia to the EU totaled 1.07 million tonnes, accounting for 7.1% of the country’s overall palm oil exports (Proforest, 2025).</ref> and timber sectors<ref>EU countries are significant importers of Malaysian forestry goods, with the Netherlands and Germany ranking as the second- and third-largest purchasers of nationally certified timber from Malaysia in 2022(Keeton-Olsen, 2024).</ref>, strengthening forest governance and ensuring compliance are paramount (Human Rights Watch, 2024).

== Key Actors ==
At the international level, EU institutions act as external regulators through EUDR requirements, shaping market access and compliance expectations. International NGOs and consumer brands exert influence through supply chain pressure, exemplified by the sourcing suspensions linked to plantation expansion in Long Urun (The Borneo Project, 2025a, 2025b).

At the national level, federal institutions such as the Malaysian Palm Oil Council, Ministry of Investment, Trade and Industry, Ministry of Plantation and Commodities, Malaysian Timber Industry Board, influence the broader economic and regulatory environment through export policy, trade negotiations, and sustainability certification systems, while engaging directly with the EU on EUDR compliance (ISIS Malaysia & UPM, 2024a, 2024b; Kumaran et al., 2021; Reuters, 2025). They continue to lead Malaysia’s challenge to the EUDR at the WTO (Brasier, 2024; Teja, 2024).

At the sub-national level, the Sarawak state government holds primary authority over land allocation, forest classification, and plantation licensing through the Sarawak Ministry of Natural Resources and Urban Development<ref>Operational authority is implemented through several key agencies. The Sarawak Forest Department oversees forest classification, management, and the issuance of timber licences, while the Sarawak Land and Survey Department is responsible for land allocation, land registration, and matters related to NCR land. In parallel, the Sarawak Forestry Corporation is mandated to manage conservation efforts, including protected areas and biodiversity (Forest Department Sarawak, 2026; Land and Survey Department Sarawak, 2026; Sarawak Forestry Corporation, 2026).</ref> (Ministry of Urban Development and Natural Resources, 2026). This enables it to approve timber concessions and oil palm expansion<ref>Power at this level remains closely aligned with major corporations, whose political and economic influence continue to shape development priorities and regulatory enforcement (Tan et al., 2023; Koh et al., 2023). </ref> (Keeton-Olsen, 2021; Mohammad et al., 2022).

At the local level, Indigenous communities alongside forest-dependent households, smallholders, and plantation workers, are most directly affected by these governance dynamics<ref>It has been observed that smallholder farmers are more unlikely to satisfy the legality and sustainability requirements stipulated by the EUDR, as financial and structural constraints could limit their capacity to comply, thereby risking their exclusion from this vital global supply chain (Jong, 2023).</ref>. They rely on NCR lands for livelihoods and cultural continuity but face persistent barriers to formal recognition under Sarawak’s Land Code (Human Rights Watch, 2024). Forest conversion threatens their subsistence resources, fuels local conflicts, exposing smallholders and labourers to economic risks<ref>Compliance with the EUDR will therefore require significant financial, technical, and institutional support from government and industry stakeholders (Proforest, 2025).</ref> (Funds for NGOs, 2024).

== Policy options ==

=== '''Option 1: Status Quo''' ===
Herein, enforcement would continue through current state mechanisms under the Land Code and Forest Ordinance alongside the MSPO certification framework. This approach preserves current development trajectories centred on oil palm and timber expansion<ref>This option largely reflects existing approaches, which have not fully curbed deforestation or addressed persistent traceability and enforcement gaps (The Borneo Project, 2024).</ref> (Human Rights Watch, 2024; UKAS, 2025a).

Continued forest loss would likely persist, reinforcing international scrutiny from regulators, civil society organisations, and consumer brands concerned (Funds for NGOs, 2024; The Borneo Project, 2024). Sarawak could face heightened due-diligence requirements or potential classification as a “high-risk” jurisdiction, increasing transaction costs (ISIS Malaysia & UPM, 2024a, 2024b). See figure 3 below for due-diligence requirements.

Figure 3: Due Diligence Requirements Under Articles 9, 10 and 11 of the EUDR

Source: ISIS Malaysia, & UPM, 2024b

The main benefit of this would be that plantation expansion proceeds without disruption, industry actors avoid new compliance costs, while state revenues linked to land-based development would remain stable in the near term (Koh et al., 2023; Tan et al., 2023).

Authority over routine enforcement priorities, administrative coordination, and public communication would be retained while avoiding initiating legislative or regulatory reforms (Forests Ordinance, 2015). This would favour plantation and timber interests while minimising confrontation with powerful industry actors. Winners would include large agribusiness firms and political actors aligned with expansion, while losers would include forest-dependent communities, environmentally oriented exporters, and stakeholders seeking stronger sustainability compliance (Human Rights Watch, 2024; The Borneo Project, 2024).

=== '''Option 2: Compliance and Traceability Strategy''' ===
This would strengthen supply-chain transparency and traceability systems while allowing continued land conversion within existing regulatory limits as seen in Indonesia which was able to achieve compliance and traceability through its mandatory national certification system, the Indonesian Sustainable Palm Oil (ISPO) scheme, paired with forest-use restrictions, audits, and traceability rules for the palm oil supply chain<ref>ISPO made compliance a legal requirement rather than a purely voluntary market choice with traceability being strengthened by requiring certified operators to identify the source of fresh fruit bunches and disclosure of supplier and buyer relationships within the value chain (Sarmiento et al., 2024).</ref> (Sarmiento et al., 2024).

Measures would include improving geolocation data, integrating plantation licensing databases, strengthening MSPO 2.0 implementation, and supporting smallholders in meeting certification requirements<ref>This will be critical given the EUDR’s post-2020 cutoff, as traceability systems must be capable of distinguishing between compliant and non-compliant production areas. This could reduce the feasibility of simply redirecting exports to alternative markets, reinforcing the need for system-wide transparency (The Borneo Project, 2024).</ref> (ISIS Malaysia & UPM, 2024a, 2024b; Reuters, 2025).

Strengthening digital monitoring systems, verification mechanisms, and compliance support programmes would require public funding and institutional coordination (Forests Ordinance, 2015). Smallholders may face additional reporting burdens, while some companies may resist transparency requirements. Reforms may also remain procedural rather than substantive if underlying drivers of deforestation remain unchanged (The Borneo Project, 2024).

Enhanced traceability and compliance systems would demonstrate legality and supply-chain transparency to EU regulators and international buyers with export-oriented producers gaining more secure access to European markets, while improved governance systems could increase investor confidence, reducing trade disruptions (Ross, 2026).

Exercising of direct control over monitoring systems, enforcement transparency, and state-level compliance infrastructure would be facilitated but would require coordination with federal agencies responsible for certification and export promotion as well as cabinet support for budget allocations and inter-agency mandates (Forests Ordinance, 2015). This would appeal to export-oriented firms and federal trade authorities while avoiding major restrictions on plantation expansion. Winners would include compliant exporters and supported smallholders, while non-compliant operators would face greater scrutiny (Human Rights Watch, 2024).

=== '''Option 3: Forest Protection and Land Governance Reform''' ===
This would ensure stronger land-use regulation and governance reform. Measures will include a moratorium on new plantations in natural forests and peatlands, expansion of protected forest areas, stricter enforcement of land-conversion rules, and improved recognition of Indigenous NCR alongside Free, Prior and Informed Consent (FPIC) requirements for development projects (Human Rights Watch, 2024; The Borneo Project, 2024).

Stricter land-use controls could slow plantation expansion, potentially reducing short-term revenue from land-based development with enforcement capacity needing strengthening. Compensation or renegotiation of existing concessions would also need to be carried out to minimize legal disputes as well as boost investor confidence (Koh et al., 2023; Tan et al., 2023). Peru was able to achieve similar structural reforms by pairing land and forest formalization with clearer rules, stronger institutions, and incentives that brought informal actors into the legal system <ref>This involved moving from informal, insecure land use to formal, contract-based forest access through the creation of Agroforestry Concessions and reorganization of land into forest-use zones. The reform worked by giving smallholders a legal path into the system instead of leaving them invisible to the state (Sarmiento et al., 2024).</ref>(Sarmiento et al., 2024).

Stronger forest protection would result, reducing deforestation, improving biodiversity conservation, while decreasing land-rights conflicts with Indigenous communities (Sarmiento et al., 2024). Alignment with the EUDR would also strengthen Sarawak’s credibility (Tang, 2025; Reuters, 2025).

Control of enforcement priorities and administrative measures would be enabled. However, major reforms focusing on land-law amendments and protected-area designations would require approval from the State Legislative Assembly and coordination with federal authorities (Forests Ordinance, 2015). This option may face resistance from agribusiness interests but would gain support from civil society, Indigenous communities, and international partners. Winners would include forest-dependent communities, sustainable producers, and long-term exporters, while firms reliant on expansion and land-conversion revenues may incur losses (ISIS Malaysia & UPM, 2024a, 2024b; Mohammad et al., 2022).

== Recommended Policy option ==
A hybrid strategy would be the most viable approach, beginning with Option 2 and transitioning toward Option 3. Strengthening traceability, MSPO 2.0 implementation, and monitoring systems would provide immediate protection of EU market access, which is critical given Sarawak’s export dependence and exposure to EUDR requirements (Sarmiento et al., 2024; UKAS, 2025). This approach is politically feasible, avoids abrupt disruption, while building on the required administrative capacity for deeper reforms (Sarmiento et al., 2024).

However, compliance alone may not address the underlying deforestation drivers. A phased transition towards stronger land-use regulation and recognition of NCR and FPIC is necessary for long-term sustainability (Sarmiento et al., 2024; The Borneo Project, 2024). This would counter the state–corporate bias by empowering Indigenous voices via NCR/FPIC, while using traceability to appease exporters (Human Rights Watch, 2024). While Malaysia’s WTO challenge may reshape future obligations, it does not eliminate the immediate need for compliance (Brasier, 2024; Teja, 2024). This combined approach balances short-term trade imperatives with longer-term governance reform.

== Decision Timeline, Next Steps, and Key Milestones ==
The approach should be adopted by 30 March 2026 to allow sufficient lead time for implementation before the EUDR takes effect. It will apply from 30 December 2026 for large operators and traders, and from 30 June 2027 for micro- and small enterprises (European Commission, 2024). In addition, the EU’s risk benchmarking review, expected in May 2026, may shape Malaysia’s classification as high or standard risk, making early preparation paramount (Meridia, 2025).

Implementation should proceed in phases. In April 2026, an inter-agency taskforce should be convened to coordinate traceability mapping. In May 2026, Cabinet should decide on budget allocations and whether Land Code amendments will be pursued. June 2026 should mark the launch of smallholder support pilots and stakeholder forums, followed by quarterly deforestation monitoring reports. In Q2 2026, legislative reforms could be considered during the State Assembly session, while a federal MSPO audit is expected in Q3 2026. Large-firm pilots should begin in December 2026, with scale-up decisions made in late 2026 ahead of April 2027 compliance checks.

= References =
Brasier, P.-J. S. (2024, September 18). ''Heated debates about the EUDR are missing the bigger picture''. Fern. <nowiki>https://www.fern.org/pt/publications-insight/article/heated-debates-about-the-eudr-are-missing-the-bigger-picture/</nowiki>

Erickson-Davis, M. (2018, March 12). ''Sarawak makes 80% forest preservation commitment, but some have doubts''. Mongabay. <nowiki>https://news.mongabay.com/2018/03/sarawak-makes-80-forest-preservation-commitment-but-some-have-doubts/</nowiki>

European Union. (2025, September 5). ''EU and Malaysia agree to strengthen their partnership and continue their joint efforts against deforestation''. <nowiki>https://www.eeas.europa.eu/delegations/malaysia/eu-and-malaysia-agree-strengthen-their-partnership-and-continue-their-joint-efforts-against_en</nowiki>

Forest Department Sarawak. (2026, March 27). ''Forest Department Sarawak''. <nowiki>https://forestry.sarawak.gov.my/web/home/index/</nowiki>

Forests Ordinance, 2015, c. 71 (Sarawak). (2015). ''Laws of Sarawak''. <nowiki>https://lawnet.sarawak.gov.my/lawnet_file/Ordinance/ORD_Watermark.pdf</nowiki>

Funds for NGOs. (2024, October 15). ''NGOs urge EU to designate Sarawak as “high risk” for timber and palm oil''. <nowiki>https://news.fundsforngos.org/2024/10/15/ngos-urge-eu-to-designate-sarawak-as-high-risk-for-timber-and-palm-oil/</nowiki>

Global Forest Watch. (n.d.). ''Malaysia''. <nowiki>https://www.globalforestwatch.org/dashboards/country/MYS/14/</nowiki>

Human Rights Watch. (2024, September 23). ''EU: Address Indigenous rights violations in Malaysian imports: Designate Sarawak as “high risk” under new anti-deforestation law''. <nowiki>https://www.hrw.org/news/2024/09/23/eu-address-indigenous-rights-violations-malaysian-imports</nowiki>

Institute of Strategic and International Studies Malaysia (ISIS Malaysia), & Universiti Putra Malaysia (UPM). (2024a). ''Availability of EU deforestation regulation relevant information for the palm oil sector in Malaysia'' (Policy Brief No. 2). <nowiki>https://www.isis.org.my/wp-content/uploads/2024/11/Policy-brief-2-Malaysia-data-readiness-for-EUDR_layout2.pdf</nowiki>

Institute of Strategic and International Studies Malaysia (ISIS Malaysia), & Universiti Putra Malaysia (UPM). (2024b). ''Reinforcing deforestation‑free palm oil supply chains: Options for Malaysia in the context of EU and global legislation''. European Forest Institute. <nowiki>https://efi.int/sites/default/files/files/flegtredd/KAMI/Resources/Deforestation_free_supply_chains_for_palm_oil_2.pdf</nowiki>

Jong, H. N. (2023, September 1). ''Palm oil giants Indonesia, Malaysia start talks with EU over deforestation rule''. Mongabay. <nowiki>https://news.mongabay.com/2023/09/palm-oil-giants-indonesia-malaysia-start-talks-with-eu-over-deforestation-rule/</nowiki>

Keeton-Olsen, D. (2021, February 18). ''In Malaysian Borneo’s rainforests, powerful state governments set their own rules''. Mongabay. <nowiki>https://news.mongabay.com/2021/02/in-malaysian-borneos-rainforests-powerful-state-government-set-their-own-rules/</nowiki>

Keeton-Olsen, D. (2024, October 9). ''NGOs push EU to label Sarawak as “high risk” source of timber, palm oil''. Mongabay. <nowiki>https://news.mongabay.com/2024/10/ngos-push-eu-to-label-sarawak-as-high-risk-source-of-timber-palm-oil/</nowiki>

Keeton-Olsen, D. (2025, November 11). ''Cautious win for Indigenous groups in Malaysia as palm oil firm pauses forest clearing''. Mongabay. <nowiki>https://news.mongabay.com/2025/11/cautious-win-for-indigenous-groups-in-malaysia-as-palm-oil-firm-pauses-forest-clearing/</nowiki>

Koh, J., Johari, S., Shuib, A., Siow, M. L., & Matthew, N. K. (2023). Malaysia’s forest pledges and the Bornean state of Sarawak: A policy perspective. ''Sustainability, 15''(2), 1385. <nowiki>https://doi.org/10.3390/su15021385</nowiki>

Kumaran, S., Chew, J. S., & Nambiappan, B. (2021). ''Moving forward with mandatory MSPO certification standards''. ''Oil Palm Industry Economic Journal, 21''(1), 1–12. <nowiki>https://doi.org/10.21894/opiej.2021.01</nowiki>

Land and Survey Department Sarawak. (2026, March 27). ''Land and Survey Department Sarawak''. <nowiki>https://landsurvey.sarawak.gov.my/web/home/index/</nowiki>

Low, C. C. (2024, July 4). ''Timber grab: The truth behind Pahang oil palm plantations in Malaysia''. Asian Dispatch. <nowiki>https://www.asiandispatch.net/timber-grab-the-truth-behind-pahang-oil-palm-plantations-in-malaysia</nowiki>

Meridia. (2025, May 28). ''EUDR benchmarking and risk categories explained: A simple guide''. <nowiki>https://www.meridia.land/blog/eudr-benchmarking-and-risk-categories-explained-a-simple-guide</nowiki>

Ministry of Urban Development and Natural Resources. (2026, March 20). ''MUDeNR – Sarawak''. <nowiki>https://mudenr.sarawak.gov.my/web/home/index/</nowiki>

Mohammad, H. H., Ripot, S., Alek, R. J., Cluny, W., & Kader, W. A. (2022). ''Sustainable forest management: Sarawak’s perspective''. Forest Department Sarawak. <nowiki>https://www.forestry.gov.my/images/pengumuman/2022/MFC/MFC2024/paperwork/Paper_2_Sustainable_Forest_Management_Sarawaks_Perspective.pdf</nowiki>

Proforest. (2025). ''Options to broaden smallholder inclusivity in legal and deforestation-free palm oil supply chains in Malaysia''. European Forest Institute. <nowiki>https://efi.int/sites/default/files/files/flegtredd/KAMI/Resources/smallholder_inclusivity_report.pdf</nowiki>

Reuters. (2025, September 10). ''EU clears Malaysia's palm oil certification for new deforestation rule''. <nowiki>https://www.reuters.com/markets/commodities/eu-clears-malaysias-palm-oil-certification-new-deforestation-rule-2025-09-10/</nowiki>

Ross, J. (2026, March 3). Malaysia warns CITES push on tropical timber is self‑interest, not science. Wood Central. <nowiki>https://woodcentral.com.au/malaysia-warns-cites-push-on-tropical-timber-is-self-interest-not-science/</nowiki>

Sarawak Forestry Corporation. (2026, March 20). ''Sarawak Forestry Corporation''. <nowiki>https://sfc.sarawak.gov.my/web/home/index/</nowiki>

Sarawak Report. (2024, June 2). ''Malaysia’s rainforest threat is focused on Sarawak''. <nowiki>https://www.sarawakreport.org/2024/06/malaysias-rainforest-threat-is-focused-on-sarawak/</nowiki>

Sarmiento, F., Larrea, C., Oeschger, A., & Jose, R. (2024, February 21). ''Measures to enhance forest conservation and reduce deforestation: Viewpoints and lessons from producing countries''. International Institute for Sustainable Development. <nowiki>https://www.iisd.org/ssi/publications/measures-enhance-forest-conservation-reduce-deforestation/</nowiki>

Tan, L. C., Toh, M. L., Looi, K. S., Tan, W. V., Ujang, M. U., Thoo, A. C., Azri, N. S. b., & Kathitasapathy, S. A. L. (2023). Towards “good” Native land governance: An evaluation in Sarawak, Malaysia. ''The International Indigenous Policy Journal, 14''(1). <nowiki>https://doi.org/10.18584/iipj.2023.14.1.13873</nowiki>

Tang, A. (2025, October 8). ''EU delays deforestation rule to Dec 2026''. ''Sarawak Tribune''. <nowiki>https://www.sarawaktribune.com/eu-delays-deforestation-rule-to-december-2026/</nowiki>

Teja, N. (2024, February 8). ''EU deforestation regulation dubbed a ‘double-edged sword’ for global palm oil markets''. Sustainable Views. <nowiki>https://www.sustainableviews.com/eu-deforestation-regulation-dubbed-a-double-edged-sword-for-global-palm-oil-markets/</nowiki>

The Borneo Project. (2024, September 26). ''Why Sarawak should be high risk under the new EU deforestation rules''. <nowiki>https://borneoproject.org/why-sarawak-should-be-high-risk-under-the-new-eu-deforestation-rules/</nowiki>

The Borneo Project. (2025a, January 10). ''Deforestation alert: Ulu Belaga''. <nowiki>https://borneoproject.org/deforestation-alert-ulu-belaga/</nowiki>

The Borneo Project. (2025b, October 30). ''Victory for Indigenous communities in Sarawak as Urun Plantations halts forest clearing''. <nowiki>https://borneoproject.org/victory-for-indigenous-communities-in-sarawak-as-urun-plantations-halts-forest-clearing/</nowiki>

UKAS. (2025a, September 19). ''Palm oil overtakes crude petroleum as Sarawak’s leading export''. Premier of Sarawak Department. <nowiki>https://premierdept.sarawak.gov.my/web/subpage/news_view/25115/UKAS</nowiki>

UKAS. (2025b, January 17). ''Sarawak Cabinet works collectively for the well-being of the people''. Government of Sarawak. <nowiki>https://premierdept.sarawak.gov.my/web/subpage/news_view/11717/UKAS#:~:text=%E2%80%9COur%20cabinet%20operates%20on%20a%20collective%20system,economy%2C%20and%20that%20is%20the%20result%20of</nowiki>

----[1] By 2024, Sarawak had lost 1.7 million hectares of humid primary forest, a 23% decline in its overall primary forest area (Global Forest Watch, n.d.).

[2] Continued forest loss and land-rights disputes risk “high-risk” classification, which could threaten Sarawak’s EU market access (Funds for NGOs, 2024).

[3] This has contributed to a cumulative decline of about 1.04 million acres between 2019 and 2023. Furthermore, associated analysis suggests that logging and oil palm expansion continue to threaten extensive areas of naturally regenerating forest (Keeton-Olsen, 2024).

[4] Additionally, although the legal framework requires the voluntary surrender or termination of customary land and compensation prior to commercial allocation, implementation has been noted to be inconsistent in practice (Human Rights Watch, 2024).

[5] The EU represents a key destination for Malaysian palm oil, ranking as the third-largest market after India and China. In 2023, palm oil exports from Malaysia to the EU totaled 1.07 million tonnes, accounting for 7.1% of the country’s overall palm oil exports (Proforest, 2025).

[6] EU countries are significant importers of Malaysian forestry goods, with the Netherlands and Germany ranking as the second- and third-largest purchasers of nationally certified timber from Malaysia in 2022(Keeton-Olsen, 2024).

[7] Operational authority is implemented through several key agencies. The Sarawak Forest Department oversees forest classification, management, and the issuance of timber licences, while the Sarawak Land and Survey Department is responsible for land allocation, land registration, and matters related to NCR land. In parallel, the Sarawak Forestry Corporation is mandated to manage conservation efforts, including protected areas and biodiversity (Forest Department Sarawak, 2026; Land and Survey Department Sarawak, 2026; Sarawak Forestry Corporation, 2026).

[8] Power at this level remains closely aligned with major corporations, whose political and economic influence continue to shape development priorities and regulatory enforcement (Tan et al., 2023; Koh et al., 2023).

[9] It has been observed that smallholder farmers are more unlikely to satisfy the legality and sustainability requirements stipulated by the EUDR, as financial and structural constraints could limit their capacity to comply, thereby risking their exclusion from this vital global supply chain (Jong, 2023).

[10] Compliance with the EUDR will therefore require significant financial, technical, and institutional support from government and industry stakeholders (Proforest, 2025).

[11] This option largely reflects existing approaches, which have not fully curbed deforestation or addressed persistent traceability and enforcement gaps (The Borneo Project, 2024).

[12] ISPO made compliance a legal requirement rather than a purely voluntary market choice with traceability being strengthened by requiring certified operators to identify the source of fresh fruit bunches and disclosure of supplier and buyer relationships within the value chain (Sarmiento et al., 2024).

[13] This will be critical given the EUDR’s post-2020 cutoff, as traceability systems must be capable of distinguishing between compliant and non-compliant production areas. This could reduce the feasibility of simply redirecting exports to alternative markets, reinforcing the need for system-wide transparency (The Borneo Project, 2024).

[14] This involved moving from informal, insecure land use to formal, contract-based forest access through the creation of Agroforestry Concessions and reorganization of land into forest-use zones. The reform worked by giving smallholders a legal path into the system instead of leaving them invisible to the state (Sarmiento et al., 2024).

[[Category:Forestry]]

Documentation:Sarawak’s Forest Governance under the European Union Deforestation Regulation: Policy Options for the Premier of the State of Sarawak, Malaysia

2026-05-15T20:25:56Z

WillEngle: /* Key Actors */

Oil palm and timber plantations expansion have been noted as the primary drivers of deforestation in Sarawak<ref>By 2024, Sarawak had lost 1.7 million hectares of humid primary forest, a 23% decline in its overall primary forest area (Global Forest Watch, n.d.).</ref> (Sarawak Report, 2024). This has created a significant governance challenge under the European Union Deforestation Regulation (EUDR) which came into force on 29<sup>th</sup> June 2023 requiring commodities entering the EU market to be deforestation-free and legally produced with a post-2020 deforestation cutoff<ref>Continued forest loss and land-rights disputes risk “high-risk” classification, which could threaten Sarawak’s EU market access (Funds for NGOs, 2024). </ref> (The Borneo Project, 2024).

= List of Abbreviations =

'''EUDR - European Union Deforestation Regulation'''

'''FPIC - Free, Prior and Informed Consent'''

'''ISIS - Institute of Strategic and International Studies'''

'''ISPO - Indonesian Sustainable Palm Oil'''

'''MSPO - Malaysian Sustainable Palm Oil'''

'''NCR - Native Customary Rights'''

'''UPM - Universiti Putra Malaysia'''

'''WTO - World Trade Organisation'''

== Background ==
The EUDR has increased pressure on producers with compliance depending on strict plot-level geolocation and supply-chain traceability requirements, limiting the scope for diverting commodities to alternative markets (Human Rights Watch, 2024).

Malaysia has challenged the EUDR, framing it as a form of disguised protectionism and a trade barrier that places disproportionate burdens on smallholders in its formal complaint to the WTO, this has introduced further uncertainty (Brasier, 2024; Teja, 2024).

Malaysia has relied on the Malaysian Sustainable Palm Oil (MSPO) certification scheme, alongside existing legal frameworks under the Land Code and Forest Ordinance, to address raised sustainability concerns (ISIS Malaysia & UPM, 2024a, 2024b). The EU has recognised the scheme as a credible certification framework that could support compliance with the EUDR, due to the incorporation of digital traceability tools that strengthen supply-chain transparency (Reuters, 2025).

However, despite these policy advancements, forest loss remains significant, with approximately 85,100 hectares cleared in 2023<ref>This has contributed to a cumulative decline of about 1.04 million acres between 2019 and 2023. Furthermore, associated analysis suggests that logging and oil palm expansion continue to threaten extensive areas of naturally regenerating forest (Keeton-Olsen, 2024).</ref> (Funds for NGOs, 2024) See figure 1 below for extent of plantation expansion. This has been intensified by the state’s target of one million hectares of timber plantations, requiring the clearance of over 400,000 hectares of natural forest (The Borneo Project, 2024).

'''Figure 1: Extent of Plantation Concessions in Sarawak'''

Source: Erickson-Davis (2018)

Local tensions too, have escalated with Long Urun recording over 40,000 satellite‑detected deforestation alerts, with nearly 500 hectares of forest lost. This triggered petitions and blockades after official avenues failed. International pressure later prompted a temporary moratorium (Keeton‑Olsen, 2025; The Borneo Project, 2025a, 2025b). (See figure 2 below, for extent).

'''Figure 2: Land Clearing Captured in Long Urun on September 24, 2025'''

Source: Keeton-Olsen (2025)

Furthermore, Sarawak’s Land Code has been criticized for limiting the legal recognition of Indigenous Native Customary Rights (NCR) lands while enabling commercial access to forested areas through state-issued leases<ref>Additionally, although the legal framework requires the voluntary surrender or termination of customary land and compensation prior to commercial allocation, implementation has been noted to be inconsistent in practice (Human Rights Watch, 2024).</ref> (The Borneo Project, 2025a, 2025b).

These governance challenges have strengthened calls by civil society organisations urging the EU to classify Sarawak as a high-risk jurisdiction which would increase regulatory scrutiny of exports to EU markets (Keeton-Olsen, 2024). Given the importance of European markets for Malaysia’s palm oil<ref>The EU represents a key destination for Malaysian palm oil, ranking as the third-largest market after India and China. In 2023, palm oil exports from Malaysia to the EU totaled 1.07 million tonnes, accounting for 7.1% of the country’s overall palm oil exports (Proforest, 2025).</ref> and timber sectors<ref>EU countries are significant importers of Malaysian forestry goods, with the Netherlands and Germany ranking as the second- and third-largest purchasers of nationally certified timber from Malaysia in 2022(Keeton-Olsen, 2024).</ref>, strengthening forest governance and ensuring compliance are paramount (Human Rights Watch, 2024).

== Key Actors ==
At the international level, EU institutions act as external regulators through EUDR requirements, shaping market access and compliance expectations. International NGOs and consumer brands exert influence through supply chain pressure, exemplified by the sourcing suspensions linked to plantation expansion in Long Urun (The Borneo Project, 2025a, 2025b).

At the national level, federal institutions such as the Malaysian Palm Oil Council, Ministry of Investment, Trade and Industry, Ministry of Plantation and Commodities, Malaysian Timber Industry Board, influence the broader economic and regulatory environment through export policy, trade negotiations, and sustainability certification systems, while engaging directly with the EU on EUDR compliance (ISIS Malaysia & UPM, 2024a, 2024b; Kumaran et al., 2021; Reuters, 2025). They continue to lead Malaysia’s challenge to the EUDR at the WTO (Brasier, 2024; Teja, 2024).

At the sub-national level, the Sarawak state government holds primary authority over land allocation, forest classification, and plantation licensing through the Sarawak Ministry of Natural Resources and Urban Development<ref>Operational authority is implemented through several key agencies. The Sarawak Forest Department oversees forest classification, management, and the issuance of timber licences, while the Sarawak Land and Survey Department is responsible for land allocation, land registration, and matters related to NCR land. In parallel, the Sarawak Forestry Corporation is mandated to manage conservation efforts, including protected areas and biodiversity (Forest Department Sarawak, 2026; Land and Survey Department Sarawak, 2026; Sarawak Forestry Corporation, 2026).</ref> (Ministry of Urban Development and Natural Resources, 2026). This enables it to approve timber concessions and oil palm expansion<ref>Power at this level remains closely aligned with major corporations, whose political and economic influence continue to shape development priorities and regulatory enforcement (Tan et al., 2023; Koh et al., 2023). </ref> (Keeton-Olsen, 2021; Mohammad et al., 2022).

At the local level, Indigenous communities alongside forest-dependent households, smallholders, and plantation workers, are most directly affected by these governance dynamics<ref>It has been observed that smallholder farmers are more unlikely to satisfy the legality and sustainability requirements stipulated by the EUDR, as financial and structural constraints could limit their capacity to comply, thereby risking their exclusion from this vital global supply chain (Jong, 2023).</ref>. They rely on NCR lands for livelihoods and cultural continuity but face persistent barriers to formal recognition under Sarawak’s Land Code (Human Rights Watch, 2024). Forest conversion threatens their subsistence resources, fuels local conflicts, exposing smallholders and labourers to economic risks<ref>Compliance with the EUDR will therefore require significant financial, technical, and institutional support from government and industry stakeholders (Proforest, 2025).</ref> (Funds for NGOs, 2024).

== Policy options ==

=== '''Option 1: Status Quo''' ===
Herein, enforcement would continue through current state mechanisms under the Land Code and Forest Ordinance alongside the MSPO certification framework. This approach preserves current development trajectories centred on oil palm and timber expansion'''[11]''' (Human Rights Watch, 2024; UKAS, 2025a).

Continued forest loss would likely persist, reinforcing international scrutiny from regulators, civil society organisations, and consumer brands concerned (Funds for NGOs, 2024; The Borneo Project, 2024). Sarawak could face heightened due-diligence requirements or potential classification as a “high-risk” jurisdiction, increasing transaction costs (ISIS Malaysia & UPM, 2024a, 2024b). See figure 3 below for due-diligence requirements.

Figure 3: Due Diligence Requirements Under Articles 9, 10 and 11 of the EUDR

Source: ISIS Malaysia, & UPM, 2024b

The main benefit of this would be that plantation expansion proceeds without disruption, industry actors avoid new compliance costs, while state revenues linked to land-based development would remain stable in the near term (Koh et al., 2023; Tan et al., 2023).

Authority over routine enforcement priorities, administrative coordination, and public communication would be retained while avoiding initiating legislative or regulatory reforms (Forests Ordinance, 2015). This would favour plantation and timber interests while minimising confrontation with powerful industry actors. Winners would include large agribusiness firms and political actors aligned with expansion, while losers would include forest-dependent communities, environmentally oriented exporters, and stakeholders seeking stronger sustainability compliance (Human Rights Watch, 2024; The Borneo Project, 2024).

=== '''Option 2: Compliance and Traceability Strategy''' ===
This would strengthen supply-chain transparency and traceability systems while allowing continued land conversion within existing regulatory limits as seen in Indonesia which was able to achieve compliance and traceability through its mandatory national certification system, the Indonesian Sustainable Palm Oil (ISPO) scheme, paired with forest-use restrictions, audits, and traceability rules for the palm oil supply chain'''[12]''' (Sarmiento et al., 2024).

Measures would include improving geolocation data, integrating plantation licensing databases, strengthening MSPO 2.0 implementation, and supporting smallholders in meeting certification requirements'''[13]''' (ISIS Malaysia & UPM, 2024a, 2024b; Reuters, 2025).

Strengthening digital monitoring systems, verification mechanisms, and compliance support programmes would require public funding and institutional coordination (Forests Ordinance, 2015). Smallholders may face additional reporting burdens, while some companies may resist transparency requirements. Reforms may also remain procedural rather than substantive if underlying drivers of deforestation remain unchanged (The Borneo Project, 2024).

Enhanced traceability and compliance systems would demonstrate legality and supply-chain transparency to EU regulators and international buyers with export-oriented producers gaining more secure access to European markets, while improved governance systems could increase investor confidence, reducing trade disruptions (Ross, 2026).

Exercising of direct control over monitoring systems, enforcement transparency, and state-level compliance infrastructure would be facilitated but would require coordination with federal agencies responsible for certification and export promotion as well as cabinet support for budget allocations and inter-agency mandates (Forests Ordinance, 2015). This would appeal to export-oriented firms and federal trade authorities while avoiding major restrictions on plantation expansion. Winners would include compliant exporters and supported smallholders, while non-compliant operators would face greater scrutiny (Human Rights Watch, 2024).

=== '''Option 3: Forest Protection and Land Governance Reform''' ===
This would ensure stronger land-use regulation and governance reform. Measures will include a moratorium on new plantations in natural forests and peatlands, expansion of protected forest areas, stricter enforcement of land-conversion rules, and improved recognition of Indigenous NCR alongside Free, Prior and Informed Consent (FPIC) requirements for development projects (Human Rights Watch, 2024; The Borneo Project, 2024).

Stricter land-use controls could slow plantation expansion, potentially reducing short-term revenue from land-based development with enforcement capacity needing strengthening. Compensation or renegotiation of existing concessions would also need to be carried out to minimize legal disputes as well as boost investor confidence (Koh et al., 2023; Tan et al., 2023). Peru was able to achieve similar structural reforms by pairing land and forest formalization with clearer rules, stronger institutions, and incentives that brought informal actors into the legal system'''[14]''' (Sarmiento et al., 2024).

Stronger forest protection would result, reducing deforestation, improving biodiversity conservation, while decreasing land-rights conflicts with Indigenous communities (Sarmiento et al., 2024). Alignment with the EUDR would also strengthen Sarawak’s credibility (Tang, 2025; Reuters, 2025).

Control of enforcement priorities and administrative measures would be enabled. However, major reforms focusing on land-law amendments and protected-area designations would require approval from the State Legislative Assembly and coordination with federal authorities (Forests Ordinance, 2015). This option may face resistance from agribusiness interests but would gain support from civil society, Indigenous communities, and international partners. Winners would include forest-dependent communities, sustainable producers, and long-term exporters, while firms reliant on expansion and land-conversion revenues may incur losses (ISIS Malaysia & UPM, 2024a, 2024b; Mohammad et al., 2022).

== Recommended Policy option ==
A hybrid strategy would be the most viable approach, beginning with Option 2 and transitioning toward Option 3. Strengthening traceability, MSPO 2.0 implementation, and monitoring systems would provide immediate protection of EU market access, which is critical given Sarawak’s export dependence and exposure to EUDR requirements (Sarmiento et al., 2024; UKAS, 2025). This approach is politically feasible, avoids abrupt disruption, while building on the required administrative capacity for deeper reforms (Sarmiento et al., 2024).

However, compliance alone may not address the underlying deforestation drivers. A phased transition towards stronger land-use regulation and recognition of NCR and FPIC is necessary for long-term sustainability (Sarmiento et al., 2024; The Borneo Project, 2024). This would counter the state–corporate bias by empowering Indigenous voices via NCR/FPIC, while using traceability to appease exporters (Human Rights Watch, 2024). While Malaysia’s WTO challenge may reshape future obligations, it does not eliminate the immediate need for compliance (Brasier, 2024; Teja, 2024). This combined approach balances short-term trade imperatives with longer-term governance reform.

== Decision Timeline, Next Steps, and Key Milestones ==
The approach should be adopted by 30 March 2026 to allow sufficient lead time for implementation before the EUDR takes effect. It will apply from 30 December 2026 for large operators and traders, and from 30 June 2027 for micro- and small enterprises (European Commission, 2024). In addition, the EU’s risk benchmarking review, expected in May 2026, may shape Malaysia’s classification as high or standard risk, making early preparation paramount (Meridia, 2025).

Implementation should proceed in phases. In April 2026, an inter-agency taskforce should be convened to coordinate traceability mapping. In May 2026, Cabinet should decide on budget allocations and whether Land Code amendments will be pursued. June 2026 should mark the launch of smallholder support pilots and stakeholder forums, followed by quarterly deforestation monitoring reports. In Q2 2026, legislative reforms could be considered during the State Assembly session, while a federal MSPO audit is expected in Q3 2026. Large-firm pilots should begin in December 2026, with scale-up decisions made in late 2026 ahead of April 2027 compliance checks.

= References =
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Ministry of Urban Development and Natural Resources. (2026, March 20). ''MUDeNR – Sarawak''. <nowiki>https://mudenr.sarawak.gov.my/web/home/index/</nowiki>

Mohammad, H. H., Ripot, S., Alek, R. J., Cluny, W., & Kader, W. A. (2022). ''Sustainable forest management: Sarawak’s perspective''. Forest Department Sarawak. <nowiki>https://www.forestry.gov.my/images/pengumuman/2022/MFC/MFC2024/paperwork/Paper_2_Sustainable_Forest_Management_Sarawaks_Perspective.pdf</nowiki>

Proforest. (2025). ''Options to broaden smallholder inclusivity in legal and deforestation-free palm oil supply chains in Malaysia''. European Forest Institute. <nowiki>https://efi.int/sites/default/files/files/flegtredd/KAMI/Resources/smallholder_inclusivity_report.pdf</nowiki>

Reuters. (2025, September 10). ''EU clears Malaysia's palm oil certification for new deforestation rule''. <nowiki>https://www.reuters.com/markets/commodities/eu-clears-malaysias-palm-oil-certification-new-deforestation-rule-2025-09-10/</nowiki>

Ross, J. (2026, March 3). Malaysia warns CITES push on tropical timber is self‑interest, not science. Wood Central. <nowiki>https://woodcentral.com.au/malaysia-warns-cites-push-on-tropical-timber-is-self-interest-not-science/</nowiki>

Sarawak Forestry Corporation. (2026, March 20). ''Sarawak Forestry Corporation''. <nowiki>https://sfc.sarawak.gov.my/web/home/index/</nowiki>

Sarawak Report. (2024, June 2). ''Malaysia’s rainforest threat is focused on Sarawak''. <nowiki>https://www.sarawakreport.org/2024/06/malaysias-rainforest-threat-is-focused-on-sarawak/</nowiki>

Sarmiento, F., Larrea, C., Oeschger, A., & Jose, R. (2024, February 21). ''Measures to enhance forest conservation and reduce deforestation: Viewpoints and lessons from producing countries''. International Institute for Sustainable Development. <nowiki>https://www.iisd.org/ssi/publications/measures-enhance-forest-conservation-reduce-deforestation/</nowiki>

Tan, L. C., Toh, M. L., Looi, K. S., Tan, W. V., Ujang, M. U., Thoo, A. C., Azri, N. S. b., & Kathitasapathy, S. A. L. (2023). Towards “good” Native land governance: An evaluation in Sarawak, Malaysia. ''The International Indigenous Policy Journal, 14''(1). <nowiki>https://doi.org/10.18584/iipj.2023.14.1.13873</nowiki>

Tang, A. (2025, October 8). ''EU delays deforestation rule to Dec 2026''. ''Sarawak Tribune''. <nowiki>https://www.sarawaktribune.com/eu-delays-deforestation-rule-to-december-2026/</nowiki>

Teja, N. (2024, February 8). ''EU deforestation regulation dubbed a ‘double-edged sword’ for global palm oil markets''. Sustainable Views. <nowiki>https://www.sustainableviews.com/eu-deforestation-regulation-dubbed-a-double-edged-sword-for-global-palm-oil-markets/</nowiki>

The Borneo Project. (2024, September 26). ''Why Sarawak should be high risk under the new EU deforestation rules''. <nowiki>https://borneoproject.org/why-sarawak-should-be-high-risk-under-the-new-eu-deforestation-rules/</nowiki>

The Borneo Project. (2025a, January 10). ''Deforestation alert: Ulu Belaga''. <nowiki>https://borneoproject.org/deforestation-alert-ulu-belaga/</nowiki>

The Borneo Project. (2025b, October 30). ''Victory for Indigenous communities in Sarawak as Urun Plantations halts forest clearing''. <nowiki>https://borneoproject.org/victory-for-indigenous-communities-in-sarawak-as-urun-plantations-halts-forest-clearing/</nowiki>

UKAS. (2025a, September 19). ''Palm oil overtakes crude petroleum as Sarawak’s leading export''. Premier of Sarawak Department. <nowiki>https://premierdept.sarawak.gov.my/web/subpage/news_view/25115/UKAS</nowiki>

UKAS. (2025b, January 17). ''Sarawak Cabinet works collectively for the well-being of the people''. Government of Sarawak. <nowiki>https://premierdept.sarawak.gov.my/web/subpage/news_view/11717/UKAS#:~:text=%E2%80%9COur%20cabinet%20operates%20on%20a%20collective%20system,economy%2C%20and%20that%20is%20the%20result%20of</nowiki>

----[1] By 2024, Sarawak had lost 1.7 million hectares of humid primary forest, a 23% decline in its overall primary forest area (Global Forest Watch, n.d.).

[2] Continued forest loss and land-rights disputes risk “high-risk” classification, which could threaten Sarawak’s EU market access (Funds for NGOs, 2024).

[3] This has contributed to a cumulative decline of about 1.04 million acres between 2019 and 2023. Furthermore, associated analysis suggests that logging and oil palm expansion continue to threaten extensive areas of naturally regenerating forest (Keeton-Olsen, 2024).

[4] Additionally, although the legal framework requires the voluntary surrender or termination of customary land and compensation prior to commercial allocation, implementation has been noted to be inconsistent in practice (Human Rights Watch, 2024).

[5] The EU represents a key destination for Malaysian palm oil, ranking as the third-largest market after India and China. In 2023, palm oil exports from Malaysia to the EU totaled 1.07 million tonnes, accounting for 7.1% of the country’s overall palm oil exports (Proforest, 2025).

[6] EU countries are significant importers of Malaysian forestry goods, with the Netherlands and Germany ranking as the second- and third-largest purchasers of nationally certified timber from Malaysia in 2022(Keeton-Olsen, 2024).

[7] Operational authority is implemented through several key agencies. The Sarawak Forest Department oversees forest classification, management, and the issuance of timber licences, while the Sarawak Land and Survey Department is responsible for land allocation, land registration, and matters related to NCR land. In parallel, the Sarawak Forestry Corporation is mandated to manage conservation efforts, including protected areas and biodiversity (Forest Department Sarawak, 2026; Land and Survey Department Sarawak, 2026; Sarawak Forestry Corporation, 2026).

[8] Power at this level remains closely aligned with major corporations, whose political and economic influence continue to shape development priorities and regulatory enforcement (Tan et al., 2023; Koh et al., 2023).

[9] It has been observed that smallholder farmers are more unlikely to satisfy the legality and sustainability requirements stipulated by the EUDR, as financial and structural constraints could limit their capacity to comply, thereby risking their exclusion from this vital global supply chain (Jong, 2023).

[10] Compliance with the EUDR will therefore require significant financial, technical, and institutional support from government and industry stakeholders (Proforest, 2025).

[11] This option largely reflects existing approaches, which have not fully curbed deforestation or addressed persistent traceability and enforcement gaps (The Borneo Project, 2024).

[12] ISPO made compliance a legal requirement rather than a purely voluntary market choice with traceability being strengthened by requiring certified operators to identify the source of fresh fruit bunches and disclosure of supplier and buyer relationships within the value chain (Sarmiento et al., 2024).

[13] This will be critical given the EUDR’s post-2020 cutoff, as traceability systems must be capable of distinguishing between compliant and non-compliant production areas. This could reduce the feasibility of simply redirecting exports to alternative markets, reinforcing the need for system-wide transparency (The Borneo Project, 2024).

[14] This involved moving from informal, insecure land use to formal, contract-based forest access through the creation of Agroforestry Concessions and reorganization of land into forest-use zones. The reform worked by giving smallholders a legal path into the system instead of leaving them invisible to the state (Sarmiento et al., 2024).

[[Category:Forestry]]

Documentation:Sarawak’s Forest Governance under the European Union Deforestation Regulation: Policy Options for the Premier of the State of Sarawak, Malaysia

2026-05-15T20:24:13Z

WillEngle:

Oil palm and timber plantations expansion have been noted as the primary drivers of deforestation in Sarawak<ref>By 2024, Sarawak had lost 1.7 million hectares of humid primary forest, a 23% decline in its overall primary forest area (Global Forest Watch, n.d.).</ref> (Sarawak Report, 2024). This has created a significant governance challenge under the European Union Deforestation Regulation (EUDR) which came into force on 29<sup>th</sup> June 2023 requiring commodities entering the EU market to be deforestation-free and legally produced with a post-2020 deforestation cutoff<ref>Continued forest loss and land-rights disputes risk “high-risk” classification, which could threaten Sarawak’s EU market access (Funds for NGOs, 2024). </ref> (The Borneo Project, 2024).

= List of Abbreviations =

'''EUDR - European Union Deforestation Regulation'''

'''FPIC - Free, Prior and Informed Consent'''

'''ISIS - Institute of Strategic and International Studies'''

'''ISPO - Indonesian Sustainable Palm Oil'''

'''MSPO - Malaysian Sustainable Palm Oil'''

'''NCR - Native Customary Rights'''

'''UPM - Universiti Putra Malaysia'''

'''WTO - World Trade Organisation'''

== Background ==
The EUDR has increased pressure on producers with compliance depending on strict plot-level geolocation and supply-chain traceability requirements, limiting the scope for diverting commodities to alternative markets (Human Rights Watch, 2024).

Malaysia has challenged the EUDR, framing it as a form of disguised protectionism and a trade barrier that places disproportionate burdens on smallholders in its formal complaint to the WTO, this has introduced further uncertainty (Brasier, 2024; Teja, 2024).

Malaysia has relied on the Malaysian Sustainable Palm Oil (MSPO) certification scheme, alongside existing legal frameworks under the Land Code and Forest Ordinance, to address raised sustainability concerns (ISIS Malaysia & UPM, 2024a, 2024b). The EU has recognised the scheme as a credible certification framework that could support compliance with the EUDR, due to the incorporation of digital traceability tools that strengthen supply-chain transparency (Reuters, 2025).

However, despite these policy advancements, forest loss remains significant, with approximately 85,100 hectares cleared in 2023<ref>This has contributed to a cumulative decline of about 1.04 million acres between 2019 and 2023. Furthermore, associated analysis suggests that logging and oil palm expansion continue to threaten extensive areas of naturally regenerating forest (Keeton-Olsen, 2024).</ref> (Funds for NGOs, 2024) See figure 1 below for extent of plantation expansion. This has been intensified by the state’s target of one million hectares of timber plantations, requiring the clearance of over 400,000 hectares of natural forest (The Borneo Project, 2024).

'''Figure 1: Extent of Plantation Concessions in Sarawak'''

Source: Erickson-Davis (2018)

Local tensions too, have escalated with Long Urun recording over 40,000 satellite‑detected deforestation alerts, with nearly 500 hectares of forest lost. This triggered petitions and blockades after official avenues failed. International pressure later prompted a temporary moratorium (Keeton‑Olsen, 2025; The Borneo Project, 2025a, 2025b). (See figure 2 below, for extent).

'''Figure 2: Land Clearing Captured in Long Urun on September 24, 2025'''

Source: Keeton-Olsen (2025)

Furthermore, Sarawak’s Land Code has been criticized for limiting the legal recognition of Indigenous Native Customary Rights (NCR) lands while enabling commercial access to forested areas through state-issued leases<ref>Additionally, although the legal framework requires the voluntary surrender or termination of customary land and compensation prior to commercial allocation, implementation has been noted to be inconsistent in practice (Human Rights Watch, 2024).</ref> (The Borneo Project, 2025a, 2025b).

These governance challenges have strengthened calls by civil society organisations urging the EU to classify Sarawak as a high-risk jurisdiction which would increase regulatory scrutiny of exports to EU markets (Keeton-Olsen, 2024). Given the importance of European markets for Malaysia’s palm oil<ref>The EU represents a key destination for Malaysian palm oil, ranking as the third-largest market after India and China. In 2023, palm oil exports from Malaysia to the EU totaled 1.07 million tonnes, accounting for 7.1% of the country’s overall palm oil exports (Proforest, 2025).</ref> and timber sectors<ref>EU countries are significant importers of Malaysian forestry goods, with the Netherlands and Germany ranking as the second- and third-largest purchasers of nationally certified timber from Malaysia in 2022(Keeton-Olsen, 2024).</ref>, strengthening forest governance and ensuring compliance are paramount (Human Rights Watch, 2024).

== Key Actors ==
At the international level, EU institutions act as external regulators through EUDR requirements, shaping market access and compliance expectations. International NGOs and consumer brands exert influence through supply chain pressure, exemplified by the sourcing suspensions linked to plantation expansion in Long Urun (The Borneo Project, 2025a, 2025b).

At the national level, federal institutions such as the Malaysian Palm Oil Council, Ministry of Investment, Trade and Industry, Ministry of Plantation and Commodities, Malaysian Timber Industry Board, influence the broader economic and regulatory environment through export policy, trade negotiations, and sustainability certification systems, while engaging directly with the EU on EUDR compliance (ISIS Malaysia & UPM, 2024a, 2024b; Kumaran et al., 2021; Reuters, 2025). They continue to lead Malaysia’s challenge to the EUDR at the WTO (Brasier, 2024; Teja, 2024).

At the sub-national level, the Sarawak state government holds primary authority over land allocation, forest classification, and plantation licensing through the Sarawak Ministry of Natural Resources and Urban Development'''[7]''' (Ministry of Urban Development and Natural Resources, 2026). This enables it to approve timber concessions and oil palm expansion'''[8]''' (Keeton-Olsen, 2021; Mohammad et al., 2022).

At the local level, Indigenous communities alongside forest-dependent households, smallholders, and plantation workers, are most directly affected by these governance dynamics'''[9]'''. They rely on NCR lands for livelihoods and cultural continuity but face persistent barriers to formal recognition under Sarawak’s Land Code (Human Rights Watch, 2024). Forest conversion threatens their subsistence resources, fuels local conflicts, exposing smallholders and labourers to economic risks '''[10]''' (Funds for NGOs, 2024).

== Policy options ==

=== '''Option 1: Status Quo''' ===
Herein, enforcement would continue through current state mechanisms under the Land Code and Forest Ordinance alongside the MSPO certification framework. This approach preserves current development trajectories centred on oil palm and timber expansion'''[11]''' (Human Rights Watch, 2024; UKAS, 2025a).

Continued forest loss would likely persist, reinforcing international scrutiny from regulators, civil society organisations, and consumer brands concerned (Funds for NGOs, 2024; The Borneo Project, 2024). Sarawak could face heightened due-diligence requirements or potential classification as a “high-risk” jurisdiction, increasing transaction costs (ISIS Malaysia & UPM, 2024a, 2024b). See figure 3 below for due-diligence requirements.

Figure 3: Due Diligence Requirements Under Articles 9, 10 and 11 of the EUDR

Source: ISIS Malaysia, & UPM, 2024b

The main benefit of this would be that plantation expansion proceeds without disruption, industry actors avoid new compliance costs, while state revenues linked to land-based development would remain stable in the near term (Koh et al., 2023; Tan et al., 2023).

Authority over routine enforcement priorities, administrative coordination, and public communication would be retained while avoiding initiating legislative or regulatory reforms (Forests Ordinance, 2015). This would favour plantation and timber interests while minimising confrontation with powerful industry actors. Winners would include large agribusiness firms and political actors aligned with expansion, while losers would include forest-dependent communities, environmentally oriented exporters, and stakeholders seeking stronger sustainability compliance (Human Rights Watch, 2024; The Borneo Project, 2024).

=== '''Option 2: Compliance and Traceability Strategy''' ===
This would strengthen supply-chain transparency and traceability systems while allowing continued land conversion within existing regulatory limits as seen in Indonesia which was able to achieve compliance and traceability through its mandatory national certification system, the Indonesian Sustainable Palm Oil (ISPO) scheme, paired with forest-use restrictions, audits, and traceability rules for the palm oil supply chain'''[12]''' (Sarmiento et al., 2024).

Measures would include improving geolocation data, integrating plantation licensing databases, strengthening MSPO 2.0 implementation, and supporting smallholders in meeting certification requirements'''[13]''' (ISIS Malaysia & UPM, 2024a, 2024b; Reuters, 2025).

Strengthening digital monitoring systems, verification mechanisms, and compliance support programmes would require public funding and institutional coordination (Forests Ordinance, 2015). Smallholders may face additional reporting burdens, while some companies may resist transparency requirements. Reforms may also remain procedural rather than substantive if underlying drivers of deforestation remain unchanged (The Borneo Project, 2024).

Enhanced traceability and compliance systems would demonstrate legality and supply-chain transparency to EU regulators and international buyers with export-oriented producers gaining more secure access to European markets, while improved governance systems could increase investor confidence, reducing trade disruptions (Ross, 2026).

Exercising of direct control over monitoring systems, enforcement transparency, and state-level compliance infrastructure would be facilitated but would require coordination with federal agencies responsible for certification and export promotion as well as cabinet support for budget allocations and inter-agency mandates (Forests Ordinance, 2015). This would appeal to export-oriented firms and federal trade authorities while avoiding major restrictions on plantation expansion. Winners would include compliant exporters and supported smallholders, while non-compliant operators would face greater scrutiny (Human Rights Watch, 2024).

=== '''Option 3: Forest Protection and Land Governance Reform''' ===
This would ensure stronger land-use regulation and governance reform. Measures will include a moratorium on new plantations in natural forests and peatlands, expansion of protected forest areas, stricter enforcement of land-conversion rules, and improved recognition of Indigenous NCR alongside Free, Prior and Informed Consent (FPIC) requirements for development projects (Human Rights Watch, 2024; The Borneo Project, 2024).

Stricter land-use controls could slow plantation expansion, potentially reducing short-term revenue from land-based development with enforcement capacity needing strengthening. Compensation or renegotiation of existing concessions would also need to be carried out to minimize legal disputes as well as boost investor confidence (Koh et al., 2023; Tan et al., 2023). Peru was able to achieve similar structural reforms by pairing land and forest formalization with clearer rules, stronger institutions, and incentives that brought informal actors into the legal system'''[14]''' (Sarmiento et al., 2024).

Stronger forest protection would result, reducing deforestation, improving biodiversity conservation, while decreasing land-rights conflicts with Indigenous communities (Sarmiento et al., 2024). Alignment with the EUDR would also strengthen Sarawak’s credibility (Tang, 2025; Reuters, 2025).

Control of enforcement priorities and administrative measures would be enabled. However, major reforms focusing on land-law amendments and protected-area designations would require approval from the State Legislative Assembly and coordination with federal authorities (Forests Ordinance, 2015). This option may face resistance from agribusiness interests but would gain support from civil society, Indigenous communities, and international partners. Winners would include forest-dependent communities, sustainable producers, and long-term exporters, while firms reliant on expansion and land-conversion revenues may incur losses (ISIS Malaysia & UPM, 2024a, 2024b; Mohammad et al., 2022).

== Recommended Policy option ==
A hybrid strategy would be the most viable approach, beginning with Option 2 and transitioning toward Option 3. Strengthening traceability, MSPO 2.0 implementation, and monitoring systems would provide immediate protection of EU market access, which is critical given Sarawak’s export dependence and exposure to EUDR requirements (Sarmiento et al., 2024; UKAS, 2025). This approach is politically feasible, avoids abrupt disruption, while building on the required administrative capacity for deeper reforms (Sarmiento et al., 2024).

However, compliance alone may not address the underlying deforestation drivers. A phased transition towards stronger land-use regulation and recognition of NCR and FPIC is necessary for long-term sustainability (Sarmiento et al., 2024; The Borneo Project, 2024). This would counter the state–corporate bias by empowering Indigenous voices via NCR/FPIC, while using traceability to appease exporters (Human Rights Watch, 2024). While Malaysia’s WTO challenge may reshape future obligations, it does not eliminate the immediate need for compliance (Brasier, 2024; Teja, 2024). This combined approach balances short-term trade imperatives with longer-term governance reform.

== Decision Timeline, Next Steps, and Key Milestones ==
The approach should be adopted by 30 March 2026 to allow sufficient lead time for implementation before the EUDR takes effect. It will apply from 30 December 2026 for large operators and traders, and from 30 June 2027 for micro- and small enterprises (European Commission, 2024). In addition, the EU’s risk benchmarking review, expected in May 2026, may shape Malaysia’s classification as high or standard risk, making early preparation paramount (Meridia, 2025).

Implementation should proceed in phases. In April 2026, an inter-agency taskforce should be convened to coordinate traceability mapping. In May 2026, Cabinet should decide on budget allocations and whether Land Code amendments will be pursued. June 2026 should mark the launch of smallholder support pilots and stakeholder forums, followed by quarterly deforestation monitoring reports. In Q2 2026, legislative reforms could be considered during the State Assembly session, while a federal MSPO audit is expected in Q3 2026. Large-firm pilots should begin in December 2026, with scale-up decisions made in late 2026 ahead of April 2027 compliance checks.

= References =
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Tan, L. C., Toh, M. L., Looi, K. S., Tan, W. V., Ujang, M. U., Thoo, A. C., Azri, N. S. b., & Kathitasapathy, S. A. L. (2023). Towards “good” Native land governance: An evaluation in Sarawak, Malaysia. ''The International Indigenous Policy Journal, 14''(1). <nowiki>https://doi.org/10.18584/iipj.2023.14.1.13873</nowiki>

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The Borneo Project. (2024, September 26). ''Why Sarawak should be high risk under the new EU deforestation rules''. <nowiki>https://borneoproject.org/why-sarawak-should-be-high-risk-under-the-new-eu-deforestation-rules/</nowiki>

The Borneo Project. (2025a, January 10). ''Deforestation alert: Ulu Belaga''. <nowiki>https://borneoproject.org/deforestation-alert-ulu-belaga/</nowiki>

The Borneo Project. (2025b, October 30). ''Victory for Indigenous communities in Sarawak as Urun Plantations halts forest clearing''. <nowiki>https://borneoproject.org/victory-for-indigenous-communities-in-sarawak-as-urun-plantations-halts-forest-clearing/</nowiki>

UKAS. (2025a, September 19). ''Palm oil overtakes crude petroleum as Sarawak’s leading export''. Premier of Sarawak Department. <nowiki>https://premierdept.sarawak.gov.my/web/subpage/news_view/25115/UKAS</nowiki>

UKAS. (2025b, January 17). ''Sarawak Cabinet works collectively for the well-being of the people''. Government of Sarawak. <nowiki>https://premierdept.sarawak.gov.my/web/subpage/news_view/11717/UKAS#:~:text=%E2%80%9COur%20cabinet%20operates%20on%20a%20collective%20system,economy%2C%20and%20that%20is%20the%20result%20of</nowiki>

----[1] By 2024, Sarawak had lost 1.7 million hectares of humid primary forest, a 23% decline in its overall primary forest area (Global Forest Watch, n.d.).

[2] Continued forest loss and land-rights disputes risk “high-risk” classification, which could threaten Sarawak’s EU market access (Funds for NGOs, 2024).

[3] This has contributed to a cumulative decline of about 1.04 million acres between 2019 and 2023. Furthermore, associated analysis suggests that logging and oil palm expansion continue to threaten extensive areas of naturally regenerating forest (Keeton-Olsen, 2024).

[4] Additionally, although the legal framework requires the voluntary surrender or termination of customary land and compensation prior to commercial allocation, implementation has been noted to be inconsistent in practice (Human Rights Watch, 2024).

[5] The EU represents a key destination for Malaysian palm oil, ranking as the third-largest market after India and China. In 2023, palm oil exports from Malaysia to the EU totaled 1.07 million tonnes, accounting for 7.1% of the country’s overall palm oil exports (Proforest, 2025).

[6] EU countries are significant importers of Malaysian forestry goods, with the Netherlands and Germany ranking as the second- and third-largest purchasers of nationally certified timber from Malaysia in 2022(Keeton-Olsen, 2024).

[7] Operational authority is implemented through several key agencies. The Sarawak Forest Department oversees forest classification, management, and the issuance of timber licences, while the Sarawak Land and Survey Department is responsible for land allocation, land registration, and matters related to NCR land. In parallel, the Sarawak Forestry Corporation is mandated to manage conservation efforts, including protected areas and biodiversity (Forest Department Sarawak, 2026; Land and Survey Department Sarawak, 2026; Sarawak Forestry Corporation, 2026).

[8] Power at this level remains closely aligned with major corporations, whose political and economic influence continue to shape development priorities and regulatory enforcement (Tan et al., 2023; Koh et al., 2023).

[9] It has been observed that smallholder farmers are more unlikely to satisfy the legality and sustainability requirements stipulated by the EUDR, as financial and structural constraints could limit their capacity to comply, thereby risking their exclusion from this vital global supply chain (Jong, 2023).

[10] Compliance with the EUDR will therefore require significant financial, technical, and institutional support from government and industry stakeholders (Proforest, 2025).

[11] This option largely reflects existing approaches, which have not fully curbed deforestation or addressed persistent traceability and enforcement gaps (The Borneo Project, 2024).

[12] ISPO made compliance a legal requirement rather than a purely voluntary market choice with traceability being strengthened by requiring certified operators to identify the source of fresh fruit bunches and disclosure of supplier and buyer relationships within the value chain (Sarmiento et al., 2024).

[13] This will be critical given the EUDR’s post-2020 cutoff, as traceability systems must be capable of distinguishing between compliant and non-compliant production areas. This could reduce the feasibility of simply redirecting exports to alternative markets, reinforcing the need for system-wide transparency (The Borneo Project, 2024).

[14] This involved moving from informal, insecure land use to formal, contract-based forest access through the creation of Agroforestry Concessions and reorganization of land into forest-use zones. The reform worked by giving smallholders a legal path into the system instead of leaving them invisible to the state (Sarmiento et al., 2024).

[[Category:Forestry]]

Documentation:Sarawak’s Forest Governance under the European Union Deforestation Regulation: Policy Options for the Premier of the State of Sarawak, Malaysia

2026-05-15T20:22:00Z

WillEngle:

Oil palm and timber plantations expansion have been noted as the primary drivers of deforestation in Sarawak<ref>By 2024, Sarawak had lost 1.7 million hectares of humid primary forest, a 23% decline in its overall primary forest area (Global Forest Watch, n.d.).</ref> (Sarawak Report, 2024). This has created a significant governance challenge under the European Union Deforestation Regulation (EUDR) which came into force on 29<sup>th</sup> June 2023 requiring commodities entering the EU market to be deforestation-free and legally produced with a post-2020 deforestation cutoff<ref>Continued forest loss and land-rights disputes risk “high-risk” classification, which could threaten Sarawak’s EU market access (Funds for NGOs, 2024). </ref> (The Borneo Project, 2024).

= List of Abbreviations =

'''EUDR - European Union Deforestation Regulation'''

'''FPIC - Free, Prior and Informed Consent'''

'''ISIS - Institute of Strategic and International Studies'''

'''ISPO - Indonesian Sustainable Palm Oil'''

'''MSPO - Malaysian Sustainable Palm Oil'''

'''NCR - Native Customary Rights'''

'''UPM - Universiti Putra Malaysia'''

'''WTO - World Trade Organisation'''

== Background ==
The EUDR has increased pressure on producers with compliance depending on strict plot-level geolocation and supply-chain traceability requirements, limiting the scope for diverting commodities to alternative markets (Human Rights Watch, 2024).

Malaysia has challenged the EUDR, framing it as a form of disguised protectionism and a trade barrier that places disproportionate burdens on smallholders in its formal complaint to the WTO, this has introduced further uncertainty (Brasier, 2024; Teja, 2024).

Malaysia has relied on the Malaysian Sustainable Palm Oil (MSPO) certification scheme, alongside existing legal frameworks under the Land Code and Forest Ordinance, to address raised sustainability concerns (ISIS Malaysia & UPM, 2024a, 2024b). The EU has recognised the scheme as a credible certification framework that could support compliance with the EUDR, due to the incorporation of digital traceability tools that strengthen supply-chain transparency (Reuters, 2025).

However, despite these policy advancements, forest loss remains significant, with approximately 85,100 hectares cleared in 2023'''[3]''' (Funds for NGOs, 2024) See figure 1 below for extent of plantation expansion. This has been intensified by the state’s target of one million hectares of timber plantations, requiring the clearance of over 400,000 hectares of natural forest (The Borneo Project, 2024).

'''Figure 1: Extent of Plantation Concessions in Sarawak'''

Source: Erickson-Davis (2018)

Local tensions too, have escalated with Long Urun recording over 40,000 satellite‑detected deforestation alerts, with nearly 500 hectares of forest lost. This triggered petitions and blockades after official avenues failed. International pressure later prompted a temporary moratorium (Keeton‑Olsen, 2025; The Borneo Project, 2025a, 2025b). (See figure 2 below, for extent).

'''Figure 2: Land Clearing Captured in Long Urun on September 24, 2025'''

Source: Keeton-Olsen (2025)

Furthermore, Sarawak’s Land Code has been criticized for limiting the legal recognition of Indigenous Native Customary Rights (NCR) lands while enabling commercial access to forested areas through state-issued leases'''[4]''' (The Borneo Project, 2025a, 2025b).

These governance challenges have strengthened calls by civil society organisations urging the EU to classify Sarawak as a high-risk jurisdiction which would increase regulatory scrutiny of exports to EU markets (Keeton-Olsen, 2024). Given the importance of European markets for Malaysia’s palm oil'''[5]''' and timber sectors'''[6]''', strengthening forest governance and ensuring compliance are paramount (Human Rights Watch, 2024).

== Key Actors ==
At the international level, EU institutions act as external regulators through EUDR requirements, shaping market access and compliance expectations. International NGOs and consumer brands exert influence through supply chain pressure, exemplified by the sourcing suspensions linked to plantation expansion in Long Urun (The Borneo Project, 2025a, 2025b).

At the national level, federal institutions such as the Malaysian Palm Oil Council, Ministry of Investment, Trade and Industry, Ministry of Plantation and Commodities, Malaysian Timber Industry Board, influence the broader economic and regulatory environment through export policy, trade negotiations, and sustainability certification systems, while engaging directly with the EU on EUDR compliance (ISIS Malaysia & UPM, 2024a, 2024b; Kumaran et al., 2021; Reuters, 2025). They continue to lead Malaysia’s challenge to the EUDR at the WTO (Brasier, 2024; Teja, 2024).

At the sub-national level, the Sarawak state government holds primary authority over land allocation, forest classification, and plantation licensing through the Sarawak Ministry of Natural Resources and Urban Development'''[7]''' (Ministry of Urban Development and Natural Resources, 2026). This enables it to approve timber concessions and oil palm expansion'''[8]''' (Keeton-Olsen, 2021; Mohammad et al., 2022).

At the local level, Indigenous communities alongside forest-dependent households, smallholders, and plantation workers, are most directly affected by these governance dynamics'''[9]'''. They rely on NCR lands for livelihoods and cultural continuity but face persistent barriers to formal recognition under Sarawak’s Land Code (Human Rights Watch, 2024). Forest conversion threatens their subsistence resources, fuels local conflicts, exposing smallholders and labourers to economic risks '''[10]''' (Funds for NGOs, 2024).

== Policy options ==

=== '''Option 1: Status Quo''' ===
Herein, enforcement would continue through current state mechanisms under the Land Code and Forest Ordinance alongside the MSPO certification framework. This approach preserves current development trajectories centred on oil palm and timber expansion'''[11]''' (Human Rights Watch, 2024; UKAS, 2025a).

Continued forest loss would likely persist, reinforcing international scrutiny from regulators, civil society organisations, and consumer brands concerned (Funds for NGOs, 2024; The Borneo Project, 2024). Sarawak could face heightened due-diligence requirements or potential classification as a “high-risk” jurisdiction, increasing transaction costs (ISIS Malaysia & UPM, 2024a, 2024b). See figure 3 below for due-diligence requirements.

Figure 3: Due Diligence Requirements Under Articles 9, 10 and 11 of the EUDR

Source: ISIS Malaysia, & UPM, 2024b

The main benefit of this would be that plantation expansion proceeds without disruption, industry actors avoid new compliance costs, while state revenues linked to land-based development would remain stable in the near term (Koh et al., 2023; Tan et al., 2023).

Authority over routine enforcement priorities, administrative coordination, and public communication would be retained while avoiding initiating legislative or regulatory reforms (Forests Ordinance, 2015). This would favour plantation and timber interests while minimising confrontation with powerful industry actors. Winners would include large agribusiness firms and political actors aligned with expansion, while losers would include forest-dependent communities, environmentally oriented exporters, and stakeholders seeking stronger sustainability compliance (Human Rights Watch, 2024; The Borneo Project, 2024).

=== '''Option 2: Compliance and Traceability Strategy''' ===
This would strengthen supply-chain transparency and traceability systems while allowing continued land conversion within existing regulatory limits as seen in Indonesia which was able to achieve compliance and traceability through its mandatory national certification system, the Indonesian Sustainable Palm Oil (ISPO) scheme, paired with forest-use restrictions, audits, and traceability rules for the palm oil supply chain'''[12]''' (Sarmiento et al., 2024).

Measures would include improving geolocation data, integrating plantation licensing databases, strengthening MSPO 2.0 implementation, and supporting smallholders in meeting certification requirements'''[13]''' (ISIS Malaysia & UPM, 2024a, 2024b; Reuters, 2025).

Strengthening digital monitoring systems, verification mechanisms, and compliance support programmes would require public funding and institutional coordination (Forests Ordinance, 2015). Smallholders may face additional reporting burdens, while some companies may resist transparency requirements. Reforms may also remain procedural rather than substantive if underlying drivers of deforestation remain unchanged (The Borneo Project, 2024).

Enhanced traceability and compliance systems would demonstrate legality and supply-chain transparency to EU regulators and international buyers with export-oriented producers gaining more secure access to European markets, while improved governance systems could increase investor confidence, reducing trade disruptions (Ross, 2026).

Exercising of direct control over monitoring systems, enforcement transparency, and state-level compliance infrastructure would be facilitated but would require coordination with federal agencies responsible for certification and export promotion as well as cabinet support for budget allocations and inter-agency mandates (Forests Ordinance, 2015). This would appeal to export-oriented firms and federal trade authorities while avoiding major restrictions on plantation expansion. Winners would include compliant exporters and supported smallholders, while non-compliant operators would face greater scrutiny (Human Rights Watch, 2024).

=== '''Option 3: Forest Protection and Land Governance Reform''' ===
This would ensure stronger land-use regulation and governance reform. Measures will include a moratorium on new plantations in natural forests and peatlands, expansion of protected forest areas, stricter enforcement of land-conversion rules, and improved recognition of Indigenous NCR alongside Free, Prior and Informed Consent (FPIC) requirements for development projects (Human Rights Watch, 2024; The Borneo Project, 2024).

Stricter land-use controls could slow plantation expansion, potentially reducing short-term revenue from land-based development with enforcement capacity needing strengthening. Compensation or renegotiation of existing concessions would also need to be carried out to minimize legal disputes as well as boost investor confidence (Koh et al., 2023; Tan et al., 2023). Peru was able to achieve similar structural reforms by pairing land and forest formalization with clearer rules, stronger institutions, and incentives that brought informal actors into the legal system'''[14]''' (Sarmiento et al., 2024).

Stronger forest protection would result, reducing deforestation, improving biodiversity conservation, while decreasing land-rights conflicts with Indigenous communities (Sarmiento et al., 2024). Alignment with the EUDR would also strengthen Sarawak’s credibility (Tang, 2025; Reuters, 2025).

Control of enforcement priorities and administrative measures would be enabled. However, major reforms focusing on land-law amendments and protected-area designations would require approval from the State Legislative Assembly and coordination with federal authorities (Forests Ordinance, 2015). This option may face resistance from agribusiness interests but would gain support from civil society, Indigenous communities, and international partners. Winners would include forest-dependent communities, sustainable producers, and long-term exporters, while firms reliant on expansion and land-conversion revenues may incur losses (ISIS Malaysia & UPM, 2024a, 2024b; Mohammad et al., 2022).

== Recommended Policy option ==
A hybrid strategy would be the most viable approach, beginning with Option 2 and transitioning toward Option 3. Strengthening traceability, MSPO 2.0 implementation, and monitoring systems would provide immediate protection of EU market access, which is critical given Sarawak’s export dependence and exposure to EUDR requirements (Sarmiento et al., 2024; UKAS, 2025). This approach is politically feasible, avoids abrupt disruption, while building on the required administrative capacity for deeper reforms (Sarmiento et al., 2024).

However, compliance alone may not address the underlying deforestation drivers. A phased transition towards stronger land-use regulation and recognition of NCR and FPIC is necessary for long-term sustainability (Sarmiento et al., 2024; The Borneo Project, 2024). This would counter the state–corporate bias by empowering Indigenous voices via NCR/FPIC, while using traceability to appease exporters (Human Rights Watch, 2024). While Malaysia’s WTO challenge may reshape future obligations, it does not eliminate the immediate need for compliance (Brasier, 2024; Teja, 2024). This combined approach balances short-term trade imperatives with longer-term governance reform.

== Decision Timeline, Next Steps, and Key Milestones ==
The approach should be adopted by 30 March 2026 to allow sufficient lead time for implementation before the EUDR takes effect. It will apply from 30 December 2026 for large operators and traders, and from 30 June 2027 for micro- and small enterprises (European Commission, 2024). In addition, the EU’s risk benchmarking review, expected in May 2026, may shape Malaysia’s classification as high or standard risk, making early preparation paramount (Meridia, 2025).

Implementation should proceed in phases. In April 2026, an inter-agency taskforce should be convened to coordinate traceability mapping. In May 2026, Cabinet should decide on budget allocations and whether Land Code amendments will be pursued. June 2026 should mark the launch of smallholder support pilots and stakeholder forums, followed by quarterly deforestation monitoring reports. In Q2 2026, legislative reforms could be considered during the State Assembly session, while a federal MSPO audit is expected in Q3 2026. Large-firm pilots should begin in December 2026, with scale-up decisions made in late 2026 ahead of April 2027 compliance checks.

= References =
Brasier, P.-J. S. (2024, September 18). ''Heated debates about the EUDR are missing the bigger picture''. Fern. <nowiki>https://www.fern.org/pt/publications-insight/article/heated-debates-about-the-eudr-are-missing-the-bigger-picture/</nowiki>

Erickson-Davis, M. (2018, March 12). ''Sarawak makes 80% forest preservation commitment, but some have doubts''. Mongabay. <nowiki>https://news.mongabay.com/2018/03/sarawak-makes-80-forest-preservation-commitment-but-some-have-doubts/</nowiki>

European Union. (2025, September 5). ''EU and Malaysia agree to strengthen their partnership and continue their joint efforts against deforestation''. <nowiki>https://www.eeas.europa.eu/delegations/malaysia/eu-and-malaysia-agree-strengthen-their-partnership-and-continue-their-joint-efforts-against_en</nowiki>

Forest Department Sarawak. (2026, March 27). ''Forest Department Sarawak''. <nowiki>https://forestry.sarawak.gov.my/web/home/index/</nowiki>

Forests Ordinance, 2015, c. 71 (Sarawak). (2015). ''Laws of Sarawak''. <nowiki>https://lawnet.sarawak.gov.my/lawnet_file/Ordinance/ORD_Watermark.pdf</nowiki>

Funds for NGOs. (2024, October 15). ''NGOs urge EU to designate Sarawak as “high risk” for timber and palm oil''. <nowiki>https://news.fundsforngos.org/2024/10/15/ngos-urge-eu-to-designate-sarawak-as-high-risk-for-timber-and-palm-oil/</nowiki>

Global Forest Watch. (n.d.). ''Malaysia''. <nowiki>https://www.globalforestwatch.org/dashboards/country/MYS/14/</nowiki>

Human Rights Watch. (2024, September 23). ''EU: Address Indigenous rights violations in Malaysian imports: Designate Sarawak as “high risk” under new anti-deforestation law''. <nowiki>https://www.hrw.org/news/2024/09/23/eu-address-indigenous-rights-violations-malaysian-imports</nowiki>

Institute of Strategic and International Studies Malaysia (ISIS Malaysia), & Universiti Putra Malaysia (UPM). (2024a). ''Availability of EU deforestation regulation relevant information for the palm oil sector in Malaysia'' (Policy Brief No. 2). <nowiki>https://www.isis.org.my/wp-content/uploads/2024/11/Policy-brief-2-Malaysia-data-readiness-for-EUDR_layout2.pdf</nowiki>

Institute of Strategic and International Studies Malaysia (ISIS Malaysia), & Universiti Putra Malaysia (UPM). (2024b). ''Reinforcing deforestation‑free palm oil supply chains: Options for Malaysia in the context of EU and global legislation''. European Forest Institute. <nowiki>https://efi.int/sites/default/files/files/flegtredd/KAMI/Resources/Deforestation_free_supply_chains_for_palm_oil_2.pdf</nowiki>

Jong, H. N. (2023, September 1). ''Palm oil giants Indonesia, Malaysia start talks with EU over deforestation rule''. Mongabay. <nowiki>https://news.mongabay.com/2023/09/palm-oil-giants-indonesia-malaysia-start-talks-with-eu-over-deforestation-rule/</nowiki>

Keeton-Olsen, D. (2021, February 18). ''In Malaysian Borneo’s rainforests, powerful state governments set their own rules''. Mongabay. <nowiki>https://news.mongabay.com/2021/02/in-malaysian-borneos-rainforests-powerful-state-government-set-their-own-rules/</nowiki>

Keeton-Olsen, D. (2024, October 9). ''NGOs push EU to label Sarawak as “high risk” source of timber, palm oil''. Mongabay. <nowiki>https://news.mongabay.com/2024/10/ngos-push-eu-to-label-sarawak-as-high-risk-source-of-timber-palm-oil/</nowiki>

Keeton-Olsen, D. (2025, November 11). ''Cautious win for Indigenous groups in Malaysia as palm oil firm pauses forest clearing''. Mongabay. <nowiki>https://news.mongabay.com/2025/11/cautious-win-for-indigenous-groups-in-malaysia-as-palm-oil-firm-pauses-forest-clearing/</nowiki>

Koh, J., Johari, S., Shuib, A., Siow, M. L., & Matthew, N. K. (2023). Malaysia’s forest pledges and the Bornean state of Sarawak: A policy perspective. ''Sustainability, 15''(2), 1385. <nowiki>https://doi.org/10.3390/su15021385</nowiki>

Kumaran, S., Chew, J. S., & Nambiappan, B. (2021). ''Moving forward with mandatory MSPO certification standards''. ''Oil Palm Industry Economic Journal, 21''(1), 1–12. <nowiki>https://doi.org/10.21894/opiej.2021.01</nowiki>

Land and Survey Department Sarawak. (2026, March 27). ''Land and Survey Department Sarawak''. <nowiki>https://landsurvey.sarawak.gov.my/web/home/index/</nowiki>

Low, C. C. (2024, July 4). ''Timber grab: The truth behind Pahang oil palm plantations in Malaysia''. Asian Dispatch. <nowiki>https://www.asiandispatch.net/timber-grab-the-truth-behind-pahang-oil-palm-plantations-in-malaysia</nowiki>

Meridia. (2025, May 28). ''EUDR benchmarking and risk categories explained: A simple guide''. <nowiki>https://www.meridia.land/blog/eudr-benchmarking-and-risk-categories-explained-a-simple-guide</nowiki>

Ministry of Urban Development and Natural Resources. (2026, March 20). ''MUDeNR – Sarawak''. <nowiki>https://mudenr.sarawak.gov.my/web/home/index/</nowiki>

Mohammad, H. H., Ripot, S., Alek, R. J., Cluny, W., & Kader, W. A. (2022). ''Sustainable forest management: Sarawak’s perspective''. Forest Department Sarawak. <nowiki>https://www.forestry.gov.my/images/pengumuman/2022/MFC/MFC2024/paperwork/Paper_2_Sustainable_Forest_Management_Sarawaks_Perspective.pdf</nowiki>

Proforest. (2025). ''Options to broaden smallholder inclusivity in legal and deforestation-free palm oil supply chains in Malaysia''. European Forest Institute. <nowiki>https://efi.int/sites/default/files/files/flegtredd/KAMI/Resources/smallholder_inclusivity_report.pdf</nowiki>

Reuters. (2025, September 10). ''EU clears Malaysia's palm oil certification for new deforestation rule''. <nowiki>https://www.reuters.com/markets/commodities/eu-clears-malaysias-palm-oil-certification-new-deforestation-rule-2025-09-10/</nowiki>

Ross, J. (2026, March 3). Malaysia warns CITES push on tropical timber is self‑interest, not science. Wood Central. <nowiki>https://woodcentral.com.au/malaysia-warns-cites-push-on-tropical-timber-is-self-interest-not-science/</nowiki>

Sarawak Forestry Corporation. (2026, March 20). ''Sarawak Forestry Corporation''. <nowiki>https://sfc.sarawak.gov.my/web/home/index/</nowiki>

Sarawak Report. (2024, June 2). ''Malaysia’s rainforest threat is focused on Sarawak''. <nowiki>https://www.sarawakreport.org/2024/06/malaysias-rainforest-threat-is-focused-on-sarawak/</nowiki>

Sarmiento, F., Larrea, C., Oeschger, A., & Jose, R. (2024, February 21). ''Measures to enhance forest conservation and reduce deforestation: Viewpoints and lessons from producing countries''. International Institute for Sustainable Development. <nowiki>https://www.iisd.org/ssi/publications/measures-enhance-forest-conservation-reduce-deforestation/</nowiki>

Tan, L. C., Toh, M. L., Looi, K. S., Tan, W. V., Ujang, M. U., Thoo, A. C., Azri, N. S. b., & Kathitasapathy, S. A. L. (2023). Towards “good” Native land governance: An evaluation in Sarawak, Malaysia. ''The International Indigenous Policy Journal, 14''(1). <nowiki>https://doi.org/10.18584/iipj.2023.14.1.13873</nowiki>

Tang, A. (2025, October 8). ''EU delays deforestation rule to Dec 2026''. ''Sarawak Tribune''. <nowiki>https://www.sarawaktribune.com/eu-delays-deforestation-rule-to-december-2026/</nowiki>

Teja, N. (2024, February 8). ''EU deforestation regulation dubbed a ‘double-edged sword’ for global palm oil markets''. Sustainable Views. <nowiki>https://www.sustainableviews.com/eu-deforestation-regulation-dubbed-a-double-edged-sword-for-global-palm-oil-markets/</nowiki>

The Borneo Project. (2024, September 26). ''Why Sarawak should be high risk under the new EU deforestation rules''. <nowiki>https://borneoproject.org/why-sarawak-should-be-high-risk-under-the-new-eu-deforestation-rules/</nowiki>

The Borneo Project. (2025a, January 10). ''Deforestation alert: Ulu Belaga''. <nowiki>https://borneoproject.org/deforestation-alert-ulu-belaga/</nowiki>

The Borneo Project. (2025b, October 30). ''Victory for Indigenous communities in Sarawak as Urun Plantations halts forest clearing''. <nowiki>https://borneoproject.org/victory-for-indigenous-communities-in-sarawak-as-urun-plantations-halts-forest-clearing/</nowiki>

UKAS. (2025a, September 19). ''Palm oil overtakes crude petroleum as Sarawak’s leading export''. Premier of Sarawak Department. <nowiki>https://premierdept.sarawak.gov.my/web/subpage/news_view/25115/UKAS</nowiki>

UKAS. (2025b, January 17). ''Sarawak Cabinet works collectively for the well-being of the people''. Government of Sarawak. <nowiki>https://premierdept.sarawak.gov.my/web/subpage/news_view/11717/UKAS#:~:text=%E2%80%9COur%20cabinet%20operates%20on%20a%20collective%20system,economy%2C%20and%20that%20is%20the%20result%20of</nowiki>

----[1] By 2024, Sarawak had lost 1.7 million hectares of humid primary forest, a 23% decline in its overall primary forest area (Global Forest Watch, n.d.).

[2] Continued forest loss and land-rights disputes risk “high-risk” classification, which could threaten Sarawak’s EU market access (Funds for NGOs, 2024).

[3] This has contributed to a cumulative decline of about 1.04 million acres between 2019 and 2023. Furthermore, associated analysis suggests that logging and oil palm expansion continue to threaten extensive areas of naturally regenerating forest (Keeton-Olsen, 2024).

[4] Additionally, although the legal framework requires the voluntary surrender or termination of customary land and compensation prior to commercial allocation, implementation has been noted to be inconsistent in practice (Human Rights Watch, 2024).

[5] The EU represents a key destination for Malaysian palm oil, ranking as the third-largest market after India and China. In 2023, palm oil exports from Malaysia to the EU totaled 1.07 million tonnes, accounting for 7.1% of the country’s overall palm oil exports (Proforest, 2025).

[6] EU countries are significant importers of Malaysian forestry goods, with the Netherlands and Germany ranking as the second- and third-largest purchasers of nationally certified timber from Malaysia in 2022(Keeton-Olsen, 2024).

[7] Operational authority is implemented through several key agencies. The Sarawak Forest Department oversees forest classification, management, and the issuance of timber licences, while the Sarawak Land and Survey Department is responsible for land allocation, land registration, and matters related to NCR land. In parallel, the Sarawak Forestry Corporation is mandated to manage conservation efforts, including protected areas and biodiversity (Forest Department Sarawak, 2026; Land and Survey Department Sarawak, 2026; Sarawak Forestry Corporation, 2026).

[8] Power at this level remains closely aligned with major corporations, whose political and economic influence continue to shape development priorities and regulatory enforcement (Tan et al., 2023; Koh et al., 2023).

[9] It has been observed that smallholder farmers are more unlikely to satisfy the legality and sustainability requirements stipulated by the EUDR, as financial and structural constraints could limit their capacity to comply, thereby risking their exclusion from this vital global supply chain (Jong, 2023).

[10] Compliance with the EUDR will therefore require significant financial, technical, and institutional support from government and industry stakeholders (Proforest, 2025).

[11] This option largely reflects existing approaches, which have not fully curbed deforestation or addressed persistent traceability and enforcement gaps (The Borneo Project, 2024).

[12] ISPO made compliance a legal requirement rather than a purely voluntary market choice with traceability being strengthened by requiring certified operators to identify the source of fresh fruit bunches and disclosure of supplier and buyer relationships within the value chain (Sarmiento et al., 2024).

[13] This will be critical given the EUDR’s post-2020 cutoff, as traceability systems must be capable of distinguishing between compliant and non-compliant production areas. This could reduce the feasibility of simply redirecting exports to alternative markets, reinforcing the need for system-wide transparency (The Borneo Project, 2024).

[14] This involved moving from informal, insecure land use to formal, contract-based forest access through the creation of Agroforestry Concessions and reorganization of land into forest-use zones. The reform worked by giving smallholders a legal path into the system instead of leaving them invisible to the state (Sarmiento et al., 2024).

[[Category:Forestry]]

Documentation:Sarawak’s Forest Governance under the European Union Deforestation Regulation: Policy Options for the Premier of the State of Sarawak, Malaysia

2026-05-15T20:18:34Z

WillEngle:

Oil palm and timber plantations expansion have been noted as the primary drivers of deforestation in Sarawak'''[1]''' (Sarawak Report, 2024). This has created a significant governance challenge under the European Union Deforestation Regulation (EUDR) which came into force on 29<sup>th</sup> June 2023 requiring commodities entering the EU market to be deforestation-free and legally produced with a post-2020 deforestation cutoff'''[2]''' (The Borneo Project, 2024).

= List of Abbreviations =

'''EUDR - European Union Deforestation Regulation'''

'''FPIC - Free, Prior and Informed Consent'''

'''ISIS - Institute of Strategic and International Studies'''

'''ISPO - Indonesian Sustainable Palm Oil'''

'''MSPO - Malaysian Sustainable Palm Oil'''

'''NCR - Native Customary Rights'''

'''UPM - Universiti Putra Malaysia'''

'''WTO - World Trade Organisation'''

== Background ==
The EUDR has increased pressure on producers with compliance depending on strict plot-level geolocation and supply-chain traceability requirements, limiting the scope for diverting commodities to alternative markets (Human Rights Watch, 2024).

Malaysia has challenged the EUDR, framing it as a form of disguised protectionism and a trade barrier that places disproportionate burdens on smallholders in its formal complaint to the WTO, this has introduced further uncertainty (Brasier, 2024; Teja, 2024).

Malaysia has relied on the Malaysian Sustainable Palm Oil (MSPO) certification scheme, alongside existing legal frameworks under the Land Code and Forest Ordinance, to address raised sustainability concerns (ISIS Malaysia & UPM, 2024a, 2024b). The EU has recognised the scheme as a credible certification framework that could support compliance with the EUDR, due to the incorporation of digital traceability tools that strengthen supply-chain transparency (Reuters, 2025).

However, despite these policy advancements, forest loss remains significant, with approximately 85,100 hectares cleared in 2023'''[3]''' (Funds for NGOs, 2024) See figure 1 below for extent of plantation expansion. This has been intensified by the state’s target of one million hectares of timber plantations, requiring the clearance of over 400,000 hectares of natural forest (The Borneo Project, 2024).

'''Figure 1: Extent of Plantation Concessions in Sarawak'''

Source: Erickson-Davis (2018)

Local tensions too, have escalated with Long Urun recording over 40,000 satellite‑detected deforestation alerts, with nearly 500 hectares of forest lost. This triggered petitions and blockades after official avenues failed. International pressure later prompted a temporary moratorium (Keeton‑Olsen, 2025; The Borneo Project, 2025a, 2025b). (See figure 2 below, for extent).

'''Figure 2: Land Clearing Captured in Long Urun on September 24, 2025'''

Source: Keeton-Olsen (2025)

Furthermore, Sarawak’s Land Code has been criticized for limiting the legal recognition of Indigenous Native Customary Rights (NCR) lands while enabling commercial access to forested areas through state-issued leases'''[4]''' (The Borneo Project, 2025a, 2025b).

These governance challenges have strengthened calls by civil society organisations urging the EU to classify Sarawak as a high-risk jurisdiction which would increase regulatory scrutiny of exports to EU markets (Keeton-Olsen, 2024). Given the importance of European markets for Malaysia’s palm oil'''[5]''' and timber sectors'''[6]''', strengthening forest governance and ensuring compliance are paramount (Human Rights Watch, 2024).

== Key Actors ==
At the international level, EU institutions act as external regulators through EUDR requirements, shaping market access and compliance expectations. International NGOs and consumer brands exert influence through supply chain pressure, exemplified by the sourcing suspensions linked to plantation expansion in Long Urun (The Borneo Project, 2025a, 2025b).

At the national level, federal institutions such as the Malaysian Palm Oil Council, Ministry of Investment, Trade and Industry, Ministry of Plantation and Commodities, Malaysian Timber Industry Board, influence the broader economic and regulatory environment through export policy, trade negotiations, and sustainability certification systems, while engaging directly with the EU on EUDR compliance (ISIS Malaysia & UPM, 2024a, 2024b; Kumaran et al., 2021; Reuters, 2025). They continue to lead Malaysia’s challenge to the EUDR at the WTO (Brasier, 2024; Teja, 2024).

At the sub-national level, the Sarawak state government holds primary authority over land allocation, forest classification, and plantation licensing through the Sarawak Ministry of Natural Resources and Urban Development'''[7]''' (Ministry of Urban Development and Natural Resources, 2026). This enables it to approve timber concessions and oil palm expansion'''[8]''' (Keeton-Olsen, 2021; Mohammad et al., 2022).

At the local level, Indigenous communities alongside forest-dependent households, smallholders, and plantation workers, are most directly affected by these governance dynamics'''[9]'''. They rely on NCR lands for livelihoods and cultural continuity but face persistent barriers to formal recognition under Sarawak’s Land Code (Human Rights Watch, 2024). Forest conversion threatens their subsistence resources, fuels local conflicts, exposing smallholders and labourers to economic risks '''[10]''' (Funds for NGOs, 2024).

== Policy options ==

=== '''Option 1: Status Quo''' ===
Herein, enforcement would continue through current state mechanisms under the Land Code and Forest Ordinance alongside the MSPO certification framework. This approach preserves current development trajectories centred on oil palm and timber expansion'''[11]''' (Human Rights Watch, 2024; UKAS, 2025a).

Continued forest loss would likely persist, reinforcing international scrutiny from regulators, civil society organisations, and consumer brands concerned (Funds for NGOs, 2024; The Borneo Project, 2024). Sarawak could face heightened due-diligence requirements or potential classification as a “high-risk” jurisdiction, increasing transaction costs (ISIS Malaysia & UPM, 2024a, 2024b). See figure 3 below for due-diligence requirements.

Figure 3: Due Diligence Requirements Under Articles 9, 10 and 11 of the EUDR

Source: ISIS Malaysia, & UPM, 2024b

The main benefit of this would be that plantation expansion proceeds without disruption, industry actors avoid new compliance costs, while state revenues linked to land-based development would remain stable in the near term (Koh et al., 2023; Tan et al., 2023).

Authority over routine enforcement priorities, administrative coordination, and public communication would be retained while avoiding initiating legislative or regulatory reforms (Forests Ordinance, 2015). This would favour plantation and timber interests while minimising confrontation with powerful industry actors. Winners would include large agribusiness firms and political actors aligned with expansion, while losers would include forest-dependent communities, environmentally oriented exporters, and stakeholders seeking stronger sustainability compliance (Human Rights Watch, 2024; The Borneo Project, 2024).

=== '''Option 2: Compliance and Traceability Strategy''' ===
This would strengthen supply-chain transparency and traceability systems while allowing continued land conversion within existing regulatory limits as seen in Indonesia which was able to achieve compliance and traceability through its mandatory national certification system, the Indonesian Sustainable Palm Oil (ISPO) scheme, paired with forest-use restrictions, audits, and traceability rules for the palm oil supply chain'''[12]''' (Sarmiento et al., 2024).

Measures would include improving geolocation data, integrating plantation licensing databases, strengthening MSPO 2.0 implementation, and supporting smallholders in meeting certification requirements'''[13]''' (ISIS Malaysia & UPM, 2024a, 2024b; Reuters, 2025).

Strengthening digital monitoring systems, verification mechanisms, and compliance support programmes would require public funding and institutional coordination (Forests Ordinance, 2015). Smallholders may face additional reporting burdens, while some companies may resist transparency requirements. Reforms may also remain procedural rather than substantive if underlying drivers of deforestation remain unchanged (The Borneo Project, 2024).

Enhanced traceability and compliance systems would demonstrate legality and supply-chain transparency to EU regulators and international buyers with export-oriented producers gaining more secure access to European markets, while improved governance systems could increase investor confidence, reducing trade disruptions (Ross, 2026).

Exercising of direct control over monitoring systems, enforcement transparency, and state-level compliance infrastructure would be facilitated but would require coordination with federal agencies responsible for certification and export promotion as well as cabinet support for budget allocations and inter-agency mandates (Forests Ordinance, 2015). This would appeal to export-oriented firms and federal trade authorities while avoiding major restrictions on plantation expansion. Winners would include compliant exporters and supported smallholders, while non-compliant operators would face greater scrutiny (Human Rights Watch, 2024).

=== '''Option 3: Forest Protection and Land Governance Reform''' ===
This would ensure stronger land-use regulation and governance reform. Measures will include a moratorium on new plantations in natural forests and peatlands, expansion of protected forest areas, stricter enforcement of land-conversion rules, and improved recognition of Indigenous NCR alongside Free, Prior and Informed Consent (FPIC) requirements for development projects (Human Rights Watch, 2024; The Borneo Project, 2024).

Stricter land-use controls could slow plantation expansion, potentially reducing short-term revenue from land-based development with enforcement capacity needing strengthening. Compensation or renegotiation of existing concessions would also need to be carried out to minimize legal disputes as well as boost investor confidence (Koh et al., 2023; Tan et al., 2023). Peru was able to achieve similar structural reforms by pairing land and forest formalization with clearer rules, stronger institutions, and incentives that brought informal actors into the legal system'''[14]''' (Sarmiento et al., 2024).

Stronger forest protection would result, reducing deforestation, improving biodiversity conservation, while decreasing land-rights conflicts with Indigenous communities (Sarmiento et al., 2024). Alignment with the EUDR would also strengthen Sarawak’s credibility (Tang, 2025; Reuters, 2025).

Control of enforcement priorities and administrative measures would be enabled. However, major reforms focusing on land-law amendments and protected-area designations would require approval from the State Legislative Assembly and coordination with federal authorities (Forests Ordinance, 2015). This option may face resistance from agribusiness interests but would gain support from civil society, Indigenous communities, and international partners. Winners would include forest-dependent communities, sustainable producers, and long-term exporters, while firms reliant on expansion and land-conversion revenues may incur losses (ISIS Malaysia & UPM, 2024a, 2024b; Mohammad et al., 2022).

== Recommended Policy option ==
A hybrid strategy would be the most viable approach, beginning with Option 2 and transitioning toward Option 3. Strengthening traceability, MSPO 2.0 implementation, and monitoring systems would provide immediate protection of EU market access, which is critical given Sarawak’s export dependence and exposure to EUDR requirements (Sarmiento et al., 2024; UKAS, 2025). This approach is politically feasible, avoids abrupt disruption, while building on the required administrative capacity for deeper reforms (Sarmiento et al., 2024).

However, compliance alone may not address the underlying deforestation drivers. A phased transition towards stronger land-use regulation and recognition of NCR and FPIC is necessary for long-term sustainability (Sarmiento et al., 2024; The Borneo Project, 2024). This would counter the state–corporate bias by empowering Indigenous voices via NCR/FPIC, while using traceability to appease exporters (Human Rights Watch, 2024). While Malaysia’s WTO challenge may reshape future obligations, it does not eliminate the immediate need for compliance (Brasier, 2024; Teja, 2024). This combined approach balances short-term trade imperatives with longer-term governance reform.

== Decision Timeline, Next Steps, and Key Milestones ==
The approach should be adopted by 30 March 2026 to allow sufficient lead time for implementation before the EUDR takes effect. It will apply from 30 December 2026 for large operators and traders, and from 30 June 2027 for micro- and small enterprises (European Commission, 2024). In addition, the EU’s risk benchmarking review, expected in May 2026, may shape Malaysia’s classification as high or standard risk, making early preparation paramount (Meridia, 2025).

Implementation should proceed in phases. In April 2026, an inter-agency taskforce should be convened to coordinate traceability mapping. In May 2026, Cabinet should decide on budget allocations and whether Land Code amendments will be pursued. June 2026 should mark the launch of smallholder support pilots and stakeholder forums, followed by quarterly deforestation monitoring reports. In Q2 2026, legislative reforms could be considered during the State Assembly session, while a federal MSPO audit is expected in Q3 2026. Large-firm pilots should begin in December 2026, with scale-up decisions made in late 2026 ahead of April 2027 compliance checks.

= References =
Brasier, P.-J. S. (2024, September 18). ''Heated debates about the EUDR are missing the bigger picture''. Fern. <nowiki>https://www.fern.org/pt/publications-insight/article/heated-debates-about-the-eudr-are-missing-the-bigger-picture/</nowiki>

Erickson-Davis, M. (2018, March 12). ''Sarawak makes 80% forest preservation commitment, but some have doubts''. Mongabay. <nowiki>https://news.mongabay.com/2018/03/sarawak-makes-80-forest-preservation-commitment-but-some-have-doubts/</nowiki>

European Union. (2025, September 5). ''EU and Malaysia agree to strengthen their partnership and continue their joint efforts against deforestation''. <nowiki>https://www.eeas.europa.eu/delegations/malaysia/eu-and-malaysia-agree-strengthen-their-partnership-and-continue-their-joint-efforts-against_en</nowiki>

Forest Department Sarawak. (2026, March 27). ''Forest Department Sarawak''. <nowiki>https://forestry.sarawak.gov.my/web/home/index/</nowiki>

Forests Ordinance, 2015, c. 71 (Sarawak). (2015). ''Laws of Sarawak''. <nowiki>https://lawnet.sarawak.gov.my/lawnet_file/Ordinance/ORD_Watermark.pdf</nowiki>

Funds for NGOs. (2024, October 15). ''NGOs urge EU to designate Sarawak as “high risk” for timber and palm oil''. <nowiki>https://news.fundsforngos.org/2024/10/15/ngos-urge-eu-to-designate-sarawak-as-high-risk-for-timber-and-palm-oil/</nowiki>

Global Forest Watch. (n.d.). ''Malaysia''. <nowiki>https://www.globalforestwatch.org/dashboards/country/MYS/14/</nowiki>

Human Rights Watch. (2024, September 23). ''EU: Address Indigenous rights violations in Malaysian imports: Designate Sarawak as “high risk” under new anti-deforestation law''. <nowiki>https://www.hrw.org/news/2024/09/23/eu-address-indigenous-rights-violations-malaysian-imports</nowiki>

Institute of Strategic and International Studies Malaysia (ISIS Malaysia), & Universiti Putra Malaysia (UPM). (2024a). ''Availability of EU deforestation regulation relevant information for the palm oil sector in Malaysia'' (Policy Brief No. 2). <nowiki>https://www.isis.org.my/wp-content/uploads/2024/11/Policy-brief-2-Malaysia-data-readiness-for-EUDR_layout2.pdf</nowiki>

Institute of Strategic and International Studies Malaysia (ISIS Malaysia), & Universiti Putra Malaysia (UPM). (2024b). ''Reinforcing deforestation‑free palm oil supply chains: Options for Malaysia in the context of EU and global legislation''. European Forest Institute. <nowiki>https://efi.int/sites/default/files/files/flegtredd/KAMI/Resources/Deforestation_free_supply_chains_for_palm_oil_2.pdf</nowiki>

Jong, H. N. (2023, September 1). ''Palm oil giants Indonesia, Malaysia start talks with EU over deforestation rule''. Mongabay. <nowiki>https://news.mongabay.com/2023/09/palm-oil-giants-indonesia-malaysia-start-talks-with-eu-over-deforestation-rule/</nowiki>

Keeton-Olsen, D. (2021, February 18). ''In Malaysian Borneo’s rainforests, powerful state governments set their own rules''. Mongabay. <nowiki>https://news.mongabay.com/2021/02/in-malaysian-borneos-rainforests-powerful-state-government-set-their-own-rules/</nowiki>

Keeton-Olsen, D. (2024, October 9). ''NGOs push EU to label Sarawak as “high risk” source of timber, palm oil''. Mongabay. <nowiki>https://news.mongabay.com/2024/10/ngos-push-eu-to-label-sarawak-as-high-risk-source-of-timber-palm-oil/</nowiki>

Keeton-Olsen, D. (2025, November 11). ''Cautious win for Indigenous groups in Malaysia as palm oil firm pauses forest clearing''. Mongabay. <nowiki>https://news.mongabay.com/2025/11/cautious-win-for-indigenous-groups-in-malaysia-as-palm-oil-firm-pauses-forest-clearing/</nowiki>

Koh, J., Johari, S., Shuib, A., Siow, M. L., & Matthew, N. K. (2023). Malaysia’s forest pledges and the Bornean state of Sarawak: A policy perspective. ''Sustainability, 15''(2), 1385. <nowiki>https://doi.org/10.3390/su15021385</nowiki>

Kumaran, S., Chew, J. S., & Nambiappan, B. (2021). ''Moving forward with mandatory MSPO certification standards''. ''Oil Palm Industry Economic Journal, 21''(1), 1–12. <nowiki>https://doi.org/10.21894/opiej.2021.01</nowiki>

Land and Survey Department Sarawak. (2026, March 27). ''Land and Survey Department Sarawak''. <nowiki>https://landsurvey.sarawak.gov.my/web/home/index/</nowiki>

Low, C. C. (2024, July 4). ''Timber grab: The truth behind Pahang oil palm plantations in Malaysia''. Asian Dispatch. <nowiki>https://www.asiandispatch.net/timber-grab-the-truth-behind-pahang-oil-palm-plantations-in-malaysia</nowiki>

Meridia. (2025, May 28). ''EUDR benchmarking and risk categories explained: A simple guide''. <nowiki>https://www.meridia.land/blog/eudr-benchmarking-and-risk-categories-explained-a-simple-guide</nowiki>

Ministry of Urban Development and Natural Resources. (2026, March 20). ''MUDeNR – Sarawak''. <nowiki>https://mudenr.sarawak.gov.my/web/home/index/</nowiki>

Mohammad, H. H., Ripot, S., Alek, R. J., Cluny, W., & Kader, W. A. (2022). ''Sustainable forest management: Sarawak’s perspective''. Forest Department Sarawak. <nowiki>https://www.forestry.gov.my/images/pengumuman/2022/MFC/MFC2024/paperwork/Paper_2_Sustainable_Forest_Management_Sarawaks_Perspective.pdf</nowiki>

Proforest. (2025). ''Options to broaden smallholder inclusivity in legal and deforestation-free palm oil supply chains in Malaysia''. European Forest Institute. <nowiki>https://efi.int/sites/default/files/files/flegtredd/KAMI/Resources/smallholder_inclusivity_report.pdf</nowiki>

Reuters. (2025, September 10). ''EU clears Malaysia's palm oil certification for new deforestation rule''. <nowiki>https://www.reuters.com/markets/commodities/eu-clears-malaysias-palm-oil-certification-new-deforestation-rule-2025-09-10/</nowiki>

Ross, J. (2026, March 3). Malaysia warns CITES push on tropical timber is self‑interest, not science. Wood Central. <nowiki>https://woodcentral.com.au/malaysia-warns-cites-push-on-tropical-timber-is-self-interest-not-science/</nowiki>

Sarawak Forestry Corporation. (2026, March 20). ''Sarawak Forestry Corporation''. <nowiki>https://sfc.sarawak.gov.my/web/home/index/</nowiki>

Sarawak Report. (2024, June 2). ''Malaysia’s rainforest threat is focused on Sarawak''. <nowiki>https://www.sarawakreport.org/2024/06/malaysias-rainforest-threat-is-focused-on-sarawak/</nowiki>

Sarmiento, F., Larrea, C., Oeschger, A., & Jose, R. (2024, February 21). ''Measures to enhance forest conservation and reduce deforestation: Viewpoints and lessons from producing countries''. International Institute for Sustainable Development. <nowiki>https://www.iisd.org/ssi/publications/measures-enhance-forest-conservation-reduce-deforestation/</nowiki>

Tan, L. C., Toh, M. L., Looi, K. S., Tan, W. V., Ujang, M. U., Thoo, A. C., Azri, N. S. b., & Kathitasapathy, S. A. L. (2023). Towards “good” Native land governance: An evaluation in Sarawak, Malaysia. ''The International Indigenous Policy Journal, 14''(1). <nowiki>https://doi.org/10.18584/iipj.2023.14.1.13873</nowiki>

Tang, A. (2025, October 8). ''EU delays deforestation rule to Dec 2026''. ''Sarawak Tribune''. <nowiki>https://www.sarawaktribune.com/eu-delays-deforestation-rule-to-december-2026/</nowiki>

Teja, N. (2024, February 8). ''EU deforestation regulation dubbed a ‘double-edged sword’ for global palm oil markets''. Sustainable Views. <nowiki>https://www.sustainableviews.com/eu-deforestation-regulation-dubbed-a-double-edged-sword-for-global-palm-oil-markets/</nowiki>

The Borneo Project. (2024, September 26). ''Why Sarawak should be high risk under the new EU deforestation rules''. <nowiki>https://borneoproject.org/why-sarawak-should-be-high-risk-under-the-new-eu-deforestation-rules/</nowiki>

The Borneo Project. (2025a, January 10). ''Deforestation alert: Ulu Belaga''. <nowiki>https://borneoproject.org/deforestation-alert-ulu-belaga/</nowiki>

The Borneo Project. (2025b, October 30). ''Victory for Indigenous communities in Sarawak as Urun Plantations halts forest clearing''. <nowiki>https://borneoproject.org/victory-for-indigenous-communities-in-sarawak-as-urun-plantations-halts-forest-clearing/</nowiki>

UKAS. (2025a, September 19). ''Palm oil overtakes crude petroleum as Sarawak’s leading export''. Premier of Sarawak Department. <nowiki>https://premierdept.sarawak.gov.my/web/subpage/news_view/25115/UKAS</nowiki>

UKAS. (2025b, January 17). ''Sarawak Cabinet works collectively for the well-being of the people''. Government of Sarawak. <nowiki>https://premierdept.sarawak.gov.my/web/subpage/news_view/11717/UKAS#:~:text=%E2%80%9COur%20cabinet%20operates%20on%20a%20collective%20system,economy%2C%20and%20that%20is%20the%20result%20of</nowiki>

----[1] By 2024, Sarawak had lost 1.7 million hectares of humid primary forest, a 23% decline in its overall primary forest area (Global Forest Watch, n.d.).

[2] Continued forest loss and land-rights disputes risk “high-risk” classification, which could threaten Sarawak’s EU market access (Funds for NGOs, 2024).

[3] This has contributed to a cumulative decline of about 1.04 million acres between 2019 and 2023. Furthermore, associated analysis suggests that logging and oil palm expansion continue to threaten extensive areas of naturally regenerating forest (Keeton-Olsen, 2024).

[4] Additionally, although the legal framework requires the voluntary surrender or termination of customary land and compensation prior to commercial allocation, implementation has been noted to be inconsistent in practice (Human Rights Watch, 2024).

[5] The EU represents a key destination for Malaysian palm oil, ranking as the third-largest market after India and China. In 2023, palm oil exports from Malaysia to the EU totaled 1.07 million tonnes, accounting for 7.1% of the country’s overall palm oil exports (Proforest, 2025).

[6] EU countries are significant importers of Malaysian forestry goods, with the Netherlands and Germany ranking as the second- and third-largest purchasers of nationally certified timber from Malaysia in 2022(Keeton-Olsen, 2024).

[7] Operational authority is implemented through several key agencies. The Sarawak Forest Department oversees forest classification, management, and the issuance of timber licences, while the Sarawak Land and Survey Department is responsible for land allocation, land registration, and matters related to NCR land. In parallel, the Sarawak Forestry Corporation is mandated to manage conservation efforts, including protected areas and biodiversity (Forest Department Sarawak, 2026; Land and Survey Department Sarawak, 2026; Sarawak Forestry Corporation, 2026).

[8] Power at this level remains closely aligned with major corporations, whose political and economic influence continue to shape development priorities and regulatory enforcement (Tan et al., 2023; Koh et al., 2023).

[9] It has been observed that smallholder farmers are more unlikely to satisfy the legality and sustainability requirements stipulated by the EUDR, as financial and structural constraints could limit their capacity to comply, thereby risking their exclusion from this vital global supply chain (Jong, 2023).

[10] Compliance with the EUDR will therefore require significant financial, technical, and institutional support from government and industry stakeholders (Proforest, 2025).

[11] This option largely reflects existing approaches, which have not fully curbed deforestation or addressed persistent traceability and enforcement gaps (The Borneo Project, 2024).

[12] ISPO made compliance a legal requirement rather than a purely voluntary market choice with traceability being strengthened by requiring certified operators to identify the source of fresh fruit bunches and disclosure of supplier and buyer relationships within the value chain (Sarmiento et al., 2024).

[13] This will be critical given the EUDR’s post-2020 cutoff, as traceability systems must be capable of distinguishing between compliant and non-compliant production areas. This could reduce the feasibility of simply redirecting exports to alternative markets, reinforcing the need for system-wide transparency (The Borneo Project, 2024).

[14] This involved moving from informal, insecure land use to formal, contract-based forest access through the creation of Agroforestry Concessions and reorganization of land into forest-use zones. The reform worked by giving smallholders a legal path into the system instead of leaving them invisible to the state (Sarmiento et al., 2024).

[[Category:Forestry]]

Documentation:Sarawak’s Forest Governance under the European Union Deforestation Regulation: Policy Options for the Premier of the State of Sarawak, Malaysia

2026-05-15T20:16:46Z

WillEngle:

Oil palm and timber plantations expansion have been noted as the primary drivers of deforestation in Sarawak'''[1]''' (Sarawak Report, 2024). This has created a significant governance challenge under the European Union Deforestation Regulation (EUDR) which came into force on 29<sup>th</sup> June 2023 requiring commodities entering the EU market to be deforestation-free and legally produced with a post-2020 deforestation cutoff'''[2]''' (The Borneo Project, 2024).

= List of Abbreviations =

'''EUDR - European Union Deforestation Regulation'''

'''FPIC - Free, Prior and Informed Consent'''

'''ISIS - Institute of Strategic and International Studies'''

'''ISPO - Indonesian Sustainable Palm Oil'''

'''MSPO - Malaysian Sustainable Palm Oil'''

'''NCR - Native Customary Rights'''

'''UPM - Universiti Putra Malaysia'''

'''WTO - World Trade Organisation'''

== Background ==
The EUDR has increased pressure on producers with compliance depending on strict plot-level geolocation and supply-chain traceability requirements, limiting the scope for diverting commodities to alternative markets (Human Rights Watch, 2024).

Malaysia has challenged the EUDR, framing it as a form of disguised protectionism and a trade barrier that places disproportionate burdens on smallholders in its formal complaint to the WTO, this has introduced further uncertainty (Brasier, 2024; Teja, 2024).

Malaysia has relied on the Malaysian Sustainable Palm Oil (MSPO) certification scheme, alongside existing legal frameworks under the Land Code and Forest Ordinance, to address raised sustainability concerns (ISIS Malaysia & UPM, 2024a, 2024b). The EU has recognised the scheme as a credible certification framework that could support compliance with the EUDR, due to the incorporation of digital traceability tools that strengthen supply-chain transparency (Reuters, 2025).

However, despite these policy advancements, forest loss remains significant, with approximately 85,100 hectares cleared in 2023'''[3]''' (Funds for NGOs, 2024) See figure 1 below for extent of plantation expansion. This has been intensified by the state’s target of one million hectares of timber plantations, requiring the clearance of over 400,000 hectares of natural forest (The Borneo Project, 2024).

'''Figure 1: Extent of Plantation Concessions in Sarawak'''

Source: Erickson-Davis (2018)

Local tensions too, have escalated with Long Urun recording over 40,000 satellite‑detected deforestation alerts, with nearly 500 hectares of forest lost. This triggered petitions and blockades after official avenues failed. International pressure later prompted a temporary moratorium (Keeton‑Olsen, 2025; The Borneo Project, 2025a, 2025b). (See figure 2 below, for extent).

'''Figure 2: Land Clearing Captured in Long Urun on September 24, 2025'''

Source: Keeton-Olsen (2025)

Furthermore, Sarawak’s Land Code has been criticized for limiting the legal recognition of Indigenous Native Customary Rights (NCR) lands while enabling commercial access to forested areas through state-issued leases'''[4]''' (The Borneo Project, 2025a, 2025b).

These governance challenges have strengthened calls by civil society organisations urging the EU to classify Sarawak as a high-risk jurisdiction which would increase regulatory scrutiny of exports to EU markets (Keeton-Olsen, 2024). Given the importance of European markets for Malaysia’s palm oil'''[5]''' and timber sectors'''[6]''', strengthening forest governance and ensuring compliance are paramount (Human Rights Watch, 2024).

== Key Actors ==
At the international level, EU institutions act as external regulators through EUDR requirements, shaping market access and compliance expectations. International NGOs and consumer brands exert influence through supply chain pressure, exemplified by the sourcing suspensions linked to plantation expansion in Long Urun (The Borneo Project, 2025a, 2025b).

At the national level, federal institutions such as the Malaysian Palm Oil Council, Ministry of Investment, Trade and Industry, Ministry of Plantation and Commodities, Malaysian Timber Industry Board, influence the broader economic and regulatory environment through export policy, trade negotiations, and sustainability certification systems, while engaging directly with the EU on EUDR compliance (ISIS Malaysia & UPM, 2024a, 2024b; Kumaran et al., 2021; Reuters, 2025). They continue to lead Malaysia’s challenge to the EUDR at the WTO (Brasier, 2024; Teja, 2024).

At the sub-national level, the Sarawak state government holds primary authority over land allocation, forest classification, and plantation licensing through the Sarawak Ministry of Natural Resources and Urban Development'''[7]''' (Ministry of Urban Development and Natural Resources, 2026). This enables it to approve timber concessions and oil palm expansion'''[8]''' (Keeton-Olsen, 2021; Mohammad et al., 2022).

At the local level, Indigenous communities alongside forest-dependent households, smallholders, and plantation workers, are most directly affected by these governance dynamics'''[9]'''. They rely on NCR lands for livelihoods and cultural continuity but face persistent barriers to formal recognition under Sarawak’s Land Code (Human Rights Watch, 2024). Forest conversion threatens their subsistence resources, fuels local conflicts, exposing smallholders and labourers to economic risks '''[10]''' (Funds for NGOs, 2024).

== Policy options ==

=== '''Option 1: Status Quo''' ===
Herein, enforcement would continue through current state mechanisms under the Land Code and Forest Ordinance alongside the MSPO certification framework. This approach preserves current development trajectories centred on oil palm and timber expansion'''[11]''' (Human Rights Watch, 2024; UKAS, 2025a).

Continued forest loss would likely persist, reinforcing international scrutiny from regulators, civil society organisations, and consumer brands concerned (Funds for NGOs, 2024; The Borneo Project, 2024). Sarawak could face heightened due-diligence requirements or potential classification as a “high-risk” jurisdiction, increasing transaction costs (ISIS Malaysia & UPM, 2024a, 2024b). See figure 3 below for due-diligence requirements.

Figure 3: Due Diligence Requirements Under Articles 9, 10 and 11 of the EUDR

Source: ISIS Malaysia, & UPM, 2024b

The main benefit of this would be that plantation expansion proceeds without disruption, industry actors avoid new compliance costs, while state revenues linked to land-based development would remain stable in the near term (Koh et al., 2023; Tan et al., 2023).

Authority over routine enforcement priorities, administrative coordination, and public communication would be retained while avoiding initiating legislative or regulatory reforms (Forests Ordinance, 2015). This would favour plantation and timber interests while minimising confrontation with powerful industry actors. Winners would include large agribusiness firms and political actors aligned with expansion, while losers would include forest-dependent communities, environmentally oriented exporters, and stakeholders seeking stronger sustainability compliance (Human Rights Watch, 2024; The Borneo Project, 2024).

==== '''Option 2: Compliance and Traceability Strategy''' ====
This would strengthen supply-chain transparency and traceability systems while allowing continued land conversion within existing regulatory limits as seen in Indonesia which was able to achieve compliance and traceability through its mandatory national certification system, the Indonesian Sustainable Palm Oil (ISPO) scheme, paired with forest-use restrictions, audits, and traceability rules for the palm oil supply chain'''[12]''' (Sarmiento et al., 2024).

Measures would include improving geolocation data, integrating plantation licensing databases, strengthening MSPO 2.0 implementation, and supporting smallholders in meeting certification requirements'''[13]''' (ISIS Malaysia & UPM, 2024a, 2024b; Reuters, 2025).

Strengthening digital monitoring systems, verification mechanisms, and compliance support programmes would require public funding and institutional coordination (Forests Ordinance, 2015). Smallholders may face additional reporting burdens, while some companies may resist transparency requirements. Reforms may also remain procedural rather than substantive if underlying drivers of deforestation remain unchanged (The Borneo Project, 2024).

Enhanced traceability and compliance systems would demonstrate legality and supply-chain transparency to EU regulators and international buyers with export-oriented producers gaining more secure access to European markets, while improved governance systems could increase investor confidence, reducing trade disruptions (Ross, 2026).

Exercising of direct control over monitoring systems, enforcement transparency, and state-level compliance infrastructure would be facilitated but would require coordination with federal agencies responsible for certification and export promotion as well as cabinet support for budget allocations and inter-agency mandates (Forests Ordinance, 2015). This would appeal to export-oriented firms and federal trade authorities while avoiding major restrictions on plantation expansion. Winners would include compliant exporters and supported smallholders, while non-compliant operators would face greater scrutiny (Human Rights Watch, 2024).

=== '''Option 3: Forest Protection and Land Governance Reform''' ===
This would ensure stronger land-use regulation and governance reform. Measures will include a moratorium on new plantations in natural forests and peatlands, expansion of protected forest areas, stricter enforcement of land-conversion rules, and improved recognition of Indigenous NCR alongside Free, Prior and Informed Consent (FPIC) requirements for development projects (Human Rights Watch, 2024; The Borneo Project, 2024).

Stricter land-use controls could slow plantation expansion, potentially reducing short-term revenue from land-based development with enforcement capacity needing strengthening. Compensation or renegotiation of existing concessions would also need to be carried out to minimize legal disputes as well as boost investor confidence (Koh et al., 2023; Tan et al., 2023). Peru was able to achieve similar structural reforms by pairing land and forest formalization with clearer rules, stronger institutions, and incentives that brought informal actors into the legal system'''[14]''' (Sarmiento et al., 2024).

Stronger forest protection would result, reducing deforestation, improving biodiversity conservation, while decreasing land-rights conflicts with Indigenous communities (Sarmiento et al., 2024). Alignment with the EUDR would also strengthen Sarawak’s credibility (Tang, 2025; Reuters, 2025).

Control of enforcement priorities and administrative measures would be enabled. However, major reforms focusing on land-law amendments and protected-area designations would require approval from the State Legislative Assembly and coordination with federal authorities (Forests Ordinance, 2015). This option may face resistance from agribusiness interests but would gain support from civil society, Indigenous communities, and international partners. Winners would include forest-dependent communities, sustainable producers, and long-term exporters, while firms reliant on expansion and land-conversion revenues may incur losses (ISIS Malaysia & UPM, 2024a, 2024b; Mohammad et al., 2022).

== Recommended Policy option ==
A hybrid strategy would be the most viable approach, beginning with Option 2 and transitioning toward Option 3. Strengthening traceability, MSPO 2.0 implementation, and monitoring systems would provide immediate protection of EU market access, which is critical given Sarawak’s export dependence and exposure to EUDR requirements (Sarmiento et al., 2024; UKAS, 2025). This approach is politically feasible, avoids abrupt disruption, while building on the required administrative capacity for deeper reforms (Sarmiento et al., 2024).

However, compliance alone may not address the underlying deforestation drivers. A phased transition towards stronger land-use regulation and recognition of NCR and FPIC is necessary for long-term sustainability (Sarmiento et al., 2024; The Borneo Project, 2024). This would counter the state–corporate bias by empowering Indigenous voices via NCR/FPIC, while using traceability to appease exporters (Human Rights Watch, 2024). While Malaysia’s WTO challenge may reshape future obligations, it does not eliminate the immediate need for compliance (Brasier, 2024; Teja, 2024). This combined approach balances short-term trade imperatives with longer-term governance reform.

== Decision Timeline, Next Steps, and Key Milestones ==
The approach should be adopted by 30 March 2026 to allow sufficient lead time for implementation before the EUDR takes effect. It will apply from 30 December 2026 for large operators and traders, and from 30 June 2027 for micro- and small enterprises (European Commission, 2024). In addition, the EU’s risk benchmarking review, expected in May 2026, may shape Malaysia’s classification as high or standard risk, making early preparation paramount (Meridia, 2025).

Implementation should proceed in phases. In April 2026, an inter-agency taskforce should be convened to coordinate traceability mapping. In May 2026, Cabinet should decide on budget allocations and whether Land Code amendments will be pursued. June 2026 should mark the launch of smallholder support pilots and stakeholder forums, followed by quarterly deforestation monitoring reports. In Q2 2026, legislative reforms could be considered during the State Assembly session, while a federal MSPO audit is expected in Q3 2026. Large-firm pilots should begin in December 2026, with scale-up decisions made in late 2026 ahead of April 2027 compliance checks.

= References =
Brasier, P.-J. S. (2024, September 18). ''Heated debates about the EUDR are missing the bigger picture''. Fern. <nowiki>https://www.fern.org/pt/publications-insight/article/heated-debates-about-the-eudr-are-missing-the-bigger-picture/</nowiki>

Erickson-Davis, M. (2018, March 12). ''Sarawak makes 80% forest preservation commitment, but some have doubts''. Mongabay. <nowiki>https://news.mongabay.com/2018/03/sarawak-makes-80-forest-preservation-commitment-but-some-have-doubts/</nowiki>

European Union. (2025, September 5). ''EU and Malaysia agree to strengthen their partnership and continue their joint efforts against deforestation''. <nowiki>https://www.eeas.europa.eu/delegations/malaysia/eu-and-malaysia-agree-strengthen-their-partnership-and-continue-their-joint-efforts-against_en</nowiki>

Forest Department Sarawak. (2026, March 27). ''Forest Department Sarawak''. <nowiki>https://forestry.sarawak.gov.my/web/home/index/</nowiki>

Forests Ordinance, 2015, c. 71 (Sarawak). (2015). ''Laws of Sarawak''. <nowiki>https://lawnet.sarawak.gov.my/lawnet_file/Ordinance/ORD_Watermark.pdf</nowiki>

Funds for NGOs. (2024, October 15). ''NGOs urge EU to designate Sarawak as “high risk” for timber and palm oil''. <nowiki>https://news.fundsforngos.org/2024/10/15/ngos-urge-eu-to-designate-sarawak-as-high-risk-for-timber-and-palm-oil/</nowiki>

Global Forest Watch. (n.d.). ''Malaysia''. <nowiki>https://www.globalforestwatch.org/dashboards/country/MYS/14/</nowiki>

Human Rights Watch. (2024, September 23). ''EU: Address Indigenous rights violations in Malaysian imports: Designate Sarawak as “high risk” under new anti-deforestation law''. <nowiki>https://www.hrw.org/news/2024/09/23/eu-address-indigenous-rights-violations-malaysian-imports</nowiki>

Institute of Strategic and International Studies Malaysia (ISIS Malaysia), & Universiti Putra Malaysia (UPM). (2024a). ''Availability of EU deforestation regulation relevant information for the palm oil sector in Malaysia'' (Policy Brief No. 2). <nowiki>https://www.isis.org.my/wp-content/uploads/2024/11/Policy-brief-2-Malaysia-data-readiness-for-EUDR_layout2.pdf</nowiki>

Institute of Strategic and International Studies Malaysia (ISIS Malaysia), & Universiti Putra Malaysia (UPM). (2024b). ''Reinforcing deforestation‑free palm oil supply chains: Options for Malaysia in the context of EU and global legislation''. European Forest Institute. <nowiki>https://efi.int/sites/default/files/files/flegtredd/KAMI/Resources/Deforestation_free_supply_chains_for_palm_oil_2.pdf</nowiki>

Jong, H. N. (2023, September 1). ''Palm oil giants Indonesia, Malaysia start talks with EU over deforestation rule''. Mongabay. <nowiki>https://news.mongabay.com/2023/09/palm-oil-giants-indonesia-malaysia-start-talks-with-eu-over-deforestation-rule/</nowiki>

Keeton-Olsen, D. (2021, February 18). ''In Malaysian Borneo’s rainforests, powerful state governments set their own rules''. Mongabay. <nowiki>https://news.mongabay.com/2021/02/in-malaysian-borneos-rainforests-powerful-state-government-set-their-own-rules/</nowiki>

Keeton-Olsen, D. (2024, October 9). ''NGOs push EU to label Sarawak as “high risk” source of timber, palm oil''. Mongabay. <nowiki>https://news.mongabay.com/2024/10/ngos-push-eu-to-label-sarawak-as-high-risk-source-of-timber-palm-oil/</nowiki>

Keeton-Olsen, D. (2025, November 11). ''Cautious win for Indigenous groups in Malaysia as palm oil firm pauses forest clearing''. Mongabay. <nowiki>https://news.mongabay.com/2025/11/cautious-win-for-indigenous-groups-in-malaysia-as-palm-oil-firm-pauses-forest-clearing/</nowiki>

Koh, J., Johari, S., Shuib, A., Siow, M. L., & Matthew, N. K. (2023). Malaysia’s forest pledges and the Bornean state of Sarawak: A policy perspective. ''Sustainability, 15''(2), 1385. <nowiki>https://doi.org/10.3390/su15021385</nowiki>

Kumaran, S., Chew, J. S., & Nambiappan, B. (2021). ''Moving forward with mandatory MSPO certification standards''. ''Oil Palm Industry Economic Journal, 21''(1), 1–12. <nowiki>https://doi.org/10.21894/opiej.2021.01</nowiki>

Land and Survey Department Sarawak. (2026, March 27). ''Land and Survey Department Sarawak''. <nowiki>https://landsurvey.sarawak.gov.my/web/home/index/</nowiki>

Low, C. C. (2024, July 4). ''Timber grab: The truth behind Pahang oil palm plantations in Malaysia''. Asian Dispatch. <nowiki>https://www.asiandispatch.net/timber-grab-the-truth-behind-pahang-oil-palm-plantations-in-malaysia</nowiki>

Meridia. (2025, May 28). ''EUDR benchmarking and risk categories explained: A simple guide''. <nowiki>https://www.meridia.land/blog/eudr-benchmarking-and-risk-categories-explained-a-simple-guide</nowiki>

Ministry of Urban Development and Natural Resources. (2026, March 20). ''MUDeNR – Sarawak''. <nowiki>https://mudenr.sarawak.gov.my/web/home/index/</nowiki>

Mohammad, H. H., Ripot, S., Alek, R. J., Cluny, W., & Kader, W. A. (2022). ''Sustainable forest management: Sarawak’s perspective''. Forest Department Sarawak. <nowiki>https://www.forestry.gov.my/images/pengumuman/2022/MFC/MFC2024/paperwork/Paper_2_Sustainable_Forest_Management_Sarawaks_Perspective.pdf</nowiki>

Proforest. (2025). ''Options to broaden smallholder inclusivity in legal and deforestation-free palm oil supply chains in Malaysia''. European Forest Institute. <nowiki>https://efi.int/sites/default/files/files/flegtredd/KAMI/Resources/smallholder_inclusivity_report.pdf</nowiki>

Reuters. (2025, September 10). ''EU clears Malaysia's palm oil certification for new deforestation rule''. <nowiki>https://www.reuters.com/markets/commodities/eu-clears-malaysias-palm-oil-certification-new-deforestation-rule-2025-09-10/</nowiki>

Ross, J. (2026, March 3). Malaysia warns CITES push on tropical timber is self‑interest, not science. Wood Central. <nowiki>https://woodcentral.com.au/malaysia-warns-cites-push-on-tropical-timber-is-self-interest-not-science/</nowiki>

Sarawak Forestry Corporation. (2026, March 20). ''Sarawak Forestry Corporation''. <nowiki>https://sfc.sarawak.gov.my/web/home/index/</nowiki>

Sarawak Report. (2024, June 2). ''Malaysia’s rainforest threat is focused on Sarawak''. <nowiki>https://www.sarawakreport.org/2024/06/malaysias-rainforest-threat-is-focused-on-sarawak/</nowiki>

Sarmiento, F., Larrea, C., Oeschger, A., & Jose, R. (2024, February 21). ''Measures to enhance forest conservation and reduce deforestation: Viewpoints and lessons from producing countries''. International Institute for Sustainable Development. <nowiki>https://www.iisd.org/ssi/publications/measures-enhance-forest-conservation-reduce-deforestation/</nowiki>

Tan, L. C., Toh, M. L., Looi, K. S., Tan, W. V., Ujang, M. U., Thoo, A. C., Azri, N. S. b., & Kathitasapathy, S. A. L. (2023). Towards “good” Native land governance: An evaluation in Sarawak, Malaysia. ''The International Indigenous Policy Journal, 14''(1). <nowiki>https://doi.org/10.18584/iipj.2023.14.1.13873</nowiki>

Tang, A. (2025, October 8). ''EU delays deforestation rule to Dec 2026''. ''Sarawak Tribune''. <nowiki>https://www.sarawaktribune.com/eu-delays-deforestation-rule-to-december-2026/</nowiki>

Teja, N. (2024, February 8). ''EU deforestation regulation dubbed a ‘double-edged sword’ for global palm oil markets''. Sustainable Views. <nowiki>https://www.sustainableviews.com/eu-deforestation-regulation-dubbed-a-double-edged-sword-for-global-palm-oil-markets/</nowiki>

The Borneo Project. (2024, September 26). ''Why Sarawak should be high risk under the new EU deforestation rules''. <nowiki>https://borneoproject.org/why-sarawak-should-be-high-risk-under-the-new-eu-deforestation-rules/</nowiki>

The Borneo Project. (2025a, January 10). ''Deforestation alert: Ulu Belaga''. <nowiki>https://borneoproject.org/deforestation-alert-ulu-belaga/</nowiki>

The Borneo Project. (2025b, October 30). ''Victory for Indigenous communities in Sarawak as Urun Plantations halts forest clearing''. <nowiki>https://borneoproject.org/victory-for-indigenous-communities-in-sarawak-as-urun-plantations-halts-forest-clearing/</nowiki>

UKAS. (2025a, September 19). ''Palm oil overtakes crude petroleum as Sarawak’s leading export''. Premier of Sarawak Department. <nowiki>https://premierdept.sarawak.gov.my/web/subpage/news_view/25115/UKAS</nowiki>

UKAS. (2025b, January 17). ''Sarawak Cabinet works collectively for the well-being of the people''. Government of Sarawak. <nowiki>https://premierdept.sarawak.gov.my/web/subpage/news_view/11717/UKAS#:~:text=%E2%80%9COur%20cabinet%20operates%20on%20a%20collective%20system,economy%2C%20and%20that%20is%20the%20result%20of</nowiki>

----[1] By 2024, Sarawak had lost 1.7 million hectares of humid primary forest, a 23% decline in its overall primary forest area (Global Forest Watch, n.d.).

[2] Continued forest loss and land-rights disputes risk “high-risk” classification, which could threaten Sarawak’s EU market access (Funds for NGOs, 2024).

[3] This has contributed to a cumulative decline of about 1.04 million acres between 2019 and 2023. Furthermore, associated analysis suggests that logging and oil palm expansion continue to threaten extensive areas of naturally regenerating forest (Keeton-Olsen, 2024).

[4] Additionally, although the legal framework requires the voluntary surrender or termination of customary land and compensation prior to commercial allocation, implementation has been noted to be inconsistent in practice (Human Rights Watch, 2024).

[5] The EU represents a key destination for Malaysian palm oil, ranking as the third-largest market after India and China. In 2023, palm oil exports from Malaysia to the EU totaled 1.07 million tonnes, accounting for 7.1% of the country’s overall palm oil exports (Proforest, 2025).

[6] EU countries are significant importers of Malaysian forestry goods, with the Netherlands and Germany ranking as the second- and third-largest purchasers of nationally certified timber from Malaysia in 2022(Keeton-Olsen, 2024).

[7] Operational authority is implemented through several key agencies. The Sarawak Forest Department oversees forest classification, management, and the issuance of timber licences, while the Sarawak Land and Survey Department is responsible for land allocation, land registration, and matters related to NCR land. In parallel, the Sarawak Forestry Corporation is mandated to manage conservation efforts, including protected areas and biodiversity (Forest Department Sarawak, 2026; Land and Survey Department Sarawak, 2026; Sarawak Forestry Corporation, 2026).

[8] Power at this level remains closely aligned with major corporations, whose political and economic influence continue to shape development priorities and regulatory enforcement (Tan et al., 2023; Koh et al., 2023).

[9] It has been observed that smallholder farmers are more unlikely to satisfy the legality and sustainability requirements stipulated by the EUDR, as financial and structural constraints could limit their capacity to comply, thereby risking their exclusion from this vital global supply chain (Jong, 2023).

[10] Compliance with the EUDR will therefore require significant financial, technical, and institutional support from government and industry stakeholders (Proforest, 2025).

[11] This option largely reflects existing approaches, which have not fully curbed deforestation or addressed persistent traceability and enforcement gaps (The Borneo Project, 2024).

[12] ISPO made compliance a legal requirement rather than a purely voluntary market choice with traceability being strengthened by requiring certified operators to identify the source of fresh fruit bunches and disclosure of supplier and buyer relationships within the value chain (Sarmiento et al., 2024).

[13] This will be critical given the EUDR’s post-2020 cutoff, as traceability systems must be capable of distinguishing between compliant and non-compliant production areas. This could reduce the feasibility of simply redirecting exports to alternative markets, reinforcing the need for system-wide transparency (The Borneo Project, 2024).

[14] This involved moving from informal, insecure land use to formal, contract-based forest access through the creation of Agroforestry Concessions and reorganization of land into forest-use zones. The reform worked by giving smallholders a legal path into the system instead of leaving them invisible to the state (Sarmiento et al., 2024).

[[Category:Forestry]]

Documentation:Sarawak’s Forest Governance under the European Union Deforestation Regulation: Policy Options for the Premier of the State of Sarawak, Malaysia

2026-05-15T20:15:55Z

WillEngle:

Oil palm and timber plantations expansion have been noted as the primary drivers of deforestation in Sarawak'''[1]''' (Sarawak Report, 2024). This has created a significant governance challenge under the European Union Deforestation Regulation (EUDR) which came into force on 29<sup>th</sup> June 2023 requiring commodities entering the EU market to be deforestation-free and legally produced with a post-2020 deforestation cutoff'''[2]''' (The Borneo Project, 2024).

== Background ==
The EUDR has increased pressure on producers with compliance depending on strict plot-level geolocation and supply-chain traceability requirements, limiting the scope for diverting commodities to alternative markets (Human Rights Watch, 2024).

Malaysia has challenged the EUDR, framing it as a form of disguised protectionism and a trade barrier that places disproportionate burdens on smallholders in its formal complaint to the WTO, this has introduced further uncertainty (Brasier, 2024; Teja, 2024).

Malaysia has relied on the Malaysian Sustainable Palm Oil (MSPO) certification scheme, alongside existing legal frameworks under the Land Code and Forest Ordinance, to address raised sustainability concerns (ISIS Malaysia & UPM, 2024a, 2024b). The EU has recognised the scheme as a credible certification framework that could support compliance with the EUDR, due to the incorporation of digital traceability tools that strengthen supply-chain transparency (Reuters, 2025).

However, despite these policy advancements, forest loss remains significant, with approximately 85,100 hectares cleared in 2023'''[3]''' (Funds for NGOs, 2024) See figure 1 below for extent of plantation expansion. This has been intensified by the state’s target of one million hectares of timber plantations, requiring the clearance of over 400,000 hectares of natural forest (The Borneo Project, 2024).

'''Figure 1: Extent of Plantation Concessions in Sarawak'''

Source: Erickson-Davis (2018)

Local tensions too, have escalated with Long Urun recording over 40,000 satellite‑detected deforestation alerts, with nearly 500 hectares of forest lost. This triggered petitions and blockades after official avenues failed. International pressure later prompted a temporary moratorium (Keeton‑Olsen, 2025; The Borneo Project, 2025a, 2025b). (See figure 2 below, for extent).

'''Figure 2: Land Clearing Captured in Long Urun on September 24, 2025'''

Source: Keeton-Olsen (2025)

Furthermore, Sarawak’s Land Code has been criticized for limiting the legal recognition of Indigenous Native Customary Rights (NCR) lands while enabling commercial access to forested areas through state-issued leases'''[4]''' (The Borneo Project, 2025a, 2025b).

These governance challenges have strengthened calls by civil society organisations urging the EU to classify Sarawak as a high-risk jurisdiction which would increase regulatory scrutiny of exports to EU markets (Keeton-Olsen, 2024). Given the importance of European markets for Malaysia’s palm oil'''[5]''' and timber sectors'''[6]''', strengthening forest governance and ensuring compliance are paramount (Human Rights Watch, 2024).

== Key Actors ==
At the international level, EU institutions act as external regulators through EUDR requirements, shaping market access and compliance expectations. International NGOs and consumer brands exert influence through supply chain pressure, exemplified by the sourcing suspensions linked to plantation expansion in Long Urun (The Borneo Project, 2025a, 2025b).

At the national level, federal institutions such as the Malaysian Palm Oil Council, Ministry of Investment, Trade and Industry, Ministry of Plantation and Commodities, Malaysian Timber Industry Board, influence the broader economic and regulatory environment through export policy, trade negotiations, and sustainability certification systems, while engaging directly with the EU on EUDR compliance (ISIS Malaysia & UPM, 2024a, 2024b; Kumaran et al., 2021; Reuters, 2025). They continue to lead Malaysia’s challenge to the EUDR at the WTO (Brasier, 2024; Teja, 2024).

At the sub-national level, the Sarawak state government holds primary authority over land allocation, forest classification, and plantation licensing through the Sarawak Ministry of Natural Resources and Urban Development'''[7]''' (Ministry of Urban Development and Natural Resources, 2026). This enables it to approve timber concessions and oil palm expansion'''[8]''' (Keeton-Olsen, 2021; Mohammad et al., 2022).

At the local level, Indigenous communities alongside forest-dependent households, smallholders, and plantation workers, are most directly affected by these governance dynamics'''[9]'''. They rely on NCR lands for livelihoods and cultural continuity but face persistent barriers to formal recognition under Sarawak’s Land Code (Human Rights Watch, 2024). Forest conversion threatens their subsistence resources, fuels local conflicts, exposing smallholders and labourers to economic risks '''[10]''' (Funds for NGOs, 2024).

== Policy options ==

=== '''Option 1: Status Quo''' ===
Herein, enforcement would continue through current state mechanisms under the Land Code and Forest Ordinance alongside the MSPO certification framework. This approach preserves current development trajectories centred on oil palm and timber expansion'''[11]''' (Human Rights Watch, 2024; UKAS, 2025a).

Continued forest loss would likely persist, reinforcing international scrutiny from regulators, civil society organisations, and consumer brands concerned (Funds for NGOs, 2024; The Borneo Project, 2024). Sarawak could face heightened due-diligence requirements or potential classification as a “high-risk” jurisdiction, increasing transaction costs (ISIS Malaysia & UPM, 2024a, 2024b). See figure 3 below for due-diligence requirements.

Figure 3: Due Diligence Requirements Under Articles 9, 10 and 11 of the EUDR

Source: ISIS Malaysia, & UPM, 2024b

The main benefit of this would be that plantation expansion proceeds without disruption, industry actors avoid new compliance costs, while state revenues linked to land-based development would remain stable in the near term (Koh et al., 2023; Tan et al., 2023).

Authority over routine enforcement priorities, administrative coordination, and public communication would be retained while avoiding initiating legislative or regulatory reforms (Forests Ordinance, 2015). This would favour plantation and timber interests while minimising confrontation with powerful industry actors. Winners would include large agribusiness firms and political actors aligned with expansion, while losers would include forest-dependent communities, environmentally oriented exporters, and stakeholders seeking stronger sustainability compliance (Human Rights Watch, 2024; The Borneo Project, 2024).

==== '''Option 2: Compliance and Traceability Strategy''' ====
This would strengthen supply-chain transparency and traceability systems while allowing continued land conversion within existing regulatory limits as seen in Indonesia which was able to achieve compliance and traceability through its mandatory national certification system, the Indonesian Sustainable Palm Oil (ISPO) scheme, paired with forest-use restrictions, audits, and traceability rules for the palm oil supply chain'''[12]''' (Sarmiento et al., 2024).

Measures would include improving geolocation data, integrating plantation licensing databases, strengthening MSPO 2.0 implementation, and supporting smallholders in meeting certification requirements'''[13]''' (ISIS Malaysia & UPM, 2024a, 2024b; Reuters, 2025).

Strengthening digital monitoring systems, verification mechanisms, and compliance support programmes would require public funding and institutional coordination (Forests Ordinance, 2015). Smallholders may face additional reporting burdens, while some companies may resist transparency requirements. Reforms may also remain procedural rather than substantive if underlying drivers of deforestation remain unchanged (The Borneo Project, 2024).

Enhanced traceability and compliance systems would demonstrate legality and supply-chain transparency to EU regulators and international buyers with export-oriented producers gaining more secure access to European markets, while improved governance systems could increase investor confidence, reducing trade disruptions (Ross, 2026).

Exercising of direct control over monitoring systems, enforcement transparency, and state-level compliance infrastructure would be facilitated but would require coordination with federal agencies responsible for certification and export promotion as well as cabinet support for budget allocations and inter-agency mandates (Forests Ordinance, 2015). This would appeal to export-oriented firms and federal trade authorities while avoiding major restrictions on plantation expansion. Winners would include compliant exporters and supported smallholders, while non-compliant operators would face greater scrutiny (Human Rights Watch, 2024).

=== '''Option 3: Forest Protection and Land Governance Reform''' ===
This would ensure stronger land-use regulation and governance reform. Measures will include a moratorium on new plantations in natural forests and peatlands, expansion of protected forest areas, stricter enforcement of land-conversion rules, and improved recognition of Indigenous NCR alongside Free, Prior and Informed Consent (FPIC) requirements for development projects (Human Rights Watch, 2024; The Borneo Project, 2024).

Stricter land-use controls could slow plantation expansion, potentially reducing short-term revenue from land-based development with enforcement capacity needing strengthening. Compensation or renegotiation of existing concessions would also need to be carried out to minimize legal disputes as well as boost investor confidence (Koh et al., 2023; Tan et al., 2023). Peru was able to achieve similar structural reforms by pairing land and forest formalization with clearer rules, stronger institutions, and incentives that brought informal actors into the legal system'''[14]''' (Sarmiento et al., 2024).

Stronger forest protection would result, reducing deforestation, improving biodiversity conservation, while decreasing land-rights conflicts with Indigenous communities (Sarmiento et al., 2024). Alignment with the EUDR would also strengthen Sarawak’s credibility (Tang, 2025; Reuters, 2025).

Control of enforcement priorities and administrative measures would be enabled. However, major reforms focusing on land-law amendments and protected-area designations would require approval from the State Legislative Assembly and coordination with federal authorities (Forests Ordinance, 2015). This option may face resistance from agribusiness interests but would gain support from civil society, Indigenous communities, and international partners. Winners would include forest-dependent communities, sustainable producers, and long-term exporters, while firms reliant on expansion and land-conversion revenues may incur losses (ISIS Malaysia & UPM, 2024a, 2024b; Mohammad et al., 2022).

== Recommended Policy option ==
A hybrid strategy would be the most viable approach, beginning with Option 2 and transitioning toward Option 3. Strengthening traceability, MSPO 2.0 implementation, and monitoring systems would provide immediate protection of EU market access, which is critical given Sarawak’s export dependence and exposure to EUDR requirements (Sarmiento et al., 2024; UKAS, 2025). This approach is politically feasible, avoids abrupt disruption, while building on the required administrative capacity for deeper reforms (Sarmiento et al., 2024).

However, compliance alone may not address the underlying deforestation drivers. A phased transition towards stronger land-use regulation and recognition of NCR and FPIC is necessary for long-term sustainability (Sarmiento et al., 2024; The Borneo Project, 2024). This would counter the state–corporate bias by empowering Indigenous voices via NCR/FPIC, while using traceability to appease exporters (Human Rights Watch, 2024). While Malaysia’s WTO challenge may reshape future obligations, it does not eliminate the immediate need for compliance (Brasier, 2024; Teja, 2024). This combined approach balances short-term trade imperatives with longer-term governance reform.

== Decision Timeline, Next Steps, and Key Milestones ==
The approach should be adopted by 30 March 2026 to allow sufficient lead time for implementation before the EUDR takes effect. It will apply from 30 December 2026 for large operators and traders, and from 30 June 2027 for micro- and small enterprises (European Commission, 2024). In addition, the EU’s risk benchmarking review, expected in May 2026, may shape Malaysia’s classification as high or standard risk, making early preparation paramount (Meridia, 2025).

Implementation should proceed in phases. In April 2026, an inter-agency taskforce should be convened to coordinate traceability mapping. In May 2026, Cabinet should decide on budget allocations and whether Land Code amendments will be pursued. June 2026 should mark the launch of smallholder support pilots and stakeholder forums, followed by quarterly deforestation monitoring reports. In Q2 2026, legislative reforms could be considered during the State Assembly session, while a federal MSPO audit is expected in Q3 2026. Large-firm pilots should begin in December 2026, with scale-up decisions made in late 2026 ahead of April 2027 compliance checks.

= References =
Brasier, P.-J. S. (2024, September 18). ''Heated debates about the EUDR are missing the bigger picture''. Fern. <nowiki>https://www.fern.org/pt/publications-insight/article/heated-debates-about-the-eudr-are-missing-the-bigger-picture/</nowiki>

Erickson-Davis, M. (2018, March 12). ''Sarawak makes 80% forest preservation commitment, but some have doubts''. Mongabay. <nowiki>https://news.mongabay.com/2018/03/sarawak-makes-80-forest-preservation-commitment-but-some-have-doubts/</nowiki>

European Union. (2025, September 5). ''EU and Malaysia agree to strengthen their partnership and continue their joint efforts against deforestation''. <nowiki>https://www.eeas.europa.eu/delegations/malaysia/eu-and-malaysia-agree-strengthen-their-partnership-and-continue-their-joint-efforts-against_en</nowiki>

Forest Department Sarawak. (2026, March 27). ''Forest Department Sarawak''. <nowiki>https://forestry.sarawak.gov.my/web/home/index/</nowiki>

Forests Ordinance, 2015, c. 71 (Sarawak). (2015). ''Laws of Sarawak''. <nowiki>https://lawnet.sarawak.gov.my/lawnet_file/Ordinance/ORD_Watermark.pdf</nowiki>

Funds for NGOs. (2024, October 15). ''NGOs urge EU to designate Sarawak as “high risk” for timber and palm oil''. <nowiki>https://news.fundsforngos.org/2024/10/15/ngos-urge-eu-to-designate-sarawak-as-high-risk-for-timber-and-palm-oil/</nowiki>

Global Forest Watch. (n.d.). ''Malaysia''. <nowiki>https://www.globalforestwatch.org/dashboards/country/MYS/14/</nowiki>

Human Rights Watch. (2024, September 23). ''EU: Address Indigenous rights violations in Malaysian imports: Designate Sarawak as “high risk” under new anti-deforestation law''. <nowiki>https://www.hrw.org/news/2024/09/23/eu-address-indigenous-rights-violations-malaysian-imports</nowiki>

Institute of Strategic and International Studies Malaysia (ISIS Malaysia), & Universiti Putra Malaysia (UPM). (2024a). ''Availability of EU deforestation regulation relevant information for the palm oil sector in Malaysia'' (Policy Brief No. 2). <nowiki>https://www.isis.org.my/wp-content/uploads/2024/11/Policy-brief-2-Malaysia-data-readiness-for-EUDR_layout2.pdf</nowiki>

Institute of Strategic and International Studies Malaysia (ISIS Malaysia), & Universiti Putra Malaysia (UPM). (2024b). ''Reinforcing deforestation‑free palm oil supply chains: Options for Malaysia in the context of EU and global legislation''. European Forest Institute. <nowiki>https://efi.int/sites/default/files/files/flegtredd/KAMI/Resources/Deforestation_free_supply_chains_for_palm_oil_2.pdf</nowiki>

Jong, H. N. (2023, September 1). ''Palm oil giants Indonesia, Malaysia start talks with EU over deforestation rule''. Mongabay. <nowiki>https://news.mongabay.com/2023/09/palm-oil-giants-indonesia-malaysia-start-talks-with-eu-over-deforestation-rule/</nowiki>

Keeton-Olsen, D. (2021, February 18). ''In Malaysian Borneo’s rainforests, powerful state governments set their own rules''. Mongabay. <nowiki>https://news.mongabay.com/2021/02/in-malaysian-borneos-rainforests-powerful-state-government-set-their-own-rules/</nowiki>

Keeton-Olsen, D. (2024, October 9). ''NGOs push EU to label Sarawak as “high risk” source of timber, palm oil''. Mongabay. <nowiki>https://news.mongabay.com/2024/10/ngos-push-eu-to-label-sarawak-as-high-risk-source-of-timber-palm-oil/</nowiki>

Keeton-Olsen, D. (2025, November 11). ''Cautious win for Indigenous groups in Malaysia as palm oil firm pauses forest clearing''. Mongabay. <nowiki>https://news.mongabay.com/2025/11/cautious-win-for-indigenous-groups-in-malaysia-as-palm-oil-firm-pauses-forest-clearing/</nowiki>

Koh, J., Johari, S., Shuib, A., Siow, M. L., & Matthew, N. K. (2023). Malaysia’s forest pledges and the Bornean state of Sarawak: A policy perspective. ''Sustainability, 15''(2), 1385. <nowiki>https://doi.org/10.3390/su15021385</nowiki>

Kumaran, S., Chew, J. S., & Nambiappan, B. (2021). ''Moving forward with mandatory MSPO certification standards''. ''Oil Palm Industry Economic Journal, 21''(1), 1–12. <nowiki>https://doi.org/10.21894/opiej.2021.01</nowiki>

Land and Survey Department Sarawak. (2026, March 27). ''Land and Survey Department Sarawak''. <nowiki>https://landsurvey.sarawak.gov.my/web/home/index/</nowiki>

Low, C. C. (2024, July 4). ''Timber grab: The truth behind Pahang oil palm plantations in Malaysia''. Asian Dispatch. <nowiki>https://www.asiandispatch.net/timber-grab-the-truth-behind-pahang-oil-palm-plantations-in-malaysia</nowiki>

Meridia. (2025, May 28). ''EUDR benchmarking and risk categories explained: A simple guide''. <nowiki>https://www.meridia.land/blog/eudr-benchmarking-and-risk-categories-explained-a-simple-guide</nowiki>

Ministry of Urban Development and Natural Resources. (2026, March 20). ''MUDeNR – Sarawak''. <nowiki>https://mudenr.sarawak.gov.my/web/home/index/</nowiki>

Mohammad, H. H., Ripot, S., Alek, R. J., Cluny, W., & Kader, W. A. (2022). ''Sustainable forest management: Sarawak’s perspective''. Forest Department Sarawak. <nowiki>https://www.forestry.gov.my/images/pengumuman/2022/MFC/MFC2024/paperwork/Paper_2_Sustainable_Forest_Management_Sarawaks_Perspective.pdf</nowiki>

Proforest. (2025). ''Options to broaden smallholder inclusivity in legal and deforestation-free palm oil supply chains in Malaysia''. European Forest Institute. <nowiki>https://efi.int/sites/default/files/files/flegtredd/KAMI/Resources/smallholder_inclusivity_report.pdf</nowiki>

Reuters. (2025, September 10). ''EU clears Malaysia's palm oil certification for new deforestation rule''. <nowiki>https://www.reuters.com/markets/commodities/eu-clears-malaysias-palm-oil-certification-new-deforestation-rule-2025-09-10/</nowiki>

Ross, J. (2026, March 3). Malaysia warns CITES push on tropical timber is self‑interest, not science. Wood Central. <nowiki>https://woodcentral.com.au/malaysia-warns-cites-push-on-tropical-timber-is-self-interest-not-science/</nowiki>

Sarawak Forestry Corporation. (2026, March 20). ''Sarawak Forestry Corporation''. <nowiki>https://sfc.sarawak.gov.my/web/home/index/</nowiki>

Sarawak Report. (2024, June 2). ''Malaysia’s rainforest threat is focused on Sarawak''. <nowiki>https://www.sarawakreport.org/2024/06/malaysias-rainforest-threat-is-focused-on-sarawak/</nowiki>

Sarmiento, F., Larrea, C., Oeschger, A., & Jose, R. (2024, February 21). ''Measures to enhance forest conservation and reduce deforestation: Viewpoints and lessons from producing countries''. International Institute for Sustainable Development. <nowiki>https://www.iisd.org/ssi/publications/measures-enhance-forest-conservation-reduce-deforestation/</nowiki>

Tan, L. C., Toh, M. L., Looi, K. S., Tan, W. V., Ujang, M. U., Thoo, A. C., Azri, N. S. b., & Kathitasapathy, S. A. L. (2023). Towards “good” Native land governance: An evaluation in Sarawak, Malaysia. ''The International Indigenous Policy Journal, 14''(1). <nowiki>https://doi.org/10.18584/iipj.2023.14.1.13873</nowiki>

Tang, A. (2025, October 8). ''EU delays deforestation rule to Dec 2026''. ''Sarawak Tribune''. <nowiki>https://www.sarawaktribune.com/eu-delays-deforestation-rule-to-december-2026/</nowiki>

Teja, N. (2024, February 8). ''EU deforestation regulation dubbed a ‘double-edged sword’ for global palm oil markets''. Sustainable Views. <nowiki>https://www.sustainableviews.com/eu-deforestation-regulation-dubbed-a-double-edged-sword-for-global-palm-oil-markets/</nowiki>

The Borneo Project. (2024, September 26). ''Why Sarawak should be high risk under the new EU deforestation rules''. <nowiki>https://borneoproject.org/why-sarawak-should-be-high-risk-under-the-new-eu-deforestation-rules/</nowiki>

The Borneo Project. (2025a, January 10). ''Deforestation alert: Ulu Belaga''. <nowiki>https://borneoproject.org/deforestation-alert-ulu-belaga/</nowiki>

The Borneo Project. (2025b, October 30). ''Victory for Indigenous communities in Sarawak as Urun Plantations halts forest clearing''. <nowiki>https://borneoproject.org/victory-for-indigenous-communities-in-sarawak-as-urun-plantations-halts-forest-clearing/</nowiki>

UKAS. (2025a, September 19). ''Palm oil overtakes crude petroleum as Sarawak’s leading export''. Premier of Sarawak Department. <nowiki>https://premierdept.sarawak.gov.my/web/subpage/news_view/25115/UKAS</nowiki>

UKAS. (2025b, January 17). ''Sarawak Cabinet works collectively for the well-being of the people''. Government of Sarawak. <nowiki>https://premierdept.sarawak.gov.my/web/subpage/news_view/11717/UKAS#:~:text=%E2%80%9COur%20cabinet%20operates%20on%20a%20collective%20system,economy%2C%20and%20that%20is%20the%20result%20of</nowiki>

----[1] By 2024, Sarawak had lost 1.7 million hectares of humid primary forest, a 23% decline in its overall primary forest area (Global Forest Watch, n.d.).

[2] Continued forest loss and land-rights disputes risk “high-risk” classification, which could threaten Sarawak’s EU market access (Funds for NGOs, 2024).

[3] This has contributed to a cumulative decline of about 1.04 million acres between 2019 and 2023. Furthermore, associated analysis suggests that logging and oil palm expansion continue to threaten extensive areas of naturally regenerating forest (Keeton-Olsen, 2024).

[4] Additionally, although the legal framework requires the voluntary surrender or termination of customary land and compensation prior to commercial allocation, implementation has been noted to be inconsistent in practice (Human Rights Watch, 2024).

[5] The EU represents a key destination for Malaysian palm oil, ranking as the third-largest market after India and China. In 2023, palm oil exports from Malaysia to the EU totaled 1.07 million tonnes, accounting for 7.1% of the country’s overall palm oil exports (Proforest, 2025).

[6] EU countries are significant importers of Malaysian forestry goods, with the Netherlands and Germany ranking as the second- and third-largest purchasers of nationally certified timber from Malaysia in 2022(Keeton-Olsen, 2024).

[7] Operational authority is implemented through several key agencies. The Sarawak Forest Department oversees forest classification, management, and the issuance of timber licences, while the Sarawak Land and Survey Department is responsible for land allocation, land registration, and matters related to NCR land. In parallel, the Sarawak Forestry Corporation is mandated to manage conservation efforts, including protected areas and biodiversity (Forest Department Sarawak, 2026; Land and Survey Department Sarawak, 2026; Sarawak Forestry Corporation, 2026).

[8] Power at this level remains closely aligned with major corporations, whose political and economic influence continue to shape development priorities and regulatory enforcement (Tan et al., 2023; Koh et al., 2023).

[9] It has been observed that smallholder farmers are more unlikely to satisfy the legality and sustainability requirements stipulated by the EUDR, as financial and structural constraints could limit their capacity to comply, thereby risking their exclusion from this vital global supply chain (Jong, 2023).

[10] Compliance with the EUDR will therefore require significant financial, technical, and institutional support from government and industry stakeholders (Proforest, 2025).

[11] This option largely reflects existing approaches, which have not fully curbed deforestation or addressed persistent traceability and enforcement gaps (The Borneo Project, 2024).

[12] ISPO made compliance a legal requirement rather than a purely voluntary market choice with traceability being strengthened by requiring certified operators to identify the source of fresh fruit bunches and disclosure of supplier and buyer relationships within the value chain (Sarmiento et al., 2024).

[13] This will be critical given the EUDR’s post-2020 cutoff, as traceability systems must be capable of distinguishing between compliant and non-compliant production areas. This could reduce the feasibility of simply redirecting exports to alternative markets, reinforcing the need for system-wide transparency (The Borneo Project, 2024).

[14] This involved moving from informal, insecure land use to formal, contract-based forest access through the creation of Agroforestry Concessions and reorganization of land into forest-use zones. The reform worked by giving smallholders a legal path into the system instead of leaving them invisible to the state (Sarmiento et al., 2024).

[[Category:Forestry]]

Documentation:Sarawak’s Forest Governance under the European Union Deforestation Regulation: Policy Options for the Premier of the State of Sarawak, Malaysia

2026-05-15T20:15:39Z

WillEngle:

== Introduction ==
Oil palm and timber plantations expansion have been noted as the primary drivers of deforestation in Sarawak'''[1]''' (Sarawak Report, 2024). This has created a significant governance challenge under the European Union Deforestation Regulation (EUDR) which came into force on 29<sup>th</sup> June 2023 requiring commodities entering the EU market to be deforestation-free and legally produced with a post-2020 deforestation cutoff'''[2]''' (The Borneo Project, 2024).

== Background ==
The EUDR has increased pressure on producers with compliance depending on strict plot-level geolocation and supply-chain traceability requirements, limiting the scope for diverting commodities to alternative markets (Human Rights Watch, 2024).

Malaysia has challenged the EUDR, framing it as a form of disguised protectionism and a trade barrier that places disproportionate burdens on smallholders in its formal complaint to the WTO, this has introduced further uncertainty (Brasier, 2024; Teja, 2024).

Malaysia has relied on the Malaysian Sustainable Palm Oil (MSPO) certification scheme, alongside existing legal frameworks under the Land Code and Forest Ordinance, to address raised sustainability concerns (ISIS Malaysia & UPM, 2024a, 2024b). The EU has recognised the scheme as a credible certification framework that could support compliance with the EUDR, due to the incorporation of digital traceability tools that strengthen supply-chain transparency (Reuters, 2025).

However, despite these policy advancements, forest loss remains significant, with approximately 85,100 hectares cleared in 2023'''[3]''' (Funds for NGOs, 2024) See figure 1 below for extent of plantation expansion. This has been intensified by the state’s target of one million hectares of timber plantations, requiring the clearance of over 400,000 hectares of natural forest (The Borneo Project, 2024).

'''Figure 1: Extent of Plantation Concessions in Sarawak'''

Source: Erickson-Davis (2018)

Local tensions too, have escalated with Long Urun recording over 40,000 satellite‑detected deforestation alerts, with nearly 500 hectares of forest lost. This triggered petitions and blockades after official avenues failed. International pressure later prompted a temporary moratorium (Keeton‑Olsen, 2025; The Borneo Project, 2025a, 2025b). (See figure 2 below, for extent).

'''Figure 2: Land Clearing Captured in Long Urun on September 24, 2025'''

Source: Keeton-Olsen (2025)

Furthermore, Sarawak’s Land Code has been criticized for limiting the legal recognition of Indigenous Native Customary Rights (NCR) lands while enabling commercial access to forested areas through state-issued leases'''[4]''' (The Borneo Project, 2025a, 2025b).

These governance challenges have strengthened calls by civil society organisations urging the EU to classify Sarawak as a high-risk jurisdiction which would increase regulatory scrutiny of exports to EU markets (Keeton-Olsen, 2024). Given the importance of European markets for Malaysia’s palm oil'''[5]''' and timber sectors'''[6]''', strengthening forest governance and ensuring compliance are paramount (Human Rights Watch, 2024).

== Key Actors ==
At the international level, EU institutions act as external regulators through EUDR requirements, shaping market access and compliance expectations. International NGOs and consumer brands exert influence through supply chain pressure, exemplified by the sourcing suspensions linked to plantation expansion in Long Urun (The Borneo Project, 2025a, 2025b).

At the national level, federal institutions such as the Malaysian Palm Oil Council, Ministry of Investment, Trade and Industry, Ministry of Plantation and Commodities, Malaysian Timber Industry Board, influence the broader economic and regulatory environment through export policy, trade negotiations, and sustainability certification systems, while engaging directly with the EU on EUDR compliance (ISIS Malaysia & UPM, 2024a, 2024b; Kumaran et al., 2021; Reuters, 2025). They continue to lead Malaysia’s challenge to the EUDR at the WTO (Brasier, 2024; Teja, 2024).

At the sub-national level, the Sarawak state government holds primary authority over land allocation, forest classification, and plantation licensing through the Sarawak Ministry of Natural Resources and Urban Development'''[7]''' (Ministry of Urban Development and Natural Resources, 2026). This enables it to approve timber concessions and oil palm expansion'''[8]''' (Keeton-Olsen, 2021; Mohammad et al., 2022).

At the local level, Indigenous communities alongside forest-dependent households, smallholders, and plantation workers, are most directly affected by these governance dynamics'''[9]'''. They rely on NCR lands for livelihoods and cultural continuity but face persistent barriers to formal recognition under Sarawak’s Land Code (Human Rights Watch, 2024). Forest conversion threatens their subsistence resources, fuels local conflicts, exposing smallholders and labourers to economic risks '''[10]''' (Funds for NGOs, 2024).

== Policy options ==

=== '''Option 1: Status Quo''' ===
Herein, enforcement would continue through current state mechanisms under the Land Code and Forest Ordinance alongside the MSPO certification framework. This approach preserves current development trajectories centred on oil palm and timber expansion'''[11]''' (Human Rights Watch, 2024; UKAS, 2025a).

Continued forest loss would likely persist, reinforcing international scrutiny from regulators, civil society organisations, and consumer brands concerned (Funds for NGOs, 2024; The Borneo Project, 2024). Sarawak could face heightened due-diligence requirements or potential classification as a “high-risk” jurisdiction, increasing transaction costs (ISIS Malaysia & UPM, 2024a, 2024b). See figure 3 below for due-diligence requirements.

Figure 3: Due Diligence Requirements Under Articles 9, 10 and 11 of the EUDR

Source: ISIS Malaysia, & UPM, 2024b

The main benefit of this would be that plantation expansion proceeds without disruption, industry actors avoid new compliance costs, while state revenues linked to land-based development would remain stable in the near term (Koh et al., 2023; Tan et al., 2023).

Authority over routine enforcement priorities, administrative coordination, and public communication would be retained while avoiding initiating legislative or regulatory reforms (Forests Ordinance, 2015). This would favour plantation and timber interests while minimising confrontation with powerful industry actors. Winners would include large agribusiness firms and political actors aligned with expansion, while losers would include forest-dependent communities, environmentally oriented exporters, and stakeholders seeking stronger sustainability compliance (Human Rights Watch, 2024; The Borneo Project, 2024).

==== '''Option 2: Compliance and Traceability Strategy''' ====
This would strengthen supply-chain transparency and traceability systems while allowing continued land conversion within existing regulatory limits as seen in Indonesia which was able to achieve compliance and traceability through its mandatory national certification system, the Indonesian Sustainable Palm Oil (ISPO) scheme, paired with forest-use restrictions, audits, and traceability rules for the palm oil supply chain'''[12]''' (Sarmiento et al., 2024).

Measures would include improving geolocation data, integrating plantation licensing databases, strengthening MSPO 2.0 implementation, and supporting smallholders in meeting certification requirements'''[13]''' (ISIS Malaysia & UPM, 2024a, 2024b; Reuters, 2025).

Strengthening digital monitoring systems, verification mechanisms, and compliance support programmes would require public funding and institutional coordination (Forests Ordinance, 2015). Smallholders may face additional reporting burdens, while some companies may resist transparency requirements. Reforms may also remain procedural rather than substantive if underlying drivers of deforestation remain unchanged (The Borneo Project, 2024).

Enhanced traceability and compliance systems would demonstrate legality and supply-chain transparency to EU regulators and international buyers with export-oriented producers gaining more secure access to European markets, while improved governance systems could increase investor confidence, reducing trade disruptions (Ross, 2026).

Exercising of direct control over monitoring systems, enforcement transparency, and state-level compliance infrastructure would be facilitated but would require coordination with federal agencies responsible for certification and export promotion as well as cabinet support for budget allocations and inter-agency mandates (Forests Ordinance, 2015). This would appeal to export-oriented firms and federal trade authorities while avoiding major restrictions on plantation expansion. Winners would include compliant exporters and supported smallholders, while non-compliant operators would face greater scrutiny (Human Rights Watch, 2024).

=== '''Option 3: Forest Protection and Land Governance Reform''' ===
This would ensure stronger land-use regulation and governance reform. Measures will include a moratorium on new plantations in natural forests and peatlands, expansion of protected forest areas, stricter enforcement of land-conversion rules, and improved recognition of Indigenous NCR alongside Free, Prior and Informed Consent (FPIC) requirements for development projects (Human Rights Watch, 2024; The Borneo Project, 2024).

Stricter land-use controls could slow plantation expansion, potentially reducing short-term revenue from land-based development with enforcement capacity needing strengthening. Compensation or renegotiation of existing concessions would also need to be carried out to minimize legal disputes as well as boost investor confidence (Koh et al., 2023; Tan et al., 2023). Peru was able to achieve similar structural reforms by pairing land and forest formalization with clearer rules, stronger institutions, and incentives that brought informal actors into the legal system'''[14]''' (Sarmiento et al., 2024).

Stronger forest protection would result, reducing deforestation, improving biodiversity conservation, while decreasing land-rights conflicts with Indigenous communities (Sarmiento et al., 2024). Alignment with the EUDR would also strengthen Sarawak’s credibility (Tang, 2025; Reuters, 2025).

Control of enforcement priorities and administrative measures would be enabled. However, major reforms focusing on land-law amendments and protected-area designations would require approval from the State Legislative Assembly and coordination with federal authorities (Forests Ordinance, 2015). This option may face resistance from agribusiness interests but would gain support from civil society, Indigenous communities, and international partners. Winners would include forest-dependent communities, sustainable producers, and long-term exporters, while firms reliant on expansion and land-conversion revenues may incur losses (ISIS Malaysia & UPM, 2024a, 2024b; Mohammad et al., 2022).

== Recommended Policy option ==
A hybrid strategy would be the most viable approach, beginning with Option 2 and transitioning toward Option 3. Strengthening traceability, MSPO 2.0 implementation, and monitoring systems would provide immediate protection of EU market access, which is critical given Sarawak’s export dependence and exposure to EUDR requirements (Sarmiento et al., 2024; UKAS, 2025). This approach is politically feasible, avoids abrupt disruption, while building on the required administrative capacity for deeper reforms (Sarmiento et al., 2024).

However, compliance alone may not address the underlying deforestation drivers. A phased transition towards stronger land-use regulation and recognition of NCR and FPIC is necessary for long-term sustainability (Sarmiento et al., 2024; The Borneo Project, 2024). This would counter the state–corporate bias by empowering Indigenous voices via NCR/FPIC, while using traceability to appease exporters (Human Rights Watch, 2024). While Malaysia’s WTO challenge may reshape future obligations, it does not eliminate the immediate need for compliance (Brasier, 2024; Teja, 2024). This combined approach balances short-term trade imperatives with longer-term governance reform.

== Decision Timeline, Next Steps, and Key Milestones ==
The approach should be adopted by 30 March 2026 to allow sufficient lead time for implementation before the EUDR takes effect. It will apply from 30 December 2026 for large operators and traders, and from 30 June 2027 for micro- and small enterprises (European Commission, 2024). In addition, the EU’s risk benchmarking review, expected in May 2026, may shape Malaysia’s classification as high or standard risk, making early preparation paramount (Meridia, 2025).

Implementation should proceed in phases. In April 2026, an inter-agency taskforce should be convened to coordinate traceability mapping. In May 2026, Cabinet should decide on budget allocations and whether Land Code amendments will be pursued. June 2026 should mark the launch of smallholder support pilots and stakeholder forums, followed by quarterly deforestation monitoring reports. In Q2 2026, legislative reforms could be considered during the State Assembly session, while a federal MSPO audit is expected in Q3 2026. Large-firm pilots should begin in December 2026, with scale-up decisions made in late 2026 ahead of April 2027 compliance checks.

= References =
Brasier, P.-J. S. (2024, September 18). ''Heated debates about the EUDR are missing the bigger picture''. Fern. <nowiki>https://www.fern.org/pt/publications-insight/article/heated-debates-about-the-eudr-are-missing-the-bigger-picture/</nowiki>

Erickson-Davis, M. (2018, March 12). ''Sarawak makes 80% forest preservation commitment, but some have doubts''. Mongabay. <nowiki>https://news.mongabay.com/2018/03/sarawak-makes-80-forest-preservation-commitment-but-some-have-doubts/</nowiki>

European Union. (2025, September 5). ''EU and Malaysia agree to strengthen their partnership and continue their joint efforts against deforestation''. <nowiki>https://www.eeas.europa.eu/delegations/malaysia/eu-and-malaysia-agree-strengthen-their-partnership-and-continue-their-joint-efforts-against_en</nowiki>

Forest Department Sarawak. (2026, March 27). ''Forest Department Sarawak''. <nowiki>https://forestry.sarawak.gov.my/web/home/index/</nowiki>

Forests Ordinance, 2015, c. 71 (Sarawak). (2015). ''Laws of Sarawak''. <nowiki>https://lawnet.sarawak.gov.my/lawnet_file/Ordinance/ORD_Watermark.pdf</nowiki>

Funds for NGOs. (2024, October 15). ''NGOs urge EU to designate Sarawak as “high risk” for timber and palm oil''. <nowiki>https://news.fundsforngos.org/2024/10/15/ngos-urge-eu-to-designate-sarawak-as-high-risk-for-timber-and-palm-oil/</nowiki>

Global Forest Watch. (n.d.). ''Malaysia''. <nowiki>https://www.globalforestwatch.org/dashboards/country/MYS/14/</nowiki>

Human Rights Watch. (2024, September 23). ''EU: Address Indigenous rights violations in Malaysian imports: Designate Sarawak as “high risk” under new anti-deforestation law''. <nowiki>https://www.hrw.org/news/2024/09/23/eu-address-indigenous-rights-violations-malaysian-imports</nowiki>

Institute of Strategic and International Studies Malaysia (ISIS Malaysia), & Universiti Putra Malaysia (UPM). (2024a). ''Availability of EU deforestation regulation relevant information for the palm oil sector in Malaysia'' (Policy Brief No. 2). <nowiki>https://www.isis.org.my/wp-content/uploads/2024/11/Policy-brief-2-Malaysia-data-readiness-for-EUDR_layout2.pdf</nowiki>

Institute of Strategic and International Studies Malaysia (ISIS Malaysia), & Universiti Putra Malaysia (UPM). (2024b). ''Reinforcing deforestation‑free palm oil supply chains: Options for Malaysia in the context of EU and global legislation''. European Forest Institute. <nowiki>https://efi.int/sites/default/files/files/flegtredd/KAMI/Resources/Deforestation_free_supply_chains_for_palm_oil_2.pdf</nowiki>

Jong, H. N. (2023, September 1). ''Palm oil giants Indonesia, Malaysia start talks with EU over deforestation rule''. Mongabay. <nowiki>https://news.mongabay.com/2023/09/palm-oil-giants-indonesia-malaysia-start-talks-with-eu-over-deforestation-rule/</nowiki>

Keeton-Olsen, D. (2021, February 18). ''In Malaysian Borneo’s rainforests, powerful state governments set their own rules''. Mongabay. <nowiki>https://news.mongabay.com/2021/02/in-malaysian-borneos-rainforests-powerful-state-government-set-their-own-rules/</nowiki>

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----[1] By 2024, Sarawak had lost 1.7 million hectares of humid primary forest, a 23% decline in its overall primary forest area (Global Forest Watch, n.d.).

[2] Continued forest loss and land-rights disputes risk “high-risk” classification, which could threaten Sarawak’s EU market access (Funds for NGOs, 2024).

[3] This has contributed to a cumulative decline of about 1.04 million acres between 2019 and 2023. Furthermore, associated analysis suggests that logging and oil palm expansion continue to threaten extensive areas of naturally regenerating forest (Keeton-Olsen, 2024).

[4] Additionally, although the legal framework requires the voluntary surrender or termination of customary land and compensation prior to commercial allocation, implementation has been noted to be inconsistent in practice (Human Rights Watch, 2024).

[5] The EU represents a key destination for Malaysian palm oil, ranking as the third-largest market after India and China. In 2023, palm oil exports from Malaysia to the EU totaled 1.07 million tonnes, accounting for 7.1% of the country’s overall palm oil exports (Proforest, 2025).

[6] EU countries are significant importers of Malaysian forestry goods, with the Netherlands and Germany ranking as the second- and third-largest purchasers of nationally certified timber from Malaysia in 2022(Keeton-Olsen, 2024).

[7] Operational authority is implemented through several key agencies. The Sarawak Forest Department oversees forest classification, management, and the issuance of timber licences, while the Sarawak Land and Survey Department is responsible for land allocation, land registration, and matters related to NCR land. In parallel, the Sarawak Forestry Corporation is mandated to manage conservation efforts, including protected areas and biodiversity (Forest Department Sarawak, 2026; Land and Survey Department Sarawak, 2026; Sarawak Forestry Corporation, 2026).

[8] Power at this level remains closely aligned with major corporations, whose political and economic influence continue to shape development priorities and regulatory enforcement (Tan et al., 2023; Koh et al., 2023).

[9] It has been observed that smallholder farmers are more unlikely to satisfy the legality and sustainability requirements stipulated by the EUDR, as financial and structural constraints could limit their capacity to comply, thereby risking their exclusion from this vital global supply chain (Jong, 2023).

[10] Compliance with the EUDR will therefore require significant financial, technical, and institutional support from government and industry stakeholders (Proforest, 2025).

[11] This option largely reflects existing approaches, which have not fully curbed deforestation or addressed persistent traceability and enforcement gaps (The Borneo Project, 2024).

[12] ISPO made compliance a legal requirement rather than a purely voluntary market choice with traceability being strengthened by requiring certified operators to identify the source of fresh fruit bunches and disclosure of supplier and buyer relationships within the value chain (Sarmiento et al., 2024).

[13] This will be critical given the EUDR’s post-2020 cutoff, as traceability systems must be capable of distinguishing between compliant and non-compliant production areas. This could reduce the feasibility of simply redirecting exports to alternative markets, reinforcing the need for system-wide transparency (The Borneo Project, 2024).

[14] This involved moving from informal, insecure land use to formal, contract-based forest access through the creation of Agroforestry Concessions and reorganization of land into forest-use zones. The reform worked by giving smallholders a legal path into the system instead of leaving them invisible to the state (Sarmiento et al., 2024).

[[Category:Forestry]]