AUSTRALIAN
AIRPORTS
ASSOCIATION

24 October 2025

Attorney-General’s Department
GPO Box 590
Canberra ACT 2601
Australia
Submitted via webform

Australian Airports Association Submission to the Review of the Disability Discrimination Act 1992

The Australian Airports Association (AAA) welcomes the opportunity to contribute to the review of the Disability Discrimination Act 1992. The AAA represents more than 340 airports and aerodromes across Australia together with over 150 corporate members who provide essential goods and services to the aviation sector. Our members range from major international gateways to small regional and remote facilities that keep communities connected.

While not a legal or disability advocacy organisation, the AAA provides this submission from the perspective of an industry duty holder responsible for the safe and inclusive operation of airports across Australia. Airports are committed to ensuring that air travel and related services are accessible, safe, inclusive and dignified for all travellers. The review of the Act provides an important opportunity to modernise the law and ensure that it remains effective in protecting rights and promoting participation in all areas of public life.

A clear and contemporary framework for accessibility and inclusion benefits passengers and helps operators understand and meet their obligations. The AAA supports reforms that clarify duties, reduce complexity and maintain fairness and practical feasibility.

Definition of discrimination

The current definitions of direct and indirect discrimination are difficult for both people with disability and duty holders to interpret and apply. The AAA supports simplifying these definitions to improve clarity and usability.

Replacing the comparator test with a simpler test, based on whether a person has been treated unfavourably because of their disability, would reduce unnecessary technicality and make the law more accessible.

For indirect discrimination, clearer guidance is needed on what constitutes “reasonable”. The AAA supports exploring a legitimate and proportionate test that assesses an action was proportionate means redacted: s22

of achieving a legitimate aim. This would provide a more transparent and balanced framework for decision-making.

Adjustments and unjustifiable hardship

The AAA supports the development of clear guidance on what constitutes unjustifiable hardship. This guidance should consider factors such as cost, safety, regulatory obligations and operational feasibility, particularly in complex airport environments.

Modernising the Disability Standards

Airports operate under multiple overlapping regulatory frameworks, including the Disability Standards for Accessible Public Transport, the Access to Premises Standards and the National Construction Code. The AAA supports efforts to modernise and harmonise these standards to ensure clarity and consistency.

The AAA also acknowledges the Department of Infrastructure, Transport, Regional Development, Communications, Sports and the Arts’ (DITRDCSA) work on developing aviation-specific Transport Disability Standards. These standards will be critical in defining practical obligations for airports and aviation operators under the DDA. It is essential that reforms to the Act are aligned with the development of these standards to ensure clarity and consistency across the system.

Reform should focus on practical compliance pathways that are achievable for all airports, including those with legacy infrastructure. Harmonising accessibility, safety and security requirements will help avoid duplication and confusion, enabling more efficient delivery of accessibility improvements.

Implementation and guidance

To support meaningful reform, the Government should provide clear guidance materials and practical tools to assist organisations in understanding and meeting their obligations under the Act.

Airports play a vital role in connecting Australians to each other and to the world. Ensuring that air travel is inclusive and accessible benefits everyone. The AAA looks forward to continuing to work with the Government, the Australian Human Rights Commission and disability advocates to strengthen the Act and to support a fair and practical approach to accessibility across the aviation network. For further information or to discuss this submission please contact redacted: s22, Senior Manager Policy and redacted: s22

Kind regards

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Chief Executive Officer
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www.airports.asn.au | ABN 89 008 647 336