NDIA Accountability Project

Recommendations for ICT Accessibility in the Disability Discrimination Act

‹ PrevPage 1 of 7 · Source p. 1Next ›

Centre for Accessibility Australia
ABN: 62 641 669 543

Submission to the Disability Discrimination Act

August 2025

Acknowledgement

We at Centre for Accessibility Australia (CFA Australia) welcome the opportunity to contribute to the review of the Disability Discrimination Act (DDA) and appreciate the efforts to ensure that the legislation remains relevant and effective in promoting the rights of people with disability.

About Centre for Accessibility Australia

CFA Australia is an award-winning disability-led not-for-profit organisation that works to promote digital access.

The digital world is an amazing resource that all of us increasingly rely on; however, the reality for people living with disability is that much of the Internet remains inaccessible. CFA Australia coordinates a few projects designed to reduce the accessibility gap and empower organisations to effectively implement accessibility.

  1. We provide training for organisations and individuals looking to implement accessibility.
  2. We provide website auditing services for organisations looking to access and improve their accessibility.
  3. We develop free, highly accessible online resources for content creators and organisations to promote and respond to digital access.
  4. We create free online resources for people with disabilities on how to use Assistive Technology. These resources will include how-to guides for Assistive Technologies (AT), product advice about AT, and a free helpdesk that provides information and assistance about AT for people with disabilities.
  5. We advocate and promote the accessibility movement via our accessibility campaign. The purpose of the campaign is to empower and encourage digital content developers to implement accessibility when designing online resources.
  6. We celebrate Accessibility success stories through the biennial Accessibility Awards.

Digital Accessibility as a Human Right

Digital accessibility is a fundamental human right, essential for equal participation in today’s digital society. Inaccessible digital environments can lead to social isolation, exclusion, and marginalisation.

Prevalence of Disability in Australia

According to the Australian Bureau of Statistics (ABS), in 2022, 5.5 million Australians (approximately 21.4% of the population) had a disability, up from 17.7% in 2018. This represents an increase in the already significant portion of the population, highlighting the importance of inclusivity and accessibility in all aspects of life. Additionally, over half (54.2% or 3.0 million people in Australia) used aids or equipment because of their condition.

The Need for ICT Accessibility in the DDA

The current DDA does not reference ICT accessibility, which we believe to be a significant oversight given the increasingly important role digital technologies play in modern life. This lack of accessibility has real-world implications, including inaccessible government services, limited access to education, and difficulty accessing employment opportunities. The WebAIM Million 2025 report found that: 94.8% of home pages had detected accessibility failures, indicating a very small percentage of websites meet international standards.

International Standards and Guidance

The Australian Human Rights Commission (AHRC) recommends conforming to the Web Content Accessibility Guidelines (WCAG) 2.2 at the AA level, which provides a clear and widely accepted framework for ensuring digital accessibility.

WCAG is a set of guidelines developed by the World Wide Web Consortium (W3C) that outlines how to make web content more accessible to people with disability. WCAG 2.2, the latest version of these guidelines, builds upon previous versions and provides additional guidance on making web content more accessible. It covers a range of aspects, including visual, auditory, motor, and cognitive accessibility, and includes new success criteria that address issues such as focus appearance, focus not obscured, dragging movements, target size, and consistent help. By conforming to WCAG 2.2, organisations can ensure that their digital content is more accessible and usable for people with disability, particularly in areas such as visual, cognitive, and motor accessibility.

However, while we acknowledge the AHRC guidance is helpful, our observations suggest that organisations often do not see it as mandatory because it is policy guidance and not a legislative requirement. Our research in various sectors, including telco and higher education (found in our Research section), has demonstrated that while there is a willingness to improve accessibility, the lack of a clear legislative requirement means accessibility issues remain.

Given this context, we strongly recommend that the DDA be updated to integrate ICT accessibility requirements compliant with the WCAG 2.2 AA standard.

Recommendations for the DDA

Captioning Requirements

We recommend that the DDA include specific requirements for captioning in digital contexts to ensure equal access to information for people who are Deaf or hard of hearing. Captioning provides a visual representation of audio content, allowing individuals to follow and understand multimedia content more easily.

Auslan Sign Language Requirements

We also recommend that the DDA include specific requirements for Auslan sign language in digital contexts to ensure equal access to information for people who are deaf or hard of hearing. Auslan is the native sign language of Australia, and providing Auslan interpretation can help to promote greater understanding and inclusion.

ICT Accessibility Procurement Requirements - AS EN 301 549

We support the inclusion of ICT accessibility procurement requirements in the DDA, specifically referencing the European Standard EN 301 549, which has been adopted in Australia as AS EN 301 549. This standard provides a comprehensive framework for ensuring that ICT products and services are accessible to people with disability, including in the workplace, where accessible technology can support employees with disability and promote equal opportunities for career advancement.

By adopting AS EN 301 549, organisations can ensure that their ICT systems and services are designed and procured with accessibility in mind, benefiting not only employees but also customers and citizens who interact with these systems.

Plain Language Requirements - ISO 24495

We also support the inclusion of plain language requirements in the DDA, specifically referencing the ISO 24495 standard. This standard provides guidelines for creating clear and concise language that is easy to understand, which can help to promote greater accessibility and inclusion for people with cognitive or intellectual disabilities

Implementation and Enforcement

To ensure effective implementation and enforcement of the updated DDA, we recommend establishing a clear compliance framework, providing education and training for organisations, implementing a monitoring and reporting system, establishing a complaints mechanism, and providing incentives for organisations demonstrating a commitment to ICT accessibility.

Future Directions and Emerging Technologies

CFA Australia is a member of the W3C and actively contributes to the development of international guidance on accessibility, including emerging areas such as the accessibility of machine learning and generative AI. While these technologies are still evolving and may not be directly applicable to the DDA, we would welcome the opportunity to provide support and expertise to government and legislative initiatives in this space. As these technologies continue to shape the digital landscape, ensuring their accessibility will be crucial for promoting equal access and opportunities for people with disability.

Summary and Call to Action

In conclusion, integrating ICT accessibility into the DDA is essential for promoting the rights and independence of people with disability. By referencing internationally recognised standards and including specific requirements, the DDA can provide clear guidance and ensure digital information is accessible to all.