COTA AUSTRALIA
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ABN 35 118 911 541
14 November 2025
Disability Discrimination Act Review
I am writing to you to respond to the Disability Discrimination Act Review.
COTA Australia is the leading national peak body representing older Australians over 50. For over 65 years our systemic advocacy has been improving the diverse lives of older people in policy areas such as health, retirement incomes, and more. Our broad agenda is focussed on tackling ageism, respecting diversity, and the empowerment of older people to live life to the full.
COTA Australia supports the submission recommendation made to this review made by the Elder Abuse Action Australia (EAAA) which are:
- Fulfillment of Australia’s obligations under the United Nations Convention on the Rights of Persons with Disabilities (CRPD) should be added as an object of the Act, embedding the right to supported decision-making tools. [Consultation Questions 10, 11]
- The Act must embed a focus on intersectionality, with an explicit focus on those cohorts most likely to live with disability including older people and Aboriginal and Torres Strait Islander people. [Consultation Questions 3, 4]
- That the language in the Act be altered to address the inherent ableism in the current deficit-based definitions and language. [Consultation Questions 1, 2]
- That the comparator test be replaced with a detriment test, reducing the burden on applicants. [Consultation Questions 5, 6]
- The addition of vilification and harassment protections within the Act in a similar format to those found in the Racial Discrimination Act. [Consultation Questions 27, 28, 29]
Further to this, reform to the Act should also consider ways to:
- Make the definition of disability more understandable and inclusive to be less deficit-based and medical and more reflective of a social model of disability.
- Improve education and awareness to drive cultural changes that include people with disabilities in employment, education, and other areas of public life.
- Ensure sufficient enforcement to address discrimination to address offensive behaviour, harassment, and discrimination.
- Provide harmonisation and consistency with relevant state legislation.
- Strengthening the complaints process under the DDA and ensuring links with the Age Discrimination Act to protect the rights of older people with disabilities
- Reinforce the role of Disability Action Plans ensuring the development of integrated plans that address issues of age discrimination.
COTA AUSTRALIA
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ABN 35 118 911 541
We would welcome any further discussion with you about these matters. Please contact redacted Senior Policy Officer on redacted if you have any questions.
Your Sincerely
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Chief Executive Officer