QCOSS
14 November 2025
Attorney-General’s Department
3-5 National Circuit
Barton ACT 2600
Lodged via web platform
Dear Colleagues,
Disability Discrimination Act Review (‘the Review’)
Thank you for the opportunity to provide feedback in relation to the above.
About QCOSS
Queensland Council of Social Service (QCOSS) is Queensland’s peak body for the social service sector. Our vision is to achieve equality, opportunity, and wellbeing for all Queenslanders.
QCOSS’ position
QCOSS welcomes the Australian Government’s review of the Disability Discrimination Act 1992 (Cth) (‘the Act’). The Review provides an important opportunity to modernise the Act in line with Australia’s international obligations, recommendations from previous reviews such as the Disability Royal Commission into Violence, Abuse, Neglect, and Exploitation of People with Disability (‘the Disability Royal Commission’), and in line with community expectations.
This submission does not provide a detailed commentary in relation to the more technical aspects of the issues and questions raised by the Review. QCOSS does, however, support the fundamental need to enhance and strengthen the Act.
We have engaged in targeted consultation to inform our understanding of the issues raised by the Review. We particularly note and appreciate the feedback we received from the Queensland Independent Disability Advocacy Network, Aged and Disability Advocacy Australia, Queenslanders with Disability Network, and the Queensland Alliance for Mental Health.
We encourage detailed engagement with their submissions to the Review, along with submissions from other disability service providers, advocates, and people with disability. This submission is also informed by prior engagement with Queensland community service organisations in connection with law reform proposals relating to the Anti-Discrimination Act 1991 (Qld).
An opportunity to modernise and strengthen the Act
We note the Review incorporates recommendations from the Disability Royal Commission and is an important opportunity to modernise and strengthen the Act. A number of the proposed reforms would assist with implementation of Australia’s international obligations, including as a signatory to the United Nations Convention on the Rights of Persons with Disabilities. The Review also presents a vital opportunity to ensure the Act meets community expectations. QCOSS supports changes that will enhance the protection, respect and fulfilment of the human rights, participation and inclusion of people with disabilities.
Additionally, improvements to the Act will send a strong signal on the standards and expectations for equality laws across Australia. For example, comprehensive recommendations for reform to redacted
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Queensland’s equality laws have also been made by the Queensland Human Rights Commission,1 and remain under consideration for implementation.
QCOSS particularly supports recommendations to modernise the Act through changes that introduce an enforceable positive duty to eliminate disability discrimination; simplify the legal tests for discrimination; allow claims to be made for multiple or combined attributes; modernise definitions and terminology; better address different forms of exclusionary school discipline; as well as provide the Australian Human Rights Commission with improved regulatory powers.
The importance of implementation activities to achieve impact
Community sector feedback underscored the importance of comprehensive implementation activities to give effect to these important potential changes. Currently, the complexity and accessibility of laws and limited access to assistance creates barriers. These issues are compounded by processes that can be intimidating, re-traumatising, time consuming, costly, difficult to navigate, as well as emotionally and mentally draining.
We emphasise the need for investment in services that support people with disability to navigate protections and processes available to them under the Act, comprehensive community education on the changes, and further resourcing to support the AHRC to undertake enforcement activities and to assist with implementation activities such as community education and awareness raising.
Robust monitoring and evaluation will also be critical. QCOSS would welcome further information about how the changes will be monitored and evaluated, and how people with disability and community services can best engage with these evaluation mechanisms.
We also encourage the government to implement other important complementary recommendations, including the remaining recommendations from the Disability Royal Commission. Additionally, we recommend the Government take steps to legislate for a federal Human Rights Act, in line with recommendations from the Australian Human Rights Commission,2 and the Parliamentary Joint Committee on Human Rights in their Inquiry into Australia’s Human Rights Framework.3 A federal Human Rights Act would further shape and guide human rights respecting decision making, law and policy at the national level. A federal Human Rights Act would also bolster and improve the interpretation and operation of federal legislative frameworks.
Conclusion
QCOSS commends the Australian Government’s commitment to review, modernise, and strengthen the Act. Along with reforms to the Act, we emphasise the importance of comprehensive and well-resourced implementation activities and initiatives to give effect to these important potential changes. We also encourage ongoing engagement with people with disability and with community services and advocates that have specialist expertise in disability settings as this work progresses.
Thank you again for the opportunity to provide our submission.
Yours sincerely
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Aimee McVeigh
Chief Executive Officer
1 Queensland Human Rights Commission. (2022). Building Belonging, Review of Queensland’s Anti-Discrimination Act 1991. https://www.qhrc.qld.gov.au/about-us/reviews/ada 2 Australian Human Rights Commission. (2023). Revitalising Australia’s Commitment to Human Rights: Free & Equal Final Report 2023. https://humanrights.gov.au/Revitalising-Australia%E2%80%99s-commitment-to-human-rights 3 Parliamentary Joint Committee on Human Rights. (2024). Inquiry into Australia’s Human Rights Framework Report. https://www.aph.gov.au/Parliamentary Business/Committees/Joint/Human Rights/HumanRightsFramework/Report
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