Disability Aviation Standards Review Consultation
OCTOBER 2
Hardwick House Unit 1, 6 Phipps Close
Deakin, ACT 2600
neda.org.au
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Acknowledgement of Country
NEDA acknowledges the Traditional Owners and Custodians of the lands across Australia. We pay our respects to Elders past, present and emerging, and acknowledge their long history of advocacy and self-determination. These efforts continue to inspire and guide our work for equity and justice.
About NEDA
The National Ethnic Disability Alliance (NEDA) is Australia’s national peak body representing people with disability from culturally and linguistically diverse (CALD) backgrounds, their families, and carers. NEDA holds Disability Representative Organisation (DRO) status and United Nations Economic and Social Council (ECOSOC) consultative status. We are governed by a Board with a majority of people with disability from migrant or refugee backgrounds and have member organisations in every state and territory. NEDA advocates federally for the human rights, inclusion and equitable access of CALD people with disability across all aspects of Australian life
Context
It is important to note that people with disability from CALD backgrounds are not a homogenous group. They include people with varied cultural identities, migration pathways, languages, and family and community structures. Various factors shape how individuals seek, access or are referred to supports, and the unique barriers they face in doing so.
Research shows that the intersectional barriers experienced do not arise simply from cultural or linguistic difference alone, but from how systems are shaped by structural barriers, complex migration pathways, and Australian institutional norms that define who is regarded as “normal”, “legitimate” or even “eligible to be included.”
From this perspective, the challenges faced by people with disability from CALD backgrounds within social services, systems are complex and intersectional.
Introduction
The National Ethnic Disability Alliance (NEDA) welcomes the opportunity to provide feedback on the proposed Aviation Disability Standards. NEDA strongly supports the development of a regulatory framework for accessible aviation and, overall, the people with disability consulted by NEDA supported regulatory intervention across the areas addressed in the consultation paper.
People consulted by NEDA felt strongly about the barriers identified throughout the consultation paper and their impact on the safety, dignity, independence and confidence of people with disability when travelling by air. Their experiences also strongly reflected the findings and recommendations arising from the Government’s earlier co-design and advisory processes. Participants were, in some instances, pleasantly surprised by the strength and scope of the proposed regulatory options, particularly where these directly addressed longstanding frustrations and placed clearer obligations on airports and airlines. In other areas, participants considered the proposed standards a positive starting point but felt they did not go far enough. (DITRDCSA 2026)
Across NEDA’s consultations, several consistent themes emerged. People with disability want clarity, consistency and certainty about what they can expect when travelling. They should not be required to repeatedly explain their disability, equipment and support needs at different stages of the same journey, nor should their safety and access depend on the knowledge, assumptions or discretion of individual staff. The people NEDA consulted particularly emphasised the importance of well-trained and competent staff; consistent processes across airports, airlines and contractors; continuity of accessibility information throughout the passenger journey; and maintaining the autonomy and dignity of people with disability.
NEDA also considers that the effectiveness of the proposed Standards will ultimately depend on accountability and enforcement. Participants expressed concern that separating reporting, compliance and other accountability mechanisms from some of the substantive accessibility requirements could weaken the practical effect of the reforms. There was a strong view that regulation must mean more than establishing expectations or requiring organisations to report on their performance. The final framework should make clear who is responsible for compliance, how compliance will be monitored, what happens when obligations are not met, and what remedies are available to people with disability when standards are breached. Without meaningful oversight and consequences
for non-compliance, there is a risk that new regulatory requirements will not result in the consistent change in passenger experience that people with disability expect.
This submission follows the structure of the consultation paper, responding under Chapters 1 to 5 and the relevant numbered subsections within each chapter. Rather than responding separately to each consultation question, NEDA has provided a consolidated response under each relevant subsection, focusing on those issues where NEDA and the people with disability we consulted have particular experience, concerns or recommendations. Accordingly, not every individual consultation question is addressed separately.
Across the submission, NEDA’s comments should therefore be read as broad support for the regulatory direction of the proposed Aviation Disability Standards, together with targeted recommendations where we consider the proposed requirements would benefit from strengthening, clarification or additional safeguards.
Chapter 1 – Whole of Journey
1.1 Set out the roles and responsibilities of airports and airlines
NEDA supports a regulated model with shared responsibility between airports and airlines (Option 1). This was also the preferred approach of all people with lived experience of disability, with recent experiences of flying within Australia who were consulted by NEDA on this issue. While a shared responsibility model carries some risk of gaps arising through poor communication, or of airports and airlines seeking to shift responsibility to one another, Options 2 and 3 risk creating more significant gaps by allocating responsibility primarily to either the airport or airline. The passenger journey frequently crosses areas of responsibility and may involve multiple airlines, airport facilities and services. A shared model therefore provides greater capacity to ensure that assistance continues across these transition points. (DITRDCSA 2026, p23)
For shared responsibility to work effectively, however, there must be sufficient clarity about who is responsible for what, together with clear expectations where responsibilities overlap. Where responsibility is shared or cannot be neatly delineated, the obligation should be on both the relevant airport and airline to coordinate and ensure the passenger receives the assistance they require, rather than allowing uncertainty about responsibility to result in a gap in support. Implementation may require changes to existing policies,
procedures and communication between airports, airlines and other relevant personnel. Consistency will also be important, particularly in areas of the passenger journey involving multiple parties, or 3rd party contractors such as security screening, food court vendors or airport shopping.
NEDA supports assistance being available from airport entry points, including public transport connections, car parks and kerbside drop-off areas, through to check-in. While there may be practical challenges in providing this assistance across all airport entry points, this should not prevent it from forming part of the accessibility standard. Possible approaches could include designated accessible drop-off and assistance points, improved accessible kerbside infrastructure, and concierge-style assistance that passengers can request or book. Some of those consulted by NEDA identified the assistance available through Travellers Aid Australia at Melbourne Airport as one example of a model that could inform approaches at other airports.
Passengers with disability travelling independently should also be able to access reasonable assistance to use food and retail facilities where accessibility barriers prevent them from doing so independently, for example where counters are too high or aisles are too narrow. Similarly, where a passenger is entitled to access an airline lounge, assistance should extend to reaching the lounge and subsequently leaving it in sufficient time to reach the departure gate, with appropriate handover between those responsible for providing assistance. Where a passenger is travelling with a support person who is already providing this assistance, additional assistance may not be required.
For passengers transferring between connecting flights or terminals, NEDA considers the airport best placed to coordinate assistance, as the airport has responsibility for and knowledge of the physical environment through which the passenger must navigate. This is particularly important where connecting flights are operated by different airlines, as airline-led coordination could create gaps where responsibility transfers from one carrier to another. Airport coordination should nevertheless include effective handover and communication with the relevant airlines. Again, the ability to arrange assistance through Travellers Aid at Melbourne Airport was highlighted as an example of an approach that could assist passengers to navigate these transitions.
1.2 Make sure staff are trained to support people with disability
NEDA supports a regulatory approach to disability training for airport and airline staff, including contractors, and broadly supports the proposed training requirements. Consistent and appropriate training should not be dependent on the individual policies or priorities of particular airports, airlines or contractors, particularly where staff are undertaking tasks that directly affect the safety, dignity and independence of passengers with disability. (DITRDCSA 2026, p26)
NEDA also sees merit in the industry proposal for nationally consistent training modules developed and maintained by government. This could provide greater consistency in the content, quality and currency of training across the aviation sector, while reducing duplication associated with individual airports and airlines developing their own programs. It may also reduce the implementation burden for smaller airports and airlines, for whom the cost of developing or significantly modifying training programs may present a greater barrier. If a nationally developed training program is not adopted, NEDA would support the proposed alternative of maintaining a national list of training programs that meet the required standards, providing greater assurance of quality and consistency while allowing organisations some flexibility in how training is delivered. (DITRDCSA 2026, pp25-26)
NEDA supports competency assessments for staff undertaking practical activities where inadequate training could compromise the safety or dignity of a passenger with disability. In addition to transferring passengers from their mobility devices or seats, this should include staff who operate boarding or transfer devices, assist passengers to transfer into airport- or airline-provided wheelchairs, or otherwise physically assist a passenger during a transfer. These practical competencies should be assessed through in-person training and demonstration rather than through theoretical or online training alone. Staff undertaking security screening should similarly receive practical training and competency assessment in supporting and screening people with disability, noting that security screening is addressed in greater detail elsewhere in the proposed standards.
1.3 Set up disability reference groups
NEDA supports a regulatory requirement for disability reference groups and broadly considers the proposed standard appropriate. Disability reference groups provide an important mechanism for ensuring that the lived experiences and perspectives of people
with disability inform the way accessibility requirements are implemented in practice. (DITRDCSA 2026, p28)
NEDA considers the proposed threshold of 150,000 passenger movements per year to be reasonable. This would ensure that the requirement applies not only to major airports, but also to a reasonable number of smaller and regional airports, while recognising that establishing and maintaining an individual reference group may not be proportionate or practical for airports with very low passenger numbers. (DITRDCSA 2026, p28)
The Terms of Reference for disability reference groups should clearly establish the purpose, scope and role of the group, including how its advice will inform organisational policies, practices and accessibility initiatives. They should also address membership and recruitment, meeting arrangements, remuneration, conflicts of interest, confidentiality where appropriate, and mechanisms for responding to advice and closing the feedback loop on actions or changes arising from that advice. Membership should reflect a diversity of disabilities, experiences and backgrounds, rather than expecting a small number of people with disability to represent the breadth of the disability community. Recruitment and participation processes should be accessible, with reasonable adjustments provided as required.
NEDA considers that shared disability reference groups could be appropriate in some circumstances. For example, airports within the same ownership or consortium could establish a shared group, particularly where airports are smaller or service regional, rural or remote communities with relatively low passenger numbers. Smaller independent airports operating in similar circumstances could also potentially collaborate to establish a reference group where maintaining individual groups would not be practical. However, shared arrangements should not become a mechanism for larger airports that would otherwise meet the threshold to avoid meaningful engagement with their own passengers and communities.
Similarly, it would generally be reasonable for an airline to maintain a single disability reference group across its operations rather than separate groups for different locations. However, large airport groups and airlines with significant passenger numbers should be encouraged to supplement their primary disability reference group with targeted engagement where particular perspectives or experiences require greater consideration. This could include engagement with people with disability from culturally and linguistically diverse (CALD) backgrounds, First Nations people with disability, rural and regional passengers or other cohorts whose experiences may not be adequately represented within
the primary reference group. This could occur through smaller advisory groups, targeted consultations or other appropriate mechanisms.
1.4 Report on how standards are being met
NEDA supports a regulatory approach to reporting on compliance with the aviation disability standards. The existing voluntary approach has not resulted in operators and providers publishing compliance data, demonstrating the need for mandatory reporting requirements if reporting is to provide meaningful transparency and accountability. (DITRDCSA 2026, p30)
NEDA considers the proposed threshold of 150,000 passenger movements per year reasonable for broader reporting against the aviation disability standards, consistent with the threshold proposed for disability reference groups. NEDA also supports annual reporting to government, with government responsible for collating and publishing the data in accessible formats. Centralised publication would enable consumers, people with disability and their representative organisations to more readily understand and compare performance across the aviation sector. Individual airlines and airports should remain able to publish their own compliance information in addition to this reporting, but this should not replace the requirement to provide consistent data to government. (DITRDCSA 2026, pp30-31)
The proposed reporting areas are broadly appropriate. (DITRDCSA 2026, p31) However, NEDA recommends that reporting also include the maintenance and operational availability of accessibility equipment owned or operated by airports and airlines, including equipment such as hoists, lifts and boarding or transfer devices. This should include instances where a passenger was refused carriage, was unable to travel as planned, or otherwise experienced a disruption to their journey because necessary accessibility equipment was unavailable, unserviceable or had not been appropriately maintained. Reporting this information would help identify where failures experienced by passengers are the result of recurring or systemic equipment and maintenance issues, rather than isolated incidents.
Importantly, people with disability consulted by NEDA consistently raised the question of what occurs when an airport or airline fails to meet its reporting obligations. Mandatory reporting requirements should therefore be accompanied by clear accountability and enforcement mechanisms for failure to report, incomplete or inaccurate reporting, or persistent non-compliance with reporting requirements. Without appropriate consequences for non-compliance, mandatory reporting risks providing transparency in principle without sufficient accountability in practice.
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Chapter 2. Planning and booking air travel
2.1 Offer passenger assistance profiles
NEDA supports a regulatory requirement for passenger assistance profiles, which have the potential to significantly reduce the burden on people with disability of repeatedly providing the same accessibility information each time they travel. (DITRDCSA 2026, p35) People with disability consulted by NEDA were generally supportive of the proposal, although a consistent concern was whether information contained within a profile would reliably reach relevant staff and be used in practice. The effectiveness of passenger assistance profiles will therefore depend not simply on the availability of a profile, but on ensuring that relevant information is accessible to, and acted upon by, those responsible for providing assistance throughout the passenger’s journey.
However, NEDA considers that passenger assistance profiles should operate through a single, centralised platform, rather than requiring individual airlines to establish and maintain separate profiles. Requiring passengers who use multiple airlines to create and maintain a profile with each carrier would perpetuate some of the duplication and administrative burden that the introduction of passenger assistance profiles is intended to address. It would also create additional points at which information may fail to transfer where a journey involves multiple airlines or airports. A centralised, passenger-controlled profile could instead provide a single source of relevant accessibility information, with the passenger able to authorise access by the airlines and airports involved in their journey. For example, a unique profile identifier could potentially be provided at the time of booking, enabling relevant organisations to access the information required to facilitate that passenger’s travel. NEDA recommends that government explore the appropriate mechanism and platform through which such a centralised system could operate. Some consulted indicated that they felt that MyGov may be able to host such a profile.
Passenger assistance profiles should focus on what the passenger needs to travel safely, accessibly and with dignity, rather than simply recording diagnoses, disability types or lists of equipment. Passengers should be able to describe the assistance they require, how that assistance should be provided, relevant communication requirements, and any other information necessary to support their journey. This should complement information about matters such as seating requirements, disability aids, assistance animals, medical equipment and relevant approvals or certifications.
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Privacy, information security and passenger control must be fundamental to the design of any centralised system. Passenger assistance profiles may contain sensitive personal, disability and health information. Passengers should be able to control and understand what information is held, update it when their circumstances or support requirements change, and request its deletion. Access to the information should be limited to organisations and personnel who require it for the purposes of facilitating the passenger’s travel.
Consideration should also be given to how the currency of information contained within a passenger assistance profile is managed. The profile itself should remain available for as long as the passenger wishes to use it, while information or documentation within it should be updated as required. For example, a passenger travelling with a lithium battery-powered wheelchair and an assistance animal could upload current specifications, approvals or certifications once and rely upon this information for subsequent bookings while it remains current, rather than repeatedly providing the same documentation for every flight. Passengers should be responsible for updating their profile where their circumstances, equipment or assistance requirements change. A periodic prompt, such as annually, could also invite passengers to review their profile and confirm that the information remains current, while particular documents or approvals could be flagged for review according to their relevant expiry or validity periods.
2.2 Clarify times where limits on passengers requiring assistance may apply
NEDA supports a regulatory approach and broadly supports the proposed standard. (DITRDCSA 2026, p36) Limits on the number of passengers requiring assistance should only be permitted where there is a genuine and demonstrable safety reason for doing so. NEDA recognises that airlines have obligations relating to passenger safety and emergency evacuation, and that in some circumstances these may place legitimate constraints on the number or nature of passengers requiring particular forms of assistance who can safely be accommodated on a flight.
However, financial considerations or operational preferences, including airline turnaround-time targets, should not provide a basis for limiting the number of passengers with disability who can travel on a particular flight. While assisting passengers to board or disembark may affect turnaround times, (DITRDCSA 2026, p36) this is an operational matter for airlines to manage in providing an accessible service. People with disability should not
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experience reduced access to air travel because an airline’s operating model relies upon particular turnaround times.
NEDA supports requiring airlines to publish the safety grounds on which any limits on passengers requiring assistance are based, providing greater transparency and assurance that restrictions are not arbitrary or being applied for operational or financial reasons. Airlines should also be required to report instances in which a passenger is refused carriage, moved to another flight or otherwise prevented from travelling as booked because a limit on passengers requiring assistance has been applied. This reporting should include the basis upon which the restriction was applied, to enable monitoring of how frequently these limits are used and whether they are being applied consistently with the Standards.
2.3 Services must be provided when passengers give advance notice of accessibility needs prior to travel
NEDA supports a regulatory approach and broadly supports the proposed requirement. Neither people with disability consulted by NEDA nor the industry feedback presented in the consultation paper suggest that 48 hours’ advance notice is generally unreasonable. (DITRDCSA 2026, p38) Indeed, some participants consulted by NEDA were surprised that the proposed notice period was only 48 hours, having expected that considerably longer notice might be required. Importantly, providing the required notice should give passengers certainty that the accessibility services they have requested will be available, rather than simply increasing the likelihood that assistance can be provided.
Where a passenger has a passenger assistance profile, as discussed in section 2.1, linking that profile to a booking should constitute formal notification of the accessibility needs identified within the profile. Passengers should not be required to separately notify the airline of information they have already provided through an approved passenger assistance profile. Where additional or different assistance is required for a particular journey, the passenger would be responsible for providing notice of those additional requirements.
NEDA recognises that there may be limited circumstances in which particular assistance requires more than 48 hours to arrange. This may be relevant, for example, where a passenger requires specific equipment to board or disembark at a small regional or rural airport , where that equipment may not be permanently located and needs to be brought in from elsewhere. Any requirement for more than 48 hours’ notice should be based on a
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genuine practical necessity associated with providing the particular assistance, rather than operating as a general extended notice requirement. Where longer notice is required, the timeframe and reason for that requirement should be clearly communicated to passengers before booking wherever possible.
The Standards should also provide sufficient clarity about what constitutes “every reasonable effort” where less than 48 hours’ notice is provided. A passenger consulted by NEDA specifically raised concern about how “reasonable” would be interpreted in practice. While airlines and airports cannot be expected to guarantee every request made with insufficient notice, the requirement should create a genuine obligation to explore available options to accommodate the passenger, rather than allowing the absence of 48 hours’ notice to operate as an automatic basis for refusing assistance.
2.4 Make sure people with disability access the same fare regardless of the method of booking
NEDA supports a regulatory approach and supports the principle that people with disability should have access to the same fares, including promotional fares, regardless of the booking method they are able to use. Where a person cannot use an airline’s standard booking method because it is inaccessible, they should not incur additional booking fees or lose access to a fare that would otherwise have been available to them. (DITRDCSA 2026, p40)
NEDA also supports measures to ensure that passengers who require additional time are not disadvantaged when booking online. (DITRDCSA 2026, p40) However, a single prescribed extension period may not meet the needs of all passengers, and merely extending an existing time limit may not adequately address the accessibility barrier. Where possible, airlines should enable the booking timeout to be suspended or provide passengers with an option to extend their session while they remain actively engaged in the booking process. For example, a prompt could ask the passenger whether they are still completing their booking and require additional time, allowing the session to continue where needed. An appropriate maximum period could apply to prevent booking inventory being held indefinitely, but this should provide sufficient flexibility to accommodate people who require substantially more time to complete a booking.
Where the passenger assistance profile proposed under section 2.1 is linked to a booking, this could also be used to automatically apply accessible booking settings, including suspending or extending relevant time limits. This would reduce the need for passengers to repeatedly identify or explain their accessibility requirements when making each booking.
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Importantly, any time limit associated with holding a fare should apply only to those elements genuinely necessary to secure the booking and complete payment. Passengers should not lose a selected fare because they are required to spend additional time entering accessibility information, providing details of disability aids or completing other disability-related processes. Where this information cannot be automatically drawn from a passenger assistance profile, passengers should be able to complete or update it separately without affecting the fare already purchased.
2.5 Clarify rules for carriage of assistance animals on aircraft
NEDA supports a regulatory approach to the carriage of assistance animals, with consistent requirements applying across airlines. (DITRDCSA 2026, p41) The current variation in airline policies and approval processes creates unnecessary uncertainty for people who travel with assistance animals, including where an animal may meet the definition of an assistance animal under the Disability Discrimination Act 1992 but does not hold accreditation recognised by a particular airline. A nationally consistent approach should provide passengers with greater certainty about the evidence required, the approval process, and the circumstances in which carriage may be refused.
NEDA supports the introduction of a single, nationally consistent application and evidence process, rather than individual airlines imposing different forms and evidentiary requirements. Where the passenger assistance profile proposed in section 2.1 is implemented, information and supporting documentation relating to an assistance animal should form part of that profile and be available for use across airlines. Approval should apply to multiple journeys for as long as the relevant information and supporting documentation remains current, rather than requiring passengers to seek approval each time they travel. Passengers would remain responsible for updating relevant information where circumstances, documentation or the status of the assistance animal change.
Importantly, any nationally consistent process should recognise that, consistent with the DDA, formal accreditation is not the only means by which an animal may qualify as an assistance animal. The process should therefore provide multiple, clearly defined evidentiary pathways. This should include recognition of relevant state or territory accreditation where available, together with accessible alternatives for people whose assistance animals are not formally accredited. Alternative evidence could include, as appropriate to the requirement being demonstrated, statutory declarations or supporting documentation from relevant health professionals, veterinary evidence, evidence of training or assessment, or other appropriate documentation. The evidentiary burden
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should be proportionate and should not require passengers to provide multiple forms of evidence where one is sufficient to establish the relevant requirement.
NEDA considers 48 hours to be a reasonable timeframe for determining an application where all required information has been provided. (DITRDCSA 2026, p42) Where further information is genuinely required, this should be communicated promptly to the passenger. Where carriage is refused, the passenger should receive clear written reasons identifying the basis for the decision. Refusal should be based on applicable regulatory requirements, including legitimate safety or biosecurity considerations, rather than additional airline-specific eligibility requirements.
Any nationally consistent application form should itself be accessible, straightforward and consistent across the aviation sector. International approaches, including the United States model identified in the consultation paper (DITRDCSA 2026, p42), may provide a useful starting point, but should not simply be replicated where aspects of their design or content are inaccessible. Development of the Australian process should involve people with disability who use assistance animals, with the aim of collecting the information genuinely required while minimising unnecessary or repetitive administrative burden.
The Standards should also provide clarity about responsibility where an assistance animal is injured or becomes unwell during the aviation journey, particularly where an incident occurs while the passenger or animal is under the care or direction of an airline, airport or contractor. This should include clarity about responsibility for facilitating access to veterinary assistance and liability for reasonable veterinary costs where injury results from an act or omission of an aviation operator or its personnel.
2.6 Explain how passengers can get approval for equipment classed as dangerous goods
NEDA supports a regulatory approach and broadly supports the proposed standard. A nationally consistent process for providing information about battery-powered mobility aids would benefit both passengers and airlines. A key difficulty identified through consultation is that passengers and their supporters do not always know what technical information airlines require, or the form in which it must be provided, resulting in incomplete applications and delays. (DITRDCSA 2026, p44) The required information should therefore be clearly explained, consistent across airlines, and collected through a simple and accessible process.
Information about a passenger’s mobility aid, including relevant battery specifications and dangerous goods approvals, should be able to be stored within the passenger assistance
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profile proposed in section 2.1 and reused while that information remains current. Passengers should not be required to repeatedly submit the same technical information or obtain a new approval for individual flights or different sectors of the same journey where the mobility aid and relevant specifications have not changed.
NEDA supports a 48-hour timeframe for decisions where the required information has been provided. (DITRDCSA 2026, p44) However, NEDA has some concerns about the proposal that no response within 48 hours should automatically constitute a refusal. A failure by an airline to assess an application within the required timeframe should not disadvantage the passenger or result in the loss of their travel arrangements. There is also potential for confusion where an application is incomplete and the passenger is unaware that further technical information is required. The Standards should clearly distinguish between an incomplete application, a request for further information, a refusal on safety grounds, and a failure by an airline to make a decision within the required timeframe. Airlines should remain accountable for meeting the prescribed decision timeframe.
NEDA also recommends that approval be digitally linked to the passenger’s booking and readily visible to relevant operational staff throughout the journey. Once the required dangerous goods assessment has been completed and the mobility aid approved by appropriately authorised personnel, frontline staff should be able to readily verify that approval, for example through the passenger’s booking record or boarding pass. An existing approval should not be informally reconsidered or overridden by individual frontline staff unless new information gives rise to a legitimate safety concern. This would reduce the risk of passengers reaching check-in or the boarding gate only to have an approval that has already been granted questioned or inconsistently interpreted.
Finally, appropriate processes and staff knowledge must distinguish between different battery types and the requirements applicable to them. Consultation participants identified instances in which powered mobility aids may be treated as though they present the same dangerous goods considerations simply because they are powered, despite differences between lithium-ion, non-spillable and spillable batteries. The approval process, information provided to passengers and information available to relevant staff should clearly identify the battery type and the applicable requirements, reducing unnecessary confusion or escalation during travel.
2.7 Ensure disability aids can be transported for free and in-cabin, where possible
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NEDA supports a regulatory approach and broadly supports the proposed standard. (DITRDCSA 2026, p47) Disability aids are necessary equipment rather than optional baggage and should not reduce a passenger’s ordinary baggage allowance or attract additional fees. None of the people with disability consulted by NEDA reported having been charged additional baggage fees for disability aids. However, participants did report inconsistent information and practices regarding whether particular aids could remain with them in the aircraft cabin, including being required to check an item at the gate despite previously being advised that it could travel in the cabin.
Greater clarity and consistency are therefore required regarding which disability aids can be carried and used in the cabin, which can be carried in the cabin but may be subject to specific use or storage requirements at particular stages of flight, and which must be stored in the cargo hold for legitimate safety reasons. This information should cover the diversity of equipment passengers with disability may use, including mobility aids, communication devices, medical and monitoring equipment and electronic disability aids. Clear guidance is particularly important for electronic devices, where uncertainty about aviation safety requirements can result in passengers or staff unnecessarily assuming that an electronic disability aid cannot be carried or used. This may include equipment such as blood glucose monitoring devices and electronic communication aids.
Where an aid can safely remain with the passenger, staff should not unnecessarily separate the passenger from equipment they require for mobility, communication, medical needs or independence. For example, a NEDA employee with lived experience described having their cane taken by cabin crew and stored in an overhead compartment some distance from their seat. While the cane was permitted in the cabin, it was no longer accessible when needed to move safely around the aircraft. The passenger was able to use seat backs for balance and ultimately relied on other passengers to retrieve the cane; otherwise, they would have needed to wait until other passengers had disembarked before being able to move independently. Clear guidance should therefore address not only whether an aid may be carried in the cabin, but whether and when it may be used, how it should be stored, and the importance of keeping it accessible to the passenger wherever safety requirements permit.
Consistent implementation will also require relevant staff to understand the requirements applying to different disability aids. NEDA recommends that the staff training requirements addressed in section 1.2 include recognition and appropriate handling of common disability aids, including the circumstances in which electronic and medical devices can safely be carried or used in the cabin. This would reduce the risk of equipment being
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unnecessarily removed, checked or restricted because individual staff members are uncertain about the applicable requirements.
2.8 Explain requirements for carers or companions travelling with a person with disability
NEDA supports a regulatory approach and supports the establishment of consistent criteria for determining when a person with disability may be required to travel with a carer or support person. (DITRDCSA 2026, p49) The level and nature of support a passenger requires will necessarily be relevant to this determination. However, current requirements are applied inconsistently between airlines and, at times, can depend on the judgement of individual staff during check-in, boarding or transitions through the airport. This creates a risk that decisions are influenced by assumptions about a person’s disability rather than an objective assessment of whether they can meet the requirements for independent travel.
The criteria for requiring a carer should therefore be clearly defined, nationally consistent and limited to functions genuinely necessary for the safe carriage of the passenger and others. Relevant considerations may include the passenger’s ability to understand and appropriately respond to essential safety instructions, and the nature and level of individual support they require during the flight. As noted in industry input to the consultation, cabin crew cannot provide personal care, administer medication or assist with feeding, although they may provide limited assistance such as opening packaged food or describing the placement of items on a meal tray. (DITRDCSA 2026, p48) A requirement for a carer may therefore be appropriate where a passenger requires ongoing individual assistance with activities that fall outside the reasonable role of cabin crew. However, the need for physical assistance in the unlikely event of an emergency evacuation should not, in itself, be sufficient to require a passenger to travel with a carer where they are otherwise able to travel independently. Meeting the established criteria for independent travel should create a clear presumption that the passenger can travel independently, rather than allowing individual staff to impose an additional requirement based on their own assessment or assumptions about the passenger’s disability.
Importantly, a passenger’s ability to travel independently should not first be questioned at check-in or boarding. Where information provided at the time of booking, including through a passenger assistance profile, gives an airline reasonable grounds to seek further information about whether the passenger meets the criteria for independent travel, this should be raised with the passenger as early as possible and with sufficient time for them
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to respond. Where supporting evidence is required, the passenger should have reasonable time to obtain and provide appropriate evidence, which may include information from a health professional, care team or support provider familiar with their functional capacity and support requirements. A passenger should not arrive at the airport expecting to travel independently only to be informed at check-in or the boarding gate that they cannot travel without a support person.
Particular care is required where the concern revolves around the question of whether a passenger can understand and respond appropriately to safety information. NEDA considers that an inability to communicate in the manner expected by individual staff should not automatically be equated with an inability to understand or respond to emergency instructions. This is particularly relevant for the CALD community, especially where there are language, communication, sensory or cultural differences in how a passenger communicates or responds. Silence, limited eye contact or an averted gaze should not in themselves be interpreted as evidence that a passenger has failed to comprehend an instruction. The criteria and assessment process should distinguish between a passenger’s capacity to understand and appropriately respond to essential safety information and the particular manner in which they communicate. Accessible and culturally appropriate communication methods should be used where required before concluding that a passenger cannot travel independently.
Where a passenger chooses or is required to travel with a support person, the passenger assistance profile proposed in section 2.1 should allow information about their carer arrangements to be recorded. Passengers should be able to nominate multiple potential carers or support people and select the person travelling with them for a particular booking, recognising that support arrangements can change, including at short notice. This would complement the proposed requirement for airlines to allow changes to carer details close to departure and reduce the need for passengers to repeatedly provide the same information. (DITRDCSA 2026, p49) NEDA considers that where an airline requires a passenger to travel with a support person as a condition of carriage, the passenger should not bear the additional financial burden created by that decision. Where a passenger chooses to travel with a support person, discounted companion fares may remain a separate policy consideration. However, where the airline determines that a carer is required, particularly where the passenger has indicated that they can travel independently and provided reasonable supporting evidence, the airline should be responsible for the carer’s fare and other reasonable travel or transfer costs directly arising from its requirement.
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2.9 Clarify when airlines can ask for medical certificates
NEDA supports a regulatory approach and supports the standards limiting the circumstances in which airlines may require passengers with disability to provide medical clearance. (DITRDCSA 2026, p50) Medical certificates should only be requested where there is an objective and reasonable basis for concern about a passenger’s ability to safely complete the flight or a specific risk to the health or safety of others, rather than because a passenger has a disability, or communicates or behaves in a way that staff consider unusual.
NEDA is particularly concerned about CASA’s suggestion of the potential use of “unusual behaviour” as a basis for requiring medical clearance. (CASA 2024, DITRDCSA 2026, p50) Atypical behaviour or communication associated with disability, including stimming, tics or non-verbal communication, should not in itself trigger a requirement for medical assessment. Similarly, behaviours or communication styles influenced by cultural background should not be interpreted as evidence of a medical or safety risk. This creates particular potential for intersectional discrimination against people with disability from culturally and linguistically diverse backgrounds and neurodivergent people. The Standards should clearly distinguish harmless atypical behaviour from behaviour that presents an objective and demonstrable safety risk. Medical clearance should not be required on behavioural grounds unless there is reasonable evidence of a specific risk to the physical safety of the passenger, other passengers, crew or aircraft.
Similar safeguards should apply where staff have concerns about communicable illness. NEDA does not consider it necessary for the aviation disability standards to establish broader public health requirements applying to all passengers. However, a visible medical condition or physical difference should not, in itself, provide grounds to require a person with disability to obtain medical clearance. Staff should not assume that visible conditions such as eczema, psoriasis, scarring or birthmarks are contagious. Where medical evidence is requested on the basis of potential transmission risk, there should be an objective and reasonable basis for believing that the passenger may have a communicable condition that presents a relevant risk.
For chronic and stable conditions, NEDA supports medical evidence remaining valid for an appropriate period rather than requiring passengers to repeatedly obtain clearance for each journey. Where relevant, current medical clearance could be stored within the passenger assistance profile proposed in section 2.1, with the passenger responsible for updating it where their medical circumstances materially change or the evidence expires.
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This would reduce unnecessary cost and administrative burden while allowing genuinely time-sensitive medical information to be treated differently.
NEDA also supports consideration of an approach similar to that provided under the United States Air Carrier Access Act (14 CFR Part 382), which allows an airline to seek further medical review where there is a legitimate medical reason to believe that there has been a significant adverse change in a passenger’s condition since their medical certificate was issued, or that the certificate materially understates the passenger’s risk to the health of others. However, any equivalent Australian provision should require more than the subjective concern of an individual staff member. The airline should be able to identify the specific and legitimate medical basis for questioning the existing evidence and should facilitate access to an appropriately qualified medical professional without unnecessary delay.
Where a passenger has provided valid medical evidence and the airline nevertheless requires an additional medical assessment, the airline should initially bear the cost of that assessment and the reasonable costs arising from disruption to the passenger’s journey. Where the additional assessment confirms that the passenger was fit to fly and the information they provided was accurate, those costs should remain with the airline. Where it is established that the passenger knowingly failed to disclose, or materially misrepresented, relevant information about their condition, responsibility for resulting costs may appropriately rest with the passenger.
2.10 Provide clear information about accessibility options before Booking
NEDA supports a regulatory approach and broadly supports the information proposed for inclusion in the Standards. (DITRDCSA 2026, p52) While many of the individual information requirements are relatively straightforward and may not, in isolation, appear to require regulation, a consistent regulatory approach is appropriate given the broader obligations proposed throughout the aviation disability standards. People with disability should be able to access reliable information before booking that enables them to understand what accessibility supports are available and make informed decisions about their travel.
Where limits apply to the number of passengers requiring particular forms of assistance who can be accommodated on a flight, this information should be visible during the flight selection and booking process, rather than requiring passengers to search separately for airline policies. For example, where a legitimate safety-based limit applies to the number of passengers requiring wheelchair assistance to board or disembark, the booking system
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could display a clearly identifiable accessibility symbol and indicate the number of places available. This could also interact with the passenger assistance profile proposed in section 2.1, allowing passengers to identify suitable flights before progressing through the booking process.
Importantly, providing information about an accessibility limitation should not relieve an airport or airline of its obligation to provide accessible services or make appropriate arrangements. For example, if a passenger requires an Eagle lift or other boarding equipment and that equipment is not ordinarily located at a particular airport, information provided before booking should explain how the required equipment or an appropriate alternative will be made available, including whether additional advance notice may be required because equipment needs to be sourced from another location. Simply advising passengers that particular accessibility equipment is unavailable should not become a substitute for making reasonable arrangements to facilitate travel.
Information available before booking should also clearly explain the assistance that passengers can and cannot expect from airline and airport staff. For example, as discussed in section 2.8, passengers should be informed that cabin crew can provide some forms of assistance but cannot provide personal care, administer medication or provide feeding assistance. Providing this information before booking would assist passengers to determine whether they can travel independently or need to make their own support arrangements.
Similarly, information should clearly identify the circumstances in which medical clearance may legitimately be required, consistent with the requirements discussed in section 2.9, and explain the process, evidence and applicable timeframes. This would reduce uncertainty and help ensure that passengers are able to provide any genuinely necessary documentation sufficiently in advance of travel.
2.11 Offer information needed to book flights in multiple accessible formats
NEDA supports a regulatory approach and broadly supports the proposed requirements for information to be available in multiple accessible formats. (DITRDCSA 2026, p55) Airports and airlines should clearly communicate which accessible formats and communication supports are available, and information about how to request them should itself be easy to locate and access.
Digital booking platforms should, at a minimum, meet the applicable WCAG AA accessibility requirements, and should be compatible with assistive technologies
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including screen readers, voice input and other alternative methods of navigating and entering information. NEDA also supports the proposed simplified or accessible booking mode, recognising that technical compliance alone does not necessarily ensure that a booking process is straightforward or usable for people with cognitive, sensory or other accessibility requirements. Accessible digital systems should be tested with people with a diverse range of disabilities as part of ongoing accessibility evaluation.
NEDA broadly supports the range of alternative formats identified in the proposed standard, including Easy Read, Auslan, Braille, pictorial information and social stories, as well as access to direct assistance through appropriate communication channels. (DITRDCSA 2026, p55) Not every format will be appropriate for every type of information or delivery channel, and the focus should be on ensuring passengers can obtain the information they need in a format that is accessible to them. Accessible information should also recognise Australia’s linguistic diversity and the intersection between disability and language, including access to translated information and interpreting where required. Access to language assistance should also recognise that a passenger’s carer or support person may require interpreting or translated information, particularly where they are assisting the passenger to communicate their accessibility requirements or advocate for support, noting that many languages do not have appropriate terms for various disability related issues.
Printed information should be available in accessible alternatives, including Braille where required, while digital information should be designed to work effectively with relevant assistive technologies
NEDA supports ensuring that important information contained within terms and conditions is available in accessible formats. However, requiring complex legal terms and conditions to be reproduced in Easy Read may risk altering or losing important meaning. NEDA therefore recommends that airlines provide Easy Read and Auslan summaries of key terms and conditions, particularly those relating to accessibility, eligibility, assistance, additional costs, cancellations and a passenger’s ability to travel, alongside access to the complete terms and conditions. The summary should clearly indicate that it is an accessible explanation of the key terms rather than a replacement for the full legal document.
2.12 Provide communication in accessible formats during disruptions
NEDA supports a regulatory approach. (DITRDCSA 2026, p57) Requirements for accessible communication during disruptions should be mandatory, as disruption is precisely the
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point at which inconsistent communication practices are likely to have the greatest impact on passengers with disability. NEDA broadly supports the proposed standard, including the requirement to advise passengers where a change affects the ability to transport them or their mobility aid and to identify accessible alternative itineraries.
Where a passenger’s accessibility needs are known, airlines and airports should provide proactive, direct communication when disruptions or changes may affect the passenger’s journey, rather than relying solely on general announcements. SMS and app notifications can be useful, but will not be accessible or effective for every passenger. This is particularly important for changes within airports, such as gate changes. A change that may be relatively straightforward for other passengers can create a significant barrier for someone with limited mobility if the new gate is some distance away, particularly where little time is available to reach it. Similarly, passengers who are Deaf or hard of hearing, or who otherwise cannot access public address announcements, may not receive information communicated primarily through loudspeaker announcements. Where a passenger is known to have accessibility requirements, staff should take reasonable steps to ensure that the passenger has received and can access the changed information and any assistance needed to respond to it.
The response to disruption should also consider the additional practical and financial consequences that may arise because of a passenger’s disability. Standard remedies may not be sufficient. For example, where an airline provides overnight accommodation following a cancellation, a passenger may require an accessible hotel room or accommodation that can also meet the needs of their support person or assistance animal. Similarly, alternative transport, transfers or other arrangements may need to be accessible. Where these additional costs arise as a consequence of a disruption for which the airline is responsible, the passenger should not be financially disadvantaged because their accessibility requirements make the alternative arrangements more expensive.
Where a disruption means that the airline can no longer transport a passenger or their mobility aid as booked, the airline should also take proactive responsibility for identifying and arranging an appropriate accessible alternative, rather than placing the burden on the passenger to locate and negotiate a suitable replacement flight themselves. This should include confirming that the alternative aircraft, airports and services can meet the passenger’s known accessibility requirements before rebooking them. Where no suitable alternative can immediately be provided, the airline should meet reasonable additional costs arising from the passenger’s accessibility requirements until an appropriate alternative journey can be provided.
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2.13 Communicate when passengers with disability or their disability aids are not accepted for travel
NEDA supports a regulatory approach and broadly supports the proposed standard. (DITRDCSA 2026, pp58-59) Where a passenger or their disability aid is refused carriage, the passenger should be provided with a clear explanation at the time of refusal, followed by written reasons as proposed. This should identify the specific basis for the decision rather than relying on general references to safety, operational requirements or airline policy.
Where a passenger has provided the required advance notice and information and the airline is subsequently unable to transport them or their disability aid, the airline should take responsibility for arranging an appropriate alternative journey. This responsibility should not be limited to identifying the airline’s own next available service. Where another carrier can accommodate the passenger and their disability aid within a reasonable timeframe, the original airline should be required to explore that option and, where available, arrange the alternative flight without additional cost to the passenger. A passenger should not experience a substantially extended disruption simply because the next accessible service happens to be operated by a competing airline.
NEDA considers that responsibility for finding and arranging alternative travel should only revert to the passenger in limited circumstances, such as where the passenger has knowingly provided materially inaccurate information or failed to provide information or documentation reasonably required to determine whether they or their disability aid can be transported safely. Even in these circumstances, airlines should provide reasonable assistance to identify available alternatives. A genuine mistake, misunderstanding or difficulty navigating unclear information requirements should not automatically absolve an airline of responsibility.
The Standards should also address circumstances in which a passenger or their disability aid has been inappropriately or unjustifiably refused carriage. A refund or rebooking alone may not adequately address the consequences of an incorrect refusal, particularly where the passenger incurs additional accommodation, transport, support or other costs, misses a connection, or experiences significant delay. Consideration should therefore be given to appropriate compensation and reimbursement of reasonable consequential costs where an airline incorrectly refuses carriage contrary to the Standards.
2.14 Allow people with disability to choose seats that best meet their needs
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NEDA supports a regulatory approach and supports the proposed standard, including the use of priority seating for passengers with disability. (DITRDCSA 2026, p61) Where particular seats have features that make them more accessible, these seats should be available to passengers who require those features before being released for general selection. If they have not been required by passengers with disability within an appropriate period before departure, they could then be made available to other passengers.
Passengers with disability should be able to identify and select a seat according to their individual accessibility requirements, rather than an airline determining which accessible seat it considers appropriate. During online booking, passengers could be shown available seats within their selected class of travel that meet their identified requirements, with filtering options for relevant accessibility features such as additional legroom, movable armrests, proximity to an accessible toilet, or other relevant seat characteristics. Clear information about the accessibility features of individual seats should be available during seat selection.
Importantly, a passenger should not be required to pay an additional seat-selection or upgrade fee where a particular seat or seating feature is required to meet their accessibility needs. This includes circumstances where the appropriate seat would ordinarily attract an additional charge because it offers additional legroom or another feature that the passenger requires because of their disability. The passenger should not be financially disadvantaged because the seat that enables them to travel accessibly happens to be sold by the airline as a higher-value seating option.
This should not provide an entitlement to a general upgrade or preferred seating unrelated to the person’s disability. Rather, the principle should be that where a particular seating feature is reasonably required because of disability, the passenger can access an available seat with that feature within their class of travel without an additional fee.
Chapter 3. the airport.
3.1 Allow people with disability to stay in their mobility device as long as possible
NEDA supports a regulatory approach and prefers Option 1, which provides passengers with greater choice and certainty about when and where they relinquish their mobility device. Allowing the point of transfer to depend on when an airline considers it “absolutely
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necessary“ risks perpetuating the inconsistent practices the proposed Standards are intended to address, particularly if existing operational processes are allowed to determine when a passenger must give up their mobility device. (DITRDCSA 2026, p65)
NEDA considers 30 minutes before gate closure to be a reasonable maximum timeframe, while recognising that passengers should be supported to remain in their own mobility device for longer whenever operationally possible. (DITRDCSA 2026, p65) Ideally, passengers should be able to remain in their device until they are ready to board and hand it over as part of the boarding process. NEDA recognises that aircraft type, loading arrangements and the time required to safely prepare and stow particular mobility devices may affect what is possible on individual flights. Airlines and ground handlers should therefore design their processes to maximise the time passengers can remain in their own mobility devices, recognising the significant impacts of unnecessary separation, including loss of independence and dignity and, for some passengers, increased risk of pain, pressure injury or other physical harm.
Where a passenger has transferred into an airline or airport provided wheelchair that they cannot independently propel or use to access airport facilities, they should not be left unattended.
NEDA does not support a model under which staff simply check on the passenger at prescribed intervals, such as every 30 minutes. A passenger who has surrendered their own means of independent mobility should continue to be supported to access toilets, food and drink, retail facilities and other airport services on the same basis as other passengers. Assistance arrangements should therefore ensure that support is available when required, rather than leaving the passenger effectively stranded until a staff member next returns to check on them.
3.2 Provide accessible check-in facilities
NEDA supports a regulatory approach and broadly supports the proposed requirements for accessible check-in kiosks, staffed check-in facilities and supporting self-service facilities such as bag drops. (DITRDCSA 2026, p67-68) As airlines increasingly move towards self-service check-in, accessibility requirements should apply to the whole check-in process, including both the hardware and software passengers are required to use and the associated processes for baggage handling and tagging.
Self-service kiosks should incorporate accessible features including appropriate screen height and reach, compatibility with assistive technologies, and text-to-speech or audio functionality that enables information displayed on screen to be read aloud.
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However, with airlines increasingly moving towards digital and phone based check-ins, care should be taken to ensure that airlines moving towards these systems do not assume all passengers have access to, or can readily use, a smartphone. Accessible kiosk and staffed alternatives should remain available for passengers who cannot use mobile check-in options.
Where a passenger cannot independently use a kiosk, bag drop or another part of the self-service process, staff assistance should be readily available, noting that many airports and airlines already provide this assistance. Information about where and how to obtain assistance should be clearly signposted and accessible, rather than requiring passengers to locate staff or navigate an inaccessible self-service process before they can request help.
NEDA also recommends consideration of the accessibility of checked baggage tags as part of the check-in process. Adhesive bag tags can be difficult to attach and remove for people with limited dexterity, fine motor control or vision, potentially making an otherwise independent check-in process inaccessible. As self-service systems continue to develop, airlines and airports should consider more accessible alternatives to current adhesive baggage-tagging processes or ensure readily available assistance with tagging where required.
3.3 Install points throughout the airport where people can ask for assistance
NEDA supports a regulatory requirement for designated assistance points throughout airports. (DITRDCSA 2026, pp69-70) These should be clearly identifiable, accessible and located at key points across the passenger journey, including arrivals, check-in, security, departure areas and baggage collection. Assistance should be readily available whenever the airport is operating, whether through a staffed location or another accessible mechanism that connects the passenger directly with staff who can provide assistance.
NEDA considers that the number and location of assistance points should be proportionate to the size, layout and passenger volumes of the airport. While dedicated assistance at or near every departure gate may be appropriate at larger airports, this may be unnecessary in smaller regional airports where gates and facilities are located within a relatively compact area. A tiered approach could establish different minimum requirements based on airport size and configuration, while ensuring that all passengers can readily locate and access assistance when required. Under such an approach, smaller
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airports could provide fewer strategically located assistance points rather than being exempt from the requirement altogether.
However, NEDA foresees that there may be the risk of these assistance points being used as waiting areas for passengers who have been transferred from their personal mobility device into an airport- or airline-provided wheelchair and are unable to move independently. NEDA does not support this.
As discussed in section 3.1, where an operator has removed a passenger’s independent means of mobility, the availability of an assistance point does not remove the responsibility to ensure that passenger continues to have access to the support they require. Assistance points should facilitate access to help and information, not become locations where passengers with disability are left while waiting for staff to return.
3.4 Make wayfinding around airports consistent and accessible
NEDA supports a regulatory approach and prefers Option 2, requiring airports to test wayfinding systems with people with disability. (DITRDCSA 2026, p72) While greater consistency between airports may assist passengers through increased familiarity and predictability, NEDA considers it more important that wayfinding systems are demonstrably accessible and effective for the diverse people who need to use them.
Testing should involve people with a diverse range of disabilities and accessibility requirements, including people with sensory, physical, intellectual and cognitive disabilities. Importantly, testing should occur under a range of realistic airport conditions rather than solely in controlled or quiet environments. This should include different times of the day and night, varying lighting conditions, and periods when terminals are crowded and noisy as well as quieter periods. In busy terminals, crowds, queues and luggage can obscure signage, information points and other wayfinding cues, or make accessible routes more difficult to identify and navigate. Testing under realistic conditions would help identify barriers that may not be apparent when wayfinding systems are assessed under ideal circumstances.
NEDA particularly supports the frequent provision of clearly identifiable “you are here” maps and information points throughout airport terminals. These should be located at logical decision points and provide passengers with a clear understanding of their current location, relevant destinations and accessible routes. Digital navigation and other
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emerging technologies may provide additional options, but should complement rather than replace accessible physical wayfinding that does not require passengers to own or use a smartphone.
Where possible, NEDA would support some national consistency in key symbols and accessibility information, particularly where familiarity assists passengers to quickly recognise essential facilities or services. However, standardisation should not be prioritised over functionality. The primary test should be whether people with diverse disabilities can effectively find and understand the information they need to navigate the airport independently.
3.5 Provide information about travel changes and disruptions in accessible formats
NEDA supports a regulatory approach, including requirements applying to both planned and unplanned disruptions. (DITRDCSA 2026, pp73-74) As discussed in section 2.12, passengers with disability should receive timely information about changes and disruptions in accessible formats and, where their accessibility needs are known, airports and airlines should provide proactive direct communication where a change may affect their journey.
Within the airport environment, information about unplanned and short-notice changes, such as gate changes, boarding delays or changes to the accessibility of airport infrastructure, should be communicated through multiple channels rather than relying on a single method such as public address announcements or digital screens. NEDA broadly supports the range of communication methods proposed, with direct assistance available where information cannot otherwise be provided in a format accessible to the individual passenger.
NEDA recognises that providing some accessible formats during an unplanned disruption may require different approaches from information prepared in advance. For example, producing bespoke Easy Read information at very short notice may not always be practicable. Airports and airlines could therefore develop accessible templates for common or foreseeable disruptions, with simple fields that can be quickly updated with information such as the affected flight, gate or facility, the nature of the change, what the passenger needs to do, and where assistance is available. This would enable clear and accessible information to be provided quickly without requiring accessible materials to be developed from scratch each time a disruption occurs.
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3.6 Improve access for arrivals at and departures from the airport
NEDA supports a regulatory approach and broadly supports the proposed requirements for accessible parking, pick-up and drop-off areas. (DITRDCSA 2026, p76) These facilities should be located as close as practicable to terminal entrances and provide a direct, continuous and accessible path between the parking or drop-off location and the terminal, recognising that distance itself can present a significant accessibility barrier. Design should also consider factors such as kerb ramps, shelter from weather, clear signage and sufficient space and time for passengers to safely enter or leave vehicles.
NEDA considers that accessible spaces should comprise approximately 20 percent of designated pick-up, drop-off and short-term parking spaces. More broadly, NEDA supports revisiting existing minimum requirements for accessible parking to better reflect the proportion of the population with disability and the level of demand for accessible parking, rather than treating existing minimum requirements as necessarily sufficient.
Accessible arrival and departure arrangements should also connect with the passenger assistance obligations discussed in section 1.1. Passengers who require assistance should be able to access support from designated kerbside drop-off and pick-up areas and accessible short-term parking, rather than assistance commencing only once they have independently reached the terminal or check-in area. Where a passenger has nominated these requirements through their passenger assistance profile, this could support coordination of assistance from their nominated arrival point through to check-in, and from baggage collection through to their onward transport when arriving at their destination.
3.7 Provide clear information and priority for people with disability at security
NEDA supports a regulatory approach and broadly supports the proposed requirements, including optional priority screening, accessible information and aviation-specific training and competency requirements for security screening staff. (DITRDCSA 2026, p79) All security screening lanes should remain accessible, with priority arrangements providing an additional option for passengers who require them rather than becoming the only location at which passengers with disability can be screened.
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The Standards should provide greater clarity about screening passengers who must temporarily relinquish a mobility aid, such as a cane, walking frame or crutches, because the aid itself requires security screening. Current practices are inconsistent, with passengers variously provided with a temporary mobility aid, offered direct physical assistance, asked to stand or balance without their aid, or, where permitted, assisted by a carer or travelling companion. Rather than staff determining which approach will be used, passengers should be informed of the available safe options and supported to choose the option that best meets their needs and preferences. No passenger should be expected to stand or balance without appropriate support, or be physically assisted or touched without their agreement, where another appropriate screening option is available.
A CALD person with disability interviewed by NEDA described routinely undergoing pat-downs and swab testing in place of the screening methods used by other passengers, having their wheelchair separately examined, and being separated from their support person, family members and others travelling with them during the process. They described the cumulative experience as making them feel “othered”, and noted that interactions with security staff can at times also leave them feeling racially marginalised.
While alternative screening methods may be legitimately required where standard screening equipment cannot accommodate a passenger or their mobility aid, the cumulative impact of these processes, and the way in which they are carried out, must be considered. Passengers should be clearly told what will occur and why and offered privacy where physical screening is required. Passengers should not be separated from a carer, support person or interpreter during screening unless separation is genuinely necessary for the screening process. For some people with disability, the presence of a trusted support person may be essential to communication, understanding what is occurring, supported decision-making, providing or communicating consent, and capacity to cooperate with the screening process. Unnecessary separation may therefore create a significant accessibility barrier and, for some passengers, cause considerable distress. Where both the passenger and their support person require screening, the process should be coordinated wherever possible so that the support person is screened first and can then be available to support the passenger through their screening. This would minimise the period of separation while still allowing security requirements to be met. Staff should seek consent before touching or physically manoeuvring a passenger wherever the security process permits, and should communicate through or with a support person where this is the passenger’s preferred or required method of communication.
The physical accessibility of the screening area must also be considered. For example, the same individual reported being unable to reach the trays provided for placing belongings
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through security screening. Accessible screening requires more than an accessible route through the checkpoint; trays, benches, document handling areas and other facilities passengers are expected to use should be positioned so they can be independently reached and used by people with different mobility and reach requirements, with assistance readily available where required.
As discussed in section 1.2, NEDA considers practical training and competency assessment particularly important for security screening staff. As proposed in those standards, this training must extend to contracted security screening personnel, recognising that screening functions are commonly delivered by external contractors. (DITRDCSA 2026, p26, 79) Training should include screening of people using different mobility and disability aids; appropriate alternatives when an aid must itself be screened; consent and physical assistance; communication with people with sensory, communication, intellectual or cognitive disability; and the potential for disability-related or culturally influenced communication and behaviour to be misinterpreted. Training should reinforce that the objective of security screening can be achieved while preserving the passenger’s dignity and autonomy.
3.8 Involve people with disability when designing accessible facilities at airports
NEDA supports a regulatory requirement for people with disability to be involved in the design, location and significant redevelopment of accessible airport facilities, and supports the range of facilities identified in the consultation paper. (DITRDCSA 2026, pp80-81) Where minimum technical design requirements already exist, co-design remains important in determining matters such as location, number, usability and integration with other facilities across the airport.
In addition to the accessible facilities identified in the consultation paper, NEDA recommends that accessible prayer and multi-faith facilities also be explicitly considered. These serve a different purpose from quiet or sensory rooms and should not be assumed to be interchangeable. A CALD person with disability interviewed by NEDA identified that prayer rooms can be difficult to locate and are often not physically accessible to wheelchair users. In some existing facilities, relatively straightforward modifications, such as a sufficiently wide accessible doorway and an automatic or easy-to-operate door, could significantly improve access. The location of prayer facilities should also be clearly incorporated into accessible airport wayfinding.
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In addition to broader engagement through disability reference groups, the co-design of specialised facilities should include people with direct lived experience of using, or needing to use, those facilities. A disability reference group can provide valuable broader input, but should not be treated as a substitute for engaging actual end users in needs analysis and later testing. Assistance animal handlers would necessarily be a part of informing design of animal relief areas, while people with relevant mobility and personal-care requirements should inform the design of transfer and Adult Change Facilities. All accessible facilities should be designed and informed in this way. Engagement should also reflect the diversity and intersectionality of airport users, including people with disability from CALD and First Nations backgrounds.
3.9 Protect disability aids from damage and loss, and track their movement
NEDA strongly supports a regulatory approach requiring airlines to protect disability aids from damage and loss and to provide passengers with timely information about the location of their aids while they are in the airline’s custody. (DITRDCSA 2026, p82) Disability aids, particularly individually configured mobility devices, are not interchangeable pieces of luggage, and damage or loss can have significant consequences for a person’s mobility, independence, safety and ability to continue their journey.
However, NEDA considers that an obligation to store and secure disability aids appropriately must be supported by appropriate equipment, handling processes and staff competency. Airlines should be required to actively investigate and invest in appropriate methods of protecting disability aids during loading, transport and unloading, recognising the diversity, complexity and value of the equipment being handled. As discussed in section 1.2, staff responsible for handling disability aids should receive appropriate practical training and competency assessment.
NEDA recognises that the range and complexity of disability aids means that staff cannot reasonably be expected to know the handling requirements of every individual device from general training alone. Passengers should therefore be able to provide device-specific handling instructions, particularly where equipment requires particular procedures for securing, dismantling or reassembly, or where incorrect handling could result in damage. This information could be stored within the passenger assistance profile proposed in section 2.1 and made readily available to the personnel responsible for the secure stowage
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of the device. Where specialised handling instructions have been provided, these should remain associated with the disability aid throughout the period it is in the airline’s custody.
NEDA also strongly supports the proposed requirement for passengers to be able to track their disability aid after relinquishing it to the airline. Consumer tracking devices such as AirTags already provide some passengers with an informal means of locating their equipment, however responsibility for tracking should not rest with the passenger. Airlines should provide an accessible means of receiving timely updates about a disability aid’s location and status, including confirmation that the aid has been loaded onto the aircraft and information about its return on arrival. Tracking should be available through more than one communication method and should not depend on passengers owning or being able to use a smartphone.
NEDA also considers that the Standards should clearly connect these preventative requirements with what occurs when prevention fails. While remedies for damaged or lost mobility aids are being considered through the separate Aviation Consumer Protections Charter process (DITRDCSA 2026, p11,82), passengers need certainty about what will happen immediately if an essential disability aid is damaged, lost or delayed. At minimum, there should be clear responsibility for providing or arranging an appropriate temporary replacement or other necessary support, facilitating urgent assessment and repair, and ensuring that the passenger is not left without the equipment or assistance required to safely continue their journey. The relationship between these immediate obligations, the aviation disability standards and any longer-term compensation or reimbursement arrangements should be clear to passengers.
3.10 Provide choice for passenger transfer to airline wheelchairs and seats
NEDA supports a regulatory approach and supports the proposed requirement that passengers with disability have choice regarding how they are transferred between their mobility aid, airline-provided wheelchairs and aircraft seating. (DITRDCSA 2026, p85) People with disability should be recognised as the experts in their own bodies, equipment and support needs, and their stated preferences should guide the transfer process wherever the requested method can be safely provided.
However, meaningful choice depends on appropriate transfer equipment being available. Airports and airlines should ensure access to a reasonable range of safe transfer options, including mechanical transfer equipment where required. NEDA recognises that smaller regional airports may not be able to maintain every type of transfer equipment onsite.
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Where equipment can reasonably be shared between airports, arrangements should be in place to enable it to be transported to the relevant airport when required. As discussed in section 2.3, this may justify additional advance notice for particular equipment where there is a genuine logistical need to bring it from another location, however this should not result in passengers simply being denied access to an appropriate transfer method. No particular transfer method should be used as the default simply because it is the cheapest, quickest or most readily available option, particularly where another method is identified as a preferred option to safely and appropriately transfer the passenger. People with disability consulted by NEDA raised particular concerns about the use of slide boards, describing the transfer process as undignified and reporting preventable injuries where passengers’ arms or other parts of their body come into contact with rigid armrests, seating or other parts of the aircraft interior during transfer. The confined space within aircraft cabins increases these risks. Transfer methods should therefore be assessed not only on whether a passenger can physically be transferred, but on whether the transfer can be undertaken safely, with dignity and without avoidable pain or injury.
Airlines and airports should also be responsible for ensuring that transfer equipment is appropriately maintained, available for use and fit for purpose. As discussed in section 1.4, maintenance and operational availability of accessibility equipment should form part of compliance reporting. A transfer option that exists theoretically; but is unavailable because equipment is unserviceable or has not been appropriately maintained, does not provide meaningful choice. Furthermore, where a passenger is denied transfer by their preferred method, the reasons for this should be clearly communicated to the passenger in advance, and an alternate choice must be offered.
Staff undertaking transfers must be appropriately trained and competent, consistent with NEDA’s position in section 1.2. Importantly, the presence of a carer or support person should not transfer the airline’s responsibility for safely assisting the passenger. People consulted by NEDA reported experiences of staff assuming that a carer or support person would undertake aspects of a transfer or other assistance because they were familiar with the passenger’s needs. While a passenger may choose to have their support person involved, this should not be assumed or relied upon as a substitute for appropriately trained staff.
NEDA also notes that the timing and manner of transfer can have consequences beyond the transfer itself. A wheelchair user interviewed by NEDA described airline policy of being boarded first and then last to disembark, making it difficult to plan onward accessible transport, which may itself need to be booked well in advance. They also described aisle wheelchairs as uncomfortable due to their necessarily narrow frames to allow their
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passage down narrow airplane aisles which may not be appropriate for some individuals for extended periods. Transfer and boarding processes should therefore seek to minimise the period during which passengers are separated from their own mobility devices and consider the flow-on impacts of extended boarding and disembarkation times wherever operationally possible.
Chapter 4 – on the aircraft
4. 1 Make it easier for people with disability to board and leave the aircraft
NEDA supports a regulatory approach and broadly supports the proposed standard, including requirements for step-free access and more consistent boarding and disembarkation processes. (DITRDCSA 2026, pp89-90) Airports and airlines should ensure that appropriate boarding infrastructure and equipment is available, including options such as Ambulifts, accessible boarding ramps and aircraft access lifts where aerobridges are unavailable.
NEDA supports priority boarding for passengers who require additional time or assistance, but considers that the Standards should make clear that airlines remain responsible for providing priority boarding where it has been requested or identified as an accessibility need. Passengers consulted by NEDA noted that priority boarding can sometimes be overlooked, particularly following delays or when staff are attempting to board an aircraft quickly. Operational pressure should not result in passengers with disability losing access to the boarding arrangements they require. Where the usual priority boarding period has been missed through no fault of the passenger, an appropriate alternative boarding arrangement should be provided.
NEDA also supports measures to prevent other passengers being required to climb over a passenger with disability who is unable to stand or readily move from their seat. (DITRDCSA 2026, pp89-90) Where a passenger is travelling with a carer, support person or other companion seated beside them, that person should be able to board first so they are seated before the passenger with disability is transferred into their seat. Where a passenger is travelling alone, and operational and seating arrangements permit,
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consideration should be given to leaving the adjacent seat unallocated. Where this is not possible and another passenger is allocated the adjacent seat, that passenger should be invited to board before the passenger with disability. Similar consideration should be given to the order of disembarkation where this would reduce unnecessary transfers, discomfort or awkward movement between passengers.
4.2 Support passengers to store disability aids inside the cabin
NEDA supports a regulatory approach and broadly supports the proposed requirements, including priority storage for disability aids, assistance from cabin crew with stowing and retrieving aids, and dedicated capacity for manual wheelchairs on larger aircraft. (DITRDCSA 2026, pp91-92) Disability aids are essential to a person’s mobility, communication, health or independence and should be treated accordingly, rather than as ordinary cabin baggage.
Where there is more than one safe and appropriate storage option, passengers should be consulted about where and how their disability aid is stored. This may include storage under the seat, in an overhead compartment or in another approved cabin storage area, depending on the nature of the aid and applicable safety requirements. Wherever possible, disability aids should remain close enough to the passenger to be readily accessed when needed. An aid being stored within the cabin is of limited benefit if it is placed somewhere the passenger cannot access or retrieve it when required. As discussed in section 2.7, cabin crew should provide assistance with retrieval where necessary.
Disability aids should also be treated as an extension of the person who relies upon them, particularly mobility and communication aids. Staff should not unnecessarily take, move or relocate a passenger’s disability aid without first communicating with the passenger and obtaining their agreement, subject to legitimate safety requirements. Where an aid must be moved or stored differently for safety reasons, this should be explained to the passenger and, where possible, an appropriate alternative agreed.
NEDA supports the proposed priority given to disability aids over ordinary passenger and crew baggage when passengers with disability use priority boarding. However, passengers should not lose reasonable access to necessary cabin storage simply because priority boarding was not provided as planned by the airline, including in the circumstances discussed in section 4.1. Staff should assist in identifying an appropriate storage solution where the passenger’s usual storage option is no longer available.
Staff responsible for handling and storing disability aids should receive appropriate training, consistent with the requirements discussed in section 1.2. This should include
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understanding that different aids have different handling and storage requirements, the importance of consulting the passenger before moving equipment, and the need to maintain access to aids that may be required during the flight.
4.3 Allow people to use their disability aids onboard, where possible
NEDA supports a regulatory approach and broadly supports the proposed requirements. (DITRDCSA 2026, pp93-94) Passengers should be able to use disability aids during a flight wherever it is safe and practicable to do so, with any restrictions based on genuine safety requirements and clearly communicated before travel.
NEDA particularly supports greater clarity regarding communication devices and less readily recognised disability supports, including positioning aids, harnesses, restraints, foot supports, slings and similar equipment. Passengers may not reasonably anticipate that these items require prior airline approval, particularly where they are routinely used in everyday life to support communication, posture, positioning or safety. Airlines should therefore publish clear and accessible information identifying which categories of disability aids can be used onboard, any restrictions that apply during particular stages of flight, and which types of equipment require prior approval. This information should be publicly available in a range of accessible formats and use terminology that passengers can readily understand.
Where commercially available disability aids or supports require safety assessment, NEDA recommends that airlines move toward approval of the product, make or model itself wherever possible, rather than requiring each passenger using the same product to undergo an identical assessment. Airlines could publish a list of products or models that have already been assessed and approved for use, together with any conditions applying to their use. Once a particular product has been determined to be compatible with applicable safety requirements, passengers using that same product should not routinely be required to repeat the approval process unless the equipment has been modified or there is another material difference relevant to its safe use. A clear and timely process should remain available for products that have not previously been assessed.
Information about a passenger’s own disability aids, including any relevant approval, should also be capable of being stored within the passenger assistance profile proposed in section 2.1, avoiding the need for the passenger to repeatedly provide the same information for subsequent journeys while it remains current.
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4.4 Return mobility aids as soon as possible following flight arrival
NEDA supports a regulatory approach and supports the requirement for mobility aids to be prioritised for retrieval and returned to passengers as quickly as possible following arrival. (DITRDCSA 2026, pp95-96) Where a passenger relies on a mobility aid for their independence, positioning or physical safety, prolonged separation from that aid can cause significant discomfort and loss of autonomy and should be minimised.
NEDA supports establishing a defined timeframe for the return of mobility aids to provide passengers with greater certainty and accountability. The timeframe should commence when passengers begin disembarking, rather than after all other baggage has been unloaded or at another point determined by airline processes. NEDA suggests an expected timeframe of within 15 minutes for domestic flights and 30 minutes for international flights, recognising that different aircraft, airport infrastructure and operational circumstances may occasionally affect what is achievable. Where the timeframe cannot be met, the passenger should be informed of the reason for the delay, the expected return time, and provided with appropriate assistance while they remain separated from their mobility aid.
NEDA strongly supports passengers being able to provide device-specific instructions for the safe disassembly and reassembly of mobility aids. As discussed in section 3.9, these instructions should be able to be stored within the passenger assistance profile and should remain associated with the mobility aid throughout the period it is in the airline’s custody. Instructions may need to include written information, photographs, diagrams or other formats appropriate to the particular equipment. Importantly, the airline must ensure that these instructions are readily available to and followed by the staff who actually handle, disassemble and reassemble the device. The existence of instructions within a booking record or passenger profile is of little value if they do not reach the personnel undertaking the task.
Where an airline has disassembled a mobility aid, it should be responsible for returning the aid fully and correctly reassembled, in the condition in which it was received and ready for the passenger to use. Passengers should not be expected to reassemble equipment themselves, nor should responsibility routinely be transferred to a carer or support person travelling with them. Appropriate staff training and competency requirements should apply, while recognising that complex or highly individualised devices may require staff to rely upon the passenger’s device-specific instructions.
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4.5 Provide critical in-flight information in accessible formats
NEDA supports a regulatory approach, particularly given the safety-critical nature of some information communicated during a flight. (DITRDCSA 2026, p97) Passengers with disability should have access to the same critical safety and operational information as other passengers, in a format they can understand and access at the time the information is provided.
NEDA also broadly supports the proposed use of pre-recorded accessible safety information. Airlines already prepare safety information specific to different aircraft and configurations, and this information could be made available in multiple versions or formats from which passengers can select according to their communication needs, including Auslan, captioned video, Easy Read, audio description and relevant community languages. Where information is made available through a passenger’s own device, an equivalent option should be available for passengers who do not have, or cannot use, a suitable personal device.
The Standards should also address live and unscheduled announcements made during the flight. Where verbal announcements interrupt in-flight entertainment, equivalent information should also be provided visually for passengers who cannot access the audio announcement. NEDA recommends consideration of real-time transcription or captioning that could be displayed through in-flight entertainment screens or other onboard information systems. This is particularly important for urgent announcements, changes to flight conditions or arrival information, where passengers need access to the information at the same time as other passengers rather than receiving it later through individual assistance.
NEDA also supports free access to onboard Wi-Fi, where available, when it is required for a passenger to use a communication or accessibility aid. Access to an accessibility support should not depend on the passenger purchasing an onboard connectivity package. However, Wi-Fi-based solutions should supplement rather than replace accessible information provided by the airline, particularly for safety-critical information, which must remain accessible regardless of connectivity, availability of a personal device or the passenger’s ability to use one.
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4.6 Make in-flight food and drink more accessible
NEDA supports a regulatory approach and broadly supports the proposed requirements for accessible information about food and drink and assistance with opening packaging and identifying the location of items. (DITRDCSA 2026, p99) These requirements should apply regardless of whether food and drink are included as part of the service or available for passengers to purchase during the flight.
Where menus are provided, accessible versions should reflect the food and drink legitimately available on the relevant flight as accurately as practicable. NEDA recognises that availability may vary between routes, flights and seasons and that substitutions or changes may occur at short notice. Where changes or items unavailable on a particular flight would ordinarily be communicated verbally, equivalent information should be made available to passengers who cannot access the verbal announcement. Accessible menus could include large print and Braille versions, as proposed, as well as accessible digital information where ordering or menu information is provided electronically.
NEDA also supports passengers being able to obtain ingredient and allergen information in an accessible format where required, regardless of how food is supplied or purchased. It may not be necessary for every complete ingredients list to routinely be produced in every accessible format. However, where the information is available on product packaging, through the airline or through its catering supplier, staff should be able to provide or communicate that information accessibly on request. The increasing use of pre-packaged food may also make this information easier for airlines and their catering suppliers to provide consistently.
NEDA considers the proposed distinction between the assistance cabin crew can reasonably provide, such as opening packaging and identifying food and drink items and their location, and personal assistance with cutting food, eating or drinking to be appropriate. These limitations should be clearly communicated before travel, consistent with the information requirements discussed in section 2.10, so that passengers who require additional personal assistance can make appropriate arrangements.
4.7 Improve accessibility of aircraft toilets
NEDA supports a regulatory approach and supports the proposed staged introduction of improved accessibility requirements for aircraft toilets. (DITRDCSA 2026, p101) Inaccessible toilets can significantly restrict the ability of people with disability to travel safely and with dignity, particularly on longer flights, and the absence of accessible facilities should not continue indefinitely as an accepted feature of air travel.
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NEDA recognises that there are significant technical and practical constraints associated with modifying aircraft interiors, particularly on single-aisle aircraft, and that airlines are dependent on accessible designs being available from aircraft manufacturers. (DITRDCSA 2026, p101) For this reason, a staged approach that introduces achievable accessibility improvements in the shorter term while establishing stronger requirements for new aircraft in the longer term is appropriate. However, the practical difficulty of retrofitting existing aircraft should not prevent the Standards from establishing clear accessibility requirements for future aircraft procurement and major refurbishment.
As an organisation representing people with disability, NEDA does not have the aircraft engineering or design expertise required to recommend specific implementation timeframes, aircraft seating thresholds or technical definitions of major refurbishment. These should be informed by appropriate engineering, manufacturing and industry evidence, while ensuring that technical and cost considerations do not result in indefinite delays to improved toilet accessibility. The fact that comparable accessibility requirements have already been introduced in the United States and Canada is also relevant to the question of feasibility. (DITRDCSA 2026, pp101-102) As significant aviation markets have established regulatory requirements in this area, these requirements are likely to influence the future design and development priorities of aircraft manufacturers. Australia would therefore be introducing requirements within a broader international shift towards improved aircraft accessibility, rather than expecting manufacturers to respond to an Australian requirement in isolation.
4.8 Make in-flight entertainment accessible
NEDA supports a regulatory approach and broadly supports the proposed requirement that, where in-flight entertainment is provided, it is accessible to people with disability. (DITRDCSA 2026, p104-105) Passengers with disability should have equitable access to entertainment offered as part of the in-flight experience, including through accessible content and interfaces that can be independently navigated and operated.
NEDA supports requirements such as closed captioning, audio description and accessible interfaces, while cautioning against the Standards becoming overly prescriptive about the specific technologies through which accessibility must be delivered. Accessibility technology and consumer expectations will continue to evolve over the life of the Standards. Airlines should therefore be required to periodically review and improve the accessibility of their in-flight entertainment systems in line with advances in available and reasonably implementable technology, rather than compliance being limited to meeting a fixed set of features established when the Standards commence.
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Where existing in-flight entertainment systems cannot provide an equivalent accessible experience, NEDA supports the proposed use of alternative accessible devices or systems. These alternatives should provide substantially equivalent access to the entertainment available to other passengers, rather than a significantly reduced selection being regarded as sufficient simply because some accessible content has been provided.
4.9 Require aircraft to have accessible passenger controls
NEDA supports a regulatory approach and broadly supports the proposed requirements for accessible passenger controls. People with disability consulted by NEDA echoed the issues identified through the co-design process, particularly that controls located overhead or requiring significant reach, grip strength or dexterity can prevent passengers from independently accessing basic functions during a flight. (DITRDCSA 2026, p106)
NEDA supports controls being designed so they can be independently reached, identified and operated by passengers with a range of physical and sensory disabilities while seated. People consulted by NEDA expressed a preference for touchscreen controls where appropriate, particularly where these allow functions that are traditionally located overhead to be controlled from a more accessible position. However, NEDA does not recommend prescribing a particular technology, as different passengers have different access requirements and technology will continue to evolve. Touchscreen interfaces themselves must also be accessible to people who cannot see or readily operate a visual touchscreen.
NEDA recognises that some passenger controls and their locations are determined by aircraft, cabin and seating manufacturers rather than airlines alone, (DITRDCSA 2026, p106) and that retrofitting existing aircraft may present significant technical and financial barriers. However, these constraints reinforce the importance of incorporating accessibility requirements when airlines purchase new aircraft or undertake major cabin refurbishments, when design changes are more feasible. Airline procurement decisions should increasingly take the accessibility of passenger controls into account, creating greater demand for manufacturers to incorporate accessible design into future aircraft and cabin configurations.
As with 4.8, NEDA is not in a position to recommend a specific implementation timeframe or aircraft seating threshold, as these decisions require technical and industry expertise regarding aircraft design, manufacturing, procurement and refurbishment cycles. However, the Standards should establish clear prospective requirements and realistic
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transition periods, rather than relying on accessibility improvements occurring voluntarily as new technology becomes available.
4.10 Increase the number of aircraft seats that have moveable armrests
NEDA supports a regulatory approach and prefers Option 1, requiring moveable armrests across all seating positions and classes when new aircraft are introduced or major seating refurbishment or replacement occurs. (DITRDCSA 2026, p108) This provides the greatest flexibility for passengers with disability to select seating that meets their individual transfer and accessibility requirements, rather than concentrating accessible seating within particular locations on an aircraft.
During any transition period, airlines should provide clear information at the time of booking about which seats have moveable armrests. This information should be incorporated directly into the seat-selection process and be readily identifiable, for example through a consistent, clearly distinguishable accessibility icon. This would allow passengers to identify appropriate seating without needing to locate separate aircraft accessibility information or contact the airline. As discussed in section 2.14, passengers who require a particular seating feature because of their disability should be able to select an appropriate available seat without additional seat-selection fees.
Where an aircraft or seat allocation changes after booking, updated accessibility information should be proactively provided to affected passengers. Where a passenger has selected a seat specifically because it has a moveable armrest or another required accessibility feature, the airline should ensure that any replacement seat continues to meet that requirement rather than simply notifying the passenger that their original seat has changed.
NEDA considers that requirements for moveable armrests should also apply when a group or section of seats is replaced, rather than relying solely on a high percentage of the aircraft’s total seating being replaced before the requirement is triggered. Where individual seats are progressively replaced or refurbished, NEDA suggests that replacement of approximately 10 per cent of the aircraft’s seating capacity should constitute a sufficient threshold to trigger the requirement. This would reduce the potential for substantial or staged seating replacements to occur without accessibility improvements simply because each individual refurbishment falls below the definition of a major seating replacement.
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Chapter 5 other matters - Current exclusion of small aircraft from parts of the Transport Standards
NEDA recognises that there may be genuine structural, engineering and operational limitations affecting the accessibility of aircraft with fewer than 30 passenger seats, and is not in a position to provide technical advice on the feasibility of applying each of the currently excluded requirements to these aircraft. However, NEDA considers that the impact of the existing exclusions on people with disability warrants further examination, particularly where small aircraft provide important connections to regional, rural and remote communities with limited or no viable alternative transport options.
A blanket exemption based solely on aircraft seating capacity does not take account of the significance of a particular route to the community it serves. NEDA recommends that consideration be given to a route-based approach for essential or critical air connections. On these routes, limitations of the aircraft should not mean that accessibility is simply set aside. Where modifications to the aircraft itself are genuinely impracticable, operators, airports, governments and other relevant parties should be required to consider how accessibility can instead be maximised through appropriate ground-based infrastructure, equipment and operational arrangements. This could include accessible boarding equipment and processes, as well as practical arrangements for the carriage of mobility aids.
The existing exclusions can also restrict travel where a route is operated using different aircraft types at different times or on different services. A person with disability may effectively be limited to those services operated by larger or more accessible aircraft, significantly reducing their choice of departure and arrival times. This can extend a journey that another passenger could complete in a single day across multiple days, with resulting additional accommodation, support and transport costs. Extended travel can also have a disproportionate impact on people with disability through fatigue, pain and the effects of prolonged travel on their disability or health.
Some people may be able to avoid an inaccessible small-aircraft service by travelling by road to a larger airport. However, this should not be regarded as an equivalent accessible
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alternative. Travelling considerable distances by road may itself be inaccessible due to a person’s disability, availability of accessible transport, support requirements, distance or the remoteness of the community. Accessibility of aviation services in regional and remote Australia should therefore be considered in the context of the realistic transport options available to the passenger, rather than assuming that another airport or transport mode provides a viable alternative.
NEDA therefore supports further work to review the small-aircraft exclusions, with particular consideration given to the impact of the exclusion on people with disability, the essential nature of particular routes and the accessibility measures that can reasonably be provided even where structural characteristics of an aircraft cannot be changed.
Conclusion
NEDA strongly supports the introduction of regulatory Aviation Disability Standards and welcomes the significant progress reflected in many of the proposed reforms. As outlined throughout this submission, there remain areas where the proposed requirements could be strengthened or clarified to better reflect the lived experience of people with disability.
Importantly, the success of these reforms will ultimately be measured not by the existence of new policies or reporting requirements, but by whether the experience of people with disability actually changes. A passenger should be able to provide their accessibility information once and have confidence that it will reach the people who need it; expect staff and contractors to have the knowledge and competency required to support them; rely on agreed accessibility arrangements being provided throughout their journey; and trust that, when something does go wrong, there is a clear pathway for accountability and remedy.
For this reason, effective oversight, enforcement and accountability must sit alongside the substantive accessibility requirements.
NEDA encourages the Government to maintain the strong involvement of people with disability, including people with disability from culturally and linguistically diverse backgrounds, as the Standards are finalised, implemented and reviewed. Their lived experience will remain critical to understanding not only whether individual requirements have technically been met, but whether Australia’s aviation system is becoming safer, more accessible, more dignified and genuinely more equitable.
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The introduction of enforceable Aviation Disability Standards is an opportunity to move accessible air travel in Australia from something people with disability must repeatedly negotiate towards something they can reasonably expect. NEDA strongly encourages the Government to seize that opportunity.
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References
Australian legislation, government and regulatory sources
Department of Infrastructure, Transport, Regional Development, Communications, Sport and the Arts (DITRDCSA) (2026), Aviation disability standards—Consultation paper, August 2026, Australian Government, accessed September 2026.
Australian Bureau of Statistics (ABS) (2024), Disability, Ageing and Carers, Australia: Summary of Findings, 2022, ABS website, accessed September 2026.
Civil Aviation Safety Authority (CASA) (2024), Multi-part Advisory Circular: Carriage of special categories of passenger, AC 121-09, 133-06 and 135-10, version 1.1, CASA website, accessed September 2026.
Department of Home Affairs (2026), Security screening at airports, Department of Home Affairs website, accessed September 2026.
Department of Infrastructure, Transport, Regional Development, Communications, Sport and the Arts (DITRDCSA) (2024), Aviation White Paper: Towards 2050, Australian Government, accessed September 2026.
Department of Infrastructure, Transport, Regional Development, Communications, Sport and the Arts (DITRDCSA) (2025), Exposure draft overview paper: Disability Standards for Accessible Public Transport Amendment 2025, Australian Government, accessed September 2026.
International legislation and regulatory sources
Canada, Accessible Transportation for Persons with Disabilities Regulations, SOR/2019-244, made under the Canada Transportation Act 1996, last amended 25 June 2022, Government of Canada, accessed September 2026, https://laws-lois.justice.gc.ca/eng/regulations/SOR-2019-244/index.html.
European Union, Regulation (EC) No 1107/2006 of the European Parliament and of the Council concerning the rights of disabled persons and persons with reduced mobility when travelling by air [2006] OJ L 204/1, Publications Office of the European Union, accessed
September 2026, https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=celex%3A32006R1107.
United States, Nondiscrimination on the Basis of Disability in Air Travel, 14 CFR Part 382, Electronic Code of Federal Regulations, accessed September 2026, https://www.ecfr.gov/current/title-14/chapter-II/subchapter-D/part-382.
United States Department of Transportation (2026), U.S. Department of Transportation Service Animal Air Transportation Form, accessed September 2026.
Other published sources
Airports Council International Europe (ACI Europe) (2018), Guidelines for Passenger Services at European Airports, 2nd edn, Airports Council International Europe, accessed September 2026.
Travellers Aid (2026), Melbourne Airport, Travellers Aid website, accessed September 2026.
Jetstar (2026), Travelling with a service dog, Jetstar website, accessed September 2026.
Qantas (2025), Qantas Disability Access Facilitation Plan, Qantas website, accessed September 2026.
Qantas (2026), Travelling with a guide, assistance or hearing dog, Qantas website, accessed September 2026.
Virgin Australia (2026), Travelling with an assistance animal, Virgin Australia website, accessed September 2026.
Lived experience consultations
National Ethnic Disability Alliance (NEDA) (2026), Lived experience consultations for NEDA’s submission on the proposed Aviation Disability Standards, September 2026.
Unpublished interviews and lived experience contributions from people with disability and
carers from culturally and linguistically diverse backgrounds, including NEDA representatives.
Individual participants are not identified in order to protect their privacy. Lived experience evidence and perspectives are attributed throughout the submission in general terms unless a participant has consented to identification.
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