Submission to the Department of Infrastructure, Transport, Regional Development, Communications, Sport and the Arts

14 October 2026

Submission author:
Matthew Hall
National Manager – Systemic Advocacy & Policy
matthew.hall@afdo.org.au
+61 414 678 520

Reviewed and approved:
Ross Joyce
Chief Executive Officer

Contents

• 1 Acronyms and abbreviations

• 2 Executive summary

2.1 Priority recommendations 11

2.2 AFDO’s preferred option for each issue 12

• 3 Introduction

• 4 Cross-cutting issues

4.1 Regulation not guidance 17

4.2 Enforcement, oversight and remedies 17

4.3 Consistency, with proportionate tiering rather than exemption 18

4.4 Dignity, autonomy and consent 18

4.5 The whole of disability, and intersectionality 19

4.6 Fit with other reforms and with safety regulation 19

4.7 The cost-benefit analysis 20

4.8 Implementation 20

4.9 Co-design needs guidance and accountability 20

• 5 Chapter 1: Whole of journey

5.1 Set out the roles and responsibilities of airports and airlines (Item 1.1) 21

5.2 Make sure staff are trained to support people with disability (Item 1.2) 23

5.3 Set up disability reference groups (Item 1.3) 26

5.4 Report on how Standards are being met (Item 1.4) 27

• 6 Chapter 2: Planning and booking air travel

6.1 Offer passenger assistance profiles (Item 2.1) 30

6.2 Clarify times when limits on passengers requiring assistance may apply (Item 2.2) 31

6.3 Services must be provided when passengers give advance notice (Item 2.3) 33

6.4 Make sure people with disability access the same fare regardless of the method of booking (item 2.4) 34

6.5 Clarify rules for carriage of assistance animals on aircraft (Item 2.5) 35

6.6 Explain how passengers can get approval for equipment classed as dangerous goods (Item 2.6) 39

6.7 Ensure disability aids can be transported for free and in-cabin, where possible (item 2.7) 40

6.8 Explain requirements for carers or companions travelling with a person with disability (Item 2.8) 41

6.9 Clarify when airlines can ask for medical certificates (Item 2.9) 42

6.10 Provide clear information about accessibility options before booking (Item 2.10) 43

6.11 Offer information needed to book flights in multiple accessible formats (Item 2.11) 44

6.12 Provide communication in accessible formats during disruptions (Item 2.12) 45

6.13 Communicate when passengers with disability or their disability aids are not accepted for travel (Item 2.13) 45

6.14 Allow people with disability to choose seats that best meet their needs (Item 2.14) 47

7 Chapter 3: At the airport …………………………………………………………………………………….. 48

7.1 Allow people with disability to stay in their mobility device as long as possible (Item 3.1) 48

7.2 Provide accessible check-in facilities (Item 3.2) 49

7.3 Install points throughout the airport where people can ask for assistance (Item 3.3) 50

7.4 Make wayfinding around airports consistent and accessible (Item 3.4) 51

7.5 Provide information about travel changes and disruptions in accessible formats (Item 3.5) 52

7.6 Improve access for arrivals at and departures from the airport (Item 3.6) 52

7.7 Provide clear information and priority for people with disability at security (Item 3.7) 53

7.8 Involve people with disability when designing accessible facilities at airports (Item 3.8) 55

7.9 Protect disability aids from damage and loss, and track their movement (Item 3.9) 55

7.10 Provide choice for passenger transfer to airline wheelchairs and seats (Item 3.10) 56

8 Chapter 4: On the aircraft …………………………………………………………………………………… 57

8.1 Make it easier for people with disability to board and leave the aircraft (Item 4.1) 57

8.2 Support passengers to store disability aids inside the cabin (Item 4.2) 58

8.3 Allow people to use their disability aids onboard, where possible (Item 4.3) 59

8.4 Return mobility aids as soon as possible following flight arrival (Item 4.4) 60

8.5 Provide critical in-flight information in accessible formats (Item 4.5) 61

8.6 Make in-flight food and drink more accessible (Item 4.6) 62

8.7 Improve accessibility of aircraft toilets (Item 4.7) 62

8.8 Make in-flight entertainment accessible (Item 4.8) 63

8.9 Require aircraft to have accessible passenger controls (Item 4.9) 64

8.10 Increase the number of aircraft seats that have moveable armrests (Item 4.10) 65

9 Chapter 5: Current exclusion of small aircraft ………………………………………………………… 66

10 Co-design solutions not progressed in the Consultation Paper ………………………………… 67

10.1 Evacuation tests should include people with disability 67

10.2 Announcing accessibility needs before flight 67

10.3 Staying in your own mobility device in flight 67

11 Issues the Consultation Paper does not address …………………………………………………… 67

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Consent to publication: Australian Federation of Disability Organisations (AFDO) consents to the publication of this submission, including the names and contact details of AFDO staff. The relevant AFDO staff also give that consent.

2026, Australian Federation of Disability Organisations (AFDO) Ltd, ABN: 25 105 510 898

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Acknowledgements

Aboriginal and Torres Strait Islander people

Australian Federation of Disability Organisations (AFDO) acknowledges Aboriginal and Torres Strait Islander people as the First Peoples and traditional custodians of the land now called Australia. We recognise their deep and continuing connection to Country and community. We pay our respects to the traditional custodians of Country where we work, connect, or meet, which always was, and always will be, Aboriginal land. We also pay our respects to Elders past, present, and emerging.

People with disability

AFDO acknowledges people with disability in all their diversity, particularly those individuals who have experienced or are continuing to experience violence, abuse, neglect, or exploitation. We also acknowledge their families, carers, supporters, and representative organisations and express our thanks for the continuing work done by the many people supporting, protecting, and advancing the rights of people with disability.

Language used in this document

AFDO has chosen to use person-first language (like “people with disability”) in this document. Person-first language puts the person before the disability and values the individual by seeing them as a person, not a condition. This aligns with the CRPD and matches the language used by all governments in Australia. Most other Australian disability peaks also use person-first language.

We recognise many people with disability prefer identity-first language. Disability is a part of their identity and shows a connection to their community and pride in disability. Views on language reflect people’s identities, experiences of disability, and community attitudes. It is a matter of individual choice and agency. AFDO respects everyone’s right to choose how to describe their identity and experiences.

About AFDO

Since 2003, the Australian Federation of Disability Organisations (AFDO) has been the pre-eminent national peak for people with disability, championing their rights through our extensive member organisation network uniquely representing both disability-specific and cross-disability population-based communities with a reach of over 4.5 million Australians.

We are, firstly, a Disabled People’s Organisation (DPO), led, governed, and predominantly staffed by people with disability. We are also a Disability Representative Organisation (DRO) funded by the Australian government.

Our member organisations are national disability-specific or cross-disability peak bodies, other disability-specific advocacy, family and support organisations. This ensures that our work is informed by lived expertise and experience, truly representing our communities.

AFDO is a strong, trusted voice for the disability sector. We advocate on national policy, inquiries, and initiatives with the Federal and state and territory governments. We work to build a community where people with disability:

• have real participation in community life
• can build respectful, valued relationships
• participate socially and economically, and
• contribute as valued citizens.

Our vision

All people with disability can take part equally in all aspects of social, economic, political, and cultural life.

Our mission

Using the strength of our member organisations to harness the collective power of uniting people with disability to change society into a community where everyone is equal.

Our strategic objectives

• To represent the interests and united voice of our members and people with disability at a national and international level in all relevant forums.
• To build the capacity, profile, reputation, and sustainability of AFDO through the strength of our member organisations.
• To enhance the connection and influence in international disability initiatives by policy, advocacy, and engagement, focused on the Asia Pacific region.

Our members

AFDO’s member organisations contribute to the national policy agenda and address issues that impact the lives of people with disability in Australia. We understand that disability-specific organisations play a key role in the provision of information and peer support to people with disability and their families. This role keeps them closely connected to their grassroots communities. Each community has its peak organisation that uses its voice to advocate on issues. Information about AFDO’s members can be found on our website.

Every Australian Counts (EAC)

AFDO has been involved in Every Australian Counts since the beginning of the grassroots campaign that successfully advocated for the introduction of the NDIS.

AFDO continues to support Every Australian Counts by auspicing the campaign, holding a position on the Steering Committee, and providing administrative, governance, marketing and communications support.

More information about Every Australian Counts, including its current priorities and activities, is available on the Every Australian Counts website.

Australian Consumers & Carers Mental Health Forum (the Forum)

The Forum is a national initiative that brings together consumer and carer perspectives to develop shared positions on mental health, suicide prevention and psychosocial disability reform. The Forum supports stronger connections between mental health and disability policy and promotes collaboration across a diversity of lived experience communities.

AFDO supports the Forum by providing administrative, coordination and organisational support as well as holding a position on its Steering Committee. More information is available at The Forum.

1 Acronyms and abbreviations

This list may assist users of this document to understand what we mean when we use the following terms or abbreviations.

ACCC	Australian Competition and Consumer Commission
AFDO	Australian Federation of Disability Organisations
AHRC	Australian Human Rights Commission
CASA	Civil Aviation Safety Authority
Consultation Paper	“Aviation disability standards—Consultation paper”, released by the Department in August 20261
CRPD	United Nations Convention on the Rights of Persons with Disabilities2
DDA	Disability Discrimination Act 1992 (Cth)
Department	Department of Infrastructure, Transport, Regional Development,
Disability Royal Commission or DRC	Royal Commission into Violence, Abuse, Neglect and Exploitation of People with Disability
DOT	U.S. Department of Transportation
DPO	Disabled People’s Organisation. A non-government organisation governed, led, and constituted by people with disability, to be distinguished from organisations for people with disability,
DRO	Disability Representative Organisations funded by the Commonwealth government to represent people with disability. AFDO is one of 11 DROs
DSAPT or Transport Standards	Disability Standards for Accessible Public Transport 2002 (Cth)
EU	European Union
JEC	Justice and Equity Centre

2 Executive summary

The Consultation Paper sets out a coherent response to barriers that people with disability have faced, and described, for many years. AFDO supports its direction and the regulatory approach.

The Standards will succeed if they are specific enough to be enforced, visible through public reporting, backed by remedies that do not depend on individual complaints, and implemented with people with disability involved throughout.

AFDO welcomes the opportunity to continue to take part in the co-design of the exposure draft of the Standards and user guides.

2.1 Priority recommendations

1. Make the standards visible and enforceable. Make reporting mandatory and public for every airline and airport, with no passenger threshold (section 5.4), and empower and fund the Australian Human Rights Commission to monitor and enforce the standards, rather than relying on individual complaints.
2. Give every journey one accountable body and no gaps. Make the airport the single body responsible for assistance throughout the journey, other than on board the aircraft (Option 2), require hand-over responsibilities to be explicit, and prohibit fees for assistance (section 5.1).
3. Protect mobility aids and the people who use them. Let passengers keep their own device as long as possible, require safe handling and tracking, return aids within 30 minutes and as close as possible to the aircraft door, and provide immediate remedies when aids are damaged or lost (sections 7.1, 7.9, and 8.4).
4. Set hard rules on refusal of carriage. Prohibit limits on the number of passengers requiring assistance, except for genuine safety reasons that are referable to the civil aviation safety framework, “confirmed means confirmed”, written reasons, and free rebooking or refund (sections 6.2, 6.3, and 6.13).
5. Make approvals consistent, timely and portable. Establish nationally consistent evidence and approval requirements for assistance animals and disability-related equipment, with clear decision timeframes, approvals valid for multiple journeys (up to 12 months where appropriate), and recognition across airlines wherever consistent with applicable safety requirements. Prohibit unnecessary accreditation requirements for assistance animals recognised under the DDA, ensure refusals are individualised, evidence-based and subject to review, and require automatic escalation and appropriate

remedies where airlines fail to make timely decisions. Passenger assistance profiles should support continuity across journeys without requiring repeated applications (sections 6.1, 6.5, 6.6, and 8.3).

6. Put people with disability in charge of design and training. Require disability-led, competency-assessed training that covers all staff and contractors, and remunerated disability reference groups with real influence (sections 5.2, 5.3, and 7.8).
7. Make information and booking accessible. Set WCAG 2.2 AA as the minimum standard, and require Auslan, Easy Read and Braille, with no price or fare penalty for the way a person books (sections 6.4, 6.10, and 6.11).
8. Set firm dates for aircraft design change. Accessible toilets, moveable armrests, accessible controls and in-flight entertainment, on fixed dates that do not depend on refurbishment or fleet replacement cycles, and with low-cost features retrofitted sooner (sections 8.7 to 8.10).
9. Do not leave regional and small-aircraft passengers behind. Use tiered obligations and a funded transition rather than exemptions, and re-examine the small-aircraft exclusions on a fixed timetable (Section 9).
10. Count the benefits properly. The cost-benefit analysis must value dignity, health and participation, not only industry compliance costs (Section 7.7).
11. Close the gaps the Consultation Paper leaves. No passenger left unattended for more than 30 minutes without their consent, guaranteed equipment to load and unload mobility aids at every airport, and a Complaints Resolution Official at every airline and airport (Section 11).

2.2 AFDO’s preferred option for each issue

Ref	Issue	AFDO preferred approach
1.1	Roles of airports and airlines	Regulatory: Option 2, with the airport as the single responsible body other than on board
1.2	Staff training	Regulatory, strengthened: baseline training for all staff, disability-led, competency-assessed, covers contractors
1.3	Disability reference groups	Regulatory, for every airline and airport, with remuneration and a published response to advice

3 Introduction

Australian Federation of Disability Organisations (AFDO) welcomes the opportunity to provide this submission to the Department and to give feedback on the proposed policy options set out in the Consultation Paper, including which approaches are preferred and to inform the impact analysis needed to finalise the aviation disability standards. AFDO is a member and co-chair of the Aviation Accessibility Steering Committee and took part in developing the options in this paper as a co-design partner, alongside PWDA and JEC. This submission builds on that work. In this submission, AFDO responds to each of the 38 numbered items of the Consultation Paper (items 1.1 to 4.10), and to the Chapter 5 questions, including the questions asked in each section of the Consultation Paper. Where we have not answered a question, it is because the question asks for operational or commercial information that only industry holds.

Discussions with our members and other member feedback have informed this response. Our assessment and recommendations are offered constructively and are developed from a systemic advocacy perspective, grounded in the rights of people with disability established by the CRPD and the Australian government’s obligations to protect and promote those rights in Australia’s domestic laws and policies.4

AFDO supports the regulatory option in every item of the Consultation Paper where one is proposed. We do not support maintaining existing practice on any issue in the Consultation Paper, other than where we say so expressly.

Our reasons are consistent. The Transport Standards have applied to air travel since 2002. The barriers described in the Consultation Paper are the result. The Consultation Paper itself records inconsistent service across airlines and airports under the current framework. Guidance that operators are only “encouraged” to follow would leave that inconsistency in place. Co-design participants and co-design partners told the Department they strongly prefer regulation. The Disability Royal Commission and the statutory reviews of the Transport Standards both raised concerns about compliance and accountability: the rights exist, but passengers have no reliable way to know what to expect or to enforce them.

Regulation is necessary, but not sufficient. The proposed standards will only change people’s travel if they are specific enough to be enforced, are monitored publicly, and carry remedies that do not depend on an individual passenger lodging a complaint after a harmful experience.

4 Cross-cutting issues

4.1 Regulation not guidance

Where the paper offers a non-regulatory option, AFDO’s answer to the first consultation question in each section is the same. We support each regulatory option.

Guidance has a role in explaining how to comply, but it cannot be the compliance obligation itself. For people with disability, an obligation that airlines and airports are merely “encouraged” to meet means the passenger cannot rely on it when planning a trip, which is exactly the uncertainty the paper identifies.

The existing law does not give passengers or operators enough certainty. The Transport Standards are not tailored to air travel, and the way the DDA interacts with aviation law makes it hard for a person to know whether a complaint will succeed and easy for an operator to obscure liability. JEC, which has represented passengers in complaints against airlines and airports in the Australian Human Rights Commission and the Federal Court, reports that operators have had many opportunities to fix these problems voluntarily and have not done so. Self-regulation is not a credible option.

Detailed regulation is also feasible. Australian airlines that fly to and from the United States demonstrate this in their current approach. As JEC notes in its submission5, Australian airlines that fly to and from the United States already meet the more detailed US rules on those routes, and offer a lower standard of access on domestic flights and on other international routes. They can comply without changing their business model. Without Australian regulation, they choose not to do so.

4.2 Enforcement, oversight and remedies

A key issue that has been raised in successive reviews of the Transport Standard is the lack of any real monitoring or reporting mechanisms, meaning that compliance with the Transport Standards is effectively unenforceable.6 Enforcement of disability standards currently depends on an individual lodging a complaint, usually after the harm has occurred, and bearing the burden of the process. People with disability should not have to bear that burden.

AFDO recommends that the aviation disability standards are accompanied by:

• an oversight function with the power to monitor compliance proactively, to audit operators, to act on systemic patterns in reported data, and to apply meaningful penalties. AFDO recommends that the Australian Human Rights Commission (AHRC) is given this role and is funded to carry it out. The AHRC already has functions under the Australian Human

Rights Commission Act 1986 (Cth),7 and the expertise of the Disability Discrimination Commissioner. We also note that the AHRC has noted its concern with the current operation of the Transport Standards (and the other Disability Standards8) due to the lack of appropriate accountability mechanisms for their implementation.9 The AHRC has proposed10 that it have regulatory powers to enforce disability standards. The Disability Royal Commission identified the lack of a government body to monitor compliance as one of the most significant weaknesses of the Transport Standards

• a clear, accessible complaints pathway that operators must tell passengers about at the time of any refusal, delay or damage
• direct remedies in the standards, such as rebooking, refund, replacement of aids and compensation for costs, rather than leaving remedies to separate processes, and
• an express statement that the standards do not reduce any existing right under the DDA or the Transport Standards.

4.3 Consistency, with proportionate tiering rather than exemption

Industry has raised the resourcing constraints of smaller and regional airports and airlines. AFDO accepts that some obligations may need staged implementation or lighter-touch forms. But regional and remote passengers often have no alternative to the services concerned, and the barriers they face are often the greatest. AFDO therefore supports tiered obligations based on size, with every operator subject to a core minimum, rather than blanket exemptions. Tiering should change how an obligation is met and not whether it applies. In particular, the duties to have a disability reference group (section 5.3) and to report on compliance (section 5.4) must apply to every airline and airport. Where regional airports need funding to meet the Standards, AFDO supports that funding being provided by government. AFDO does not support the cost being recovered from passengers with disability through fees or fare differences (or otherwise).

4.4 Dignity, autonomy and consent

The co-design principle of “nothing about us without us” is a principle about design. It is also a principle about how staff treat passengers. People with disability are the experts on their own bodies, aids and support needs. Across the standards, AFDO wants to see: informed consent before any physical contact or transfer, respect for a person’s chosen method, no requirement to disclose a diagnosis, and a right to refuse an unsafe method without losing the right to travel.

4.5 The whole of disability, and intersectionality

Much of the Consultation Paper, and much of existing industry practice, is built around wheelchair users. People with sensory, intellectual, cognitive and psychosocial disability, neurodivergent people, and people with non-visible disability also face serious barriers and are affected differently by many of the proposals. AFDO asks that, for each of the provisions in the Standards, the Department tests them with these groups: for example, assistance that relies on a phone call, a website timeout, a security process that involves unexpected touch, or a noisy and overstimulating environment.

The Consultation Paper notes that intersectionality is not explicitly addressed because the Standards sit under the DDA. AFDO accepts that limitation for this consultation (noting that this remains a significant limitation of the DDA to account for and address intersectionality of barriers or exclusion). However, we ask the Department to use the user guides, the reference group guidance (section 5.3) and the reporting framework (section 5.4) to ensure that the voices of First Nations people, people from culturally and linguistically diverse backgrounds, women, girls and gender-diverse people, LGBTIQA+ people, children, older people, and people in regional and remote areas with disability are heard and their experiences are addressed.

4.6 Fit with other reforms and with safety regulation

The Standards sit alongside several other processes and regulatory or compliance regimes, including the reforms to the Transport Standards, the Aviation Consumer Protections Framework and Charter (including the remedies for damaged mobility aids), the review of the DDA, the Assistance Animal National Principles, the Premises Standards, and CASA’s safety regulations. AFDO supports alignment between these. We also ask that the Department ensures there are no gaps between or among them. For example, a remedy that is “out of scope” for the aviation disability standards should be clearly provided for elsewhere. Further, a passenger should not need to understand which framework applies to make a claim or complaint.

On safety, AFDO accepts that safety is paramount. However, “safety” and “operational requirements” are the reasons often given for limiting access for people with disability, and they are rarely explained. AFDO asks that, wherever the Standards permit a restriction for safety reasons, the airline or airport must be required to identify the specific safety basis, publish it, and make it available to the oversight body on request.

Restrictions based on convenience, turnaround time, or cost are not safety reasons.

4.7 The cost-benefit analysis

The Consultation Paper states that a cost-benefit analysis will inform decisions. AFDO asks that the analysis:

• value the costs of the status quo borne by people with disability, including avoided travel, health harm (for example from restricting fluids to avoid using a toilet), damaged or lost aids, lost income, lost opportunities to travel for work, health care and family, and the cost of passengers’ time
• count non-monetised benefits such as dignity, autonomy and participation, which the paper itself identifies as central, and treat them as benefits rather than “intangibles”
• take account of the benefits to the wider travelling public (older people, parents with prams, people with temporary injuries) and to the tourism economy
• distinguish one-off from ongoing costs, and account for industry cost-offsets (for example, fewer injuries to staff from unsafe manual handling), and
• present the distributional impact on regional and remote communities separately.

4.8 Implementation

AFDO recommends:

• staged commencement dates that are published in advance and are firm
• co-design of user guides with people with disability (to which the White Paper commits)
• an exposure draft that allows a further round of public consultation on the wording and formats of any user guides
• a requirement that operators publish (in accessible formats) their implementation plans, and
• a built-in review of the Standards as part of the 2027 statutory review of the Transport Standards, with a clear commitment to deal with any items deferred to that review.

4.9 Co-design needs guidance and accountability

Several of the proposed standards require operators to consult or co-design with people with disability. Where proposals refer to “consultation”, AFDO’s clear preference is for “co-design”.

The disability reference groups proposed in section 5.3 are central to this. Reference groups should not be the only input operators seek. The scale of co-design needs to match the significance of the project. A minor change to a facility may need only the reference group, while a major terminal redevelopment needs a wider process that reaches the full range of users, which the reference group could take part in, oversee, or lead.

AFDO recommends that the Standards or their guidance notes define what co-design is, how it should be conducted, and what it requires in different circumstances. The Standards or their guidance notes also must state expressly that engaging a reference group does not always discharge an operator’s co-design obligations. The Department should also consider an independent assessment or accreditation mechanism, so that there is a consistent, expert view of whether a process was genuine, representative and responsive. AFDO recognises the practical questions this raises, including which body would do it.

5 Chapter 1: Whole of journey

5.1 Set out the roles and responsibilities of airports and airlines (Item 1.1)

Preferred approach: Regulatory. Option 2: the airport is the single body responsible for assistance throughout the journey, other than on board the aircraft.

AFDO supports Option 2.

The most important outcome is that a person with disability never finds themselves in a gap between two organisations. That is the current experience: help at the departure airport but none at the destination, stranded kerbside, or left without help to reach a connection. Any option must be judged on how it fills or prevents those gaps.

Responsibility should sit with the entity best placed to deliver the service, and the arrangement should be the same at every airport.

Airports manage the terminal infrastructure. An airport is also responsible for assisting people through that infrastructure and has a direct incentive to find and remove barriers in it. Airlines hold the customer relationship but do not control the terminal and cannot change it. Splitting responsibility for the service from control of the infrastructure weakens that incentive. This is the reason why AFDO does not support Option 3.

Option 2 is the model used in the European Union11. Further, we note JEC’s submission12 reports that industry in the United States and Canada (where airlines are responsible) has said airport responsibility is preferable.

AFDO does not support Option 1. Shared responsibility is the arrangement most likely to leave gaps, and to confuse passengers and staff, particularly because airport layouts and procedures differ. JEC’s casework includes people left stranded at airports without assistance, sometimes at risk of harm, where the airline and the airport each later explained that it believed the other was assisting.13 Option 1 would allow that known failure to continue.

We recommend that Option 2 is adopted with the following features:

• A single accountable body. The airport should be the one body responsible for ensuring assistance at every stage of the journey except on board the aircraft, including between terminals and to onward ground transport. Airports and airlines already work together across many areas of aviation, and an airport remains free to arrange with airlines how a service is delivered or how its cost is shared. Those arrangements must not move the responsibility, and the passenger deals with one entity.
• Information flows with deadlines. Airlines must pass assistance requests to the relevant airports and ground handlers within a set time (Option 2 suggests 48 hours) and airports must confirm receipt. Without this, the airport cannot deliver what Option 2 requires of it.
• No gaps between zones. The standards should state expressly that the airport’s responsibility covers every segment, including the airside areas between security and the gate, security screening itself, and the baggage hall to the kerb, and should state where and how the hand-over to the airline at the aircraft door takes place. This includes toilets, food and waiting time between security and boarding.
• Assistance is free. The standards should prohibit any fee for assistance, and any suggestion that costs are passed on to passengers.
• Published responsibility maps. Each airport and airline should publish, in accessible formats and in its Disability Access Facilitation Plan, who is responsible for what at each airport.
• Assistance from outside the terminal. Because the responsible body must assist passengers to onward ground transport, it should equally assist them from every entry point to check-in. Designated points at public transport stops, car parks and drop-off zones should let a passenger give notice of their arrival and be met outside the terminal building, as the European Union requires14.

AFDO acknowledges that there are barriers to implementing Option 2. These barriers include the following:

• Airports do not hold passenger information, so information-sharing arrangements are essential (see section 6.1).
• Airlines do not have staff outside the terminal and regional airports have few staff. These are reasons for a funded, tiered approach (Section 7.3), including the funding for regional airports that industry itself has suggested, and for clear contractual arrangements between airlines, airports and ground handlers.

However, these barriers are not reasons to leave the allocation of responsibility unclear.

Specific questions asked in the Consultation Paper

Which option is most effective and transparent?

Option 2 with the features above. Option 1 (shared responsibility) would preserve the gaps between organisations that leave passengers stranded today. Option 3 (airline responsibility) would require airline staff to work in areas they do not control and would separate responsibility for the service from control of the infrastructure.

Assistance from all entry points to check-in?

Yes. AFDO supports assistance from every entry point, including car parks, public transport and kerbside drop-off. In practice, this requires a clearly signed meeting point or call point at each entry (see section 7.3), a staffed or on-call assistance service and, where the passenger has an assistance profile, advance notice to the airport so it can plan resourcing.

Food and shopping outlets?

Yes. A passenger who needs a push in an airline chair should be able to reach toilets, food, drink and shops on the same basis as other passengers, and be told how to request help. At minimum, staff should offer these opportunities and return to the passenger at a scheduled time.

Who coordinates connecting flights and terminal changes?

The airport, as the responsible body, using the booking and assistance information that the airline must give it. Where the connection is on a separate booking or with another airline, the airport’s assistance service should take the passenger to the onward airline, and the passenger should not be left without help between the two.

5.2 Make sure staff are trained to support people with disability (Item 1.2)

Preferred approach: Regulatory, building on the reforms to the Transport Standards and the aviation-specific outcomes in the Consultation Paper.

AFDO strongly supports the regulatory option, but it falls short and should be expanded. Training was raised in every co-design workshop as a systemic issue, and the Transport Standards reforms alone would not address aviation-specific risks such as transfers, aid handling and security screening. We recommend the following strengthening.

(a) Baseline training for all staff, with tiered, role-based content. Airports raised that construction contractors, for example, have no role in assisting passengers, and cautioned against training staff who do not deal with customers. AFDO does not accept that these staff should be left out. A baseline level of disability awareness training for

every member of staff shapes an organisation’s culture and reinforces its habits and values. Many of the poor experiences passengers report come from attitudes, not only from gaps in technical skill. This is consistent with the new requirement in the Transport Standards that training be tailored to different roles and responsibilities. The content should be tiered:

(i) a short baseline module for all airline and airport staff, whether or not their job brings them into contact with passengers, including contractors, call centres, cleaners and retail staff

(ii) full role-specific training for staff who assist or make decisions affecting passengers, and

(iii) practical, in-person, competency-assessed training for anyone who transfers passengers or handles aids.

(b) Disability-led. Training must be designed with, and delivered or co-delivered by, people with disability or disability-led organisations, and those people must be paid. The reforms already require consultation with disability representative groups and a qualified trainer. The Standards should add that the content must be co-designed and delivered (or co-delivered), not merely consulted on.

(c) A national outcomes framework. AFDO supports the industry suggestion of nationally developed training modules or a national list of approved programs, developed with people with disability. This would also give regional operators an affordable, ready-made option, and would make training content transparent. Programs should be outcomes-based, with mandated minimum content and mandated minimum practical components.

(d) Public information. AFDO supports the proposal that operators publish high-level information about their programs on request. We recommend that they publish it proactively, on their websites, in accessible formats.

(e) Contractors. The obligation must reach ground handlers, security screening providers and call centres, and operators should be required to include training requirements in their contracts.

(f) A Commonwealth module for security screening. At minimum, the Commonwealth should produce a national disability awareness or confidence training module for security screening staff. Screening is one of the hardest stages of the journey (section 7.7), and a single module would remove the variation between airports and screening providers.

(g) Co-design when programs change. Programs should be co-designed and delivered by disability-led organisations, and co-design should be required again whenever an airline or airport changes its training program.

(h) No “commercially sensitive” carve-out. The information operators provide about their training programs should not exclude material on the ground that it is commercially sensitive. That exception invites broad claims and reduces public accountability. Training staff to support passengers with disability is a basic part of an accessible service and should not be treated as a matter of commercial competition.

AFDO acknowledges that there are barriers including the following:

• Regional workforce size
• staff turnover, and
• the cost of face-to-face practical training.

AFDO supports funded access to the national modules for regional operators and recognises that practical training may need regional delivery arrangements. We do not accept that these barriers justify weaker outcomes for people with disability.

Specific questions asked in the Consultation Paper

Training outcomes that should require in-person training and competency assessment

At minimum, the following matters must be the subject of in-person training and competency assessments:

(a) transfers and the use of hoists, slide boards, aisle chairs and other equipment

(b) handling, disassembling and reassembling mobility aids, including powered chairs and battery handling

(c) guiding people who are blind or have low vision, and communicating with people who are d/Deaf, hard of hearing or DeafBlind, including the use of interpreters and relay services

(d) supporting people with intellectual, cognitive and psychosocial disability, and recognising and responding to distress or sensory overload in ways that respect the person

(e) interacting with assistance animals and their handlers

(f) assisting evacuation of passengers who need help

(g) screening of people with disability aids, implanted devices and medical equipment (section 7.7), and

(h) the “what not to do” rules, such as no hand-carrying (section 8.1), no transfer without consent, and no separation of a person from their aids, assistance animal or support person.

Competency should be reassessed at least annually, consistent with the annual refresh requirement in the Transport Standards reforms, with records kept and reportable (section 5.4). AFDO notes that comparable training and competency assessment requirements took effect in the United States on 17 June 202615, which shows that airlines operating there (including Australian airlines) can meet them.

5.3 Set up disability reference groups (Item 1.3)

AFDO supports the requirement for every airline and airport to set up and make use of disability reference groups. We recommend that the obligation applies to every airline and airport, with no minimum passenger threshold. This requirement gives practical effect to the principle of “nothing about us without us”. We also note that industry is broadly supportive. The question is whether the groups will have real influence. We recommend that the Standards require each of the following:

(a) Real influence. Groups must be consulted at the design stage, before decisions are made, and the operator must give a written response to the group’s advice, including where it does not adopt it. Operators should publish a summary of advice and responses.

(b) Remuneration and access. Members must be paid at a fair rate, and operators must meet access costs (Auslan interpreting, accessible materials, support persons, travel). Without this, only organisations and people who can afford to volunteer will take part.

(c) Independence and diversity. A majority of members should be people with disability or representatives of their organisations, with an independent chair or co-chair, and with representation of different disability types, First Nations people, culturally and linguistically diverse communities, and regional voices. These membership requirements should be set in the standards themselves and supplemented by guidance, not left to non-binding guidance alone. Membership decides whether a group is effective. JEC reports examples of groups drawn solely from an operator’s own employees with disability, which does not meet the principle of independence and limits the group’s ability to give frank advice.

(d) Transparency. Terms of reference, membership (with the consent of members) and meeting frequency should be published.

(e) Not the only form of engagement. Consulting the reference group will not always discharge an operator’s co-design obligations. Larger projects need a wider process (Part 3.9).

Specific questions asked in the Consultation Paper

What should the terms of reference cover?

Purpose and scope; the matters on which the group must be consulted (including significant changes to facilities, information and communications technology and websites, assistance profile systems, training programs, policies on aids and animals, disruption communication, wayfinding, and security processes); membership and selection; remuneration and access support; meeting frequency (at least twice a year as proposed, and more often during implementation); how advice is recorded and answered; publication; and how conflicts of interest are managed.

What threshold?

None. Every airline and airport should be required to have a disability reference group. A threshold would exclude many regional and remote locations, where barriers are often greatest and air travel is often essential. Guidance may provide for groups of a different size and scope for smaller operators, but it should not allow a small airline or airport to avoid having a group at all.

When is a shared group appropriate?

Shared groups may be appropriate for airlines in the same corporate group, and for airports under common ownership. They should not be used to dilute local voice. A shared group for a multi-airport owner should include local representation from each airport it covers, and decisions about a specific airport’s facilities should involve people who use that airport.

Airlines and airports at the same location could also form a joint group for whole-of-journey matters.

5.4 Report on how Standards are being met (Item 1.4)

AFDO strongly supports mandatory, public reporting. It is the main mechanism through which people with disability, regulators and the public can see whether the Standards are working.

We also note that this was a key concern of the Disability Royal Commission and the previous statutory reviews. We support the Consultation Paper’s proposal, including the additional annual reporting obligations for airlines. We recommend that the obligations apply to every airline and airport and cover a wider data set.

The history of the Transport Standards shows what happens without mandatory, public reporting. For more than two decades there was no national mechanism to monitor or assess compliance. Voluntary reporting gave operators little reason to remove barriers. That history

also raises questions about Australia’s compliance with Articles 31 and 33 of the Convention on the Rights of Persons with Disabilities, which concern data collection and national monitoring. By contrast, reporting has been required of US airlines since 2019. The reporting, including aggregate complaint logs and mishandled mobility device reports from 2019 to 2023, supported the US Department of Transportation’s US$50 million penalty against American Airlines in October 2024 for its treatment of passengers with disability and their mobility aids16.

In addition to the items to be included in any reporting data set, as proposed in the Consultation Paper, AFDO recommends data collection and reporting on each of the following:

(a) the number of passengers who requested assistance, and the number for whom the assistance was not delivered or was delivered late, as the denominator that makes the other numbers meaningful

(b) the number of mobility aids carried, so that damage and loss can be expressed as a rate, and the time taken to repair or replace aids and the outcome for the passenger

(c) time taken to return aids on arrival, and time people with disability wait to deplane

(d) decisions on assistance animal and dangerous goods applications, including time taken, refusals and reasons

(e) boardings denied or deferred because of a limit on passengers requiring assistance (section 6.2)

(f) the availability and status of accessible features by airport, such as aisle chairs, hoists, lifts and accessible toilets, including outages, and

(g) the outcomes of accessibility testing of websites, apps and kiosks.

Data should be reported by airport, route, and aircraft type where relevant, and in a form that can be compared between operators.

The reporting framework should prescribe the auditing methodologies and performance indicators to be used, as the development of the Transport Standards reporting framework has shown is necessary, so that data is consistent, comparable and able to show progress over time. AFDO notes that the United States publishes wheelchair mishandling rates by airline monthly17 and the UK Civil Aviation Authority publishes performance reports on airports’ accessibility in its annual Airport Accessibility Report18.

Reporting is necessary but will not secure compliance by itself, and a system that depends on individual complaints is ineffective (Part 3.2). The government needs a way to know whether the Standards are reducing barriers and to act when they are not. AFDO recommends that the AHRC is empowered to monitor compliance, investigate potential breaches and take enforceable action, and be adequately funded to do so. Independent oversight encourages compliance up front and gives people with disability confidence in the published data.

Specific questions asked in the Consultation Paper

Priorities for reporting?

Aid damage and loss (rates and outcomes), refusals of carriage, assistance not delivered, and complaints with outcomes. These are the areas where harm is most direct and where passengers currently have no visibility.

Thresholds?

None.

Every airline and airport should report on compliance with the standards, regardless of size, and airlines should report the aid, refusal, training and complaint data regardless of size, as the paper proposes. Limiting reporting to larger operators would mean that barriers at smaller, regional and remote locations are never identified, and that non-compliance persists there.

Should government publish the data?

Yes, centrally, annually at minimum, in accessible formats and as open, machine-readable data. Operators should also publish their own results. This is not either/or. Government publication should also cross-check airline-reported complaint numbers against complaints received by the AHRC, state and territory bodies and the Aviation Consumer Ombuds Scheme, so that under-reporting is detected.

Is annual reporting feasible?

AFDO considers annual publication to be the minimum. Data on aid damage and delays should be collected continuously, and AFDO would support six-monthly publication of that data (noting that this data is published monthly in the US).

Transitional arrangements?

A 12-month period to establish data collection against standard definitions (co-designed with people with disability), a first baseline reporting year, and then public reporting. Operators with persistent poor results should be required to publish a remediation plan and its progress in implementing that remediation plan.

International examples?

The United States, Canada and the European Union examples cited in the Consultation Paper, and the examples in the US and UK cited above.

6 Chapter 2: Planning and booking air travel

6.1 Offer passenger assistance profiles (Item 2.1)

AFDO strongly supports passenger assistance profiles. The repeated burden of re-explaining the same needs for every flight, and the failure of that information to reach staff on the day, were consistent themes in the co-design workshops. Industry’s view that a global solution is needed must not delay action in Australia. The Standard should require airlines operating in Australia to offer a profile within a fixed period, using existing industry codes as an interim measure, and should require profiles to be interoperable so that they can be shared easily between airlines and airports.

AFDO recommends that a passenger assistance profile is designed and implemented according to the following principles.

1. Optional, passenger-controlled and consent-based.

A person who does not have a profile must still receive the services they need. No one should be disadvantaged for not creating one. For those who do, the profile should let them travel with the same flexibility as other passengers, without having to give fresh advance notice for each trip (section 6.3).

2. Data minimisation.

The profile should record what a person needs, not their diagnosis. Airports and ground handlers should receive only the assistance information they need to deliver their part.

3. Wider content.

In addition to the items identified in the Consultation Paper, the passenger profile must allow a person to disclose each of the following:

• communication needs and preferred channels (Auslan, text, Easy Read, no phone calls)
• preferred transfer method (section 7.10)
• preferred boarding approach (section 8.1)
• assistance needed at each stage of the journey
• sensory and non-visible disability supports

• emergency contacts, and
• authorised representatives who may manage the profile on the passenger’s behalf, including family members, support workers and travel agents.

4. Reusable approvals.

Approvals for assistance animals (section 6.5), batteries and dangerous goods (section 6.6) and aids needing assessment (section 8.3) should attach to the profile and remain valid for up to 12 months or until the aid changes, whichever occurs first.

5. Accessible to use.

The profile system must meet WCAG 2.2 AA standards (at least). The profile system must also have non-digital, accessible alternatives.

6. A designated airline contact.

AFDO supports the proposal for a designated airline contact rather than a generic line, with a maximum response time also mandated.

Specific questions asked in the Consultation Paper

What information should be included?

See design principle 3 above.

How long should information be held, and how should it be stored and shared?

Information should be held as part of the passenger profile until the passenger deletes it. The system must include an annual prompt (provided to each passenger with a profile in an accessible format) to review their profile and to update any relevant information. All information in a profile must be handled as sensitive information under the Privacy Act 1988 (Cth), used only for the purpose it is provided, and never shared with third parties other than with the person’s prior, fully informed consent. Passengers should be able to see (or request to see) who has received their information.

Can information be shared across airlines and airports?

Yes, with the passenger’s consent, limited to what each passenger needs, and with an audit trail.

6.2 Clarify times when limits on passengers requiring assistance may apply (Item 2.2)

AFDO opposes any blanket numerical limit such as a “two-wheelchair” policy.

The regulatory option proposed in the Consultation Paper permits limits where there is a “significant safety or operational issue”. “Operational issue” is too broad. Industry has said

turnaround times and low-cost operating models are a reason for limits. Those are commercial considerations, not safety or valid “operational” considerations. Allowing an “operational issue” justification would almost certainly lock in the status quo.

In King v Jetstar Airways Pty Ltd19, upheld on appeal20, the Federal Court of Australia found that Jetstar’s two-wheelchair policy was discriminatory but lawful under the DDA, because removing it would have caused the airline “unjustifiable hardship”. That finding rested heavily on the airline’s operating model, including the effect on its profit, on its fares and schedule, and on delays to other passengers. Airlines have relied on that decision to defend similar limits ever since. A passenger who wants to challenge a limit faces speculative, expert-heavy and expensive litigation. As a result, the limits go unchallenged. If the Standards permit limits for “operational” reasons, airlines will keep them, relying on the King decision.

Australia’s domestic airline market has very little competition. The ACCC explicitly describes domestic aviation as “one of the most concentrated industries in Australia”21. A person with disability should not be pushed towards a full-service airline because a low-cost carrier caps the number of passengers it will assist based on its operating model and effect on its profit. Equal access to air travel must mean equal access to every carrier.

AFDO recommends that:

• the Standards prohibit airlines from limiting the number of passengers who require assistance on a flight, except only where a limit is necessary for genuine safety reasons that are referable to the regulatory framework for civil aviation safety or where the size of the aircraft or its doors makes the embarkation or carriage of that person with disability physically impossible. This would set one rule for all carriers and align Australia with the United States22 and the European Union23
• where an airline relies on the safety exception, it must:
  • demonstrate the specific safety basis for the aircraft type and configuration, for example by reference to evacuation analysis, and
  • publish, in accessible formats, the basis
• the Standards expressly prohibit any limit justified on turnaround, cost, operating model, or on-time performance grounds
• passengers who need assistance only within the airport, and not to board or evacuate an aircraft, do not count toward any limit (as the Consultation Paper proposes)
• any safety-based limit be shown at booking, with remaining capacity visible, and be applied when the passenger books, so that a confirmed booking is never cancelled to make room

• for a later request
• where a group of passengers requiring assistance travels together, the airline be required to work with the group on a solution, and not simply refuse some of them, and
• the number of boardings denied or deferred because of a safety-based limit be reported (section 5.4).

Specific question asked in the Consultation Paper

Should airlines publish their operational and safety reasons?

Yes (noting that AFDO does not support “operational reasons” as a valid basis for limiting numbers of passengers with disability).

Publication by aircraft type is a basic transparency measure, enables independent scrutiny, and would show whether limits are justified.

6.3 Services must be provided when passengers give advance notice (Item 2.3)

AFDO supports the 48-hour rule as a guarantee. If a passenger asks at least 48 hours ahead of the scheduled departure time, the service must be provided. However, the 48-hour timeframe should operate as the point at which the guarantee applies to the provision of assistance to the passenger. It must not apply as a condition for receiving any service.

Advance notice requirements limit the ability of people with disability to travel on the same basis as everyone else. The United States does not require advance notice for most assistance24, which shows that airlines can meet many needs at short notice. Examples of types of assistance that require preparation time that airlines in the US may require up to 48 hours’ advance notice include respirator hook-up, and transportation of an electric wheelchair on an aircraft with less than 60 seats.25

AFDO recommends that:

• services that do not need special equipment or scheduling (for example, wheelchair assistance within the terminal) be available without notice
• “every reasonable effort” where less than 48 hours’ notice is given be defined, with the airline bearing the burden of showing why it could not provide the service. Assistance should be declined only where a genuine safety or operational (and not commercial) reason prevents it, and never merely because it would cost more. Whether the airline has met the same need before should be relevant: where it has, and the person’s needs have not materially changed, there should be a strong expectation that it can do so again
• written confirmation, in an accessible format, be given within a short, fixed period (24

hours) of the request, and failure to deliver a confirmed service trigger a remedy, such as rebooking, refund or compensation

• notice be given once, through the passenger assistance profile, for the whole itinerary including the return journey, and not separately per flight or per airport
• “reasonable accessibility related service” be defined so that it does not become an unconstrained ground for refusal
• the standards include a non-exhaustive list of the accessibility services and processes to which the 48-hour notice rule applies. Several other sections of the Consultation Paper set timeframes for particular services. It is not always clear why those services would sit outside the 48-hour framework, and
• airline and airport reservation and administrative systems are required to pass a person’s accessibility needs, clearly and on time, to the staff who will deliver the assistance, as US rules require26.

Specific question asked in the Consultation Paper

Requests that take longer or shorter than 48 hours.

Some arrangements, such as stretcher travel, in-flight oxygen, or unusual aid loading, may legitimately need longer lead times, and those categories should be specified and published, with a specific time within which any request must be made, and within which any decision must be given.

Simple requests, such as terminal wheelchair assistance and priority boarding, need little or no notice.

AFDO’s view is that an airline should be required to process requests more quickly, and not require passengers to notify earlier.

6.4 Make sure people with disability access the same fare regardless of the method of booking (item 2.4)

AFDO supports the regulatory option.

We consider existing practice inadequate.

People with disability being sent to a phone line, with longer waits and sometimes higher prices, was a clear co-design finding. JEC’s clients report being unable to book online, and having to call to give accessibility information before a booking can be made27. The extra time can mean missing the preferred flight, or being unable to book at short notice. The inequity is greater where sale fares are offered online only.

We recommend that the Standards:

• require the full online booking path to be accessible, including nominating accessibility needs, so no one must phone to complete a booking
• require a fare hold. Where a person starts a booking online and must switch to a different channel, the price shown must be held for a reasonable period (for example 24 hours). This addresses industry’s point about dynamic pricing
• cover all fees and surcharges, not only the base fare, so that no differential fee based on or determined by booking-method is payable, and
• require several accessible channels, including chat, email, text relay and video relay, and set a maximum phone wait or a call-back option.

We recognise that travel agents and third-party platforms are outside the Transport Standards. However, we ask the Department to consider how airlines should be required to give agents the information and functions needed to book accessible travel.

Specific question asked in the Consultation Paper

What session time is accessible?

No single session time will meet everyone’s needs. AFDO recommends a warning (in accessible formats) is given within a reasonable time before the session expires, together with a simple one-step way to extend the session, consistent with WCAG’s timing-adjustable requirements. We also suggest a default period of at least 30 minutes.

6.5 Clarify rules for carriage of assistance animals on aircraft (Item 2.5)

AFDO supports national consistency in how airlines process and decide requests for the carriage of assistance animals on aircraft, aligned with the DDA definition and the National Principles for the regulation of Assistance Animals28.

People who rely on assistance animals continue to experience inconsistent airline policies, unnecessary approval processes and restrictions that can prevent them from accessing air travel on an equal basis with other passengers. Some airlines impose training and accreditation requirements that extend beyond those provided for under the DDA29.

The Full Federal Court has held, in a case about domestic flights, that an animal can be an assistance animal under the DDA if it has the relevant training, whoever provided that training30. However, the Civil Aviation Act 1988 (Cth)31 allows civil aviation regulations to be inconsistent with the DDA, and the Civil Aviation Safety Regulations 1998 let an operator or pilot refuse an assistance animal if they reasonably believe its carriage may adversely affect the safety of air navigation.32. Further, CASA says that operators “may” require dogs to meet

Assistance Dogs International standards33. The circular is only guidance, but airlines rely on it to justify strict training and accreditation rules.

We recommend the following, with the detail to be settled after consultation with people who use assistance animals:

1. Recognise all assistance animals covered by the DDA. This must include animals meeting the requirements of section 9(2)(c), regardless of whether their training was provided by an accredited organisation. Airlines must not impose accreditation requirements that unnecessarily exclude otherwise recognised assistance animals. As the DDA definition is not limited to dogs, requests involving other animals must be individually assessed, subject to applicable aviation safety and biosecurity requirements.

2. Establish nationally consistent evidence and approval requirements. The Standards should prescribe the information airlines may reasonably request, consistent with the DDA, and establish a common application and assessment process. Evidence requirements must be minimal, proportionate, accessible and non-discriminatory. Passengers travelling on itineraries involving multiple airlines should not be required to complete unnecessary duplicate applications. Airlines should coordinate approval arrangements and identify any specific safety requirements before travel.

3. Require approvals to remain valid for multiple journeys. AFDO supports the co-design proposal for approvals to remain valid for up to 12 months, provided the relevant circumstances and safety requirements have not changed. Passengers should not be required to repeat the full approval process for each flight. Approvals should be recognised across airlines wherever consistent with applicable safety requirements, with a simplified renewal process.

4. Establish mandatory decision timeframes and consequences for airline inaction. AFDO opposes the Consultation Paper’s proposal that an application not determined within the required timeframe is deemed to have been refused. This places the consequences of airline inaction on the person with disability. Instead, the Standards should require automatic escalation of overdue applications, prompt determination by a designated senior decision-maker, accessible written reasons for any refusal and urgent review where travel is imminent.

Where airline delays prevent travel, passengers must be entitled to rebooking or a refund without additional charges. Overdue applications and refusals must also be recorded through mandatory compliance reporting. Airline inaction should not override unresolved

aviation safety or biosecurity requirements, but neither should it result in an automatic refusal without review and accountability.

5. Limit refusals to lawful, individualised and evidence-based grounds. Airlines must not refuse an assistance animal solely because of its breed, type, size, training provider or accreditation pathway. Refusals must be based on a specific and substantiated safety, biosecurity or other lawful ground, rather than general assumptions or blanket policies.

Relevant considerations may include whether the animal presents a direct threat to health or safety, demonstrates behaviour that creates a significant safety risk, or cannot be accommodated consistently with applicable aviation safety requirements, as reflected in comparable United States provisions.[vii] Before refusing carriage, airlines must consider reasonable alternatives.

All refusals must be documented, explained in writing in an accessible format and subject to an effective review process. Decisions made by a pilot in command must also be recorded and reported.

6. Provide effective remedies when carriage is refused. Consistent with AFDO’s recommendations under section 6.13, a passenger whose assistance animal is refused carriage must be offered a refund or suitable alternative travel arrangements without additional charges. Where a refusal is unlawful or discriminatory, the passenger must retain access to appropriate complaints, compensation and other remedies.

7. Extend accessible check-in arrangements to international travel. AFDO supports the proposal to enable online check-in for domestic passengers travelling with approved assistance animals. This should also extend to international flights wherever practicable, subject to mandatory animal health, biosecurity and destination-country documentation requirements.

Where in-person verification is necessary, airlines must provide clear information and accessible arrangements that minimise additional delays and inconvenience.

8. Provide appropriate animal welfare and relief facilities. AFDO supports reasonable requirements for relief accessories on long-haul flights, provided these do not compromise animal welfare or impose unreasonable burdens on handlers.

Airlines should provide appropriate disposal arrangements and must not require handlers to restrict an animal’s food or water in a manner that compromises its health. Airports should provide accessible and appropriately located assistance animal relief facilities, including

within secure areas where practicable, consistent with AFDO’s recommendations under section 7.8.

9. Ensure consistency between the Standards, national assistance animal principles and CASA requirements. The Australian Government should work with CASA, the Australian Human Rights Commission, people who use assistance animals and their representative organisations to review existing guidance and clarify the interaction between aviation safety requirements and disability discrimination protections. This should include reviewing accreditation requirements that go beyond what is necessary for lawful and safe carriage, establishing consistent guidance on acceptable evidence and ensuring that airline policies do not impose unnecessary restrictions.

AFDO considers that the proposed Standards must provide certainty for passengers and airlines while ensuring that aviation safety obligations are applied consistently, transparently and without discrimination.

The detailed requirements should be finalised through further co-design with people who use assistance animals and their representative organisations, in consultation with airlines, CASA and relevant government agencies.

The fundamental requirement must be that people with disability who rely on assistance animals recognised under the DDA can access air travel on an equal basis with other passengers, subject only to lawful, necessary and demonstrable aviation safety and biosecurity requirements.

Specific questions asked in the Consultation Paper

Is 48 hours appropriate for a decision?

Yes, for a complete, new application. Decisions on a previously approved animal should be immediate. The clock should start when the application is complete. For any incomplete application, the airline must tell the handler within 24 hours what is missing.

Would a national form help?

Yes.

Further, any form must be accessible, pre-fillable and reusable. It must also be consistent with the DDA’s limits on the evidence that can be requested, and should not ask about the handler’s diagnosis.

What is the minimum evidence?

Accreditation under a state or territory law, by a prescribed organisation, or by an internationally recognised organisation, should be accepted without further evidence. Otherwise, a signed handler declaration, covering the animal’s training to assist with the person’s disability and to meet hygiene and behaviour standards, should be sufficient, with no demonstration or interview. The data in the Consultation Paper show that accreditation does not prevent problems, and so the evidence rules must be clear and short.

Staff time per request?

This is a question for industry.

6.6 Explain how passengers can get approval for equipment classed as dangerous goods (Item 2.6)

While recognising that dangerous goods safety rules are set by CASA and are not negotiable, AFDO supports standardising the information and fixing the decision timeframe. The process can be made easier and more predictable. We recommend each of the following:

• a single national information checklist for batteries and mobility aids, consistent with CASA requirements and the airlines’ dangerous goods procedures
• portable approvals. Once a particular aid and battery has been approved, the approval should attach to the device and the profile, remain valid for up to 12 months or until the aid or battery changes (whichever is earlier), and be accepted across the airline’s flights without being re-assessed each time
• a 48-hour timeframe for a decision for a new device, the same-day for a previously approved device, and a requirement that the airline identify any missing information within 24 hours so that the 48 hours is not consumed in silence
• the same position on deemed refusal as for assistance animals: if the airline fails to decide, it must rebook or refund at no cost, and the failure must be reported as a refusal
• a named contact who can make a decision, and an expedited process for urgent travel,
• consideration of a shared register of pre-assessed mobility aid models, which would reduce repeat assessments across the industry; and
• protection for the full range of aids and battery types that people use. The Standards should define the batteries covered by category, for example by watt-hour thresholds, and not by reference to particular aid models, and should define the categories broadly so that they keep up with changes in technology. Any register of models should add to that protection and not limit it.

Specific question asked in the Consultation Paper

What timeframe is appropriate?

48 hours for a new device, with shorter timeframes as recommended above. Where the application is made later, every reasonable effort must be made, and a late request must not be refused simply because of timing.

6.7 Ensure disability aids can be transported for free and in-cabin, where possible (item 2.7)

AFDO supports the proposal that disability aids do not count towards baggage allowances and attract no fees.

We recommend that the Standards:

• cover everything within the DDA definition of disability aid, including consumables such as medication, stoma and continence supplies, feeding supplies, spare batteries and chargers, repair kits and portable ramps, and communication devices, and allow reasonable quantities for the length of the journey plus delay
• prohibit any fee for the carriage, handling, packaging or storage of an aid, including large or heavy aids and aids that fold into a case
• allow people who use more than one aid to carry all those they reasonably require
• exempt aids needed in flight from carry-on size and weight limits, since the proposal would otherwise leave airline size limits in place and make some necessary aids ineligible
• require a standard one-page aid information summary on each airline’s website, in a consistent structure, and in accessible formats, and
• require airlines to decide a request to transport a disability aid within 48 hours, where the passenger has given at least 48 hours’ notice of travel, consistent with section 6.3.

Specific question asked in the Consultation Paper

Disruptions, where an aid is checked in?

Passengers should be able to retrieve a checked aid within a short, fixed period (for example, one hour) during a disruption, or be provided with an equivalent aid at no cost. Medical items needed within 24 hours should never be in the hold if they can be carried in the cabin.

Which aids should be included?

All those within the DDA definition, as noted above.

What information would help?

Clear lists by type of aid, what can go in the cabin and the hold, what documents are needed, how long approval takes, and a contact person, in a standard format (and accessible formats) across airlines.

6.8 Explain requirements for carers or companions travelling with a person with disability (Item 2.8)

AFDO supports a regulatory option, but the option proposed in the Consultation Paper is not sufficient.

The central principle is that requiring someone to travel with a carer is a last resort. The requirement must never be based on a diagnosis, the use of a wheelchair, or the airline’s unfamiliarity with a disability. The proposal would require each airline to keep a consistent policy, but it would not produce consistency between or among airlines, which industry itself has asked for.

We recommend:

• uniform criteria set in the Standards. The Standards must set out the criteria for when a person can be required to travel with a carer, developed following engagement with CASA and with people with disability and their representative organisations. This must not be left to each airline’s policy. Under those criteria, an airline may require a carer only where:
  • after reasonable adjustments (such as safety information in an accessible format), the person cannot understand or respond to safety instructions, or cannot respond in an emergency, and
  • this has been assessed individually, with the person’s input, by trained staff
• the criteria must be published before booking, and the person must be given written reasons and a way to seek review
• the airline pays where it requires the carer. Where an airline requires a carer for safety reasons, it should provide the carer’s seat at no cost, as in the United States34. The cost is the consequence of the airline’s decision. AFDO recognises that this has commercial implications, but a requirement that the passenger pay for the airline’s own safety decision cannot be justified
• wider support for carer travel. AFDO supports the guidance recommending carer discounts and asks that the guidance also encourage recognition of the Companion Card and equivalent schemes. The adjoining seat for a carer should carry no seat selection fee
• flexible naming of a carer. AFDO supports the proposed free changes up to one hour before domestic, and three hours before international, departure. We ask that a carer can be booked with name or other details as “to be confirmed”, because arrangements often

change at short notice, and

• increased scope of “carer”. The DDA definition includes assistants, interpreters and readers. The standard should cover paid support workers and Auslan interpreters.

Specific questions asked in the Consultation Paper

When should a carer be required?

Only in the narrow circumstances above. AFDO notes the airline position that cabin crew cannot assist with eating or toileting. Where a person needs that help, travelling with or without a support person is the person’s choice. It is not a condition the airline may impose unless the criteria are met.

Can airlines ask for proof of ability to travel independently?

A self-declaration should ordinarily be enough. If an airline has a specific, individual concern, it should discuss it with the person and give written reasons. A medical certificate should not be required (section 6.9).

Should the airline pay the carer’s fare where it requires a carer?

Yes (see above). Barriers are commercial rather than technical, and the cost is likely to be small, because the circumstances are narrow.

6.9 Clarify when airlines can ask for medical certificates (Item 2.9)

AFDO supports limiting the circumstances in which a medical certificate can be requested. It is an intrusive requirement that adds administrative and other costs to the passenger with disability. We support the three proposed triggers (reasonable doubt about completing the flight safely, in-flight medical oxygen, and stretcher or incubator travel), with the following changes:

• “reasonable doubt” and “extraordinary medical assistance” are vague. The Standards should require objective, published criteria, and should state that a disability, or use of an aid or an assistance animal, is not in itself a ground for doubt
• a certificate must never be required to justify an accessibility adjustment, an aid or an assistance animal
• certificates for stable, chronic conditions should be valid for up to 12 months or until the condition changes, and attached to the passenger assistance profile
• time limits for short-term conditions (for example, seven days for a communicable disease) should be set in guidance, and not applied to chronic conditions, and
• the provisions apply to airports as well as airlines. People with disability report being asked for medical clearances at security screening when there is no need. There is no reason to

limit the rule to airlines.

Specific questions asked in the Consultation Paper

Other circumstances?

AFDO does not support adding any further circumstances.

Should an additional medical review clause like the US one be adopted?

AFDO does not support the proposal as drafted. It would permit an airline to second-guess a clinician’s certificate, with the risk of discrimination. If the Department considers it, any additional medical review should be limited to a specific, documented and recent change in the person’s condition, and carried out quickly by an independent medical practitioner. The airline or airport should pay the costs. The passenger should receive a complete copy of the review and written reasons for any decision by the airport or airline based on the review and have a right of further independent review.

6.10 Provide clear information about accessibility options before booking (Item 2.10)

AFDO supports the regulatory option.

The reforms to the Transport Standards do not address aviation-specific information. We recommend a standard accessibility information statement that each airline and airport must publish, in a consistent structure, in accessible formats, and in machine-readable form so that booking platforms and agents can display it.

In addition to the Consultation Paper’s list, the information statement should include:

• by aircraft type and route: door and aisle widths, onboard wheelchair availability, accessible toilet availability, number of moveable-armrest seats, and the maximum aid dimensions and weights the hold can take
• any limit on passengers requiring assistance for each aircraft type, and live remaining availability at booking (section 6.2);
• the equipment and boarding methods available at each airport (aerobridge, ramp, lift or stairs only), and service hours
• typical times for aid return, and whether aids are returned at the gate or the carousel
• policies on assistance animals, carers, medical certificates and aids, and the time each approval takes
• the airline’s performance data published under section 5.4

• the 24-hour on-the-day assistance contact, and
• how to complain, and the remedies available.

We also recommend that airports are required to provide an information statement providing information about the services they offer for accessibility, including the accessibility of the airport’s ground transport.

For connections and codeshares, the information should cover the operating carrier.

Industry has asked for a phased approach for smaller operators. AFDO accepts a core set of mandatory items for all, with the extended set phased for smaller operators (Section 7.3).

Specific question asked in the Consultation Paper

What additional information would people find useful?

See our response above.

6.11 Offer information needed to book flights in multiple accessible formats (Item 2.11)

AFDO supports the regulatory option proposed in the Consultation Paper.

We recommend that:

• WCAG 2.2 AA is the minimum standard for websites, apps, emails, kiosks and push notifications, with a requirement to track new versions
• core booking information is available proactively in Auslan, Easy Read, Braille, large print and audio, and other information on request within a fixed period, for example 5 business days
• information is also available in community languages and, where relevant, First Nations languages
• booking channels include text-based and video options, relay services and a call-back option, in addition to a phone line
• the simplified booking mode proposed in the Consultation Paper is supported, provided it offers the same functions and fares as the standard site, and is not a lesser service, and users can choose it without disclosing a disability
• operators test accessibility with people with disability and with their disability reference groups, and publish an accessibility statement
• third-party accessibility “overlay” tools be treated as a supplement only. They do not make a site compliant and cannot replace accessible design, and
• timeouts be adjustable (section 6.4).

Specific questions asked in the Consultation Paper

Other formats?

Plain English; captioned and audio-described video; text-based chat; pictorial journey guides and social stories; and tactile materials.

Should terms and conditions be in Easy Read?

Yes.

At a minimum, the parts that affect accessibility, cancellation and refunds, conditions of carriage for aids and animals, and the consent terms for the passenger assistance profile, and booking confirmations.

6.12 Provide communication in accessible formats during disruptions (Item 2.12)

AFDO supports the regulatory option and recommends that it go further. The key risk for a person with disability in a disruption is not only that they receive the information late, but that their rebooking puts them on a flight that cannot carry them or their aid. We recommend:

• personalised notification through the channel the person chose in their profile, sent as soon as the change is known, and not only through general announcements
• an accessibility check before an aircraft swap or re-accommodation, using the passenger assistance profile, so that no one is moved to a flight that cannot carry them or their aid without their agreement and a workable alternative
• priority rebooking support, and a named contact, for passengers whose needs affect their options
• accessible accommodation and ground transport where a passenger is stranded
• no exemption from the communication duty where the disruption is outside the operator’s control, such as weather. The cause may excuse the delay, but it cannot excuse the failure to tell people, and
• a right to rebooking at the lower of the original and the new fare, or a refund, where the disruption means the service is not delivered or is not delivered in a reasonable time (section 7.5).

6.13 Communicate when passengers with disability or their disability aids are not accepted for travel (Item 2.13)

AFDO supports the proposal.

We recommend the following changes.

Written reasons must be provided quickly. A written notice “no later than 10 days” after a refusal is too slow. Reasons should be given in writing at the time or within 24 hours, identify the specific safety or legal basis, say what could resolve it, and say how to seek internal review and external complaint.

“Confirmed means confirmed.” Where an airline has confirmed in writing that it will carry a person or aid, it should not be able to refuse at the airport unless a new safety issue has arisen. This also solves the problem industry raised about third-party bookings. The airline should confirm acceptance for every booking, and not wait until the person reaches check-in.

A wider remedy must be available. Rebooking at the “lesser of the original and alternative fare” is a start, but if the next accessible flight on the airline is not within a reasonable time (for example 24 hours), the airline should rebook the passenger on another carrier, and pay for accommodation, meals, accessible transport and the carer’s fare in the meantime. Refunds must cover the carer’s ticket and be prompt.

Care at the airport must be provided. If a person is refused on the day, particularly in a regional location, the airline must ensure they are safe and supported.

The right to reasons and remedies should not depend on 48 hours’ notice having been given. The right must apply to every refusal.

Specific questions asked in the Consultation Paper

When should the passenger be responsible for rebooking?

The airline should be responsible wherever the refusal results from its own policy, equipment, staffing or decision. A passenger should only be responsible if they decline the airline’s alternative offer, and even then the airline should provide reasonable assistance or help.

When is refusal reasonable?

Only on a documented, individually assessed safety or legal ground, for example where an aid exceeds the physical limits of the aircraft’s hold after every reasonable adaptation, where a battery does not comply with dangerous goods rules, or where a required medical certificate is not provided.

It should not be reasonable because a person has a disability, uses a wheelchair or an accredited assistance animal, because of a numerical cap, or because of staffing, turnaround or cost.

6.14 Allow people with disability to choose seats that best meet their needs (Item 2.14)

AFDO supports extending the Transport Standards provisions as the Consultation Paper proposes, but the proposed option is not sufficient.

We recommend that the Standards also address each of the following:

• prohibit additional fees, including seat selection fees, where a person needs a particular seat because of disability (for example extra legroom, a moveable armrest, a bulkhead, or proximity to a toilet), without requiring the person to disclose a diagnosis or provide extensive proof. The Consultation Paper treats pricing as out of scope, but charging more for what a person needs because of disability raises a discrimination issue, and the question the Consultation Paper itself asks is whether airlines can assist without charging. A fee of this kind is a “disability tax”, and for some people it puts flying out of reach
• address the position of a person who needs more space than one economy seat provides. Comparable jurisdictions do not allow disability-related seating needs to result in extra cost
• require seat maps to identify accessible seats and their features (including moveable armrests, section 8.10) and show seat dimensions, with an explanation for any restriction such as exit-row rules
• ensure an airline cannot change an assigned seat without the passenger’s consent and an alternative that meets their needs, and keeps a carer in an adjoining seat
• require airlines to ask each passenger about their needs, and to “honour” those seating needs, as US rules do. A duty only to “take into account” a passenger’s opinion would let an airline give it little weight. People with disability are the experts on their own needs, and an airline should be able to depart from the passenger’s view of which seat suits them only where it has good reason
• enable airlines to designate priority seats for people with disability, which co-design participants asked for and the proposal does not address. Some US airlines already block seats on each aircraft for this purpose35, and
• ensure the online booking process lets a passenger record their seating needs, so that the choice of booking method in section 6.4 is real.

Specific questions asked in the Consultation Paper

Would the US blocked-seat model work in Australia?

Yes in principle. A set of accessible seats could be held in the booking system for passengers with disability, and released to other passengers at a fixed time before departure (for example when

check-in opens). This is consistent with the co-design request and with practice on other public transport.

How would seat selection work online?

Accessible seats could be flagged in the seat map, the passenger assistance profile could filter by need, and there could be a simple “ask for help choosing” option linked to a human channel. The passenger must be able to select without proving disability.

Can airlines assist without a fee?

Yes, by waiving the fee for these seats for people who need them, as above.

7 Chapter 3: At the airport

7.1 Allow people with disability to stay in their mobility device as long as possible (Item 3.1)

AFDO prefers Option 1, with some changes.

Option 2 relies on the concept of “absolutely necessary”, which the Consultation Paper acknowledges is open to interpretation. We note that airlines have told JEC36 that early hand-over reflects necessary operational limits. We are very concerned that under Option 2 airlines are likely to describe this current practice as “absolutely necessary”, and leave airlines requiring hand-over at check-in. A passenger will only be able to test whether this is “absolutely necessary” through costly litigation that turns on facts the airline alone holds.

A defined time limit gives passengers certainty and can be enforced.

We recommend that Option 1 is strengthened as follows:

• the passenger chooses where to hand over (check-in, gate, or the aircraft door or tarmac, where the boarding method allows), within the permitted window
• the time limit is a baseline
• the Standards must also require the transfer to take place as close as possible to the aircraft door unless the passenger chooses an earlier point, so that an airline able to offer a later transfer than the baseline must offer it. We note this is the position in the US.37
• the cut-off is published and justified by aircraft type and airport. The Consultation Paper’s example of 30 minutes before gates close should be a maximum, not a default. Airlines should plan loading so that mobility aids are loaded last and unloaded first, and not treat containerisation as a reason for early hand-over
• aids must stay with the person until the cut-off, including powered chairs and cushions.

• people at risk of pressure injury must be able to keep their own cushion
• airport or airline ground transport must carry the person in their device. Where passengers are bused to the aircraft, the airline or airport must provide an accessible vehicle, and not use the bus as a reason to take the aid early
• no one is left unattended. Where a person has transferred to an airline chair, staff should check on them at least every 20 minutes and offer toilet, food and drink opportunities at least hourly. The person should be able to summon help immediately by call button or phone. These checks sit within the general rule AFDO proposes in Section 11, that no passenger is left unattended for more than 30 minutes without their explicit consent.

Specific questions asked in the Consultation Paper

Which option?

Option 1, with the changes outlined above.

Reasonable time limit at the gate?

30 minutes before gate closure should be a maximum, and aircraft type may justify a shorter one but not a longer one, and must be explained.

Equipment to move aids from gate to hold?

Ramps, passenger lifts or ambulifts, belt loaders and custom containers suited to powered chairs. Industry is best placed to specify these, but the equipment that is available must not be left to chance at any airport.

Frequency of check-in?

Staff should check on them at least every 20 minutes and offer toilet, food and drink opportunities at least hourly. The person should be able to summon help immediately by call button or phone.

7.2 Provide accessible check-in facilities (Item 3.2)

AFDO supports the proposed regulatory option.

We recommend that the Standards also:

• guarantee a staffed, human alternative at no cost and with no longer wait, wherever self-service is offered, so that no one is forced into a digital-only process
• require kiosks to meet a recognised ICT accessibility standard38, with tactile controls, audio output and a headphone socket, screen reader support, suitable height and reach, privacy for audio, and a clear, easy way to call for help
• require bag drops to be reachable and operable from a seated position, with help to lift and

tag bags available

• require at least one accessible staffed counter or assisted bag drop to be open at all times in each check-in zone; and
• apply to all check-in kiosks and supporting self-service facilities, and not to a percentage of them. We note that the proposed option does not set a percentage. AFDO supports this. Universal design lets people with disability check in on the same basis as other passengers.

Specific question asked in the Consultation Paper

Has the 5% requirement for accessible counters worked?

In principle, AFDO supports a requirement for more than 5% of check-in counters to be accessible. Further, the obligation must extend to accessible counters (or an accessible counter) always being open and staffed. 5% of counters is a small share. At a bank of 20 counters, it means a single counter must be accessible, which can be closed or unstaffed.

AFDO asks the Department to review whether 5% is sufficient and to ensure at least one accessible counter is always open.

7.3 Install points throughout the airport where people can ask for assistance (Item 3.3)

AFDO supports the proposal, with suggested changes.

The threshold of one million passenger movements suggested in the Consultation Paper would exclude many regional airports, which are the airports where help is hardest to find. Any threshold for full compliance should be set as low as is feasible for an airport to support the infrastructure, with a scaled-down requirement below it. Passenger movements must not distinguish between domestic and international passengers. For example, Canberra airport, with 2,764,770 domestic passenger movements and 38,371 international passenger movements (in 2024-2025)39, should not be able to avoid providing assistance points in its international terminal.

Further, if the threshold for a “large” airport was dropped to 500,000 annual passenger movements (based on 2024-2025 figures), only four additional airports (Mackay, Karratha, Rockhampton and Proserpine) would be included40, compared to if the threshold is set at one million. It is also important to keep in mind that this type of resource benefits all travellers, not only people with disability.

AFDO recommends three tiers for compliance:

1. Large airports (above 500,000 annual passenger movements): the full requirement as proposed.

2. Medium airports (for example, 100,000 to 500,000): assistance points at the entry, check-in, security and gate area, which may be shared and may be delivered by call point.

3. Small airports (for example, less than 100,00 annual passenger movements) a clearly signed point and an on-duty contact number, with a named staff member responsible for assistance during operating hours.

At every tier, assistance points must be signed in accessible formats, usable by people who are d/Deaf or hard of hearing (not only by phone), and have seating. Response times should be specified, so that a call point is not simply a button. They should be located at kerbside drop-off and car park entries, terminal entries, check-in, security, each gate or gate cluster, arrivals and baggage claim, and near accessible toilets and quiet rooms. Airline staff must also be present at gates. The assistance point must be separate from the boarding queue.

7.4 Make wayfinding around airports consistent and accessible (Item 3.4)

AFDO supports Option 1 proposed in the Consultation Paper.

Non-regulatory options and existing practice would not resolve the issue. Option 2 by itself could still leave signage, symbols and navigation differing from airport to airport. This is unacceptable.

Option 1 delivers the nationally consistent approach that people need. Further, testing wayfinding with people with disability and their representative organisations must be a required part of developing and implementing the national approach of Option 1. The Department should begin that work now, with the aviation industry, people with disability and their representative organisations, and other stakeholders, on a firm and published timetable.

Specific question asked in the Consultation Paper

What should be standardised?

Pictograms for accessible facilities; colour, contrast, font size and sign height and placement; tactile and Braille information and maps; audio and tactile guidance; “you are here” maps with step-free routes clearly marked; consistent terminology (for example “assistance point”); signage for quiet and sensory rooms; and the standards for accessible navigation apps (screen-reader compatible, step-free routing, real-time).

Airport branding should not override consistency, as the European guidance the Consultation Paper cites recognises.

7.5 Provide information about travel changes and disruptions in accessible formats (Item 3.5)

AFDO supports the regulatory option proposed in the Consultation Paper, and the proposed list of formats, but with some changes. Information in accessible formats is necessary but not sufficient by itself. Co-design participants asked for proactive effort so that people are not left stranded. A person with disability caught in a disruption may need to arrange other travel or accommodation at short notice, with specific needs, through booking channels that may not be accessible.

We recommend that the proposed regulatory option also includes the following:

• use personalised notification and, for people whose profile shows they need help, proactive staff assistance when the gate changes, so that the person does not need to find and interpret a screen
• require announcements to be available in text on screens, so that they are visible to people who are d/Deaf or hard of hearing, and use hearing loops at gates and assistance points
• not rely on apps alone, and provide human assistance
• cover airport infrastructure disruptions, such as lift outages, and airport-to-airline coordination, as the Consultation Paper notes
• require the airline, where it can no longer deliver the service or cannot deliver it in a reasonable time, to give the passenger information about alternative flights that can carry them (and any aid), and to offer to rebook them at the lower of the original and the new fare, consistent with section 6.13, and
• require a refund where no suitable alternative is available, including where the change has defeated the purpose of the trip.

Specific question asked in the Consultation Paper

What formats are required?

The formats listed in the Consultation Paper, together with text announcements, hearing loops, plain language, and video relay or remote Auslan interpreting.

7.6 Improve access for arrivals at and departures from the airport (Item 3.6)

AFDO supports the regulatory proposal, but it is not sufficient.

In addition:

• the proportion of accessible drop-off, pick-up and short-term spaces should be set higher than the general minimum in the Premises Standards. People with disability travel with more luggage and equipment, take longer to load and unload, and often cannot use public transport
• free short-term parking should be available to holders of a disability parking permit issued in any state or territory, for long enough to allow an assisted drop-off or pick-up, with covered, step-free, well-lit paths to the terminal, and rest seating
• accessible taxi and rideshare ranks, and accessible shuttles and public transport interchanges, should be located as close as possible to the terminal entry and exit points, so that access is consistent whichever mode of transport a person uses
• the responsible body (the airport, on AFDO’s position in section 5.1) must designate points of arrival and departure both inside and outside terminal buildings, at which people with disability can, with ease, announce their arrival at the airport, request assistance and be assisted, as the EU requires41, and
• the limit to areas where an airport has “legal control” should not create gaps or absolve liability. Where areas (for example, car parks and ground transport areas) are operated by third parties, airports must be required to include compliance with the Standards in the relevant leases, licences, and other contracts.

Specific question asked in the Consultation Paper

What proportion should accessible spaces be?

See above, and in any case no lower than the current minimum.

Should the nominated number of accessible parking spaces be revisited?

Yes.

7.7 Provide clear information and priority for people with disability at security (Item 3.7)

AFDO supports the regulatory proposal.

Priority lines should be optional, available without proof of disability, and open to a person’s companions, carers, and assistance animal. Priority lines should not replace the need for every lane to be accessible and every screener to be properly trained.

Training is the most practically important piece of this section of the Standards. A large share of the unacceptable experiences at security screening are as a result of staff who do not understand disability or disability aids, lack training to deal with people with disability safely

and with dignity, and who apply procedures inflexibly. Screening staff who may be asked to give manual assistance should have to complete competency assessments (section 5.2). Training for screening staff must be disability-led.

We also recommend that the Standards require:

• consent-based screening: staff explain the process before screening, ask before touching or moving a person, and use the person’s preferred communication method
• a private screening room available on request, with the person’s support person and, where requested, staff of a particular gender
• no unnecessary separation from aids, assistance animals, interpreters or carers. Any necessary separation is for the least amount of time reasonably possible
• information about what to expect, in pictorial and accessible formats, is made available before the journey, with tactile or audio guidance as proposed, and
• a clear complaint path, incident recording and public reporting, so that it is clear who is accountable and how a complaint can be made and, if necessary, escalated, at the time.

Specific questions asked in the Consultation Paper

Implementation of a dedicated line at airports with more than one checkpoint?

AFDO supports the proposed threshold. Where a lane closes outside peak hours, the priority function should continue in any open lane. Priority assistance should be available at every airport that has security screening.

Other training outcomes? Competency assessment?

Yes, with competency assessment (section 5.2). In addition to the Consultation Paper’s items:

screening people with implanted devices, ostomies, insulin pumps, prostheses, powered chairs and assistance animals; sensory sensitivity; communication with d/Deaf, blind, DeafBlind passengers. And passengers with intellectual disability.

Small and regional airports?

These airports should not be excluded. Training can be provided through national modules, shared with remote supervision, and funded. A trained supervisor should be on call where there is not a full workforce.

7.8 Involve people with disability when designing accessible facilities at airports (Item 3.8)

AFDO supports the regulatory proposal, but it is not sufficient. Co-design must be real (see also section 4.9). The airport must explain how the advice shaped the design. Larger projects need a process wider than the reference group (Part ##).

We recommend:

• the Standards mandate that all airports provide specific accessibility features and facilities, drawing on those identified in co-design and in responses to the Consultation Paper, so that there is a baseline of access that is consistent between airports
• the Standards set a timeframe for providing those facilities, so that the obligation is not triggered only when an airport installs or upgrades a facility. Without a timeframe, access will continue to vary between airports indefinitely
• the facilities identified in the Consultation Paper (including accessible toilets and accessible adult change facilities, assistance animal relief areas, lifts, quiet and sensory rooms, wheelchair transfer spaces, and powered wheelchair charging points) be covered, together with hearing loops, varied seating, and accessible retail and food areas
• minimum design standards be set for facilities not currently regulated, such as sensory rooms, animal relief areas, and private transfer spaces with hoists and change tables
• no existing accessible facility can be removed without consultation with people with disability and their representative organisations, and
• operators publish the status of facilities, including outages, in real time, and provide an alternative when one is out of order.

Specific questions asked in the Consultation Paper

What facilities are necessary?

The list above, located both before and after security screening, and near arrival and departure gates.

Should minimum design standards be regulated, and for which?

Yes, for accessible adult change facilities, animal relief areas, quiet and sensory rooms, and transfer spaces.

7.9 Protect disability aids from damage and loss, and track their movement (Item 3.9)

AFDO supports the regulatory proposal.

Prevention and visibility are where the Standards can add greater protection and minimise claims for compensation. To be effective, the Standards must be detailed enough for an airline’s compliance to be assessed and for the airline to be held to account when it falls short. At a minimum, the Standards must specify the equipment and processes airlines must have and the training their staff must receive.

We recommend that the Standards require the following:

• a specified minimum set of equipment for handling, loading and securing mobility aids, and specified training for the staff and contractors who use it (see also Section 5.2)
• a condition check at hand-over, with the passenger present, which is recorded and provided to the passenger, and repeated on return, and instruction tags on the aid
• loading confirmation given to the passenger, before boarding, that the aid has been scanned and loaded, so that no one flies without their aid
• tracking at each custody step (accepted, loaded, unloaded, delivered), with notifications through the person’s chosen channel, and a non-app alternative
• immediate access to a comparable loan aid at the destination where an aid is damaged or not delivered, and prompt repair, replacement or reimbursement under the Charter, and
• the airline remains responsible for ground handlers it contracts, and corrective action where damage rates exceed a benchmark (using the data reported under section 5.4).

Specific questions asked in the Consultation Paper

Equipment, ground handler training and tracking methods?

Industry holds the operational detail, but AFDO does not accept that these matters should be left to industry. The equipment, processes and training should be specified in the Standards. AFDO notes that the co-design participants called for performance targets, and supports them.

7.10 Provide choice for passenger transfer to airline wheelchairs and seats (Item 3.10)

AFDO supports the regulatory proposal, but it is not sufficient.

The risk in the draft wording is that choice is limited to the “available equipment in that location”. This means choice may disappear at smaller airports. A right to state a preference is of little value if the equipment and trained staff needed to act on it are not there to give effect to that preference.

We recommend that the Standards mandate specific transfer methods, with the equipment and the number of trained staff needed to deliver them, including a minimum equipment suite

at every airport receiving scheduled services, and a minimum range of methods. Choices must also include, as a minimum:

• the passenger’s own technique, with standby assistance
• assisted transfer using a transfer board or slide sheet
• mechanical lift or hoist with a suitable sling, with the person able to bring their own
• an aisle chair with a safe harness, and
• assistance from the person’s own carer.

No method should involve lifting or dragging a person by hand (consistent with section 8.1). The person must consent, transfers should be done privately where possible, and the person must be able to refuse an unsafe method without losing the right to travel. The passenger should be able to record their chosen or preferred method in their passenger assistance profile.

Airlines should be required to publish, and keep up to date, the transfer methods and equipment available at each airport they serve, so that a person can make an informed decision before booking.

The Standards could allow airlines to meet the equipment obligation through cost-sharing or other co-operative arrangements with the airport or with other airlines serving it.

Specific question asked in the Consultation Paper

Is additional infrastructure needed?

Yes at many airports. The co-design participants asked for hoists at every gate. AFDO suggests at least one hoist per terminal or pier with a maximum response time, and funded support for regional airports.

Volumes are a matter for industry.

8 Chapter 4: On the aircraft

8.1 Make it easier for people with disability to board and leave the aircraft (Item 4.1)

AFDO supports the step-free access part of the proposal. The part dealing with choice about boarding and disembarking is not sufficient.

AFDO supports clarifying that no gap or rise may remain, and that there must be a continuous, step-free path, where a boarding device is used.

AFDO supports the ultimate removal of any carrying of a person by hand, even with consent. Hand carrying is undignified and unsafe for the person and for staff. However, AFDO understands that some people are currently carried onto small aircraft where no device is available. A prohibition that takes effect before devices are available will leave these people unable to travel.

Accordingly, we support the prohibition but also recommend that there is a fixed, certain, and funded transition date, with interim safeguards of informed consent, properly trained staff and safe techniques, and no refusal of carriage.

Choice of boarding time is essential. Boarding early is an entitlement and not an obligation. The proposal would let airlines require a person to board first or leave last whenever the person has asked for assistance and equipment is used, or whenever the person’s safety is “relevant”, irrespective of the person’s choice. This is likely to leave current practices in place, with no positive change for people with disability. The Standards should allow an airline to override the passenger’s choice only where:

1. it is necessary for safety reasons, or
2. the passenger has asked for assistance that uses equipment, and that assistance cannot be provided safely and effectively while other passengers are boarding or disembarking.

Where an airline does require early boarding on one of those grounds, passengers beside the person should be seated first, so they are not climbed over, as the Consultation Paper proposes.

Airlines say priority disembarkation is hard to control. AFDO’s view is that where a passenger asks, crew should ensure the equipment and staff are ready at the door on arrival, and the airline must report waiting times to deplane (section 5.4). The same narrow grounds as proposed for boarding should apply to any requirement to leave last.

Specific question asked in the Consultation Paper

Preferred step-free methods where there is no aerobridge?

Passenger lifts or ambulifts and ramps of suitable gradient, with stairs alone not acceptable, and an accessible vehicle where the passenger is bussed. For small aircraft, see Section 9.

8.2 Support passengers to store disability aids inside the cabin (Item 4.2)

AFDO supports the regulatory proposal.

Cabin crew must be obliged to help to stow and retrieve aids. Aids must be stored near the passenger, and passengers with aids must be able to pre-board, if they choose. We also recommend that an aid needed in flight is never taken to the hold after boarding because lockers are full.

The Consultation Paper proposes that priority space for a manual wheelchair only applies to aircraft with 100 or more passenger seats. Many aircraft on regional routes have fewer than 100 seats. AFDO is concerned that this would exclude the very routes where people have the fewest alternatives. We ask the Department to review the threshold against the Australian regional fleet before finally determining the relevant limit.

Specific questions asked in the Consultation Paper

Aids for which information is unclear?

Portable oxygen concentrators, CPAP and ventilation equipment, power banks, folding scooters, seat cushions and positioning supports, communication devices, and walking frames.

Airlines should publish a standardised list.

Operational considerations for strapped wheelchair storage?

This is for airlines. The Consultation Paper notes the US requires it.

8.3 Allow people to use their disability aids onboard, where possible (Item 4.3)

AFDO supports the regulatory proposal, including the standardised approval process for aids that need assessment, and the requirement that restrictions be explained. We recommend that approvals be portable (valid for up to 12 months and attached to the passenger assistance profile) and that airlines be required to explain, in advance, which restrictions apply during taxi, take-off, landing and turbulence.

We also recommend that:

(a) the Standards include examples of the uses of disability aids that are permitted in flight, and

(b) airlines be required to publish the aids they can provide to passengers, such as a support harness, so that people can plan their travel and equipment.

Specific questions asked in the Consultation Paper

Timeframe for approval?

48 hours for a new item, same day or immediate for an item previously approved, where the passenger has given at least 48 hours’ notice (section 6.3).

Aids relied on in flight because the person cannot use their own wheelchair seat?

Pressure-relief and positioning cushions, trunk and head supports, restraints and harnesses, travel vests, pillows, and communication boards.

Assistance animal policies in flight?

AFDO supports animals being secured during critical phases of a flight, and being allowed to remain close to and support their handler at other times, including resting on a lap where that is part of the support. The animal should be at the handler’s feet or in the space the handler needs, and the airline must provide enough space at no extra cost. Airlines should not require the animal to stay in the footwell throughout the flight. Outside take-off and landing, this prevents the animal doing what it is trained to do. US rules allow an assistance animal on the passenger’s lap or in their foot space unless that is unsafe or encroaches on another passenger42. We support this approach.

8.4 Return mobility aids as soon as possible following flight arrival (Item 4.4)

AFDO supports regulation, and strongly supports a specified time for return.

An obligation to return “as quickly as possible” is not an enforceable standard. Allowing a choice of return point only “where possible” gives no certainty either. Together these phrases would let airlines keep their current practices. This is unacceptable.

AFDO agrees with industry that aids must be returned safely, but safety and timeliness do not compete. Airport layout, lifts, staffing and reassembly are operational matters that an airline can and should plan for.

We recommend that the Standards set a clear, objective baseline. The aid must be returned in a minimal time and no more than 30 minutes after arrival, consistent with Option 1 in section 7.1. Also, the aid must be returned as close as possible to the aircraft door unless the passenger asks otherwise, as US rules require43. In the European Union, a passenger receives their aid on disembarking and cannot be required to collect it at baggage claim44. If the passenger chooses collection in the terminal, the aid should be among the first items on the carousel or oversize belt.

Where there is a delay, the airline must provide an aisle chair so that no one waits on board without a chair. The aid must be returned assembled and in the condition received45, with the

passenger’s written or illustrated instructions followed, and with a remedy where it is delayed or damaged.

Specific questions asked in the Consultation Paper

Should there be a timeframe?

Yes: no more than 30 minutes, as above. The reason is that it makes the right testable and reportable.

Equipment from hold to tarmac to gate?

For industry, but the standard should set the minimum infrastructure (baggage lifts, ambulifts and suitable vehicles).

How should handlers receive instructions?

Illustrated instruction tags on the aid and the information in the passenger assistance profile, as well as written instructions, with plain-language and diagram formats.

8.5 Provide critical in-flight information in accessible formats (Item 4.5)

AFDO supports the regulatory proposal.

We recommend that:

• safety briefings be available as captioned video with Auslan and audio description, and as Easy Read and tactile or Braille cards
• one-to-one briefings be offered to anyone who wants one without needing to disclose a reason. Pre-recorded materials supplement but do not replace in-person communication of emergency information
• crew have a reliable way to alert d/Deaf and DeafBlind passengers to announcements, including turbulence,
• free Wi-Fi be activated for passengers with disability who need it, without proof, for example through their profile, and that content be available offline before the flight.

Specific questions asked in the Consultation Paper

Formats needed in flight? Would pre-recorded formats be enough?

They meet part of the need, particularly for general information, but not for emergencies, where a person-to-person briefing is needed.

Periods when Wi-Fi is unavailable? This is for airlines to answer.

Is Wi-Fi needed?

Yes. Many people use cloud-based captioning, speech-to-text, translation, communication and relay applications as their aids, and in those cases Wi-Fi is the access tool.

8.6 Make in-flight food and drink more accessible (Item 4.6)

AFDO supports the regulatory proposal.

In addition, menus and ingredient information should be available online before the flight, readable by screen readers, and read aloud by crew on request. Airlines should offer adaptive cutlery and cups with lids on request, pre-cut or easy-to-eat meal options as a reasonable adjustment, and water and hot water on request. Passengers should be allowed to carry and consume their own food, fluids and feeding supplies where needed for medical reasons.

AFDO accepts that crew will not provide personal care or assist with eating, but this must not be used to require a carer unless the criteria in section 6.8 are met.

Specific questions asked in the Consultation Paper

Should ingredients lists be available in accessible formats?

Yes. Allergen and ingredient information is a safety issue, and should be available in large print, Braille, audio and by direct assistance.

8.7 Improve accessibility of aircraft toilets (Item 4.7)

AFDO strongly supports the steps in both stages of the regulatory proposal.

The consequences described in the Consultation Paper (dehydrating oneself, withholding, using a catheter or diaper that one finds degrading, and avoiding flying) are significant harms to health and dignity of people with disability. These significant harms justify firm dates for implementation of both stages being set by the Standards.

As drafted, the stages would apply only when an aircraft is refurbished or replaced. People with disability will wait many years with no certainty about when change will come. The Standards must set clear implementation timeframes that do not depend solely on refurbishment or replacement cycles of individual airlines. Those timeframes can be generous and reflect the realities of aircraft procurement, but a defined pathway is what will drive investment by airlines and manufacturers and bring accessible design forward.

We recommend:

• Interim measures now. Onboard wheelchair on every aircraft with a toilet, help to the toilet door if requested, information at booking on the aircraft’s toilet (section 6.10), and accessible toilets at gates (section 7.8). No airline should require a person to use a

continence product as a condition of carriage.

• Stage 1 (features): The low-cost features should not wait for a major refurbishment. Tactile signage, Braille, door handles and latches operable with minimal force, flush and tap controls, and call buttons should be retrofitted within a fixed period. Structural features (grab bars) at refurbishment or on delivery of new aircraft, and in any case by a fixed end date for the whole fleet.
• Stage 2 (space): for new single-aisle aircraft, with a threshold low enough to capture the aircraft that dominate Australian trunk routes. AFDO would be concerned by any threshold that exempts these aircraft. The Standards should set the dates. The United States requires the Stage 2 features on new single-aisle aircraft with 125 or more seats that are ordered after 2033 or delivered after 2035^46. Australia should not have a timetable (for new single-aisle aircraft with a seat threshold low enough to capture the aircraft that dominate Australian trunk routes) that is later.

Specific questions asked in the Consultation Paper

Costs per toilet?

For airlines and manufacturers to provide the relevant data. AFDO asks the cost-benefit analysis to include the health costs of the status quo (Part 4.7).

What is a “major refurbishment”?

Any replacement or reconfiguration of a lavatory module, regardless of other work. The obligation should not depend on this trigger alone (see above).

8.8 Make in-flight entertainment accessible (Item 4.8)

AFDO supports the regulatory proposal.

In addition to captions, audio description and WCAG-compliant interfaces, we recommend compatibility with hearing aids (including wired and Bluetooth connections and the use of the passenger’s own headphones), screen-reader-compatible menus, large text and high contrast, and streaming to the passenger’s own device. The fallback portable device is welcome, provided it is offered proactively, carries the same or comparable content, is charged, and carries no fee.

Advance notice should not be a condition, although airlines can ask for it.

Specific questions asked in the Consultation Paper

Retroactive accessibility?

Airlines should require accessible content in all new licensing agreements from now, and prioritise adding captions and audio description to the most-watched existing content.

Controllers?

Tactile, high-contrast, low-force controllers should be required.

8.9 Require aircraft to have accessible passenger controls (Item 4.9)

AFDO supports the measures in the regulatory proposal. However, those measures are not sufficient, as they would apply only when aircraft are refurbished or replaced. People with disability sit in any seat. We expect that it is cheaper to make every seat’s controls accessible than to design for a subset of seats on any aircraft.

AFDO’s preferred position is that the requirements apply to all seats on new aircraft ordered after a specified date and on refurbishment, and in any case to the whole fleet by a fixed date.

As with toilets (section 8.7), the timeframes can be reasonable, but the Standards must set them so that improvements do not depend solely on replacement and refurbishment cycles.

If the Department adopts a phased approach, controls at all designated accessible seats (section 8.10) should comply from day one. Controls should be operable with minimal force, by one hand and without fine motor control, tactile and high-contrast, with an alternative way to call crew for people who cannot use a button.

The scope should also include seatbelts and tray latches, charging points for aids and devices, and window shades.

Specific questions asked in the Consultation Paper

Timeframe?

The same as for toilets (section 8.7), set as fixed dates in the Standards.

What percentage of seating capacity?

100%, or at least all designated accessible seats.

“Major refurbishment”?

Any replacement or reconfiguration of seats or panels.

8.10 Increase the number of aircraft seats that have moveable armrests (Item 4.10)

AFDO prefers Option 1 as proposed in the Consultation Paper. It is the only option that guarantees a person can be seated wherever they and their carer need or choose to sit, in any class. Option 2 as drafted, counts any seats towards its 50% target and not specifically aisle seats. As a result, an airline could meet Option 2 without installing moveable armrests where they matter most for transfer.

Options 2 and 3 would both leave a significant share of seats with fixed armrests, and so leave people with disability with unequal access to some seats and some flights. AFDO does not support either Option 2 or 3.

Every option in the Consultation Paper depends on when an airline carries out a “major seating refurbishment” or brings in new aircraft. As with the changes discussed above, people with disability could wait many years. The Standards should set clear implementation timeframes that are not based on replacement or refurbishment cycles, so that passengers know when to expect accessible seating.

In the meantime, AFDO recommends that the Standards provide that any seat that is newly installed or replaced must have a moveable armrest. This removes the need to define “major seating replacement” and means that progress starts immediately. Information about which seats have moveable armrests must be available at booking, shown on seat maps, held in the passenger profile, and updated if the aircraft or seat changes.

Specific questions asked in the Consultation Paper

Barriers?

Seat certification and weight. Moveable armrests are already installed in many seats, so we expect these to be manageable.

How can passengers identify the seats?

On seat maps and in the accessibility statement (section 6.10).

Transition period?

For new aircraft, ordered after 2033 or delivered after 2035, or earlier.

For existing aircraft, at each seat replacement, and in any case across the whole fleet by a fixed date set in the Standards (for example, 2035).

What percentage of seats replaced should trigger the requirement?

None. Any seat that is newly installed or replaced must have a moveable armrest.

9 Chapter 5: Current exclusion of small aircraft

The 16 exclusions in the Transport Standard for aircraft with fewer than 30 seats have not changed since 2002. These exclusions were based on a 1999 assessment that more work was needed on what was structurally possible. The Consultation Paper does not report any testing of the original reasons for exclusion in the years since 1999.

AFDO’s position is that the exclusions should be re-examined on a fixed timetable, and narrowed.

People in regional and remote areas often have no alternative to a small aircraft, including for medical travel. Because boarding devices and some access features are not required on small aircraft, a person may have no step-free way to board and no assured way to travel independently.

Many exclusions concern boarding, not the aircraft interior. The exclusions for boarding devices (8.2, 8.3, 8.5, 8.6), ramps (6.2 to 6.4) and stairs (14.1) concern ground equipment that an airport can supply. This is regardless of aircraft size. AFDO asks the Department to examine whether these exclusions are still justified, and to require airports to provide suitable lifts or ramps.

The Department should commission an independent technical review, with people with disability, covering the aircraft types in regular service, and identifying what is feasible now and what would be possible when aircraft are replaced.

Accessibility must be the default position, and the operator must carry the burden. After more than two decades, any broad exclusion should continue only where there is clear evidence for it. Airlines should have to show why a particular standard cannot reasonably be met, and each requirement should be assessed individually. Whole categories of aircraft should not be exempted. An exclusion should be kept only where compliance is demonstrably not feasible because of the physical characteristics or operational limits of the aircraft. Any exclusion that is kept should be reviewed periodically.

AFDO urges the Department to replace blanket exclusions with graduated duties. Where something is genuinely infeasible, the exclusion should be replaced by an obligation to provide equivalent access to the extent feasible, to publish what is and is not available, and not to refuse carriage on this basis without the safeguards in section 6.13.

Further, exclusions should have an end date, and aircraft acquired after a stated date must meet the Standards unless it is shown to be impossible.

Everything else in the Standards must still apply. The new Standards on information, assistance profiles, training, assistance, reporting and refusal must apply to small-aircraft operators.

Questions directed to operators (the proportion of fleet with fewer than 30 seats, structural and engineering barriers, current access considerations, and fleet replacement plans) are for industry. AFDO asks that the Department publishes what it learns.

10 Co-design solutions not progressed in the Consultation Paper

AFDO acknowledges the Department’s explanation of why three solutions from the co-design workshops were not developed into options for the Consultation Paper. However, in doing so, we ask that the Department keeps each of those three matters under active review, and not leave them in a holding pattern. We also make the following comments in respect of each issue.

10.1 Evacuation tests should include people with disability

This is the underlying reason for many of the limits discussed in section 6.2, and for airline concerns about carrying passengers who need assistance. AFDO asks the Department to ask CASA to commit to a timetable, to report publicly on progress, and to involve people with disability and their representative organisations in the work. Until evacuation certification reflects the real passenger population, limits on passengers requiring assistance will continue to be justified by a test that does not include them.

10.2 Announcing accessibility needs before flight

The Consultation Paper records that co-design participants did not agree. AFDO agrees that it must remain the passenger’s choice, and that no announcement should be made about a person without their consent. Cabin crew should be able to help a person communicate their needs to other passengers when asked.

10.3 Staying in your own mobility device in flight

AFDO supports retaining this issue for future review. The Consultation Paper notes that the technology does not yet exist. We ask the Department to commit to track developments in aircraft design and to place this item on the agenda of the 2027 statutory review.

11 Issues the Consultation Paper does not address

The Consultation Paper does not raise, or propose resolution of, three issues that the Standards must address, namely:

1. a time limit on leaving passengers unattended
2. equipment to load and unload disability aids, and
3. a designated contact to resolve disability-related complaints on the spot.

In respect of each of these three issues, AFDO relies on JEC’s casework, as set out in its submission, and endorses JEC’s arguments and recommendations.^47

The Standards must prohibit airlines and airports from leaving a passenger with disability unattended for more than 30 minutes without the person’s explicit prior, fully informed consent.

The Standards must require airlines to:

• (a) have, at every passenger airport they fly to or from, access to (including through cost- or other sharing arrangements) a specified range of equipment for safely loading and unloading mobility aids
• (b) have access to (including through cost- or other sharing arrangements) a further range of equipment, covering items that are more capital-intensive or less often needed, at airports where they carry more than a set number of passengers a year, and
• (c) publish in accessible formats, and keep up to date, details of the equipment available at each airport they fly to and from, so that passengers can check in advance whether their needs can be met.

The Standards should require airlines and airports to appoint a Complaints Resolution Official for disability-related complaints, to ensure prompt and appropriate resolution of complaints. The official must be trained as an expert in disability-related issues and have full authority to resolve disability-related complaints at or as close to the time of complaint as far as reasonably possible. The Standards must also require airlines and airports to publish and promote in accessible formats, including (by airlines) advice included with each ticket issued by the airline, the contact details (including by voice (toll-free within and outside Australia), text message, and email) for the Complaints Resolution Official.

Endnotes

1 Department of Infrastructure, Transport, Regional Development, Communications, Sport and the Arts, Aviation disability standards—Consultation paper, Commonwealth of Australia, August 2026, retrieved from https://www.infrastructure.gov.au/department/media/publications/aviation-disability-standards-consultation-paper, accessed 4 September 2026.

2 United Nations Convention on the Rights of Persons with Disabilities, 2515 UNTS 3 (entered into force 3 May 2008), retrieved from https://social.desa.un.org/issues/disability/crpd/convention-on-the-rights-of-persons-with-disabilities-crpd, accessed 7 January 2026.

3 https://www.wcag.com/resource/what-is-wcag/, accessed 1 October 2026.

4 Australian Human Rights Commission, Disability Rights Guide, Commonwealth of Australia, 5 May 2025, retrieved from https://humanrights.gov.au/resource-hub/by-resource-type/pages-missing-assets/chapter-1-legal-and-human-rights-obligations, accessed 5 August 2026.

5 Justice and Equity Centre, Submission: Aviation Disability Standards – Consultation Paper, 2 October 2026, p. 11.

6 See, for example, Australian Federation of Disability Organisations (AFDO) and National Inclusive Transport Advocacy Network, A Line in the Sand: Institutional Neglect and the Disability Transport Standards, Joint Submission to the Royal Commission into Violence, Abuse, Neglect, and Exploitation of People with Disability, (September 2022), p. 10.

7 Section 11.

8 Disability Standards for Education 2005 (Cth) and Disability (Access to Premises – Buildings) Standards 2010 (Cth).

9 Australian Human Rights Commission, Free and Equal: A Reform Agenda for Federal Discrimination Laws (Position Paper, December 2021), p. 135, retrieved from https://humanrights.gov.au/resource-hub/human-rights/free-and-equal-reform-agenda-federal-discrimination-laws, accessed 30 September 2026.

10 Note 9, p. 141.

11 Regulation (EC) No 1107/2006 of the European Parliament and of the Council of 5 July 2006 concerning the rights of disabled persons and persons with reduced mobility when travelling by air, Art 5.

12 Note 5.

13 Note 5, p. 12.

14 Note 11.

15 US Department of Transport, Ensuring Safe Accommodations for Air Travelers with Disabilities Using Wheelchairs, (noting DOT delayed enforcement of four separate rule provisions until 31 December 2026, but said other requirements are not affected), as reported by Deep Arrival, “New Airline Wheelchair Training Deadline Is Here. What Travelers Should Expect”, 18 June 2026, retrieved from https://deeparrival.com/news/airline-wheelchair-training-deadline-2026/, accessed 30 September 2026.

16 https://www.transportation.gov/briefing-room/dot-issues-landmark-50-million-penalty-against-american-airlines-its-treatment, accessed 29 September 2026.

17 U.S. Department of Transportation, Air Travel Consumer Report, pursuant to the FAA Reauthorization Act of 2018 (sic), Pub L No 115-254, 132 Stat 3186 (2018).

18 For example, see https://www.caa.co.uk/data-and-publications/publications/documents/content/cap3264/ (report published 4 August 2026), accessed 29 September 2026.

19 King v Jetstar Airways Pty Ltd (No 2) [2012] FCA 8.

20 [2012] FCAFC 115.

21 See the ACCC’s quarterly Domestic Airline Competition in Australia reports, retrieved from https://www.accc.gov.au/about-us/publications/serial-publications/domestic-airline-competition-monitoring-reports, accessed 30 September 2026.

22 14 CFR § 382.19.

23 Regulation (EC) No 1107/2006 of the European Parliament and of the Council, Article 4.

24 US Department of Transport, About the Air Carrier Access Act, retrieved from https://www.transportation.gov/airconsumer/passengers-disabilities, accessed 30 September 2026.

25 Note 24.

26 14 CFR § 382.27.

27 Note 5, p. 20.

28 Noting that the Department of Health, Disability and Ageing (formerly within the portfolio responsibility of the Department of Social Services) is yet to finalise the draft principles that were the subject of consultation in 2025. See https://engage.dss.gov.au/assistance-animal-national-principles/, accessed 1 October 2026.

29 Note 5, p.24.

30 Mulligan v Virgin Australia Airlines Pty Ltd (2015) 234 FCR 207.

31 Subsection 98(6B).

32 Regulation 91.620(3).

33 Civil Aviation Safety Authority, Advisory Circular AC 91-03 v 1.1, Carriage of assistance animals, September 2024.

34 14 CFR § 382.35.

35 14 CFR § 382.83.

36 Note 5, p.30.

37 14 CFR § 382.95.

38 Such as AS EN 301 549 2020, Accessibility requirements for ICT products and services.

39 Bureau of Infrastructure and Transport Economics, Airport Traffic Data 1985–1986 to 2024–2025, 3 February 2025, retrieved from https://www.bitre.gov.au/resource/aviation/airport-traffic-data, accessed 2 October 2026.

40 Note 39.

41 Note 23, Article 5.

42 14 CFR § 382.77.

43 14 CFR § 382.125.

44 European Commission, Interpretative Guidelines on 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, 23 August 2021, p. 13.

45 See section 7.9 in relation to the requirement for a condition report.

46 US Department of Transport, Final rule for Accessible Lavatories on Single-Aisle Aircraft, 1 August 2023, retrieved from https://www.federalregister.gov/documents/2023/08/01/2023-16178/accessible-lavatories-on-single-aisle-aircraft, accessed 2 October 2026.

47 Note 5, pp. 43-46.