Submission 1 — Australian Federation of Disability Organisations (AFDO) — Inclusive Communities Fund Consultation

Design and operation of the Inclusive

Communities Fund

Submission to the Department of Health, Disability and Ageing

31 August 2026

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

• 1Acronyms and abbreviations

• 2Executive summary

• 3Introduction

• 4Background

• 5Core design features of the Fund

  5.1 Co-design with people with disability 15

  5.2 Accessible application processes 15

  5.3 Tiered and flexible funding structure 16

  5.4 Assessment criteria grounded in the Social Model 16

  5.5 Capacity-building support (not funding alone) 16

  5.6 Accessible promotion and outreach 17

  5.7 Proportionate reporting 17

  5.8 Accessible complaints and feedback mechanism 17

  5.9 Intersectionality 17

5.10 Alignment with legal and policy frameworks 17

• 6Conditions of grant funding to further improve inclusion

  6.1 Design considerations 18

  6.2 Grantee organisational requirements 18

• 6.2.1 Employment of people with disability — real work, real pay

• 6.2.2 Accessible policies across the employment lifecycle

• 6.2.3 Disability Inclusion and Access Plan (DIAP)

6.2.4 Representation in senior and project-critical roles, and co-presentation/co

• facilitation of activities

• 6.2.5 Grantee Disability Advisory Committee

  6.3 Mirrored requirements for the administering agency 20

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• 6.3.1 Fund-level Disability Advisory Committee

• 7Inclusion versus access

• 8Issues with “more” as the benchmark

• 9Exclusion of direct activity funding

• 10 Proposed “light -touch” partnership model

10.1 Why partnership, on its own, is the wrong benchmark 26

10.2 Our recommended approach 27

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Australian Federation of Disability Organisations (AFDO) Ltd is

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Commission. It is also a Public Benevolent Institution, endorsed by the

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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

CC BY-NC-SA (version 4.0): AFDO publishes, distributes, and otherwise makes available its

advocacy and policy materials, including this submission, under a Creative Commons licence.

This licence allows any person to distribute, remix, adapt, and build upon the material in any

medium or format for non-commercial purposes only, and only if AFDO is credited as the creator of

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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.

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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.

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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

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 Australian Consumers and Carers Mental Health Forum (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.

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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.

ADS or Strategy Australia’s Disability Strategy 2021-2031.

AFDO Australian Federation of Disability Organisations

Consultation “Inclusive Communities Fund Consultation Paper”, released

Paper by the Department in August 2026

CRPD United Nations Convention on the Rights of People with

Disabilities1

CRPD United Nations Committee on the Rights of Persons with Disabilities. This is a body of independent experts that Committee monitors the implementation of the CRPD by countries and

provides recommendations to support the implementation of

the provisions of the CRPD

DDA Disability Discrimination Act 1992 (Cth)

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,

DRCO Disability Representative and Carer Organisations funded by the NDIA to work with the NDIA on reforms, changes and

improvements to the NDIS. AFDO is one of 27 DRCOs

DRO Disability Representative Organisations funded by the Commonwealth government to represent people with disability.

AFDO is one of 11 DROs

Department Department of Health, Disability and Ageing

Disability Royal Royal Commission into Violence, Abuse, Neglect and

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Commission or Exploitation of People with Disability

DRC

DPSC program Disability Peer Support and Connections program, a new government funding program that will commence from 1 July

2027

Fund The Inclusive Communities Fund, which is the subject of this consultation

ILC program Information, Linkages and Capacity Building program, a current government funding program that will end in December 2028

Minister Hon. Mark Butler MP, the Minister for Disability and the National

Disability Insurance Scheme

NDIS National Disability Insurance Scheme

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2 Executive summary

AFDO urges the Government to adopt the following recommendations to strengthen the design and

operation of the Fund:

Recommendation One

The Government should publish clear guidance that:

 distinguishes “access” from “inclusion”;  explains what is required for an organisation, service or activity to become “more accessible” or “more inclusive”;  establishes appropriate minimum or end-state standards and measures against which progress will be assessed; and  explains how improvement from baseline will be balanced against existing performance, so that organisations with mature inclusive practice are not disadvantaged merely

because their scope for incremental improvement is smaller.

The policy approach adopted, including the relevant evidence and reasons supporting it, should be

clearly documented and published to the disability community.

Recommendation Two

Separate funding streams for access capability and inclusion capability should be established. Each

stream should have clearly defined objectives, eligibility and assessment criteria, timelines, focus

areas, milestones, success measures, decision-makers and reporting requirements.

Recommendation Three

The Fund should be designed around the following core features: co-design with people with

disability and DROs; accessible application processes; tiered and flexible funding, including multi

year options; assessment grounded in the Social Model of Disability; non-financial capacity-building

support; accessible promotion and outreach; proportionate outcomes reporting; an accessible and

independent complaints and feedback mechanism; an intersectional approach; and explicit

alignment with relevant disability rights, discrimination and policy frameworks.

Recommendation Four

Grant conditions should promote meaningful disability inclusion and decision-making by people with

disability and should be applied proportionately to the size, structure and value of the grant.

Depending on the nature of the grantee and project, these conditions should include:

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 a genuine procurement preference for disability-owned, disability-led businesses, and businesses that employ people with disability, where such suppliers are reasonably

available and capable of delivering the required goods or services;  genuine, paid employment and project roles for people with disability, where paid roles exist;  accessible recruitment, onboarding, workplace adjustment, exit, staff development and skills development policies and processes, or a credible funded plan to develop them;  a disability inclusion and access plan (DIAP) or an appropriately scaled equivalent;  people with disability in senior and project-critical roles with real decision-making authority over the funded project;  presentation, facilitation, co-presentation or co-facilitation by people with disability of relevant training, presentations and similar project activities; and  a functioning disability advisory committee or appropriately scaled equivalent mechanism that gives people with disability genuine and documented influence over

decisions.

Recommendation Five

The department or agency administering the Fund should be required to demonstrate equivalent

standards of disability inclusion, accessibility and lived-experience leadership in the Fund’s

governance and administration. This should include people with disability in genuine paid roles and

senior or delivery-critical program roles, accessible employment-lifecycle policies, an organisational

DIAP or equivalent, co-presentation or co-facilitation of relevant training and public activities, and a

dedicated fund-level disability advisory committee.

Recommendation Six

The blanket exclusion on funding project delivery should be replaced with a sustainability-tested

model that can allow a capped, time-limited establishment or start-up delivery phase where justified.

Sustainability planning should be a core assessed component of every application. The Government

should also publish the rationale and scope of any remaining restriction on delivery costs, map

referral pathways to complementary government or philanthropic delivery funding, and monitor the

effect of the restriction and any delivery-phase exception over the life of the Fund.

Recommendation Seven

Partnerships with disability-led organisations should be treated as a support mechanism on the path

to internal capability, not as a substitute for it. Where a grantee relies on a partnership to

demonstrate that it is working with people with disability, minimum standards should require a

documented agreement, meaningful advisory or decision-making authority, fair remuneration of the

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disability-led partner, a costed and time-bound plan to build internal capability, and assessment

weighting that favours lasting internal capability over reliance on an external relationship alone.

3 Introduction

AFDO welcomes the opportunity to provide this submission to the Department to “help inform the

design” of the new Inclusive Communities Fund. In this submission, AFDO responds to the

Consultation Paper.

We also address other concerns we, and many in the disability community, have with the timing,

extent, and limitations of this current consultation process, including the level of meaningful

engagement with, and the lack of leadership by, people with disability and their representative

organisations, and some of the decisions about the Fund’s design and operation that government

has already made, and that are not considered within this consultation process.

Discussions with our members and other member feedback have informed this response. Our

assessment and recommendations are offered constructively to improve the design and operation of

the Fund.

AFDO wants to ensure that the Fund is designed and will operate to maximise opportunities for

people with disability to take part fully, and on an equal basis with others, in community activities.

Our recommendations were developed from a systemic advocacy perspective, centred on the rights

and lived-experience leadership of people with disability, by reference to the following key

principles:

 The social model of disability  “Nothing about us without us” full engagement of people with disability; and  Co-design and lived-experience leadership, not merely information sharing or consultation.

This approach and our recommendations are grounded in the rights of people with disability

established by the CRPD and the Australian government’s obligations to:

(a) protect and promote those rights in Australia’s domestic laws and policies, and

(b) ‘urge’ and ‘encourage’ other sectors of Australian society to uphold those rights.2

In particular, the following CRPD provisions are relevant, and must be reflected in, and protected and

promoted by the Fund’s design and operation:

(a) Article 30 (participation in cultural life, recreation, leisure and sport)

(b) Article 9 (accessibility)

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(c) Article 19 (living independently and being included in the community) and

(d) Article 4(3) (close consultation and active involvement of people with disability through

their representative organisations in decision-making).

4 Background

On 22 April 2026, the Minister announced3 that the government would provide $200 million for the

Fund for three years, commencing 1 July 2027.

The Department’s public consultation process to help inform the design of the Fund started on 3

August 2026. The opportunity to make a submission ends on 31 August 2026. The design of the Fund “will be informed by consultation” with the disability community4.

The Fund’s objective will be to create more opportunities for people with disability, including (but not

exclusively) NDIS participants, to take part in social, recreational, arts, sporting, cultural and other

community activities. To achieve this, the Fund will fund not-for-profit community organisations to strengthen their capability to offer “more inclusive” services and activities.5 The focus will be

projects that create lasting change. Building the capability, capacity and confidence of community organisations will help them to embed inclusive practices into their ongoing activities.6

Despite this statement, and whilst the fund is called the “Inclusive Communities Fund”, other parts of

the Consultation Paper make it clear that the Fund will support community organisations to become both more inclusive of and more accessible to people with disability.7 We note, however, that the

Consultation Paper does not provide any guidance on the differences between “inclusion” and

“access”, nor what the government considers is necessary for a service to be “more inclusive” or

“more accessible”.

The Consultation Paper also does not identify a minimum standard or any objective measure of the

level of improvement that a funded organisation must demonstrate for their services to be

considered “more” inclusive or “more” accessible.

Funded organisations will need to show they are working with people with disability. The

Consultation Paper identifies partnership arrangements between community organisations and

disability-led organisations (including community organisation partnerships with disability advocacy groups, representative organisations or NDIS providers) as a “good way to do this”.8

Before this consultation process, the government decided that the Fund will not:

(a) pay the costs of delivering inclusive community activities9

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(b) pay for things organisations are already legally required to do or provide. This includes

making any reasonable adjustments required under the Disability Discrimination Act 199210

(c) provide funding directly to individuals11.

These matters are not included in the Consultation Paper, and government does not seek any

feedback from the community about these aspects of the Fund. We have included our consideration

of the exclusion of funding direct activity costs and our recommendations for improvement

nonetheless.

The Consultation Paper seeks the views of DROs, advocates and community organisations about each of the following issues12:

1. the support, resources or changes that would help organisations become more inclusive and accessible for people with disability

2. the ways in which community organisations could partner with disability-led organisations to become more inclusive and accessible for people with disability

3. the activities the Fund should support

4. the role of local governments in supporting community inclusion

5. the best way for community organisations to build meaningful and lasting inclusion to make sure the benefits of the Fund continue after the funding ends, in 2030

This submission does not respond directly to those questions, but we do address all the issues, and

provide our recommendations on the design of the Fund, having regard to those issues. We also raise

other matters not dealt with by those questions or excluded from the Consultation Paper which, if

addressed, will improve the Fund and the benefits it is seeking to deliver.

5 Foundational design issues

5.1 Inclusion versus access

Access is about the removal of barriers that prevent or limit participation by a person with disability

in an activity or an event on the same basis as others. Access is improved by addressing physical,

technological, financial, procedural, societal, attitudinal and other barriers. Examples include:

 physical accessibility: providing ramps, elevators, accessible restrooms, and sensory friendly spaces  digital accessibility: ensuring digital resources comply with international standards, including WCAG 2.2 AA and PDF/UA and any updates or revisions, are compatible with

screen readers and other assistive technologies; providing access to communication

devices and applications, and

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 instructional accessibility: offering materials in multiple formats (e.g., Braille, large print, tactile graphics, audio, Auslan, and Easy Read), providing audio descriptions for visual

aids, and providing accommodations like extended time for completing activities.

Many aspects of accessibility can be assessed against relatively clear technical, functional or

compliance-based criteria, although accessibility is not always binary and may vary across

environments and disability. This makes many access barriers easier to identify and measure than

inclusion. Practical questions may include:

 get in the door  use the website  afford the service  navigate the form?

This means many aspects of accessibility can be assessed systematically using established

standards, audit tools and practical checks.

Inclusion goes beyond accessibility. Its focus is on the quality of participation once present.

Inclusion seeks to create and sustain an equitable environment where all people, regardless of their

abilities, backgrounds, or identities, feel welcomed and valued. Inclusion seeks to ensure people are

heard, retained, promoted, culturally accommodated, and recognised as full members, and not

seemingly tolerated guests. Inclusion is relational and ongoing, and harder to measure than

accessibility.

As an example, inclusive education involves:

 curriculum design and adjustment: developing lessons that consider the diverse needs of all students, including those with disability, English language learners, and students from

various cultural backgrounds

 classroom environment: promoting a sense of belonging and community, and supporting all students’ sensory and emotional needs, where every student is an integral part of the

class.  teaching strategies: using differentiated instruction to cater to the varied learning styles and needs of students

 specialist teachers (Visiting Advisory Teachers, and Special Education Teachers) in schools to support the teaching and learning of children with disability (eg. the provision of

information in Braille is only useful if the specialist teachers are there to teach the student

how to read Braille, which is an important aspect of literacy for children who are blind or

vision impaired).

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5.2 Issues with “more” as the benchmark

The Fund is intended to build capability for organisations to provide “more” access and “more”

inclusion. This is a comparative and potentially vague benchmark. AFDO is concerned that, if

“more” is assessed only as improvement from an organisation’s existing baseline, relatively small

changes from a very low starting point could be treated as sufficient while organisations with

stronger existing practice may have less scope to demonstrate large incremental gains.

This may disadvantage organisations that have already invested significantly in making their

activities accessible and inclusive, even where their remaining barriers are more complex and costly

to address.

An improvement-based assessment can over-emphasise change from baseline rather than the

quality of the end-state. For example, an organisation moving from a very low level of accessibility

to a modest level may record a large percentage improvement, while an organisation already

performing strongly may record only a small percentage gain despite addressing more difficult

remaining barriers.

Organisations starting from a low baseline may have relatively straightforward early improvements

available. Organisations already demonstrating mature accessible and inclusive practice may have

already captured those gains, leaving more complex and expensive work such as systemic

redesign, deeper workforce development or sustained cultural change.

If grant assessment focuses too heavily on the size of the gap to be closed, an organisation already

close to compliance or good practice may be deprioritised, while a poor starting point can become a

de facto qualifying credential even where the applicant has a weaker plan to sustain change.

Proposal-based funding also places weight on future intent. Organisations with an established track

record may therefore be judged partly on what they have already achieved, while organisations at

an earlier stage may be assessed more heavily on what they propose to do.

Strong existing performance can therefore appear less ambitious if progress has plateaued at a high

level, while organisations starting from a lower baseline may be able to promise larger visible gains.

AFDO recognises that designing the Fund in this way may be a deliberate policy choice, particularly

if the objective is to direct resources toward organisations that would not otherwise have the

capability or resources to improve accessibility and inclusion.

This may be particularly relevant in the community not-for-profit sector. The policy question is how

to balance the potential social value of lifting organisations from a low baseline against the value of

supporting organisations with stronger existing practice to address the more difficult barriers that

remain.

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Recommendation 1: The Government should publish clear guidance that distinguishes “access”

from “inclusion”; explains what is required for an organisation, service or activity to become “more

accessible” or “more inclusive”; establishes appropriate minimum or end-state standards and

measures; and explains how improvement from baseline will be balanced against existing

performance. The policy approach adopted, including the relevant evidence and reasons supporting

it, should be clearly documented and published to the disability community.

5.3 Separate access and inclusion capability streams

The Consultation Paper does not make it clear whether the Fund will seek to encourage greater

capability in access and inclusion as separate work programmes and funding streams.

This is a critical issue for the design and successful operation of the Fund. AFDO is concerned that

funding capability building for both accessibility and inclusion through a single undifferentiated

stream creates design tensions and increases the risk that one objective will be prioritised at the

expense of the other.

Accessibility programs have different time horizons than inclusion programs. A grant cycle that

funds capability development of both on the same timeline will tend to reward access wins and

starve inclusion work.

Measurement mismatch drives money toward access. Access capability is easier to quantify, so

grant scorecards and impact reports skew toward access metrics, even when inclusion is the stated

goal. Applicants learn to frame inclusion work in access-shaped terms (“we hired X people from

underrepresented groups”) because that’s fundable, even though hiring without inclusion often

produces high turnover — access without inclusion.

Capability requirements also diverge. Building access may require engineering, facilities or

procurement capability. Building inclusion may require human resources, organisational culture and

management capability. A single funding stream that assumes one organisational competency can

address both dimensions risks underfunding one or directing funding to organisations that are

strong in one area but not the other.

It may also create a perverse sequencing incentive. If access capability is the visible, front-loaded

deliverable, this will incentivise organisations to focus on access first and treat inclusion as a stretch

goal or an afterthought. This could occur even when durable outcomes require inclusion work to

happen in parallel or first.

Lastly, reporting can conflate different failure modes. An organisation can “succeed” on combined

grant metrics by meeting access capability targets while inclusion outcomes stagnate or regress.

Aggregate reporting may therefore appear positive while masking a significant gap.

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Recommendation 2: Separate funding streams for access capability and inclusion capability

should be established. Each stream should have clearly defined objectives, eligibility and

assessment criteria, timelines, focus areas, milestones, success measures, decision-makers and

reporting requirements.

6 Core design features of the Fund

6.1 Co-design with people with disability

The Fund’s guidelines, criteria, application forms and assessment rubric must be co-designed

with people with disability and DROs. Do not wait until documents are drafted before involving

the disability community. This includes:

• Establishing a co-design reference group with a majority of members who are people with disability to shape fund objectives, eligibility and criteria.

• Including people with lived experience of disability as members of the funding assessment panel, appropriately remunerated for their time.

• Piloting the application process with community organisations and people with disability before public launch, and iterating based on feedback.

6.2 Accessible application processes

The way organisations apply for funding should itself model accessible practice:

• Guidelines and forms available in plain language and Easy Read versions, and compatible with screen readers.

• Multiple channels for submitting an application — written, video, audio, or with phone-based support — recognising that small or volunteer-run community groups

may have limited administrative capacity.

• Realistic, flexible application timeframes, with extensions available on request.
• A dedicated application support line or advisory service, including support for applicants seeking to meet any disability-related conditions.

6.3 Tiered and flexible funding structure

A single funding tier and a single reporting standard will disadvantage small, volunteer-run

organisations relative to larger, better-resourced ones. The Fund should offer:

• A small/light-touch grant stream for grassroots groups, with proportionate reporting requirements.

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• A larger capability-building stream for organisations ready to embed more structural change (e.g. facility upgrades combined with workforce and governance

change).

• Eligible expenditure that explicitly includes “invisible” access costs — staff and volunteer disability awareness training, Auslan/language interpreters, access

audits, alternative format materials — not only physical infrastructure.

• Multi-year funding options, recognising that genuine organisational and cultural change (including the governance conditions discussed in section 7) takes longer

than a single project cycle.

6.4 Assessment criteria grounded in the Social Model

Assessment  criteria  and  scoring  should  reward  applicants who  address  attitudinal,

communication and organisational barriers, in addition to physical access. Applicants should be

required to demonstrate how people with disability have been or will be involved in shaping the

funded activity, and assessors should weight this involvement as a core merit criterion rather

than a bonus item.

6.5 Capacity-building support (not funding alone)

Funding should be paired with non-financial support so that smaller organisations are not simply

left to meet disability inclusion conditions unassisted:

• Access to disability awareness training and access consultants, funded or brokered by the program.

• A community of practice or peer-mentoring network connecting grantees to one another and to established disability-led organisations.

• Warm referral pathways to local DPOs, disability employment services and relevant community connectors.

6.6 Accessible promotion and outreach

The Fund should be actively promoted through disability networks, DPOs and disability media,

not only through mainstream grants channels, so that the program reaches organisations that

may not otherwise see themselves as eligible or capable applicants.

6.7 Proportionate reporting

Reporting requirements should scale with grant size and should measure meaningful outcomes

co-designed with people with  disability,  for example, changes in organisational practice,

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participation and retention of people with disability, and satisfaction of participants with disability,

rather than defaulting to simple output counts (e.g. “one ramp installed”).

6.8 Accessible complaints and feedback mechanism

The Fund needs a clear, accessible, independent mechanism through which applicants,

grantees, staff, or program participants can raise concerns about accessibility, fairness of

assessment, or a grantee’s conduct.

6.9 Intersectionality

Fund  design, outreach and assessment should account  for  the compounded  barriers

experienced by First Nations people with disability, people with disability from culturally and

linguistically diverse (CALD) backgrounds, LGBTQIA+ people with disability, people with

disability in rural, regional and remote areas, younger people, older people, and people with low

income.

6.10Alignment with legal and policy frameworks

Fund  guidelines must  explicitly reference  the CRPD,  the DDA and  relevant  disability

discrimination legislation in the states and territories, the Strategy, Employ My Ability, the

Disability Employment Strategy, and the relevant recommendations of the Disability Royal

Commission. This will ensure that Fund objectives are anchored in existing legal and policy

commitments.

Recommendation 3: The Fund should be designed around the core features set out in this section:

co-design with people with disability and DROs; accessible application processes; tiered and flexible

funding, including multi-year options; assessment grounded in the Social Model of Disability; non

financial capacity-building support; accessible promotion and outreach; proportionate outcomes

reporting; an accessible and independent complaints and feedback mechanism; an intersectional

approach; and explicit alignment with relevant disability rights, discrimination and policy frameworks.

7 Conditions of grant funding to further improve inclusion

In addition to the Fund’s objectives to build increased capabilities in disability inclusion and disability

access through project funding, there is also a significant opportunity to use the terms and conditions

of grant funding to influence behaviours, change societal attitudes to disability, inclusion, and access

and deliver meaningful change in employment of people with disability.

These conditions should be applied proportionately to the size, structure, staffing model and value

of the grant. Proportionality should not weaken the core requirement for meaningful participation

and decision-making by people with disability. Rather, smaller or volunteer-led organisations should

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be permitted appropriately scaled equivalents where full corporate mechanisms would be

disproportionate.

Where a grantee proposes to engage other businesses to deliver any part of the funded project the

grantee should be required to give preference to businesses that are disability-owned, disability-led,

or that employ people with disability, where such businesses are available and capable of delivering

the required goods or services.

7.1 Design considerations

• Define “disability-owned,” “disability-led” and “employ people with disability” with clear, workable thresholds (for example, ownership or leadership by a person

with disability, or a stated minimum proportion of the workforce identifying as

having disability), drawing on existing supplier diversity definitions where they

exist in the jurisdiction (e.g. Indigenous or social enterprise procurement

schemes) rather than creating an entirely new taxonomy.

• Provide or link to a directory or marketplace of disability-owned/led businesses and disability employment social enterprises, since grantees — particularly small

community groups — are unlikely to be able to identify suitable suppliers

unassisted.

 Frame the obligation as a genuine preference tied to a fair and transparent procurement process (e.g. “must seek quotes from at least one

disability-owned/led business where one is reasonably available”) rather than an

unworkable guarantee, given that in some regions or trades no such supplier

may exist.

• Require grantees to briefly record and report on procurement decisions (who was approached, who was selected, and why) so the condition is auditable without

imposing full public-procurement-style documentation on small community

organisations.

7.2 Grantee organisational requirements

7.2.1 Employment of people with disability — real work, real pay

Where a grantee has paid employees, it should be required to demonstrate genuine, paid

employment of people with disability and should not rely on unpaid “work experience”,

token placements or disability-specific subminimum wage arrangements as evidence of

inclusion. Where a smaller or volunteer-run grantee has no paid workforce, any paid roles

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created through the funded project should provide genuine opportunities for people with

disability, and lived-experience expertise should not be treated as an unpaid substitute for

professional input. All paid roles should be award-compliant (or better), with real duties

and normal employment conditions and entitlements.

7.2.2 Accessible policies across the employment lifecycle

Grantees should be required to have — or demonstrate a credible, funded plan to develop

— accessible recruitment, onboarding, exit, staff development and skills development

policies and processes, covering matters such as accessible job advertisements, flexible

and accessible interview formats, workplace adjustment processes, accessible exit

interviews and clear pathways to promotion and professional development for staff with

disability.

7.2.3 Disability Inclusion and Access Plan (DIAP)

Grantees should have, or be actively developing, a disability inclusion and access plan

(DIAP or equivalent) covering the whole organisation, addressing physical and digital

access, employment, service delivery, procurement, and culture. Given that a DIAP is a

substantial organisational document, smaller grantees should be permitted to submit a

scaled-down access plan with a funded commitment to develop a full DIAP within a

defined period.

7.2.4 Representation in senior and project-critical roles, and co presentation/co-facilitation of activities

The funded project team should include people with disability in senior and project-critical

roles — that is, roles with real decision-making authority over the funded project, not only

advisory or peripheral positions. In addition, any training, presentations or similar project

activities delivered under the grant should be presented or facilitated, or co-presented or

co-facilitated, by a person with disability. This ensures that disability inclusion content is

not delivered exclusively by non-disabled staff or consultants on behalf of people with

disability.

7.2.5 Grantee Disability Advisory Committee

For larger grantees and capability-building grants, grantees should be required to

establish and maintain a functioning disability advisory committee. Smaller or volunteer

led grantees should be permitted a scaled equivalent advisory mechanism where a

standalone committee would be disproportionate, provided it gives people with disability

genuine and documented influence over decisions. Where a committee is required, it

should have:

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• Authority to investigate and provide advice and recommendations on any aspect of the grantee’s business (not limited to the funded project).

• A majority of members who are people with disability.

• An independent Chair who is a person with disability. Guidelines should clarify what “functioning” and “authority to investigate” mean in

practice — for example, a documented terms of reference, a minimum meeting

frequency, a requirement  that the grantee's governing body formally respond  to

committee recommendations within a set period, and a requirement that committee

members (particularly the independent Chair) be paid sitting fees or honoraria rather

than expected to volunteer their expertise.

Recommendation 4: Grant conditions should promote meaningful disability inclusion and

decision-making by people with disability and should be applied proportionately to the size,

structure and value of the grant. Depending on the nature of the grantee and project, this

should include a genuine procurement preference for disability-owned or disability-led

suppliers and businesses employing people with disability; genuine paid roles for people with

disability where paid roles exist; accessible employment-lifecycle policies; a DIAP or scaled

equivalent; people with disability in senior and project-critical roles; co-presentation or co

facilitation of relevant activities; and a functioning disability advisory committee or

appropriately scaled equivalent mechanism.

7.3 Equivalent requirements for the administering agency

The department or agency administering the Fund should be required to demonstrate equivalent

standards of disability inclusion, accessibility and lived-experience leadership appropriate to a

government administering entity. This should include people with disability in genuine paid roles

and in senior and delivery-critical roles within the program team; accessible employment

lifecycle policies; an organisational DIAP or equivalent; co-presentation or co-facilitation of

relevant training and public activities; and a dedicated fund-level disability advisory committee.

7.3.1 Fund-level Disability Advisory Committee

This committee should be additional to (not a substitute for) any existing whole-of-agency

disability advisory body, and should have a remit specific to this grants program:

• Authority to review and advise on fund guidelines, assessment criteria, assessment decisions on request, and the fund’s complaints mechanism.

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• A majority of members who are people with disability, drawn where possible from a mix of individual applicants, DPO nominees and grantee-sector

representatives.

 An independent Chair who is a person with disability, engaged on a paid, arm’s-length basis.

• A standing role in reviewing the fund’s performance and reporting data, and in the periodic review of the grant conditions themselves.

Recommendation 5: The department or agency administering the Fund should be required to

demonstrate equivalent standards of disability inclusion, accessibility and lived-experience

leadership in the Fund’s governance and administration, including people with disability in

genuine paid roles and senior or delivery-critical program roles, accessible employment

lifecycle policies, an organisational DIAP or equivalent, co-presentation or co-facilitation of

relevant activities, and a dedicated fund-level disability advisory committee.

8 Exclusion of direct activity funding

As noted above, it is already settled government policy that the Fund will not fund the delivery of

community programs, events or other activities, including activities for or targeted to people with

disability.

Funding is confined to capability-building inputs and excludes funding for the actual delivery of the

programs, events or activities that this capability is meant to support.

This restriction has been set before, and outside, the public consultation process. It is nonetheless

included in this submission because it materially affects how much the Fund’s other design features

can achieve in practice.

The Consultation Paper gives an explicit rationale for this exclusion. Funding is not expected to pay

for direct service delivery so that “services do not stop when funding ends,” and so that the Fund

can “create lasting change” rather than a dependency that disappears at the end of the three-year

funding period.

This is consistent with the Fund’s framing as a time-limited investment intended to build capability,

capacity and confidence that community organisations then embed into their ongoing activities.

Notwithstanding this rationale, the exclusion sits in tension with the Fund’s stated purpose and with

several of the design features and conditions discussed below:

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The rationale assumes uniform unsustainability: The stated concern (that services will stop when

funding ends) treats all funded activity as equally unable to survive without recurrent government

funding. In practice, community programs vary widely.

Some genuinely have no viable ongoing funding model and would only ever be sustained by

continued grants. Others may fail not because the activity itself is inherently unsustainable, but

because the organisation has not yet had the chance to demonstrate demand, refine the offer based

on participant feedback, and build a paying, membership-based, or otherwise self-sustaining

participant base.

Treating these as the same problem, and responding to both with a blanket delivery exclusion, risks

screening out the kind of project the Fund would most want to support. That is, one that needs

limited, time-bound delivery funding to prove itself and become self-sustaining. We think a

sustainability-tested delivery funding model is a better targeted response to manage the stated risk.

Eligibility requirements of this model will not exclude an application for funding for service delivery.

Each application would be assessed on its merits, including the applicant’s plan to secure the

sustainability of the project before the funding period ends. This plan could include activities to

demonstrate need, build participant awareness and uptake, refine the activity based on participant

feedback, grow a sustainable participant base, and identify alternative or additional funding options.

A successful applicant would be required to monitor and report against the performance measures

in this plan, for example quarterly or half-yearly. Funding agreements could allow the funding body

to pause or withdraw all or part of contracted funding if it is not satisfied that the funded organisation

is on a credible path to at least emerging sustainability by the end of the funding period.

This shifts the safeguard from a blanket rule — no service delivery funding for any project — to a

merit-based assessment of a detailed sustainability strategy, supported by regular reporting and

testing. This approach more directly targets the Government’s stated concern and provides multiple

points of assurance without assuming that every project is equally unsustainable without ongoing

government support.

Our proposed early-stage service delivery funding model separates capability from proof of

capability. We contrast this position with the model proposed in the Consultation Paper. Under that

model, the Fund can provide funding to an organisation to install accessible facilities, train staff in

disability awareness and confidence, develop a Disability Inclusion Action Plan, establish a disability

inclusion advisory committee and accept, reject or partially accept that committee’s advice or

recommendations.

Despite all that activity, and the allocation, management and proper reporting of the organisation’s

use of funding resources, no product or service has been offered or provided to anyone. There has

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not been any change to the number, frequency, or quality of products or services that are inclusive

or accessible to people with disability.

The organisation cannot be funded to deliver the inclusive program, event or activity those

investments were intended to enable. Without that activity, the organisation may have no practical

way to test demand, refine the activity or identify and develop a sustainable operating model.

A significant effect of the government’s decision to exclude funding of service delivery is the gap

that will be created between building the capacity to be inclusive and demonstrating that the

capacity translates into real participation by people with disability.

We are very concerned that this automatic exclusion will fall hardest on disability-specific

programming and activities. We appreciate that the exclusion as described in the Consultation

Paper applies equally to programs of any not-for-profit community organisation. However, the

practical effect of the blanket exclusion is likely to be felt more acutely by programs designed by and

for people with disability.

This should be weighed against sector feedback, recorded in the Consultation Paper, that the Fund

should not recreate segregated programs that separate people with disability from the wider

community; the critique here concerns funding for the establishment phase of genuinely inclusive,

mixed-participation activities, not a case for funding disability-only service delivery in the way earlier,

segregated models operated.

This decision may incentivise disconnected capability-building projects. If an organisation cannot

obtain funding to pilot or deliver the program or service that relies on the capability investment,

applicants may design generic capability projects that are not connected to a specific, validated

activity or service that people with disability want and will use.

Recommendation 6: The blanket exclusion on funding project delivery should be replaced with a

sustainability-tested model that can allow a capped, time-limited establishment or start-up delivery

phase where justified. The following safeguards should apply:

(a) Reframe the exclusion from a blanket rule against delivery funding to a sustainability-tested

model: allow a capped, time-limited establishment or start-up delivery phase, conditional on

the grantee submitting a costed plan for how the activity will demonstrate need, refine its

offering, build a sustainable participant base, and continue on an identified funding model

once Fund support ends.

(b) Require sustainability planning as a core, assessed component of every application (and not

only for projects seeking a delivery-phase exception). Every applicant must show how the

capability being funded will translate into activity that outlasts the three-year funding period.

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(c) Seek an explicit, published rationale and scope statement for the restriction as finally adopted,

so that applicants understand clearly, and in advance, what delivery costs (if any) are in or out

of scope.

(d) Map and publish referral pathways to other government or philanthropic program-delivery

funding (including the Disability Peer Support and Connections Program’s Community

Capacity Building stream), so that organisations can sequence this Fund with a

complementary program-delivery grant, and align application windows across schemes where

possible.

(e) Track, as part of the periodic review recommended elsewhere in this document whether the

exclusion is in practice reducing delivery of accessible programs by grantees, whether it

disproportionately affects disability-led or disability-specific organisations, and whether a

sustainability-tested delivery phase (if introduced) is resulting in activities that continue past

the funding period, and report this evidence back to government as a basis for revisiting the

restriction in future funding rounds.

9 Proposed “light-touch” partnership model

The Consultation Paper proposes a materially lighter mechanism than the conditions set out above.

Rather than  requiring  the employment, governance,  leadership-representation and  advisory-

committee features described above, it proposes that organisations “show they are working with

people with disability,” and suggests that partnership arrangements with disability-led organisations,

disability advocacy groups, representative organisations, or NDIS providers would be “a good way to

do this.”

This paper challenges that proposed model directly, and recommends it not be adopted as the Fund’s

primary mechanism for demonstrating disability inclusion.

9.1 Why partnership, on its own, is the wrong benchmark

Partnership confers no authority: a partnership arrangement, without more, gives a

disability-led organisation a seat at the table, not a hand on the lever. Nothing in the

consultation paper’s description requires the partner organisation to have any power to

require, veto, or compel a change in the grantee’s practice.

This is consultation, not the “close consultation and active involvement … in decision-making”

that Article 4(3) of the UNCRPD calls for, and it falls well short of the authority the grantee

level disability advisory committee in section 7.2.5 would confer.

It outsources expertise instead of building it: the model as proposed allows a grantee to

demonstrate inclusion by pointing to an external relationship, rather than by developing

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internal capability — employing people with disability, embedding them in senior and project

critical roles, and building the accessible organisational policies described in section 7.2.

A grantee could partner with a disability advocacy group for the life of a project and remain,

internally, exactly as it was before: no staff with disability, no accessible recruitment practices,

no lived-experience voice in governance.

That is not capability building; it is capability borrowing, and it does not survive the end of the

grant. This directly undermines the Fund’s stated objective of creating change that lasts

beyond the three-year funding period.

It risks becoming extractive rather than reciprocal: disability-led organisations and DPOs

are themselves typically under-resourced.

A partnership model that does not require the grantee to remunerate the disability-led partner

for their expertise, time and advice risks treating that expertise as a free input the mainstream

organisation can draw on to satisfy a funding condition, while the disability-led organisation

carries the cost.

This risks entrenching a pattern in which disability expertise is sought informally and unpaid,

and should not be built into the design of a $200 million Commonwealth fund.

The bar is undefined and easily satisfied in form only: the consultation paper does not

specify what a partnership must involve to count: its duration, whether it is documented,

whether it includes any decision-making role, or whether the disability-led partner has any

ability to withhold endorsement.

Without minimum standards, “partnership” can be satisfied by a single meeting, a letter of

support, or a referral relationship that exists on paper for the purposes of the application and

nowhere else in the organisation’s practice. A benchmark that can be met this easily is not a

meaningful test of disability-led practice.

It preserves, rather than corrects, the existing power imbalance: under the proposed

model, the mainstream community organisation holds the grant funding, the decision-making

authority, and the relationship with government; the disability-led partner holds none of these.

This reproduces, inside the Fund’s own design, the precise power asymmetry between

disability and mainstream organisations that the Fund is meant to help correct. Genuine

disability-led practice requires people with disability inside the decision-making structure of the

funded organisation, not adjacent to it.

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9.2 Our recommended approach

AFDO does not argue that partnership arrangements have no place in the Fund. We accept that

partnership can be a valuable “bridge”, particularly for very small organisations in the early

stages of building capability.

However, we believe that any partnership needs to be treated as a support mechanism on the

way to internal capability, not as an acceptable substitute for it.

A partnership arrangement with a disability-led organisation cannot be accepted as sufficient,

on its own, to demonstrate a grantee is inclusive and disability-informed.

If partnerships are part of the Fund, there must be clearly defined minimum standards that a

partnership must meet where a funded organisation relies on that partnership to show it is

working with people with disability.

Those minimum standards must include the following:

• A documented partnership agreement specifying its duration, the disability-led partner’s role, and what decision-making or advisory authority it carries — assessed as a merit criterion, not accepted as a checkbox declaration.

• Fair remuneration for the disability-led partner organisation’s time and expertise, funded from the grant, so the arrangement is reciprocal rather than extractive.

• A requirement that partnership be paired with a costed, time-bound plan to build internal capability — progressing toward the employment, policy, and governance features in section 7.2 — rather than standing alone as the grantee’s only demonstrated connection to people with disability.  Assessment weighting that favours applicants building lasting internal capability over those relying solely on an external partnership, consistent with the Fund’s own objective of change that persists after funding ends.

Recommendation 7: Partnerships with disability-led organisations should be treated as a support

mechanism on the path to internal capability, not as a substitute for it. Where a grantee relies on a

partnership to demonstrate that it is working with people with disability, minimum standards should

require a documented agreement, meaningful advisory or decision-making authority, fair

remuneration of the disability-led partner, a costed and time-bound plan to build internal capability,

and assessment weighting that favours lasting internal capability over reliance on an external

relationship alone.

1 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.

2

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.

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3 Hon Mark Butler MP, Speech at the National Press Club, Canberra, 22 April 2026, p. 6, transcript retrieved from https://www.health.gov.au/ministers/the-hon-mark-butler-mp/media/minister-butler speech-at-the-national-press-club-22-april-2026?language=e n, accessed 22 April 2026

4 https://consultations.health.gov.au/disability-and-carers-group/inclusive-communities-fund/, accessed 5 August 2026.

5

Department of Health, Disability and Ageing, Inclusive Communities Fund – Consultation Paper,

Commonwealth of Australia, August 2026, p. 3.

6 Note 3, p. 6.

7 Note 4.

8 Note 3, p. 5.

9 Note 4.

10 Note 3, p. 4.

11 Note 5.

12 Note 3, p. 7.

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