Submission 18 — Blind Citizens Australia (BCA) — Inclusive Communities Fund Consultation

Sz Blind Citizens Australia

Ph 1800 033 660 | E bca@bca.org.au | W bca.org.au | ABN 90 006 985 226

Submission to the Australian Government’s

Inclusive Communities Fund Consultation

Due 31 August 2026

Submission online via: Inclusive Communities Fund Consultation - Privacy Notice

Australian Government Department of Health, Disability and Ageing - Citizen Space

Prepared by: Melanie Chatfield, National Policy Officer

Contact: Melanie.chatfield@bca.org.au

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Background

Blind Citizens Australia, in consultation with Guide Dogs Australia, Deafblind

Australia and Vision 2020, welcomes the purpose of the Inclusive Communities Fund to build the capability of community organisations to become more inclusive and accessible.

For people who are blind or vision impaired, meaningful inclusion requires more than being welcomed or invited to participate. It requires practical access to information, communication, services and environments so people can participate in community life on an equitable basis. For Deafblind people, the interaction of hearing and vision loss can create additional and highly individual barriers to communication, information access and mobility.

Access requirements vary considerably between individuals, may involve a range of communication methods, and can change over time. This reinforces the importance of building community capability that is responsive to different sensory access needs rather than relying on a one-size-fits-all approach.

This approach also aligns with the direction of reform recommended by the Disability Royal Commission towards a positive duty under the Disability Discrimination Act: building the capability of organisations to proactively identify and prevent barriers rather than relying on people with disability to highlight obstacles they’ve already faced.

Design of the Inclusive Communities Fund

The Fund should focus on building practical and sustainable organisational capability, supported by appropriately resourced specialist disability expertise.

1. Define the capability the Fund is seeking to build and establish a baseline

The Fund needs a clear and practical definition of “inclusive” and “accessible”.

For people who are blind or vision impaired, accessibility extends beyond physical access. Barriers commonly arise through inaccessible websites and registration systems, information provided only visually, poor signage or confusing layouts, inaccessible touchscreen appliances or kiosks, dog guide access issues, and staff or volunteer practices.

For Deafblind people, accessibility can be more complex again because communication methods vary widely and may include Auslan, spoken language, braille, tactile communication and other methods. The Fund should recognise sensory disability and establish a baseline that every funded organisation must meet, rather than simply asking applicants how they intend to be inclusive. Without a baseline an organisation might consider an activity “accessible” because the venue

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has a wheelchair ramp, thus overlooking barriers for deafblind, blind and low-vision people.

Recommendation: Establish a baseline that clearly defines “inclusive” and “accessible” for funding, assessment and evaluation purposes.

2. Focus on practical capability, not disability awareness alone Disability awareness training can help, but it is not sufficient on its own. Organisations need practical capability to identify barriers, implement changes and assess whether those changes are working.

This is particularly important for sensory disability. Generic training may not equip an organisation to address screen-reader accessibility, navigation and orientation through a space, communication access or the individual needs of people with intersecting disabilities.

In practice, a funded initiative might combine training with an accessibility review, digital accessibility testing, accessible communication guidance, changes to organisational procedures and subsequent testing with people with disability including those who are blind or have low vision.

Recommendation: Prioritise funding for practical organisational change and ongoing organisational practice rather than stand-alone disability awareness training.

3. Direct investment where it can achieve the greatest improvement

The Fund’s eligibility and assessment processes should not inadvertently favour organisations that already have strong disability capability or established relationships with people with disability.

One of the Fund’s greatest opportunities is to reach broader community organisations where accessibility and disability confidence are currently low. For example, an organisation with limited previous disability engagement could be a strong candidate where it identifies significant barriers and presents a credible plan to address them. Conversely, an organisation already demonstrating strong accessibility should need to show what additional improvement Fund investment would achieve.

Identified accessibility gaps should be informed by people with disability, particularly where an initiative is intended to address barriers experienced by a specific disability cohort such as blindness, Deafblindness or low vision.

Recommendation: Assess funding on demonstrated need, additionality and potential impact. Applicants should be required to establish their current accessibility baseline, identify the barriers or capability gaps they will address and demonstrate the measurable and sustainable improvement the investment will achieve.

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4. Invest in scalable capability and specialist expertise The Fund should avoid spreading investment so thinly that it produces many small, short-term projects with little lasting effect. A large number of disconnected small grants risks repeatedly funding similar resources, training and solutions while producing limited lasting impact. At the same time, community organisations cannot reasonably be expected to develop specialist knowledge across every disability.

The Fund should leverage the expertise of disability representative organisations, specialist providers and people with lived experience to develop practical resources, tools and advice that can be shared and applied across multiple organisations and communities. This expertise should be appropriately funded, rather than creating additional unfunded expectations on disability organisations.

In some circumstances, shared infrastructure may also provide greater reach and value than individual purchases. For example, libraries or community resource centres could provide community access to selected high-cost assistive technology or accessible equipment, where this supports broader community participation and is consistent with the Fund’s eligibility parameters.

Capability also needs to survive beyond the funded initiative. This is particularly important for community organisations reliant on volunteers and part-time staff, where staff turnover can quickly erode knowledge. Accessibility should therefore be embedded into ongoing systems such as induction, communications, procurement, digital standards and governance.

Recommendation: Prioritise scalable and sustainable investments that give community organisations access to specialist disability and lived-experience expertise, practical tools, resources and advisory support.

Recommendation: Support disability specialist organisations to develop high-quality resources, assessment tools and advisory capability that community organisations can access nationally and apply locally.

Recommendation: Utilise existing local infrastructure, including councils, libraries and community resource centres, to help connect organisations with disability resources.

5. Recognise the limits of community capability-building Improving an organisation’s accessibility can remove barriers within that organisation’s control but cannot remove every barrier a person experiences in participating in community life. For example, a person who is blind may still require individual support to travel to or navigate an unfamiliar environment.

Fund guidance should encourage organisations to consider the whole participation journey - from finding accessible information and registering through to locating,

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navigating and participating at the venue - while recognising that some barriers and individual support needs to sit outside the Fund’s capability-building role.

Recommendation: Make clear that improvements in community accessibility do not, in themselves, demonstrate that an individual’s disability-related support needs have reduced.

6. Measure whether accessibility actually improves Success of the Fund should not be measured primarily through grants awarded, training completed or resources produced. The focus should be on demonstrable measures in accessibility, inclusion and participation. For example, an organisation could test its website, information and service processes before and after funding with people who are blind or vision impaired and demonstrate which barriers were removed and whether accessibility and useability was improved.

Venue accessibility should consider lighting, contrast, signage, tactile information, safe navigation acoustics, orientation to unfamiliar environments and guide dog users. An accessible activity is of little value if a person can not independently and safely reach it. Fund guidelines must allow organisations to address transport, meeting points and other facilitative assistance.

Evaluation should consider whether improvements are accessible to people with different and intersecting needs, including people who are blind or vision impaired, people with additional disabilities, people from culturally and linguistically diverse backgrounds, and people in regional and remote communities.

Recommendation: Measure impact against an established baseline. Require funded initiatives to demonstrate sustained improvements in accessibility and participation including through feedback or testing by people with relevant disability experience.

Conclusion

The Inclusive Communities Fund is an opportunity to make a strategic investment in the accessibility capability of Australia’s community sector. For people who are blind or vision impaired, and Deafblind people, this requires particular attention to information, communication, digital and environmental barriers that generic disability initiatives can overlook.

The Fund should build the capability of community organisations to identify, prevent and remove these barriers themselves, supported by specialist expertise where required. Improved community accessibility should complement, rather than be confused with, the individual disability supports some people continue to require to participate. For people who are blind, vision impaired and deafblind , genuine inclusion means being able to find out about an activity, register for it, travel to and navigate the venue, communicate with others, access information that is being

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shared, participate on an equal basis and do with dignity and as much independence as possible.

Recommendations

1. Establish a baseline that clearly defines “inclusive” and “accessible” for funding, assessment and evaluation purposes.

2. Prioritise funding for practical organisational change and ongoing organisational practice rather than stand-alone disability awareness training.

3. Assess funding on demonstrated need, additionality and potential impact. Applicants should be required to establish their current accessibility baseline, identify the barriers or capability gaps they will address and demonstrate the measurable and sustainable improvement the investment will achieve.

4. Prioritise scalable and sustainable investments that give community organisations access to specialist disability and lived-experience expertise, practical tools, resources and advisory support.

b) Support disability specialist organisations to develop high-quality resources, assessment tools and advisory capability that community organisations can access nationally and apply locally.

c) Utilise existing local infrastructure, including councils, libraries and community resource centres, to help connect organisations with disability resources.

5. Make clear that improvements in community accessibility do not, in themselves, demonstrate that an individual’s disability-related support needs have reduced.

6. Measure impact against an established baseline. Require funded initiatives to demonstrate sustained improvements in accessibility and participation, including through feedback or testing by people with relevant disability experience.

About Blind Citizens Australia

Blind Citizens Australia (BCA) is the national representative organisation of people who are blind or vision impaired. We are a disability-led organisation, with people with lived experience at the centre of our governance, policy and advocacy.

BCA works to advance the rights and interests of people who are blind or vision impaired and to remove barriers to full and equal participation in community life. Our work is informed by the lived experience of our members and includes systemic and individual advocacy, policy development, peer support and community engagement.

BCA has more than 3,000 members across Australia and works with governments, disability organisations, service providers and the broader community to promote accessibility, inclusion, choice and independence.

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End of Document.

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