Sg Blind Citizens Australia
Ph 1800 033 660 | E bca@bca.org.au_| W bca.org.au | ABN 90 006 985 226
Response to consultation on the Victorian
State Disability Plan 2027-2031
Lodged via: engage.vic.gov.au
Author: Melanie Chatfield, National Policy Officer
Melanie.chatfield@bca.org.au
Submission date: 17 July 2026
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Content
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- Response to consultation on the Victorian State Disability Plan 2027—2031 CONTENHS……. eee eeeeeessceeceseeceesseeecesseeecesssceesesseeecessseecessaeeecessceecesseeeceesaceesesseeecesseceseeseceesesseeecesseeeeeesaees® 2 1.0 INtrOCUCTION. …. ee eee eeeeeeeseeeeeeesseessceesceeseecsaecaeceaeeeseceseeeseecseecneceaeceaeeeseeeseecseecaesaeseaeeeaeeeeeeeeees 3 2.0 About Blind Citizens Australian… esc eeeesessecssceeseceseceseeesecsnecssceeseceaeeeseceseceaeesaeesseceaeesseeeseseaeesaes 3 3.0 The current Victorian State Disability Plan………… cc ccccsssssscccccecssssssecececccesesssscessecceesessssseeseesecs 4 4.0 Priorities for the new State Disability Plan…………..cccsesessssscccccccessssssssssecsscccceessssssssssseseccesesens 5
4.1 Ensure government information and digital services are USADIE……………::ccccessssccceeesseeeeeseneees 5 4.2. Create communities that enable independent participation…………..cccecccccceesssssseseceeeveeessseees 7 4.3. Increase economic and COMMUNIty ParticiPAtiON ………… cc cececssseessstseceseceesssessssessseeseeceeeeees 14 4.4. Sustain specialist blindness supports alongside mainstream iNClUSION……………cccccceeceseseeees 17 4.5. Deliver measurable outcomes through accountability and CO-deSIgN…………ccccccccsssseceeeseees 18 5.0 RECOMMENAATIONS……….eeeesceeseceseeeseeceseeeseeeseeeeecnecsneceaeeeseeeseecseecseeceaecaeceaeeeseeeeeseeseaeeeaeeeaeeesees 20
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1.0 Introduction
Blind Citizens Australia (BCA) welcomes the opportunity to contribute to the development of Victoria’s next State Disability Plan (the Plan). BCA supports a Plan that delivers practical, measurable improvements in accessibility, independence and participation for all Victorians.
Recent prevalence estimates indicate that more than 145,000 Victorians are likely to be blind or vision impaired by 2030, with demand for accessible communities, services and specialist supports continuing to grow as the population ages.*
The next State Disability Plan provides an opportunity to move beyond establishing policy settings and focus on implementation. For people who are blind or vision impaired - whether they live in or visit Victoria - the success of the next State Disability Plan will be measured by whether government information and services are genuinely accessible, people can travel safely and independently, participate equally in employment and community life, and exercise their rights on an equal
basis with others.
The next State Disability Plan should retain a whole-of-government approach while incorporating targeted actions, performance measures and accountability mechanisms that address the barriers experienced by people who are blind or vision
impaired and other people with sensory disability.
2.0 About Blind Citizens Australia
BCA is the peak national representative organisation of people who are blind or vision impaired. Our submission is informed by lived experience and reflects the barriers that continue to prevent many Victorians who are blind or vision impaired
from participating equally in community life.
- People who are deaf, hard of hearing, blind or have low vision in our community - Victorian Law
Reform Commission
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For more than 50 years, BCA has worked to remove barriers, promote inclusion and uphold the rights of Australians who are blind or vision impaired. BCA provides systemic advocacy, individual advocacy, peer support and policy leadership informed directly by lived experience. As a disability-led organisation, all directors are blind or vision impaired and the majority of staff and volunteers have lived
experience of blindness or low vision.
3.0 The current Victorian State Disability Plan
BCA acknowledges the significant progress made through /nclusive Victoria: State Disability Plan 2022-2026. The Plan reinforced disability inclusion as a whole-of government responsibility and established stronger foundations for co-design, universal design, intersectionality and shared accountability. These principles align with contemporary disability policy, Australia’s obligations under the Convention on the Rights of Persons with Disabilities (CRPD) and Australia’s Disability Strategy 2021-2031.
However, the Victorian Government’s Inclusive Victoria Midway Report (2022-2024)
demonstrates that progress has largely been measured by the completion of actions and implementation activities rather than by whether government services have become more accessible. While the Outcomes Framework represented an important step towards greater accountability, many indicators measure broad population outcomes influenced by factors beyond the State Disability Plan, making it difficult to
assess the impact of individual government actions.
For people who are blind or vision impaired, many of the systemic barriers identified at the commencement of the Plan remain. Public transport, for example, is still not consistently accessible across the entire passenger journey. The Victorian Auditor General’s Office’s 2025 follow-up audit of Accessibility of Tram Services found that accessibility across Melbourne’s tram network had improved only marginally since 2020 and that significant work remained to achieve an accessible, network-wide tram
system’.
? Accessibility of Tram Services: Follow-up | Victorian Auditor-General's Office
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The current Plan also adopts a largely disability-general approach that does not consistently address the distinct barriers experienced by people with sensory disability. While universal design and inclusion are important guiding principles, practical measures that support independent participation for people who are blind or
vision impaired are still required.
“Public transport is still a big barrier. Too many buses either don’t have stop announcements or don’t use them consistently, making it difficult to travel independently. There are also still pedestrian crossings without audible signals, and the built environment often lacks good colour contrast on stairs, poles and street furniture, making it harder to navigate safely.” BCA Member 2026
4.0 Priorities for the new State Disability Plan
4.1 Ensure government information and digital services are
usable
People who are blind or vision impaired rely on government correspondence, websites, online forms, digital identity systems and other digital services to obtain information, access services and exercise their rights. The next State Disability Plan should ensure these channels can be used independently with assistive technologies and that information is provided in accessible formats without people having to repeatedly request it.
4.1.1 Accessible information and communication
Victoria established an important foundation through the Victorian Government Accessible Communications Policy. The next State Disability Plan should focus on consistent application across departments and agencies through clear responsibilities, practical staff training, regular compliance checks and public reporting.
Government information should be published in an accessible primary format wherever possible, such as HTML or accessible Word, at the same time as any PDF
version. Where additional formats are required, including Braille, large print or audio,
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they should be provided within clear service timeframes. Government services should also record and use a person’s preferred communication format, with consent, so that individuals do not need to repeat the same request each time they
interact with government.
“Provide both induction and ongoing refresher training to all government employees to ensure that all of its service provision is accessible, usable and inclusive.” BCA Member 2026
4.1.2 Digital accessibility and emerging technologies
The next State Disability Plan should require accessibility to be considered throughout the procurement, design, development, testing and ongoing maintenance of government digital services. Websites, online forms, mobile applications, portals, payment systems, kiosks and digital identity services should meet recognised standards and be demonstrably compatible with screen readers, screen magnification, keyboard navigation, voice control and other assistive technologies.
This should be supported by mandatory procurement requirements, independent technical assurance, testing by people with disability, routine auditing, enforceable
remediation timeframes and transparent public reporting.
Artificial intelligence, digital identity and automated decision-making may improve access to government services, but they can also create new barriers for people who are blind or vision impaired. The Plan should require these technologies to be assessed before implementation for compatibility with assistive technologies, inaccessible identity-verification requirements, discriminatory impacts and the availability of human assistance and review. Ongoing monitoring should ensure that new technologies expand, rather than restrict, independent and equitable access for people who are blind or vision impaired.
“All government buildings should enable inclusive access when entering and exiting. This includes their security systems. An example is having to provide a photograph to enter without other more inclusive options is not inclusive. Co
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designing with disability stakeholder groups and those with a lived experience of disability before procurement of such systems is essential.” BCA Member 2026
4.2. Create communities that enable independent
participation The next State Disability Plan should adopt a whole-of-community approach that
ensures the places, services and systems people rely on every day are designed to
be inclusive and usable by people with disability.
4.2.1 Transport People who are blind or vision impaired should be able to travel safely, confidently and independently from their front door to their destination. The next State Disability Plan should adopt a whole-of-journey approach to transport accessibility by addressing the barriers that arise before, during and after travel.
Priority actions should include accessible real-time passenger information, reliable audio announcements, accessible digital journey planning and ticketing, effective wayfinding at stations and interchanges, accessible replacement transport during service disruptions, accessible pedestrian environments, and disability capability training for frontline transport staff developed in partnership with people with
disability.
Progress should be measured through publicly reported performance indicators that assess the accessibility and reliability of the entire passenger journey including service disruptions, regional transport and passenger experience rather than relying
solely on infrastructure compliance measures.
“Ensure inclusive delivery of all public transport, providing announcements and notifications that all Victorians can identify and correctly interpret. Always consult and co-design new and updated rolling stock with disability stakeholders before, not after procuring it.” BCA Member 2026
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4.2.2 Public spaces
The Plan should strengthen requirements for accessible public spaces by improving the consistency and availability of tactile and audible wayfinding, audible pedestrian crossings, high-contrast and tactile signage, accessible maps and orientation information, appropriate lighting and colour contrast, clear pedestrian routes, and the effective management of temporary works, detours and street obstructions to ensure
people who are blind or vision impaired can navigate safely and independently.
In partnership with local government and in line with recognised standards and best practice, the Plan should establish consistent requirements for maintaining clear, continuous and obstacle-free pedestrian paths of travel. This should include minimum clear footpath widths, appropriate placement and management of outdoor dining, advertising signs, bins, street furniture and e-scooters, accessible temporary pedestrian routes during construction, and enforcement of local laws where public
spaces create barriers for people who are blind or vision impaired.
4.2.3 Healthcare
People who are blind or vision impaired continue to experience avoidable barriers when accessing healthcare, limiting their ability to obtain information, navigate health
services, Communicate with clinicians and make informed decisions about their care.
While Victoria has strengthened disability inclusion through initiatives such as Disability Liaison Officers and workforce capability programs, the next State Disability Plan should require all publicly funded health services to deliver equitable
access as a core quality and safety expectation.
Health services should provide information, communication and digital services in formats that people can use independently, including appointment booking systems, patient portals, consent processes, referrals, pathology requests, discharge information and follow-up care. These services should comply with recognised
accessibility standards and be compatible with assistive technologies.
Healthcare environments should also support independent navigation through consistent wayfinding, high-contrast and tactile signage, appropriate lighting, and
tactile or audible navigation features where they improve safe and independent
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access. The next Plan should extend these requirements beyond hospitals to primary care, community health, allied health, pharmacies, pathology and diagnostic
imaging.
The Plan should also strengthen workforce capability by requiring practical training for health professionals on communicating effectively with people who are blind or vision impaired, providing information in accessible formats, and meeting individual access requirements. Progress should be supported through measurable accessibility standards, regular monitoring and public reporting, including patient
experience measures for people who are blind or vision impaired.
“Even in eye clinics, accessibility is often overlooked. Patients are expected to watch visual screens to know when they’ve been called, reception staff don’t always provide verbal directions to waiting areas or toilets, and clinicians often don’t identify themselves when they enter the room. These are simple things that
make a huge difference to whether | can access healthcare independently and
with dignity.“ BCA Member 2026
“[I’d like to see] the establishing of guidelines for hospitals in relation to the issuance of enrolment of patient forms prior to admission i.e. the offer to either help complete them over the phone with those who are blind or who have low vision and/or make them available in formats which can be filled in electronically. [I’d like to avoid] having an appointment to see a specialist scheduled, not being told there is to be a lengthy questionnaire required to be filled in and having it thrust into one’s hand at the time of arrival. It’d be good to have the default setting change to have such things sent out ahead of time.”
[There should be] training for staff to help [people who are blind or vision impaired] to complete menus during their hospital stay and advise resident
patients about the presence of meals when delivering them to the ward. | have
missed out on meals when in hospital because of the neglect of both these things.” BCA Member 2026
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4.2.4 Mental health and wellbeing
People who are blind or vision impaired experience significantly higher rates of depression, anxiety and social isolation than the general population**. While adjustment to vision loss can affect mental wellbeing, evidence shows that poorer mental health outcomes are often driven by preventable social and environmental barriers, including inaccessible services, reduced employment opportunities, limited
independent mobility and exclusion from community life®.
Victoria has made substantial progress in reforming its mental health system. However, mental health policies and services continue to treat people with disability as a broad cohort, with limited recognition of the distinct experiences and support needs of people who are blind or vision impaired. The next State Disability Plan should explicitly recognise blindness and low vision within mental health planning and service reform, consistent with the person-centred and equitable approach
recommended by the Royal Commission into Victoria’s Mental Health System.
Mental health services should be accessible by design, with accessible communication, digital services, information and physical environments, supported by clinicians who understand the practical and psychosocial impacts of blindness and vision impairment. Workforce capability should extend beyond general disability awareness to include blindness-specific training, co-designed with people who are blind or vision impaired and disability-led organisations such as Blind Citizens Australia.
The next Plan should ensure blindness and vision impairment is included within routine mental health service monitoring, patient experience surveys and outcome reporting. The next Plan should also strengthen partnerships between mental health services and specialist blindness organisations to improve referral pathways, early
intervention and holistic support. It should recognise that improving mental wellbeing
3 Virgili, G.; Parravano, M.; Petri, D.; Maurutto, E.; Menchini, F.; Lanzetta, P.; Varano, M.; Mariotti, S.P.; Cherubini, A.; Lucenteforte, E. The Association between Vision Impairment and Depression: A Systematic Review of Population-Based Studies. J. Clin. Med. 2022, 11, 2412.
4 Almidani L, Miller R, Varadaraj V, Mihailovic A, Swenor BK, Ramulu PY. Vision Impairment and Psychosocial Function in US Adults. JAMA Ophthalmol. 2024;142(4):283-291.
5 Demmin DL, Silverstein SM. Visual Impairment and Mental Health: Unmet Needs and Treatment
Options. Clin Ophthalmol. 2020
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requires coordinated action across government to address the broader determinants of health, including accessible transport, housing, employment, education, digital
inclusion and community participation.
“There is a lack of accessibility, care and attention given in the space of neurodivergence assessments to the blind and low vision community. Psychiatrists are ill-equipped to understand or provide alternative formats, digital platform creators are not interested in retrospectively increasing digital accessibility, and complaints go nowhere. We are being shut out and directly discriminated against and miss out on the services we need.” BCA Member 2026
“It is critical for front line admin staff, building managers, general managers, as well as therapeutic professionals to understand and implement blindness access and inclusion.” BCA Member 2026
4.2.5 Housing
Victoria has invested in increasing the supply of accessible housing and applying universal design principles to new social housing. The next State Disability Plan should build on this work by recognising that accessible housing must address the needs of people with sensory disability, not only physical mobility.
The Plan should require publicly funded housing to incorporate sensory-inclusive design principles, including effective lighting and colour contrast, accessible wayfinding, accessible communication systems and digital technologies such as intercoms, building access systems and smart home technologies that comply with recognised accessibility standards. These principles should apply not only within individual dwellings but also to entrances, lifts, common areas and shared facilities to ensure residents can navigate and use their homes independently.
The Plan should also expand home modification programs to include sensory accessibility and low vision adaptations and strengthen partnerships between housing providers and specialist blindness organisations to support independent living, Successful tenancies and ageing in place.
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4.2.6 Children and families
The next State Disability Plan should strengthen support for children who are blind or vision impaired by recognising specialist childhood blindness services as an
essential complement to mainstream health, education and disability services.
The Plan should improve coordination between health, education and specialist blindness providers to ensure families can access timely information, understand what supports are available, and access specialist early intervention and peer support from the time of diagnosis, regardless of where they live or whether they are eligible for the NDIS.
The Plan should also ensure that early childhood services, schools, maternal and child health services and family support programs are equipped to meet the needs of children who are blind or vision impaired through improved workforce capability, information in accessible formats and stronger referral pathways to specialist
blindness organisations.
In addition, the Plan should strengthen support for parents who are blind or vision impaired by ensuring parenting information, maternal and child health services, family services and community programs are accessible, inclusive and free from
discriminatory assumptions about parenting capability.
4.2.7 Emergency preparedness
The Plan should require all emergency communications, warning systems and digital information to be accessible by design, ensure evacuation centres, relief services and recovery programs are accessible and inclusive for people who are blind or vision impaired, and strengthen local emergency planning through genuine
partnership with people with disability and disability representative organisations.
Emergency planning and management should recognise the specific needs of people who are blind or vision impaired by supporting continuity of assistive technology, dog guide access, orientation and mobility supports, accessible transport and other essential services during emergencies. The Plan should include
measurable outcomes and public reporting to monitor whether emergency
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management systems enable people who are blind or vision impaired to prepare for,
respond to and recover from emergencies safely and independently.
“There should be increased alert systems ensuring that they operate inclusively, to include audible, written and captioning and sign language notifications where possible, accessible to mobile and landline phones and when required, in buildings and open spaces.” BCA Member 2026
4.2.8 Assistance animals
Victoria has strong legislative protections for people who use dog guides and other assistance animals. However, people who are blind or vision impaired continue to experience unlawful access refusals and inconsistent treatment when using transport, accommodation, hospitality, retail and other public services when accompanied by a dog guide. The next State Disability Plan should focus on improving implementation and enforcement so that legal rights translate into
consistent everyday practice.
The Plan should strengthen compliance with existing access rights by improving public awareness, increasing disability confidence across customer-facing industries, and supporting frontline staff to understand their legal obligations. It should also improve complaint resolution, monitor patterns of access refusals and use this
information to drive targeted education and compliance activities.
Victoria should continue to support nationally consistent assistance animal recognition arrangements and work with disability representative organisations to identify emerging barriers and promote best practice across government, business and the broader community.
“Victoria Police need the knowledge and confidence to enforce assistance animal legislation so people who rely on dog guides can exercise their rights in practice, not just on paper.” BCA Member 2026
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4.3. Increase economic and community participation
People who are blind or vision impaired should have the same opportunities as other Victorians to work, learn, volunteer, and contribute to their local communities. While individual supports play an important role, participation ultimately depends on inclusive mainstream systems that remove barriers and enable people to participate
on an equal basis.
4.3.1 Employment
Employment is a key driver of economic independence, social inclusion and wellbeing. People who are blind or vision impaired continue to experience lower employment rates than the broader population despite having the skills, qualifications and capacity to contribute across all sectors of the economy. Evidence from a Survey by Vision Australia indicates that this disparity is driven largely by systemic barriers including inaccessible recruitment processes, inaccessible workplace technologies, delayed workplace adjustments, employer attitudes and assumptions about capability rather than blindness or low vision itself.°
The Victorian Government should demonstrate leadership as an inclusive employer of people who are blind or vision impaired by ensuring all recruitment systems, workplace technologies, human resource technologies and workplace adjustment processes are accessible by design, comply with recognised accessibility standards and are independently tested by people who use screen readers, screen magnification and other assistive technology before procurement and implementation. BCA’s Eye to the Future project supports employers to improve recruitment and retention of employees who are blind or vision impaired and isa
useful resource for jobseekers and employers’.
Victorian Public Sector Commission workforce data shows that 10.3% of Victorian Public Service employees identified as having disability in 2025 which falls short of the 12% target.2 The next State Disability Plan should build on existing disability
employment commitments by strengthening accountability for recruitment, retention,
® ‘| was not of value to society’: New survey finds employment discrimination for blind and low vision
people still rife | Vision Australia. Blindness and low vision services
7 Eye to the Future Employment Project — Blind Citizens Australia
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career progression and leadership outcomes across the Victorian Public Service. This should include disability-disaggregated workforce reporting and measurable performance indicators, consistent with the Victorian Government’s response to the Disability Royal Commission’.
4.3.2 Civic Participation
People who are blind or vision impaired should be able to participate independently and on an equal basis in Victoria’s democratic and civic life. This includes voting,
participating in public consultations, serving on government advisory bodies and
accessing information about government policies, services and decisions.
Victoria has taken important steps to improve electoral accessibility which is welcomed by the blind and vision impaired community. However, despite the Victorian Government’s Accessible Communications Policy, people who are blind or vision impaired continue to encounter consultation materials and supporting documents that are not consistently available in the most accessible digital formats and public engagement activities do not consistently consider the access
requirements of people who are blind or vision impaired.
The next State Disability Plan should require all Victorian Government consultations and civic participation processes to be designed for accessibility. Consultation papers, surveys, websites and supporting materials should be provided in accessible formats (e.g. in HTML or accessible Word, not PDF only), compatible with assistive technologies and available in alternative formats where required. Public consultation events should be held in accessible venues, supported by accessible registration processes and communication methods, and provide reasonable adjustments to
enable people with disability to participate on an equal basis with others.
The Plan should also continue to strengthen the accessibility of Victorian elections by supporting measures to ensure independent and secret voting, accessible voter information and polling places, and ensuring people who are blind or vision impaired can participate in all aspects of the electoral process — including as part of the
electoral workforce - with confidence and dignity.
8 Victorian Government’s Getting to Work: Victorian Public Sector Disability Employment Action Plan
2018-2025
° Volume 7, Inclusive education, employment and housing | vic.gov.au
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4.3.3 Regional and rural Victoria
People who are blind or vision impaired living in regional and rural Victoria continue to experience reduced access to specialist blindness services, accessible transport
and healthcare, resulting in greater travel, cost and delays in accessing support.
The next State Disability Plan should improve regional access by expanding outreach services, Supporting telehealth and remote service delivery where appropriate, and strengthening referral pathways between local services and specialist providers. These initiatives should complement, rather than replace, access to face-to-face services when they are required.
The Plan should also require major statewide disability and accessibility initiatives to demonstrate how they will deliver equitable access for regional and rural communities, including through measurable regional service targets and public reporting.
4.3.4 Sport, Recreation and Tourism The current Plan has strengthened Victoria’s commitment to inclusive sport, recreation and tourism. The next State Disability Plan should ensure these commitments translate into equitable participation for people who are blind or vision impaired by addressing the sensory barriers that continue to limit access to venues,
programs and visitor experiences.
People who are blind or vision impaired should be able to independently discover, book, travel to, navigate and fully participate in sport, recreation and tourism
experiences. This requires more than physical access.
Victoria has recently published a revised Design for Everyone Guide for sport and active recreation settings. The next Plan should translate such guidance into funding,
delivery and reporting requirements where the government has direct leverage.
Facilities and events should provide accessible pre-visit information, accessible booking systems, consistent wayfinding, tactile and high-contrast signage, audible navigation cues where appropriate, logical venue layouts and staff who are trained to
provide effective assistance when required.
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The Plan should also require government-funded sport, recreation, tourism and cultural organisations to provide equitable access to the experience itself. This should include audio description for sporting events, performances and exhibitions; accessible information about attractions and points of interest; tactile and multisensory interpretation; accessible guided tours; and interactive exhibits, equipment and activities that can be experienced through touch, sound and other
Senses.
As a condition of government funding, organisations should be required to demonstrate that they have removed barriers to participation through accessible information and digital services, inclusive program design, accessible facilities and workforce capability, and to publicly report on the actions taken and outcomes achieved.
4.4. Sustain specialist blindness supports alongside
mainstream inclusion
BCA strongly supports the principle that mainstream services should be accessible, inclusive and responsive to the needs of all Victorians. However, accessible mainstream services do not remove the need for specialist blindness expertise. For many people who are blind or vision impaired, specialist supports are what make independent participation in education, employment, healthcare, transport and community life possible.
Blindness and vision impairment are relatively low-incidence disabilities with highly specialised support requirements. Effective support depends on expertise that is not typically available through mainstream disability or community services. Specialist blindness services complement accessible mainstream systems by building the skills, confidence and independence needed to navigate everyday life.
These services include orientation and mobility training, assistive technology assessment and training, low vision rehabilitation, independent living skills, peer
support, information and advocacy, and specialist advice to mainstream service
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providers. Together, they improve safety, increase independence and enable participation across all areas of life.
The next State Disability Plan should explicitly recognise the role of specialist blindness services as an essential component of an inclusive disability support system. This includes strengthening partnerships between specialist providers and mainstream services, supporting workforce capability across health, education, transport, employment and local government, and ensuring specialist expertise is
available to inform service design and delivery.
As national disability reforms, including changes to the NDIS and the introduction of Foundational Supports, continue to be implemented, Victoria has an important role in monitoring their impact on people who are blind or vision impaired. The next Plan should commit the Victorian Government to working with the Commonwealth, disability representative organisations and specialist blindness and low vision service providers to identify and respond to emerging service gaps, ensuring that no one loses access to essential specialist supports because of changes to national funding
or service arrangements.
The Plan should also recognise the vital role of disability representative organisations and independent advocacy in strengthening public policy, identifying systemic barriers and ensuring that government decisions are informed by the lived
experience of people who are blind or vision impaired.
4.5. Deliver measurable outcomes through accountability
and co-design
While Inclusive Victoria 2022-2026 established stronger governance and reporting arrangements, it has been difficult to determine whether completed actions have resulted in more accessible government services and measurable improvements for
people with disability.
The next State Disability Plan should require every government commitment to
identify a lead agency, implementation milestones, measurable outcome indicators
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and annual public reporting. Progress should be assessed against improvements in the accessibility and usability of government services and the experiences of people with disability, rather than the completion of activities or publication of policies. Outcome indicators should measure changes that government can directly influence. For example, improvements to the proportion of government websites and online services that meet recognised accessibility standards, the percentage of public transport services with reliable audio announcements, the proportion of patients who are blind or vision impaired that report they received information in a format they could use independently, and the experiences of people with disability when
accessing government services.
Government agencies should also demonstrate how accessibility requirements have been applied in policy development, procurement, digital services, infrastructure projects and service delivery, supported by regular auditing.
Implementation and evaluation should be undertaken in partnership with disability representative organisations, recognising their role in monitoring progress and identifying emerging barriers. The Plan should also improve disability data by reporting outcomes for different disability cohorts, including people who are blind or vision impaired, So government can identify where inequities remain and target
future reform.
“There should be yearly revision and consultation with disability Stakeholder groups in order to capture both the progress and adherence of all of the disability plan’s goals and outcomes.” BCA Member 2026
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5.0 Recommendations
Recommendation 1 - Ensure people who are blind or vision impaired can
obtain, read and respond to government information. Actions:
e Require departments and agencies to publish public information in an accessible primary format, such as HTML or accessible Word, at the same time as any PDF version.
e Require correspondence, forms, consultation papers, reports, emergency information and other essential documents to be available in formats compatible with screen readers, magnification software and other assistive
technologies.
e Enable government services to record a person’s preferred communication
format, with consent, and use it consistently in future interactions.
e Publish departmental results, including the proportion of audited content that meets required standards and the time taken to fulfil alternative-format
requests.
Recommendation 2 - Require digital services and technologies to be demonstrably usable by people who rely on screen readers, screen magnification, keyboard navigation, voice control and other assistive
technologies.
Actions
e Apply current recognised digital accessibility standards to websites, online forms, mobile applications, portals, booking systems, payment systems, kiosks and digital identity services.
e Include mandatory accessibility criteria and evidence requirements in
procurement documents, contracts, grants and funding agreements.
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e Require accessibility testing before launch, after major updates and at regular intervals, including testing by people with disability who use relevant assistive
technologies.
e Publish an annual register of major digital accessibility audits, identified
barriers and remediation progress.
Recommendation 3 - Deliver an accessible whole-of-journey transport system and measure whether people who are blind or vision impaired can complete an
entire journey safely and independently
Actions
e Set reliability targets for onboard and station audio announcements, including
stop information, platform changes and service disruptions.
e Require accessible real-time information across websites, apps, displays,
telephone services and public announcements.
e Ensure journey-planning, ticketing and account-management systems can be
used independently with assistive technologies.
e Require disruption plans to provide accessible replacement transport, accessible instructions and assistance that does not depend on visual
signage.
e Include blindness-specific practical training in induction and refresher training
for frontline transport staff.
e Involve people who are blind or vision impaired before procuring or substantially modifying rolling stock, ticketing systems, stations and
passenger-information systems.
e Publish indicators including the percentage of services with functioning audio announcements; accessibility of disruption information and replacement transport; passenger-reported ability to complete journeys independently; performance in regional as well as metropolitan areas; and the time taken to
resolve reported barriers.
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Recommendation 4 - Work with local government to ensure pedestrian
environments remain predictable, obstacle-free and independently navigable
by people who are blind or vision impaired.
Actions
Require appropriate provision and maintenance of audible pedestrian signals, tactile ground-surface indicators, tactile and high-contrast signage, lighting and colour contrast, accessible maps and orientation information, and safe
crossing points.
Regulate the placement of outdoor dining, advertising boards, bins, street furniture, e-scooters and other shared-mobility devices so they do not obstruct
pedestrian routes.
Require construction projects and temporary works to maintain safe pedestrian access or provide a clearly defined, accessible alternative route and require timely public information about footpath closures and significant
route changes in accessible digital formats.
Introduce routine inspection and enforcement arrangements, including clear
responsibility for removing hazards and responding to complaints.
Recommendation 5: Make equitable healthcare a measurable quality and
safety requirement and improve accessibility and support for patients who are
blind or vision impaired
Actions
Require accessible appointment booking, patient portals, electronic forms,
telehealth platforms and digital check-in systems.
Provide consent forms, referrals, pathology information, medication instructions, discharge information and follow-up instructions in formats the
patient can use independently.
Record and act on patients’ communication and access requirements across
admissions, outpatient appointments and transfers.
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Require hospitals and other state-funded facilities to provide verbal notification when patients are called, staff identification and clear verbal directions, accessible menus and assistance where requested, information before appointments where forms must be completed, and support that
protects privacy and independent decision-making.
Improve health service navigation through logical layouts, high-contrast and tactile signage, appropriate lighting and tactile or audible wayfinding where
appropriate.
Require regular practical training for clinical, administrative, reception, security and facilities staff on communicating and working effectively with people who
are blind or vision impaired.
Apply equivalent expectations, where within Victoria’s funding or regulatory authority, to community health, public mental health, allied health, pathology
and diagnostic services.
Publish patient-experience measures that can identify the experiences of people who are blind or vision impaired, including whether information was provided in a usable format, communication requirements were met, the service could be navigated independently; and reasonable adjustments were
provided without undue delay.
Recommendation 6 - Expressly recognise people who are blind or vision
impaired in mental health planning, workforce development, service
monitoring and referral systems.
Actions
Require public mental health information, assessment tools, telehealth
platforms and digital services to be compatible with assistive technologies.
Include blindness-specific content in workforce training, covering communication, accessible assessment, the psychosocial effects of vision
loss and the impact of environmental barriers.
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e Review commonly used assessment instruments to ensure they do not depend unnecessarily on visual tasks, visual materials or inaccessible digital
interfaces.
e Establish referral pathways between mental health services, eye health
services, low-vision services and specialist blindness organisations.
e Include blindness and vision impairment in patient-experience surveys and
service outcome reporting.
e Fund or commission early support and referral following diagnosis or significant vision loss, particularly where social isolation, loss of employment
or reduced mobility increases mental health risks.
Recommendation 7 - Include sensory access in publicly funded housing and support independent orientation, communication and daily living for people
who are blind or vision impaired.
Actions
e Develop and apply sensory-inclusive housing requirements covering lighting and glare, colour and luminance contrast, logical layouts, tactile and high contrast signage, wayfinding in entrances and common areas, lift controls, intercoms and visitor-entry systems, and building-management and smart home technologies. Apply these requirements to dwellings, entrances, lifts, corridors, mail areas, waste facilities, communal spaces and emergency
systems.
e Require digital building systems to be independently operable through
accessible interfaces, tactile controls or compatible personal devices.
e Extend home-modification programs to cover low-vision lighting, contrast,
tactile identification, accessible appliances and other sensory modifications.
e Require housing providers to identify and respond to residents’
communication and orientation requirements.
e Establish referral arrangements with specialist blindness services to support
successful tenancies, ageing in place and adjustment to vision loss.
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Recommendation 8: Ensure that a child’s diagnosis of blindness or vision
impairment triggers timely information, coordinated referrals and access to
specialist support, regardless of NDIS eligibility or location.
Actions
Establish a statewide referral pathway connecting ophthalmology and eye health services with specialist early childhood blindness services, orientation and mobility, low-vision support, assistive technology assessment and
training, education support, and peer support.
Train maternal and child health, early childhood and school staff to recognise access requirements of people who are blind or vision impaired and connect
families with specialist services.
Provide parenting and family-service information in formats accessible to
parents who are blind or vision impaired.
Review government-funded parenting and family programs to remove assumptions that unnecessarily restrict the participation of parents who are
blind or vision impaired.
Recommendation 9: Ensure emergency arrangements enable people who are
blind or vision impaired to receive warnings, understand instructions,
evacuate, use relief services and recover safely.
Actions
Require emergency warnings to be delivered through multiple channels,
including accessible text, audio, telephone and digital formats.
Test emergency websites, applications, maps and registration systems with
assistive-technology users.
Require evacuation and relief-centre plans to address dog guide access and toileting, orientation within unfamiliar environments, use of assistive technology, accessible registration and information, and communication
during power or telecommunications failures.
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e Require councils and emergency agencies to involve disability representative
organisations in local risk planning and exercises.
e Publish post-event evaluations assessing whether people with disability received warnings in time, could evacuate and could use relief and recovery
services.
Recommendation 10: Improve enforcement of dog guide and assistance animal access rights, ensuring existing legal protections result in consistent
access.
Actions
e Provide practical training for Victoria Police and other relevant enforcement agencies on assistance animal rights and their powers to respond to unlawful access refusals, supported by clear operational guidance and consistent
enforcement.
e Establish a consistent process for recording and analysing assistance-animal access complaints across transport, accommodation, hospitality, retail and public services in partnership with disability representative organisations. Use complaint data to identify industries and locations requiring targeted
education, investigation or enforcement.
e Provide practical, industry-specific guidance for frontline workers and
business operators in partnership with disability representative organisations.
e Include assistance-animal obligations in relevant government licensing,
procurement and grant conditions where legally available.
¢ Continue contributing to nationally consistent assistance animal recognition
arrangements.
Recommendation 11 - Strengthen employment outcomes within the Victorian public sector and measure whether employees with disability are recruited,
retained, supported and able to progress into senior roles.
Actions
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Develop targeted recruitment, mentoring and leadership pathways for employees who are blind or vision impaired across the Victorian Public
Service.
Test recruitment portals, online assessments, onboarding systems, human resources platforms and mandatory learning systems with assistive
technology users.
Partner with disability representative organisations and specialist employment initiatives to build employer capability and address misconceptions about
blindness.
Publish disability-disaggregated data on recruitment, retention, career progression and leadership outcomes, consistent with the Victorian
Government’s response to the Disability Royal Commission.
Recommendation 12: Guarantee independently accessible civic and
democratic participation
Actions
Ensure advisory and co-design bodies provide papers, meeting platforms, voting processes and reimbursement systems in accessible formats. Require agencies to test consultation platforms before use and provide a clear
alternative submission method where barriers remain.
Work with the Victorian Electoral Commission to continue to strengthen independent and secret voting options, accessible candidate and voter information, polling-place information and navigation, voting technology, staff training and opportunities for people who are blind or vision impaired to join
the electoral workforce.
Recommendation 13 - Require government-funded sport, recreation, tourism
and cultural experiences to provide equitable sensory access
Actions
Include minimum sensory-access requirements in relevant grants, contracts
and capital funding programs.
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e Require funded venues and events to provide accessible destination, event, booking and pre-visit information and address independent navigation through logical layouts, tactile and high-contrast signage, audible information and
trained staff assistance.
e Require proportionate provision of audio description, tactile and multisensory interpretation, accessible guided tours, accessible information about exhibits and points of interest, and equipment and activities that can be explored
through touch, sound or other non-visual means.
e Require organisations to consult people with sensory disability during program
and experience design.
e Require funding recipients to report what access features were provided, how many accessible sessions or experiences were available and what
participants with disability reported about their experience.
e Include accessible tourism information in government-operated destination
and visitor-information platforms.
Recommendation 14 - Reduce regional and rural inequities for people who are
blind or vision impaired
Actions
e Map regional access to orientation and mobility, assistive technology, low
vision rehabilitation, healthcare and peer support.
e Establish minimum regional service expectations, including referral, waiting
time and outreach targets.
e Fund regional outreach, visiting specialist services and telepractice where
clinically and practically suitable.
Recommendation 15 - Identify and address gaps in specialist blindness supports that are necessary for the effective delivery of state services and are
not reliably available through the NDIS or other national systems.
Actions
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Establish commissioning or partnership arrangements to address identified gaps, particularly for people who are blind or vision impaired and not eligible for the NDIS.
Monitor the effects of NDIS and Foundational Supports reforms through a standing mechanism involving disability representative organisations and
specialist providers.
Publish identified gaps, agreed government responsibilities and actions taken
to prevent service loss.
Maintain access to independent systemic and individual advocacy for people
who are blind or vision impaired.
Fund specialist organisations to build the capability of mainstream services
where blindness-specific expertise is required.
Recommendation 16 - Establish a single, enforceable performance and
accountability framework that specifies who is responsible, what will change,
when it will occur and how the public will know whether it has worked.
Actions
Assign a responsible minister, lead department and accountable senior
executive to every action. Specify funding, implementation milestones and completion dates.
Establish baseline data before implementation and publish annual results
against the baseline and target.
Publish outcomes for different disability groups, including sensory disability,
where the data can be collected safely and reliably.
Fund disability representative organisations to participate in implementation,
monitoring and evaluation rather than relying on unpaid consultation.
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