National Lived Experience Commission assessment of NDIS Amendment Bill co-design process | External submission

National Disability Insurance Scheme Amendment (Securing the NDIS for Future Generations) Bill 2026 Submission 1129 National Lived Experience Commission

commissioner@nlec.au | nlec.au Registered Australian Charity | ABN 79 919 184 486 | Listed on the ACNC Charity Register

SUPPLEMENTARY SUBMISSION | SENATE COMMUNITY AFFAIRS LEGISLATION COMMITTEE National Disability Insurance Scheme Amendment (Securing the NDIS for Future Generations) Bill 2026 Supplementary Submission — National Lived Experience Commission

17 June 2026 | Submitted to: community.affairs.sen@aph.gov.au | Senate Community Affairs Legislation Committee

Note to the Committee

The National Lived Experience Commission (NLEC) was established and published its foundational evidence documents on 17 June 2026 — after the formal submission deadline of 1 June 2026. NLEC respectfully requests that the Committee accept this supplementary submission, noting that it provides independent, methodologically grounded evidence directly relevant to the provisions of the Bill, including the co-design obligations under the UN Convention on the Rights of Persons with Disabilities. NLEC’s National Co-Design Standards Framework and 2026 National Lived Experience Intelligence Report are attached as appendices.

Contents

About NLEC 2. Executive Summary
NLEC’s Interest in the Bill 4. The Co-Design Accountability Gap
Assessment of the Bill’s Co-Design Process 6. Concerns Regarding Specific Provisions
Recommendations 8. Conclusion

Appendix A: Co-Design Assessment Appendix B: About NLEC’s Publications

About the National Lived Experience Commission

The National Lived Experience Commission (NLEC) is a registered national Australian charity with a recognised charitable purpose of advancing public debate. NLEC was established to convert lived experience into structured systems intelligence — identifying recurring patterns of preventable harm, governance failure and service-system dysfunction across Australia’s social, health, justice, housing, disability and community service systems, and publishing evidence-based recommendations for reform.

NLEC is not a government agency, regulator, ombudsman or complaints body. It does not hold coercive statutory power. Its authority rests in the quality of its evidence, the rigour of its methodology and the legitimacy of its public-benefit purpose. NLEC is governed by an independent board of directors and operates in full compliance with ACNC governance standards.

NLEC’s core doctrine is that lived experience is not symbolic consultation. It is operational intelligence. The people who know most about how Australia’s systems work — and where they fail — are the people who have lived inside them. NLEC’s role is

to ensure that knowledge is captured, structured, analysed and published in a form that cannot be ignored.

Executive Summary

NLEC makesNationalthis DisabilitysupplementaryInsurancesubmissionSchemetoAmendmentthe Senate (SecuringCommunitytheAffairsNDIS forLegislationFuture Generations)Committee’sBillinquiry2026 into the Submission 1129 National Disability Insurance Scheme Amendment (Securing the NDIS for Future Generations) Bill 2026 on the basis of two independent publications released on 17 June 2026:

The National Co-Design Standards Framework — Australia’s first independent assessment tool for evaluating whether government reform processes meet the standards of genuine co-design, grounded in CRPD Article 4(3)

The 2026 National Lived Experience Intelligence Report — an independent assessment of the state of Australia’s disability and NDIS system, among nine other reform domains

NLEC’s assessment of the NDIS Amendment Bill 2026 process against its National Co-Design Standards Framework scored it 10 out of 28 — Consultation Only. This finding is consistent with the evidence presented to the Committee by the Australian Federation of Disability Organisations and other disability organisations, which argued that consultation occurred but genuine co-design did not.

NLEC makes four recommendations to the Committee:

The Committee recommend that the Bill not proceed in its current form until a genuine co-design process meeting the standards of CRPD Article 4(3) has been completed
The Committee recommend that an independent lived experience impact assessment of the Bill’s provisions be commissioned before passage, with particular focus on the impact on people with psychosocial disability
The Committee recommend that the Bill be amended to include a statutory requirement for genuine co-design in the development of any subordinate legislation, guidelines or operational policies made under the Bill
The Committee recommend that the government adopt NLEC’s National Co-Design Standards Framework as the basis for assessing co-design quality in future NDIS reform processes
NLEC’s Interest in the Bill

NLEC’s interest in the Bill arises from its charitable mandate to advance public debate and its specific reform focus on the Disability and NDIS domain. NLEC’s 2026 National Lived Experience Intelligence Report assesses this domain as Critical — deteriorating, identifying the proposed NDIS Amendment Bill 2026 as the most urgent reform priority in Australia’s current policy landscape.

NLEC’s interest is not partisan. NLEC does not oppose the principle that the NDIS should be sustainable and well-governed.

NLEC’s concern is with the process by which the Bill was developed and the adequacy of the evidence base for its most significant provisions — particularly those affecting people with psychosocial disability.

NLEC’s submission addresses the following aspects of the Bill:

The adequacy of the co-design process used to develop the Bill, assessed against NLEC’s National Co-Design Standards Framework and Australia’s obligations under CRPD Article 4(3)

The evidence base for the Bill’s most significant provisions, including the reduction of Social and Community Participation and Capacity Building supports

The absence of an independent lived experience impact assessment of the Bill’s provisions

The implications of the Bill for people with psychosocial disability

The Co-Design Accountability Gap

Australia’s governments routinely describe their reform processes as “co-designed” with affected communities. NLEC’s National Co-Design Standards Framework — published on 17 June 2026 — provides the first independent, methodologically grounded tool for assessing whether those claims are accurate.

The frameworkNationalestablishesDisability Insuranceseven standardsSchemethatAmendmentmust be met(Securingfor a theprocessNDIStoforconstituteFuture Generations)genuine co-design,Bill 2026each with Submission 1129 minimum criteria and accountability indicators. The framework is grounded in CRPD Article 4(3), which requires States Parties to closely consult with and actively involve persons with disability in the development and implementation of legislation and policies. Processes are scored on a 28-point scale:

Score Range Assessment Description

22–28 Genuine Co-Design Process meets the standards of genuine co-design

15–21 Substantial Consultation Goes beyond tokenism but falls short of genuine co-design

8–14 Consultation Only Consultation occurred but did not meaningfully shape outcomes

7 or below Symbolic Consultation Does not meet minimum standards for meaningful participation

The seven standards are: (1) Early and Sustained Involvement; (2) Shared Power in Decision-Making; (3) Fair Remuneration and Resource Equity; (4) Representative Diversity; (5) Transparent Methodology and Documentation; (6) Feedback Loops and Iterative Engagement; and (7) Public Accountability for Outcomes. Each standard has minimum criteria and accountability indicators. The full framework is attached as Appendix A.

Assessment of the Bill’s Co-Design Process

NLEC has assessed the process used to develop the NDIS Amendment Bill 2026 against its National Co-Design Standards Framework, based on publicly available information. This assessment is preliminary and subject to revision as further evidence becomes available. NLEC invites the Committee, the government and affected organisations to provide additional evidence that would change this assessment.

Assessment basis: Based on publicly available information

about the Bill’s development process, including the 10 government’s consultation documentation, the Bill’s explanatory Consultation Only memorandum, and evidence presented to this Committee by out of 28 possible points disability organisations.

Consistent with: AFDO Submission No. 446, which argued that

consultation occurred but genuine co-design did not, in breach

of CRPD Article 4(3).

5.1 Standard 1 — Early and Sustained Involvement: Not Met (Score: 1/4)

The evidence before the Committee indicates that disability organisations and people with disability were not involved in the development of the Bill before its key parameters were determined. The Bill was introduced to Parliament on 14 May 2026 with a Senate inquiry deadline of 16 June 2026 — a period of approximately five weeks for public consultation on legislation projected to affect 346,000 people. This does not meet the standard of early and sustained involvement.

5.2 Standard 2 — Shared Power in Decision-Making: Not Met (Score: 1/4)

The evidence before the Committee does not demonstrate that people with disability held meaningful decision-making power in the development of the Bill’s provisions. The Bill’s most significant measure — the $13.2 billion reduction in Social and Community Participation and Capacity Building supports — was not the subject of genuine co-design with the people most affected by it. There is no publicly available documentation of how lived experience input influenced the design of this measure.

5.3 StandardNational3 — DisabilityFair RemunerationInsurance andSchemeResourceAmendmentEquity: (SecuringPartially Metthe (Score:NDIS for2/4)Future Generations) Bill 2026 Submission 1129 NLEC notes that some consultation processes conducted by the government included remuneration for participants. However, the evidence before the Committee suggests that the scale and accessibility of these processes was insufficient to reach the full diversity of people affected by the Bill, particularly people with psychosocial disability, people in remote and regional areas, and people from culturally and linguistically diverse backgrounds.

5.4 Standard 4 — Representative Diversity: Not Met (Score: 1/4)

The evidence before the Committee does not demonstrate that the consultation processes used to develop the Bill actively recruited and included the full diversity of people affected by the proposed reforms, including those with the most severe and complex experiences of the NDIS. The Bill’s own explanatory memorandum acknowledges that women — who make up the majority of primary carers — will be disproportionately affected, but there is no evidence that women carers were specifically targeted in the consultation process.

5.5 Standard 5 — Transparent Methodology: Partially Met (Score: 2/4)

The government has published some information about its consultation processes. However, the full findings of those consultation processes have not been publicly disclosed, and there is no independent review of the methodology used to gather

and analyse lived experience input.

5.6 Standard 6 — Feedback Loops and Iterative Engagement: Not Met (Score: 1/4)

The evidence before the Committee does not demonstrate that participants in the government’s consultation processes were provided with structured feedback on how their input influenced the Bill’s provisions, or that they had the opportunity to respond to draft proposals before the Bill was finalised.

5.7 Standard 7 — Public Accountability for Outcomes: Not Met (Score: 2/4)

The government has not published a co-design outcomes report explaining how lived experience input influenced the Bill’s provisions, or providing a transparent explanation of decisions made contrary to lived experience input. The Bill’s explanatory

memorandum acknowledges some of the Bill’s impacts but does not provide a comprehensive account of how the co-design process shaped the final legislation.

Total score: 10/28 — Consultation Only. This assessment is based on publicly available information and is subject to revision. NLEC notes that if the evidence of genuine co-design is not publicly available, that is itself a finding — transparency is one of the seven co-design standards.

Concerns Regarding Specific Provisions of the Bill

6.1 Social and Community Participation and Capacity Building Supports

NLEC’s 2026 National Lived Experience Intelligence Report identifies the proposed reduction of Social and Community Participation and Capacity Building supports as the most significant threat to the wellbeing of people with psychosocial disability in Australia’s current policy landscape. The government’s own modelling projects that $13.2 billion in savings — more than one-third of total savings — will come from this category of supports.

For people with psychosocial disability, Social and Community Participation supports are not peripheral. They are often the primary mechanism through which people maintain community connection, develop daily living skills, manage their mental health and avoid crisis. The reduction of these supports is likely to generate significant downstream costs in mental health services, emergency departments, homelessness services and justice systems — costs that are not reflected in the Bill’s

financial modelling.

NLEC is notNationalaware Disabilityof any independentInsurancelivedSchemeexperienceAmendmentimpact(SecuringassessmenttheofNDISthe proposedfor FuturereductionGenerations)of SocialBilland2026Community Submission 1129 Participation supports on people with psychosocial disability. NLEC submits that no reform of this scale and consequence should proceed without such an assessment.

6.2 The Scale of Projected Participant Reduction

The government’s own modelling, tabled in the Senate on 27 May 2026 in response to orders moved by Senator Steele-John,

projects that:

241,000 people who join the Scheme before 1 January 2028 will be exited between then and 30 June 2031

A further 105,000 people who would otherwise have been expected to access the Scheme will be denied entry

Total participant numbers will reach 598,000 by 30 June 2031, down from a pre-reform projection of 944,000

NLEC submits that the removal of 346,000 people from or denial of access to the NDIS represents a reform of extraordinary scale and consequence. The evidence before the Committee does not demonstrate that the people most affected by this reform were genuinely involved in designing it. NLEC submits that this is a fundamental failure of the co-design obligations under CRPD Article 4(3).

6.3 The Absence of a Gender Impact Assessment

The Bill’s own explanatory memorandum acknowledges that, due to the gendered nature of caring, women are more likely to be affected by the Bill’s changes, including through reduced paid work. More than twice as many primary carers are women

as men, and 84.7% of primary carers for children with disability are women, many of whom live with disability themselves.

NLEC notes that the Bill meets the government’s own criteria for requiring a Gender Impact Assessment, and that none has been provided. NLEC submits that the Committee should recommend that a Gender Impact Assessment be completed before the Bill proceeds.

6.4 Fraud and Provider Integrity Measures

NLEC notes that fraud and provider integrity measures account for approximately $1.1 billion of the Bill’s projected $38 billion in savings — under 3% of the total. This is a useful reality check against suggestions that fraud is a primary driver of the Scheme’s costs. NLEC supports measures to address fraud and provider integrity, but submits that these measures should not be used to justify the scale of participant reduction projected under the Bill.

Recommendations

NLEC makes the following recommendations to the Senate Community Affairs Legislation Committee:

R1 Genuine Co-Design Before Passage

The Committee recommend that the Bill not proceed in its current form until a genuine co-design process meeting the standards of CRPD Article 4(3) has been completed. This process should meet the minimum criteria of NLEC’s National Co-Design Standards Framework, including early and sustained involvement, shared power in decision-making, fair remuneration, representative diversity, transparent methodology, feedback loops and public accountability for outcomes.

R2 Independent Lived Experience Impact Assessment

The Committee recommend that an independent lived experience impact assessment of the Bill’s provisions be commissioned before passage, with particular focus on: the impact of the reduction of Social and Community

Participation and Capacity Building supports on people with psychosocial disability; the impact of projected participant

reductionsNationalon peopleDisabilitywithInsurancecomplex andSchemeintersectingAmendmentsupport(Securingneeds; andthetheNDISgenderedfor FutureimpactsGenerations)of the Bill onBillwomen2026 Submission 1129 carers.

This assessment should be conducted by an independent body with no financial interest in the outcome of the Bill, using rigorous qualitative and quantitative methods, and with fair remuneration for all lived experience contributors.

R3 Statutory Co-Design Requirement

The Committee recommend that the Bill be amended to include a statutory requirement for genuine co-design — meeting the standards of CRPD Article 4(3) — in the development of any subordinate legislation, guidelines or operational policies made under the Bill. This requirement should specify minimum standards for co-design processes, including the involvement of people with disability and their representative organisations from the earliest stages of

development.

R4 Adoption of National Co-Design Standards

The Committee recommend that the government adopt NLEC’s National Co-Design Standards Framework as the basis for assessing co-design quality in future NDIS reform processes, and that the government publicly report against the framework’s seven standards and 28-point assessment tool for all major NDIS reform processes.

Conclusion

NLEC does not oppose the principle that the NDIS should be sustainable and well-governed. NLEC’s concern is with the process by which the Bill was developed and the adequacy of the evidence base for its most significant provisions.

The evidence before the Committee — including NLEC’s independent co-design assessment, the government’s own modelling, and the submissions of disability organisations — demonstrates that the Bill was developed through a process that does not meet the standards of genuine co-design under CRPD Article 4(3). The people most affected by the Bill’s most significant provisions — people with psychosocial disability, people with complex support needs, and women carers — were not genuinely involved in designing those provisions.

NLEC submits that a reform of this scale and consequence — projecting the removal of 346,000 people from or denial of access to the NDIS — should not proceed without genuine co-design, an independent lived experience impact assessment, and a statutory requirement for co-design in the development of subordinate legislation.

“Lived experience is not symbolic consultation. It is operational intelligence. The people who know most

about how the NDIS works — and where it fails — are the people who have lived inside it. Their evidence should have shaped this Bill. It did not.“

— National Lived Experience Commission, June 2026

NLEC thanks the Committee for the opportunity to provide this supplementary submission and is available to provide further evidence or to appear before the Committee if required.

Daniel Vamplew MICDA Executive Director National Lived Experience Commission commissioner@nlec.au | nlec.au

Registered Australian Charity | ABN 79 919 184 486 | Listed on the ACNC Charity Register

National Disability Insurance Scheme Amendment (Securing the NDIS for Future Generations) Bill 2026 Appendix A — NLEC Co-Design Assessment: NDISSubmissionAmendment1129 Bill 2026 Process

The following table summarises NLEC’s assessment of the NDIS Amendment Bill 2026 development process against the seven standards of NLEC’s National Co-Design Standards Framework. This assessment is based on publicly available information and is subject to revision.

Score Standard Basis for Assessment (0–4)

S1: Early and Sustained 1/4 Bill introduced 14 May 2026; Senate inquiry deadline 16 June 2026 — five weeks for

Involvement consultation on legislation affecting 346,000 people. No evidence of involvement before key parameters determined.

S2: Shared Power in 1/4 No publicly available documentation of how lived experience input influenced the

Decision-Making Bill’s most significant provisions. $13.2B reduction in participation supports not subject

to genuine co-design.

S3: Fair Remuneration 2/4 Some consultation processes included remuneration. Scale and accessibility

and Resource Equity insufficient to reach full diversity of affected people, particularly those with

psychosocial disability.

S4: Representative 1/4 No evidence of targeted recruitment of people with psychosocial disability, women

Diversity carers, people in remote areas or people from CALD backgrounds. Explanatory

memorandum acknowledges gendered impacts but no Gender Impact Assessment

provided.

S5: Transparent 2/4 Some consultation documentation published. Full findings of consultation processes

Methodology not publicly disclosed. No independent methodological review.

S6: Feedback Loops and 1/4 No evidence of structured feedback to participants on how their input influenced the

Iterative Engagement Bill’s provisions. No opportunity to respond to draft proposals before finalisation.

S7: Public 2/4 No co-design outcomes report published. Explanatory memorandum acknowledges

Accountability for some impacts but does not provide comprehensive account of how co-design shaped

Outcomes the legislation.

TOTAL 10/28 Consultation Only

Note: Scores of 1 = Not Met; 2 = Partially Met; 3 = Substantially Met; 4 = Fully Met. This assessment is preliminary, based on publicly available information, and subject to revision as further evidence becomes available. NLEC invites the government and affected organisations to provide

additional evidence.

Appendix B — About NLEC’s Publications

The following NLEC publications are relevant to this submission and are available at nlec.au:

National Co-Design Standards Framework (June 2026) — establishes seven standards of genuine co-design, each with minimum criteria and accountability indicators, and a 28-point assessment tool grounded in CRPD Article 4(3). Freely available and reproducible with attribution.

National Lived Experience Intelligence Report 2026 (June 2026) — Australia’s first independent assessment of the state of social, health, justice, housing and disability systems from the perspective of people with lived experience. Assesses the Disability and NDIS domain as Critical — deteriorating.

The CaseNationalfor a DisabilityNational InsuranceLived ExperienceScheme CommissionAmendment (Securing(June 2026)the—NDISfoundationfor FuturepaperGenerations)explaining whyBill 2026Australia Submission 1129 needs independent lived experience evidence infrastructure.

All NLEC publications are freely available at nlec.au and are reproducible with attribution. NLEC is an ACNC-registered national charity. Its publications are not subject to editorial control by any funder, partner or government body.

Submission details

Submitted to: Senate Community Affairs Legislation Committee Inquiry: National Disability Insurance Scheme Amendment (Securing the NDIS for Future Generations) Bill 2026 Submission type: Supplementary submission Date: 17 June 2026 Contact: commissioner@nlec.au | nlec.au

Organisation: National Lived Experience Commission | ABN 79 919 184 486 | ACNC Registered Charity