National Co-Design Standards Framework

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

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

NATIONAL STANDARDS FRAMEWORK | FIRST EDITION National Co-Design Standards Framework Distinguishing Genuine Co-Design from Symbolic Consultation in Australian Policy and Service Reform

National Lived Experience Commission | June 2026 | Version 1.0 | Public Interest Publication

Contents

1. Purpose and Scope 2. The Problem: Consultation Without Co-Design

2. Definitions 4. The Spectrum of Participation

3. The Seven Standards of Genuine Co-Design 6. Co-Design Assessment Tool

4. Accountability Indicators 8. Obligations Under International Law

5. Application to Current Reform Processes 10. NLEC’s Role in Co-Design Accountability

6. Purpose and Scope

This framework establishes national standards for distinguishing genuine co-design from symbolic consultation in Australian policy and service reform processes. It is published by the National Lived Experience Commission (NLEC) in the exercise of its charitable mandate to advance public debate and to convert lived experience into public-interest evidence directed at changes

to law, policy, practice and system design.

The framework is intended for use by:

Government departments, statutory bodies and regulatory agencies designing or evaluating consultation and co-design processes

Lived experience organisations, advocacy bodies and peak bodies assessing the quality of engagement offered to their communities

Parliamentary committees, Senate inquiries and review bodies examining whether genuine co-design obligations have been met

Researchers, evaluators and auditors assessing the quality of participation processes

People with lived experience who wish to understand whether the processes they are invited to participate in constitute genuine co-design

This framework does not have statutory force. It is a public-interest standards document published by a registered charity in the exercise of its charitable mandate to advance public debate. Its authority rests in the quality of its evidence base, the rigour of its methodology and the legitimacy of its public-benefit purpose.

2. The Problem: Consultation Without Co-Design

Australia has a well-documented consultation problem. Across health, disability, housing, justice, social services and education, governments and institutions routinely engage people with lived experience of their systems — and then design, implement and evaluate those systems largely without reference to what they heard.

National Disability Insurance Scheme Amendment (Securing the NDIS for Future Generations) Bill 2026 “Consultation occurred, but genuineSubmissionco-design1129 - Supplementarydid not.” Submission

— Australian Federation of Disability Organisations, Submission No. 446 to the Senate Inquiry into the National Disability Insurance

Scheme Amendment (Securing the NDIS for Future Generations) Bill 2026, June 2026

The consequences of this failure are not abstract. When the proposed NDIS Amendment Bill was introduced to Parliament on 14 May 2026, the government’s own modelling projected that 346,000 people would be removed from or denied access to the NDIS by 2031. The largest single savings measure — $13.2 billion — targeted Social and Community Participation and Capacity Building supports, which are the supports most critical for people with psychosocial disability. Disability organisations, including AFDO, argued before the Senate inquiry that this outcome was the direct result of a process that consulted but did not genuinely co-design.

This is not an isolated example. The Royal Commission into Violence, Abuse, Neglect and Exploitation of People with Disability, the Royal Commission into Aged Care Quality and Safety, the Royal Commission into Mental Health in Victoria, and numerous other national inquiries have all identified the same pattern: consultation processes that satisfy procedural requirements without producing substantive influence on outcomes.

The problem is not that governments and institutions are unwilling to engage with lived experience. The problem is that there are no agreed national standards for what genuine co-design requires — and therefore no basis for holding institutions accountable when they fall short.

This framework addresses that gap.

3. Definitions

Term Definition

Lived experience The direct, first-hand experience of people who have navigated, been subject to, or been

affected by the systems, policies, services and institutions that are the subject of reform.

Lived experience is not a demographic category — it is a form of knowledge generated by

direct system contact.

Consultation A process in which people with lived experience are invited to provide input to a decision-

making process that has already been substantially framed by others. Consultation may be genuine or tokenistic. Even genuine consultation does not constitute co-design.

Co-design A process in which people with lived experience are involved as genuine partners in

defining the problem, generating options, evaluating alternatives and shaping the final

decision. Co-design requires shared power, not merely shared information.

Symbolic consultation A process that satisfies the procedural requirements of consultation without producing

substantive influence on outcomes. Symbolic consultation is characterised by:

predetermined conclusions; tokenistic participation; inadequate time and resources;

absence of feedback loops; and no accountability for whether input was used.

Genuine co-design A process that meets the standards set out in Section 5 of this framework. Genuine co-design

is characterised by: shared power; early and sustained involvement; fair remuneration;

transparent decision-making; feedback loops; and public accountability for outcomes.

Co-design accountability The obligation of institutions that claim to have co-designed policies, services or systems to demonstrate, through transparent public reporting, that the standards of genuine co-design

National Disability Insurance Scheme Amendment (Securing the NDIS for Future Generations) Bill 2026 Term DefinitionSubmission 1129 - Supplementary Submission

were met.

4. The Spectrum of Participation

Participation in policy and service reform exists on a spectrum. The following spectrum, adapted from Arnstein’s Ladder of Citizen Participation (1969) and updated to reflect contemporary Australian practice, provides a framework for understanding where any given process sits:

Level Description Characteristics Co-Design?

1. Tokenism Participation for appearance only No genuine influence; No

predetermined outcomes;

participants used for legitimacy

2. Information One-way communication to Participants informed of decisions No provision participants already made; no input sought

3. Consultation Input sought but not binding Views gathered; institution retains No

full decision-making power; no

obligation to act on input

4. Involvement Ongoing engagement with feedback Input genuinely considered; Partial

feedback provided on how input

was used; institution retains

decision-making power

5. Collaboration Shared problem definition and Lived experience contributors Partial

option generation involved in framing the problem

and generating options; institution

retains final decision

6. Co-design Shared power in design and Lived experience contributors Yes decision-making involved from the outset; shared

power in defining problems,

generating options and shaping

decisions; transparent

accountability for outcomes

7. Lived experience Lived experience contributors lead People with lived experience hold Yes — highest

leadership the process decision-making authority; form

institution provides resources and

support; outcomes determined by

lived experience community

Most Australian government consultation processes currently operate at Levels 2–3. Many processes described as “co-design” operate at Levels 3–4. Genuine co-design requires Level 6 or above.

5. The Seven Standards of Genuine Co-Design

NLEC’s NationalNationalCo-DesignDisability StandardsInsurance FrameworkScheme Amendmentestablishes(Securingseven standardsthe NDISthatformustFuturebeGenerations)met for a processBill 2026to constitute Submission 1129 - Supplementary Submission genuine co-design. These standards are derived from: Australia’s obligations under the UN Convention on the Rights of Persons with Disabilities (CRPD); the principles of the National Disability Strategy; the findings of multiple royal commissions and parliamentary inquiries; and the lived experience intelligence gathered by NLEC and its sector partners.

S1 Early and Sustained Involvement

People with lived experience must be involved from the earliest stages of the reform process — before the problem has been

defined, before options have been generated and before any preferred direction has been identified. Involvement that begins

after key decisions have been made does not constitute co-design.

Minimum criteria:

Lived experience contributors involved before problem definition is finalised

Involvement sustained throughout the design, development, implementation and evaluation phases

No predetermined conclusions at the point of engagement

Accountability indicators:

Documentation of when lived experience contributors were first engaged relative to the reform timeline

Evidence that lived experience input influenced problem definition, not merely solution selection

S2 Shared Power in Decision-Making

Genuine co-design requires that lived experience contributors hold meaningful decision-making power — not merely advisory

influence. This does not require that lived experience contributors hold a veto over all decisions, but it does require that their

input has a demonstrable and documented effect on outcomes.

Minimum criteria:

Lived experience contributors involved in defining the decision-making process itself

Clear documentation of how lived experience input influenced each major decision point

Transparent explanation of any decisions made contrary to lived experience input, including the reasons

Accountability indicators:

Decision log showing lived experience input at each major decision point

Public reporting on how input was used and where it was not used, with reasons

S3 Fair Remuneration and Resource Equity

Participation in co-design is not voluntary labour. People with lived experience who contribute to co-design processes must be

fairly remunerated for their time, expertise and contribution. Processes that rely on unpaid participation systematically

exclude people who cannot afford to participate without payment, and therefore produce evidence that does not represent the

full range of lived experience.

Minimum criteria:

All lived experience contributors offered fair payment at or above sector benchmark rates

Remuneration not conditional on the content of contributions

Participants informed of any potential impacts on income support or other entitlements before agreeing to participate

Accessibility supports provided (transport, interpreting, cultural support, carer support) as required

Accountability indicators:

PublicNationaldisclosureDisabilityof remunerationInsuranceratesSchemeofferedAmendmentto lived experience(Securingcontributorsthe NDIS for Future Generations) Bill 2026 Submission 1129 - Supplementary Submission Evidence that accessibility barriers were identified and addressed

S4 Representative Diversity

Co-design processes must actively seek to include the full diversity of people affected by the reform, including those who are

hardest to reach, most marginalised and most likely to be excluded from standard consultation processes. A co-design process

that engages only the most articulate, most connected or most available members of a community does not produce

representative lived experience intelligence.

Minimum criteria:

Active recruitment strategies targeting under-represented groups, including First Nations peoples, people from culturally

and linguistically diverse backgrounds, people with communication support needs, and people in remote and regional areas

Demographic reporting on the diversity of participants

Specific strategies to include people with the most severe and complex experiences of the system under reform

Accountability indicators:

Published demographic profile of participants

Evidence of targeted recruitment strategies for under-represented groups

Assessment of whether the participant group is representative of the affected population

S5 Transparent Methodology and Documentation

The methods used to gather, analyse and use lived experience input must be clearly documented and publicly disclosed.

Processes that gather lived experience input through undisclosed or poorly documented methods cannot be assessed for

quality, and their findings cannot be verified or replicated.

Minimum criteria:

Clear documentation of the methods used to gather lived experience input

Transparent analysis methodology, including how themes were identified and weighted

Public disclosure of the full findings of lived experience engagement, not merely selected excerpts

Independent review of methodology where the reform is of significant public importance

Accountability indicators:

Published methodology document

Full publication of lived experience findings (subject to participant privacy protections)

Independent methodological review for high-stakes reforms

S6 Feedback Loops and Iterative Engagement

Genuine co-design is iterative. Lived experience contributors must be provided with meaningful feedback on how their input

has been used at each stage of the process, and must have the opportunity to respond to draft proposals, preliminary findings

and proposed decisions before they are finalised.

Minimum criteria:

Structured feedback provided to participants at each major stage of the process

Opportunity for participants to review and respond to draft proposals before finalisation

Clear explanation of any changes made between draft and final proposals, including the reasons

OngoingNationalengagementDisabilitythroughoutInsuranceimplementation,Scheme Amendmentnot merely(Securingduring designthe NDIS for Future Generations) Bill 2026 Submission 1129 - Supplementary Submission Accountability indicators:

Documentation of feedback provided to participants at each stage

Evidence of iterative revision in response to lived experience input

Participant satisfaction assessment at the conclusion of the process

S7 Public Accountability for Outcomes

Institutions that claim to have co-designed policies, services or systems must publicly account for the outcomes of that process

— including what was changed as a result of lived experience input, what was not changed and why, and how the outcomes of

the reform will be monitored against the priorities identified by lived experience contributors.

Minimum criteria:

Public report on the outcomes of the co-design process, including a clear account of how lived experience input influenced

the final design

Transparent explanation of any decisions made contrary to lived experience input

Commitment to ongoing monitoring of reform outcomes against lived experience priorities

Independent evaluation of whether co-design obligations were met

Accountability indicators:

Published co-design outcomes report

Independent evaluation of co-design quality

Ongoing monitoring framework aligned with lived experience priorities

6. Co-Design Assessment Tool

The following assessment tool enables organisations, advocates, parliamentary committees and independent evaluators to assess whether a given process meets the standards of genuine co-design. Each standard is assessed on a four-point scale:

1 — Not Met 2 — Partially Met 3 — Substantially Met 4 — Fully Met

Standard not addressed; Some elements present but Most elements present; minor All minimum criteria and symbolic consultation only significant gaps remain gaps accountability indicators met

Standard Key Assessment Questions Score (1–4)

S1: Early and Sustained Were lived experience contributors involved before problem [ ] Involvement definition? Was involvement sustained throughout all phases?

S2: Shared Power in Is there documented evidence that lived experience input influenced [ ]

Decision-Making major decisions? Were decisions made contrary to input explained

publicly?

S3: Fair Remuneration and Were all participants fairly remunerated? Were accessibility barriers [ ]

Resource Equity identified and addressed?

S4: Representative Diversity Were under-represented groups actively recruited? Is the participant [ ]

profile representative of the affected population?

National Disability Insurance Scheme Amendment (Securing the NDIS for Future Generations) Bill 2026 Standard Key AssessmentSubmissionQuestions1129 - Supplementary Submission Score (1–4)

S5: Transparent Is the methodology publicly documented? Were full findings [ ]

Methodology published?

S6: Feedback Loops and Were participants provided with structured feedback at each stage? [ ]

Iterative Engagement Did they have the opportunity to respond to draft proposals?

S7: Public Accountability for Has a public co-design outcomes report been published? Has [ ]

Outcomes independent evaluation been conducted?

Total Score (out of 28) [ ]

Total Assessment Interpretation Score

22–28 Genuine Co-Design Process meets the standards of genuine co-design. Minor gaps may exist but do not

undermine the overall quality of participation.

15–21 Substantial Process goes beyond tokenism but falls short of genuine co-design. Significant Consultation improvements required to meet co-design standards.

8–14 Consultation Only Process constitutes consultation, not co-design. Lived experience input may have been

gathered but did not meaningfully shape outcomes.

7 or Symbolic Process does not meet minimum standards for meaningful participation. Lived experience

below Consultation engagement was tokenistic or absent.

7. Accountability Indicators

The following accountability indicators provide a basis for public reporting on co-design quality. NLEC recommends that all government departments, statutory bodies and service providers that claim to have co-designed policies, services or systems publish an annual co-design accountability report addressing these indicators:

Participation data: Number of lived experience contributors engaged; demographic profile; remuneration rates paid; accessibility supports provided

Process data: Timeline of engagement relative to decision-making milestones; methods used; feedback mechanisms employed

Influence data: Documented account of how lived experience input influenced each major decision; explanation of decisions made contrary to lived experience input

Outcome data: Assessment of reform outcomes against priorities identified by lived experience contributors; independent evaluation findings

Co-design score: Self-assessed score against NLEC’s Co-Design Assessment Tool, with supporting evidence

8. Obligations Under International Law

Australia’s obligations to involve people with disability in decisions that affect them are not merely aspirational. They are

binding obligations under international law.

Article 4(3) of the UN Convention on the Rights of Persons with Disabilities (CRPD), which Australia ratified in 2008, requires that:

National Disability Insurance Scheme Amendment (Securing the NDIS for Future Generations) Bill 2026 “In the development and implementationSubmissionof legislation1129 - andSupplementarypolicies to implementSubmissionthe present Convention, and in other decision-making processes concerning issues relating to persons with disabilities, States Parties shall closely consult with and actively involve persons with disabilities, including children with disabilities, through their representative organisations.”

The UN Committee on the Rights of Persons with Disabilities has consistently interpreted Article 4(3) as requiring genuine participation — not merely consultation — in all decisions that affect people with disability. The Committee has specifically stated that consultation processes that do not give people with disability meaningful influence over outcomes do not satisfy

the requirements of Article 4(3).

Similar obligations apply under the UN Convention on the Rights of the Child (Article 12), the UN Declaration on the Rights of Indigenous Peoples (Articles 18–19), and Australia’s own National Disability Strategy 2021–2031, which commits to “meaningful participation” of people with disability in decisions that affect them.

NLEC’s National Co-Design Standards Framework is designed to operationalise these obligations — to translate the principle of genuine participation into concrete, assessable standards that institutions can apply and that communities can use to hold institutions accountable.

9. Application to Current Reform Processes

The following table applies NLEC’s Co-Design Assessment Tool to three current major Australian reform processes, based on publicly available information. These assessments are preliminary and will be updated as further information becomes available. NLEC invites affected organisations and individuals to contribute evidence to these assessments.

Reform Process S1 S2 S3 S4 S5 S6 S7 Total Assessment

NDIS Amendment Bill 2026 1 1 2 2 2 1 1 10 Consultation Only

National Mental Health Workforce Capability 2 2 2 2 2 2 2 14 Consultation Only

Framework

AAPW Establishment Process 4 3 3 4 2 3 2 21 Substantial

Consultation

Important note on preliminary assessments: These assessments are based on publicly available information only and are subject to revision as further evidence becomes available. NLEC has not conducted a full independent assessment of any of these processes. These preliminary scores are published to demonstrate the application of the framework and to invite further evidence from affected communities and organisations. They do not constitute a final NLEC finding.

10. NLEC’s Role in Co-Design Accountability

NLEC’s National Co-Design Standards Framework is the first of a series of public-interest publications through which NLEC will build Australia’s lived experience intelligence infrastructure. NLEC’s role in co-design accountability includes:

Standards development: Developing, publishing and updating national standards for genuine co-design, in consultation with lived experience organisations, advocacy bodies, researchers and institutions

Independent assessment: Conducting and publishing independent assessments of the co-design quality of major Australian reform processes, based on lived experience evidence and publicly available information

EvidenceNationalgathering:DisabilityGatheringInsurancelivedSchemeexperienceAmendmentevidence on(Securingthe qualitythe ofNDISco-designfor FutureprocessesGenerations)from peopleBill who2026have Submission 1129 - Supplementary Submission participated in them, and publishing that evidence in the public interest

Capacity building: Providing training, advisory services and resources to institutions seeking to improve the quality of their co-design processes

Sector collaboration: Working with lived experience organisations, advocacy bodies, peak bodies and research institutions to strengthen the sector’s collective capacity to hold institutions accountable for co-design quality

Invitation to Contribute

NLEC invites contributions to the development of this framework from:

People with lived experience who have participated in government or institutional co-design processes and wish to share their assessment of the quality of that engagement

Lived experience organisations, advocacy bodies and peak bodies with evidence relevant to the assessment of specific reform processes

Researchers and evaluators with expertise in participation methodology, co-design quality assessment or related fields

Government departments, statutory bodies and service providers that wish to have their co-design processes independently assessed against this framework

Contributions can be submitted to: commissioner@nlec.au

This framework is a living document.

It will be updated annually to reflect new evidence, emerging practice and feedback from the sector. NLEC welcomes critique, challenge and contribution — because the quality of this framework depends on the same principle it seeks to establish: that the people most affected by a system are the most important source of intelligence about how to improve it.

National Lived Experience Commission | commissioner@nlec.au | nlec.au Registered Australian Charity | ABN 79 919 184 486 | Listed on the ACNC Charity Register June 2026 | Version 1.0 | Public Interest Publication — freely reproducible with attribution

commissioner@nlec.au | nlec.au | Registered Australian Charity | ABN 79 919 184 486 | Listed on the ACNC Charity Register The ACNC Registered Charity Tick indicates NLEC is registered with the ACNC. It does not constitute ACNC endorsement of this document or its contents.