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Concerns regarding the National Disability Insurance Scheme Amendment Bill impacting CALD women (Provider advocacy)

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National Disability Insurance Scheme Amendment (Securing the NDIS for Future Generations) Bill 2026

Submission 154

Australian Multicultural Women’s Alliance

RE: Concerns regarding the National Disability Insurance Scheme Amendment (Securing the NDIS for Future Generations) Bill 2026

Dear Committee Secretary, The Australian Multicultural Women’s Alliance (AMWA) writes to raise serious concerns regarding the National Disability Insurance Scheme Amendment (Securing the NDIS for Future Generations) Bill 2026 and the potential impacts the proposed amendments may have on women, girls and gender-diverse people from culturally and linguistically diverse (CALD) communities across Australia.

AMWA is the national peak body (led by Federation of Ethnic Communities Councils’ of Australia – FECCA) representing women from multicultural, migrant and refugee backgrounds across Australia. We work to ensure that the voices, lived experiences and priorities of CALD women are centred within policy reform, service delivery and national decision-making processes.* AMWA forms part of the National Women’s Alliances,* alongside Women With Disabilities Australia*(WWDA),the National Aboriginal and Torres Strait Islander Women’s Alliance(NATSIWA),theworking withWomenAlliance(WWNA),andthenationalRuralWomen’sCoalitionNRWC.Together,theallianciesprovideadvocacyandrepresentationfordiversegroupsofwomenacrossAustralia,includingswomenthosexperiencingsystemicdisadvantage,marginalisationandintersectionaldiscrimination.

AMWA stands alongsidewomenwithDisabilitiesAustraliawwwdaandmanyotherdisablelandcommunityorganisationsinexpressingeepconcernregardingthelimitedtimeframeprovidedforconsultationonthisBillandthesignificantimplicationstheproposedamendmentsmayhavefopplanelivingwithdisabilitytheirfamilysandcommunities.Westronglysupportwwwdasubmission andrecommendthat**the Bill not proceed in the absenceof a comprehensive public gender impact analysis,andgender-responsive reforms co-designed wit hwomen,girlsagender-diversewith disability.ForCALD communities,thisco-designmustexplicitl include w omen whose primary language isnotEnglishwhoseengagementwit he NDISisalreadyshapedby linguistic anda cultural barriers.

AMWNoteswelcomestheadm endmentsproposedbymember for FowlerMs Dai Le whichspecifically address intersection of cultur al and linguisti c diversity withNDIS access eligibility.MSLe’s second reading amendmentright notes that culturallya ndlinguisticallydiversecom munitiesexperienceadditionalbarriersinaccessingan d engagingwi ththen DIS,anda lack consultation CAL D participants service providers mayresult further barri ers inequity.H er substantive amendments seek ensure person’s linguis tic environment treated factor affecting functional capacity any appropriate treatment test requirestreatment be linguisticallyculturallyaccessibleatperson’ s geographical location.Thes e amends represent minimum floor protection.AMWA urges Committee recommend these provisions incorporated intoBill Government commit genuineconsultation C ALD comm unities designing implementation.

National Disability Insurance Scheme Amendment (Securing the NDIS for Future Generations) Bill 2026

Submission 154

Australian Multicultural Women’s Alliance

CALD women in Australia experience disability at significant rates, yet remain chronically underrepresented in the NDIS. Barriers to access are compounded by language and literacy challenges, cultural stigma around disability, under-documentation and delayed diagnosis — particularly for conditions that are already less recognised in clinical settings. Women from CALD communities are more likely to rely on family and community networks to navigate complex systems, and less likely to have the professional advocacy support needed to build the evidence base that NDIS eligibility and planning processes demand. The Bill’s proposed reforms risk deepening this exclusion before adequate alternative supports, safeguards and culturally competent service systems exist.

AMWA’s key concerns in relation to CALD women

  • Tightened eligibility will deepen CALD exclusion: Proposed functional capacity thresholds, permanence tests and “appropriate treatment” requirements will operate in a system where CALD women already face delayed diagnosis, clinical dismissal and under-documentation. Where treatment is not available in a person’s language or is culturally unsafe, it will be inaccessible in practice –yet risk being treated as“not exhausted.” Conditions disproportionately affecting women, including chronic pain, pyschosocial disability,fatigue-relatedand trauma-related impairment ,arealreadyunderrecognised;thisriskis amplifiedforwomenwho cannotadvocateinEnglishorwhofaceculturalbarrierstoclinicalengagement.AMWS stronglysupportsrequiringthatanytreatmentdeemed“appropriatemustbedemonstrablyavailableinan accessiblelanguageandanaccessiblelocationconsistentwithMsLe’sproposedamendments.-**Support reductionswillshiftunpaidcareontoCALDwomen:WomenfromCaldcommunitiesaredisproportionatelyrepresentedamongAustralia’s unpaidcarers.Mancharri dualortreecaringresponsibilities—forchildren withdisability,ageingparentsandedxtendedcommunitymembers—withinkinshipand communitystructures that are often invisibletoformalservicessystems.WhenNDIS-funded supportsares reduced,the need for care does no disappear ;itisa bsorbedbythesewomen.This affects workforce participationfinancialsecuritymentalanda physicalhealth,andcommunitywellbeing.Reductions tosocial,civic anda nd communityparticipationsupportsa reparticularlydangerousforcALDWomene andpeoplew ithd is abilityfork whomcommunityconnectionisanoftenprimarys afetymechanismalifelinef oridentifyingservicen eedsandal protectionagainstviolenceabusean d neglect. - Delegated evidenceandsessmentsettings willentrench culturalaland linguisticbias: The Bill delegates significant decision-making power ton future rulestechnical advisorybodiesstandardised assessment toolsa n automatedorc omputer-assistedprocesses.AMWAisd elpconcernedthatthese mechanismsmay reproduceexisting biases.CALD women w i th disabilityareunder-representedinpublished researchhave lower rates of NDIS plan utilisation — oftenduetoservicegap s rather thanlowerneed—andarel ess likelyt o have formal documentationoffunctionalimpactintheformatassessment toolsexpect.Auto m at ed an df ormula-basedsystemsthatusetistoricaldataaned peer-reviewedgeneralisableevidence risktreatingtheses structuralexclusionsas evidenc eofl owerneed.AnyTechnicalAdvisoryGroup,evid enceframeworkora ssess menttoolmustincludeexpertise inCalddisabilityexperienceintersection aldiscriminationandculturallyresponsive practice,anda mustbe testedforcultural anda ndlinguistic biasbeforebeingapplied.

AMW Aisalso concernedabout theimplicationso fth eBill forCALDWomen navigatingageing andd is abilitysupport pathways.M anypeoplefrom CALDb ackgrounds experiencer accelerated ageing due tocumulative disadvantage, occupationalhazards,delayedhealthcareaccessan d then physical toll offmigration.agedcaresystems arenotdesignedto replace disabilitysupportsandfrequentlycannotprovide tlhe linguisticallya n dacultura llyappropriate services that C AL Dindividualsrequire.The Billm ust not treat aged care asana dequatealternativeforcALD people

National Disability Insurance Scheme Amendment (Securing the NDIS for Future Generations) Bill 2026

Submission 154

Australian Multicultural Women’s Alliance

who need disability-specific support, particularly where those services would not be delivered in the person’s language or within their cultural framework.

AMWA respectfully urges the Committee to:

  • Recommend that the Bill not proceed without a comprehensive public gender impact analysis that specifically examines the impacts on women from CALD communities;
  • Require that any co-design process for NDIS reforms include the genuine, funded participation of CALD women with disability and CALD carer organisations;
  • Support the incorporation of Ms Dai Le’s amendments to ensure linguistic and cultural accessibility is embedded in eligibility and treatment provisions;
  • Require that any future rules, assessment tools, Technical Advisory Group membership and evidence standards be tested for cultural and linguistic bias and include CALD disability expertise; and
  • Ensure that no tightening of access or reduction of supports occurs until alternative systems, including linguistically and culturally accessible foundational supports, are available, tested and sufficient. Reforms of this scale require meaningful co-design, comprehensive consultation and transparent impact analysis before legislative changes are progressed. CALD women with disability are among the most marginalised and least heard in national policy conversations and must be actively and resourced to participate in these processes. The current consultation timeframe does not enable this. AMWA thanks the Committee for considering these concerns and welcomes continued engagement with the Committee, the Government and sector partners on these critical issues. Yours sincerely, Malini Raj Executive Director Australian Multicultural Women’s Alliance (AMWA)