Concerns regarding the cumulative impact of proposed reforms on Aboriginal and Torres Strait Islander people with disability | External submission

First Peoples Disability Network

First Peoples Disability Network Australia

Submission to the Community Affairs Legislation Committee, May 2026

About First Peoples Disability Network Australia

First Peoples Disability Network Australia (FPDN) is the national peak organisation representing Aboriginal and Torres Strait Islander people with disability, their families and communities. FPDN’s work is based on the principles of self-determination and “nothing about us, without us”. It is also guided by the:

UN Convention on the Rights of Persons with Disabilities (CRPD).
UN Convention on the Elimination of All Forms of Discrimination Against Women (CEDAW)
UN Declaration on the Rights of Indigenous Peoples (UNDRIP)
Australia’s Disability Strategy 2021-2031
National Agreement on Closing the Gap

FPDN advocates for the rights, inclusion and wellbeing of First Nations people with disability across all areas of life, including health, justice, education, housing and social security. We believe and follow our framework for a Cultural Model of Inclusion which emphasises ensuring the cultural, social and emotional wellbeing of First Nations people with disability to move past the rigid and culturally unsafe medical and social models of disability.

This submission has been endorsed by:

Bullinah Aboriginal Health Service
Indigenous Allied Health Australia
Lowitja Institute
SNAICC

First Peoples Disability Network

Introduction

The purpose of this submission is to raise significant concerns regarding the cumulative impact of the proposed National Disability Insurance Scheme Amendment (Securing the NDIS for Future Generations) Bill 2026 on Aboriginal and Torres Strait Islander people with disability, their families and communities.

While some amendments raise immediate concerns and others may appear administrative or technical in isolation, the combined effect of the reforms risks significantly increasing exclusion, disengagement and inequity for people already experiencing systemic disadvantage.

These reforms increase reliance on, or force engagement with, systems that many Aboriginal and Torres Strait Islander people with disability, their families and communities already struggle to access or navigate.

The proposed changes collectively increase:

evidentiary requirements
eligibility thresholds
reassessment processes
reliance on digital systems
ongoing engagement with government administration
requirements to access specialist healthcare and treatment
expectations of informal supports
risks associated with loss of contact with the NDIA.

They also increase the practical consequences of not being able to meet those requirements.

These reforms must also be assessed within the broader context in which Aboriginal and Torres Strait Islander people with disability already experience:

structural racism and discrimination
poverty and financial exclusion
housing insecurity, homelessness or overcrowding
digital exclusion
barriers to diagnosis and evidence gathering
barriers to accessing healthcare
geographic isolation
institutional distrust arising from historical and ongoing harm
overrepresentation in child protection, justice and restrictive systems.

The explanatory memorandum itself acknowledges that elements of the Bill may disproportionately affect Aboriginal and Torres Strait Islander people with disability and may negatively impact Closing the Gap outcomes.

The concerns raised in this submission are not arguments against accountability, integrity or sustainability within the NDIS. The Scheme must remain sustainable and capable of delivering equitable supports into the future.

First Peoples Disability Network

However, sustainability cannot be pursued in a manner that reproduces structural harm, deepens inequality or undermines human rights protections.

The repeated framing of people as falling outside the “original intent” of the Scheme risks shifting disability support away from human rights, equity and inclusion and toward increasingly restrictive and cost-driven approaches. Some of the proposed measures also risk reintroducing forms of exclusion, fragmentation and administrative gatekeeping that the NDIS was originally intended to replace.

Disability policy must be grounded in human rights, equity, dignity, cultural safety and self-determination.

FPDN draws attention to the expertise, findings and lived experience reflected in the following Aboriginal and Torres Strait Islander-led reports, reviews and submissions relevant to the issues raised in the submission:

Closing the Gap Independent Aboriginal and Torres Strait Islander Led Review
Productivity Commission Review of the National Agreement on Closing the Gap
NACCHO Australia’s Disability Strategy Review
FPDN Culture is Inclusion
Telling It Like It Is - FPDN
FPDN Submission: Inquiry into NDIS participant experience in rural, regional and remote Australia
Options to improve service availability and accessibility for First Nations people with disability

Key Concerns

The combined impact of these reforms risks increasing exclusion for Aboriginal and Torres Strait Islander people with disability.
Many of the proposed changes rely on systems that are already difficult, inaccessible or culturally unsafe for many people and communities.
Narrower eligibility rules and tighter reassessment processes risk leaving people without the supports they need.
Increased automation and ministerial decision-making powers risk reducing transparency, safeguards and practical review rights
Restrictive reforms should not be introduced before accessible, culturally safe and community-based supports are properly established.

Human Rights Framework

The proposed reforms should be assessed against Australia’s obligations under:

Convention on the Rights of Persons with Disabilities | OHCHR
UN Declaration on the Rights of Indigenous Peoples | OHCHR
The United Nations Declaration on the Rights of Indigenous Peoples (UNDRIP)
International Covenant on Economic, Social and Cultural Rights | OHCHR

First Peoples Disability Network

Convention on the Rights of the Child | OHCHR
National Agreement on Closing the Gap
Australia’s Disability Strategy

This submission is particularly concerned with compatibility with:

CRPD Article 5 (Equality and Non-Discrimination)
CRPD Article 13 (Access to Justice)
CRPD Article 19 (Living Independently and Being Included in the Community)
CRPD Article 21 (Freedom of Expression and Access to Information)
CRPD Article 26 (Habilitation and Rehabilitation)
CRPD Article 28 (Adequate Standard of Living and Social Protection)

as well as:

UNDRIP Article 19 (obtain free, prior and informed consent before adopting and implementing legislative or administrative measures)
UNDRIP Article 21 (Improvement of Economic and Social Conditions)
UNDRIP Article 22 (Particular Attention to the Rights and Needs of Indigenous Elders, Women, Youth, Children and Persons with Disabilities)
UNDRIP Article 23 (Active involvement in developing and determining social programs including administering through own institutions)
UNDRIP Article 24 (Traditional Medicines and Access to Health Services)
UNDRIP 40 (Access to Just and Fair Procedures for Dispute Resolution)

The Bill should also be considered alongside findings and recommendations of:

Disability Royal Commission
NDIS Review
Priority Reforms | Closing the Gap

Of particular concern is that the Bill repeatedly invokes the NDIS Review as justification for reform while departing from the sequencing, safeguards and broader ecosystem approach proposed by the Review itself.

The NDIS Review recommended:

stronger foundational supports
coordinated community systems or “ecosystems of support”
improved mainstream service responses
gradual implementation of reforms alongside strengthened safeguards.

Many restrictive measures contained within this Bill are being advanced prior to the establishment of those protective systems and supports.

First Peoples Disability Network

The Bill also reflects a broader shift away from individualised and tailored approaches toward increasingly standardised, rules-based and administratively determined models of support, including through Support Needs Assessments and new framework plan arrangements. This includes expanded ministerial rule-making powers, limiting funding to specific impairments, and removing important planning principles that support participant choice, control and personalised supports.

Existing Structural Inequity Within the Scheme

Aboriginal and Torres Strait Islander People experience disability at significantly higher rates than non-Indigenous Australians, yet Aboriginal Community Controlled Organisations remain substantially underrepresented within the disability service system. In many communities, significant numbers of participants are already unable to fully access the supports contained within their plans.

The NDIS already does not work equitably for many Aboriginal and Torres Strait Islander participants. These reforms risk widening existing gaps rather than fixing them.

Many aspects of the Bill assume access to:

specialist healthcare
stable telecommunications
permanent and locally established health services
transport
internet access
culturally safe services
consistent engagement with administrative systems

Those assumptions do not reflect the reality for many people across remote communities, regional towns or urban communities already navigating poverty, housing instability, thin markets and inaccessible, unsafe systems.

The increasing emphasis on integrity, fraud and sustainability within the reform narrative contributes to more punitive, restrictive and surveillance-based approaches that disproportionately impact people already facing systemic disadvantage.

Cumulative Impact of the Proposed Reforms

A central concern with the Bill is the cumulative impact of the reforms.

No single amendment fully captures the level of risk created by the Bill, although some are highly concerning in their own right. The significant concern is the way these measures interact with each other within a Scheme that already underserves many Aboriginal and Torres Strait Islander people with disability.

The proposed amendments collectively create a system that increasingly requires people with disability to:

continually prove disability and functional impairment
access specialist evidence and healthcare
navigate reassessment systems

First Peoples Disability Network

maintain ongoing communication with government systems
engage with digital systems and online processes
demonstrate that treatment options have been exhausted
respond to reassessment and compliance requirements within strict timeframes.

These obligations assume equal access to:

healthcare
specialist assessments
stable housing
transport
internet and digital infrastructure
financial resources
literacy and digital literacy
translators or translation services
culturally safe services
informal support networks
disability related supports.

These conditions do not exist equally across Australia.

For many Aboriginal and Torres Strait Islander people with disability, engagement with systems is already shaped by ableism, racism, institutional harm, poverty, inaccessible healthcare and deep distrust of government systems. The cumulative effect of these reforms risks increasing exclusion not because support is unnecessary, but because the systems required to prove eligibility and maintain access are themselves inaccessible.

FPDN have consistently highlighted the double disadvantage of racism and ableism experienced by Aboriginal and Torres Strait Islander people with disability and how these intersecting forms of exclusion can shape how people experience and engage with systems. FPDN continues to advocate for the implementation of the Cultural Model of Inclusion.

Repeated scrutiny and reassessment can also produce significant psychological and emotional harm. Constantly requiring people to prove disability, justify support needs and navigate adversarial systems can reshape how individuals understand themselves, their worth and their right to support. This level of scrutiny is inherently shaped by ableism and risks causing many people to disengage from support systems entirely.

FPDN is deeply concerned that the cumulative effect of repeated scrutiny, instability, loss of supports and ongoing engagement with adversarial systems may contribute to significant psychological distress and disengagement for some Aboriginal and Torres Strait Islander people with disability. This is particularly serious in communities already experiencing disproportionately high rates of psychological distress, suicide and intergenerational trauma.

The Bill also substantially increases waiting periods and administrative delays across access and reassessment processes, including extending some decision-making periods from 21 days to 90 days while simultaneously weakening, limiting or removing review and appeal pathways and procedural safeguards. Delayed access to

First Peoples Disability Network

reassessment, review or supports can have serious consequences for people whose conditions are degenerative, fluctuating or worsening, particularly where people are left without appropriate supports while waiting for decisions.

Functional Capacity Assessments and Cultural Validation

Assessment systems, including the Support Needs Assessment within the new framework plans, that are not culturally validated risk:

misunderstanding disability presentation
communication differences being misread as lack of capacity, disengagement or behavioural issues
cultural obligations and community relationships not being properly understood
people masking disability because of racism, distrust or fear of systems
behavioural presentations being racialised or criminalised rather than recognised as disability-related
increasing risk of inappropriate service responses, child protection involvement or justice system contact
reproducing structural racism and ableism

There is also a real risk that people’s living circumstances could be wrongly interpreted as meaning they need less support.

There is also concern that exclusion from disability supports, delayed access to assessment or inappropriate assessment outcomes may contribute to increased contact with child protection and youth justice systems, particularly for Aboriginal and Torres Strait Islander children and young people with disability who are already significantly overrepresented within those systems.

These concerns are heightened by provisions enabling increased automation of administrative processes and decision-making.

FPDN is concerned about the growing reliance on systems presented as necessary for integrity and sustainability despite limited evidence that they are culturally safe, equitable, transparent or capable of meaningfully understanding the realities of people’s lives, communities and support needs.

The proposed functional capacity definition is also concerning because it seeks to assess a person’s capacity in a way that excludes, as far as possible, the impacts of environmental and personal circumstances. This risks ignoring the significant role that poverty, housing instability, remoteness, racism, ableism and structural inequality already play in shaping how disability is experienced and supported.

For many Aboriginal and Torres Strait Islander people with disability, functional capacity cannot be meaningfully separated from living conditions, infrastructure, transport availability and access to services and supports. In some communities, the absence of disability infrastructure and accessible services may substantially increase the day- to-day impacts of impairment.

While the Explanatory Memorandum presents this approach as improving consistency and objectivity, consistency is not the same as equity. Removing environmental and personal circumstances from assessment risks erasing

First Peoples Disability Network

critical context required to meaningfully understand how disability is experienced in many Aboriginal and Torres Strait Islander communities.

Concerns Regarding “Appropriate Treatment” Requirements

The proposed amendments relating to permanence and “appropriate treatment” are particularly concerning.

The Bill provides that treatment may still be considered “appropriate treatment” even where a person’s circumstances prevent them from accessing it, including due to financial barriers or geographic location.

This creates the risk of structurally impossible eligibility requirements.

Many Aboriginal and Torres Strait Islander people with disability already experience:

poverty
healthcare workforce shortages
specialist waitlists
lack of local services
inaccessible transport
limited culturally safe healthcare
chronic illness
multiple diagnoses
high out-of-pocket medical costs.

A framework that effectively requires people to access unavailable or unaffordable treatment before they can qualify for support embeds systemic discrimination within the eligibility framework itself.

There cannot be a fair or equitable disability support system where people are excluded because they cannot afford treatment or because services do not exist where they live.

Additionally, People should not lose access to disability supports because they refuse, cannot tolerate or do not consent to particular treatment pathways.

Narrowing Disability to “eligible Impairments”

The proposed shift toward funding only supports directly linked to “eligible impairments” also raises significant concerns.

Disability, chronic illness, trauma, and social disadvantage are often cumulative, interactive and deeply interconnected and cannot always be separated into neat bureaucratic categories.

This is particularly relevant for Aboriginal and Torres Strait Islander communities given the cumulative impacts of colonisation, intergenerational trauma, poverty and inequitable healthcare access.

The explanatory memorandum itself acknowledges that Aboriginal and Torres Strait Islander people are more likely to experience chronic disease and cumulative disadvantage.

First Peoples Disability Network

The explanatory memorandum also specifically acknowledges that amendments requiring supports to be directly linked to impairments meeting access criteria may disproportionately affect Aboriginal and Torres Strait Islander participants because of the interaction between disability, chronic illness and cumulative disadvantage.

Restricting supports to narrowly defined impairment categories risks:

unsafe or inadequate support arrangements
increased exclusion
cost shifting to already overwhelmed systems
greater reliance on informal carers and family networks
worsening inequity between participants

People do not experience separate impairments in real life and disability support cannot always be meaningfully separated into isolated functional categories. Narrow eligibility frameworks risk ignoring the cumulative and interconnected realities of people’s lives and disabilities.

The move toward increasingly narrow impairment-linked funding risks fragmenting people’s support needs into artificial administrative categories that do not reflect how disability is actually experienced in daily life.

Reliance on Other Systems and Schemes

The Bill raises significant concerns regarding increasing reliance on other service systems and schemes as alternatives to NDIS supports.

Formal eligibility for another system does not necessarily mean that system is designed to provide the type, intensity or long-term nature of supports required by people with significant disability. Disability supports should not be treated as interchangeable with aged care, health or mental health responses simply because a person may technically qualify for those systems.

This is particularly concerning in the context of:

aged care systems
health systems
mental health systems
motor vehicle injury schemes
workplace injury schemes.

Aboriginal and Torres Strait Islander people may become eligible for some systems, including aged care, at younger ages due to existing government policy settings and significantly lower life expectancy. Earlier eligibility for another system should not be treated as equivalent to equitable access to appropriate disability supports.

There is significant concern that increasing reliance on other systems may contribute to:

cost shifting between government systems
fragmented and inconsistent supports
people falling through service gaps

First Peoples Disability Network

increased crisis-driven responses
worsening inequity for people living in regional and remote communities
increased criminalisation and interaction with police or justice systems where disability support needs go unmet.

Many of these systems are not designed to provide long-term, individualised disability supports or uphold the same principles of choice, control and disability inclusion that underpin the NDIS.

Risks Associated with Loss of Contact

FPDN is also concerned by provisions enabling participant plans to be suspended, and participant status ultimately revoked, where the NDIA is unable to make contact with an individual within 90 days.

This is a particularly concerning aspect of the Bill.

These provisions assume a level of stability, accessibility and individualised service engagement that may not exist for many participants and does not always align with Aboriginal and Torres Strait Islander cultural and community ways of living.

The ability to remain consistently contactable often depends on:

phone access
stable housing
internet access
transport
financial stability
and the ability to regularly engage with government systems.

There are many circumstances in which a participant may temporarily lose contact with the NDIA without their support needs changing in any way.

This may include:

movement between communities
severe weather events
cultural responsibilities
sorry business
family violence
periods of crisis
hospitalisation
incarceration
lack of infrastructure
telecommunications outages in remote areas.

First Peoples Disability Network

Disability alone can create barriers to communication and system navigation without additional factors such as cultural responsibilities, ill health, poverty or limited access to communication technologies.

While these decisions are technically reviewable, the effectiveness of those safeguards will depend heavily on whether people are realistically able to access advocacy, legal assistance and review processes in practice. Procedural safeguards are significantly weakened if people cannot meaningfully challenge decisions affecting their supports or access to the Scheme, particularly where they are unable to obtain assistance to navigate those processes.

Community Participation, Return to Country and Informal Supports

For many Aboriginal and Torres Strait Islander people with disability, these supports are often essential to maintaining connection to family, community, culture and Country.

Many Aboriginal and Torres Strait Islander people with disabilities are also required to leave Country in order to access disability-related supports, healthcare, housing or other essential services that are unavailable within their communities.

These supports may be essential to:

participating in community life
maintaining wellbeing
sustaining informal support relationships
meeting cultural obligations
maintaining connection to Country
accessing return to Country travel

The Disability Royal Commission recognised the importance of these connections and recommended that the NDIS support return to Country travel for Aboriginal and Torres Strait Islander people with disability.

Reducing these supports while simultaneously tightening reassessment and eligibility processes risks increasing isolation and disconnection for people.

There is also a substantial risk that increasing reliance on informal supports will disproportionately shift care responsibilities onto Aboriginal and Torres Strait Islander families and communities already experiencing systemic disadvantage and service gaps.

Reduced access to these supports may also weaken the informal community and family support structures that many Aboriginal and Torres Strait Islander people with disability rely upon to remain connected, safe and included within community life. Increased isolation and disconnection can have significant impacts on wellbeing, mental health, cultural identity and long-term participation.

Reduction of Capacity Building Supports

The proposed reductions to capacity building supports risk undermining early intervention and maintenance supports that assist people to sustain independence, functional capacity, participation and wellbeing. This is

First Peoples Disability Network

particularly concerning for Aboriginal and Torres Strait Islander people with disabilities who already experience substantial barriers to accessing allied health and culturally safe therapeutic supports.

Reducing these supports while simultaneously increasing expectations around treatment and functional improvement risks creating an increasingly contradictory system in which people are expected to demonstrate improvement whilst losing access to supports that may assist them to maintain stability, sustain functional capacity or prevent deterioration.

There is also concern that reductions in disability-related therapeutic supports may increasingly shift responsibility for disability support onto systems that are not designed to provide long-term, specialised disability supports.

FPDN is aware of existing concerns that some disability-related supports are already being treated as supports that Aboriginal Health Services can absorb, despite many of these being specialised disability and therapeutic supports. Aboriginal Health Services are designed to support entire communities, not only people with disability.

This creates a significant risk that people with disability may lose access to specialised disability supports while responsibility is increasingly shifted into systems not designed to deliver them.

Funding Below the Real Cost of Support

The Bill also allows situations where a support may still be considered reasonable and necessary even when the funding provided is not enough to fully access that support in practice.

This creates significant concern because approving a support without funding the real cost of accessing it does not remove the need for that support. Instead, it risks shifting the consequences and costs elsewhere.

There is concern that support needs assessments and new framework planning arrangements will operate as mechanisms through which funding limitations, impairment-linked budgeting and increasingly standardised support allocations are applied at scale. This will reduce flexibility within plans and further disconnect funding from the real cost and complexity of people’s support needs.

For Aboriginal and Torres Strait Islander people with disability, particularly in regional and remote areas, this may contribute to:

deteriorating functional capacity and health outcomes
delayed access to treatment, therapy and early intervention
increased pressure on already overstretched health and community services
greater reliance on unpaid family and community care
increased financial hardship and poverty
increased risk of housing instability or crisis
increased contact with child protection systems where families are unable to access adequate supports
increased interaction with police, justice and restrictive systems where disability support needs go unmet
widening inequity between people who can privately absorb service gaps and those who cannot.

First Peoples Disability Network

These risks are particularly concerning in communities already experiencing limited provider availability, thin markets, transport barriers and difficulty accessing culturally safe services.

Automation and Structural Bias

The proposed expansion of automated administrative decision-making also requires careful scrutiny.

Automated systems can reproduce and reinforce existing inequities if they are built on biased assumptions, incomplete data or decision-making frameworks that do not reflect the realities of people’s lives. Without robust oversight, transparency and culturally informed safeguards, algorithmic systems risk reproducing existing racial, cultural and disability bias.

There must be clear safeguards regarding:

cultural validation
human oversight
transparency of decision-making criteria
accountability mechanisms
review rights
bias monitoring
intersectional impact assessments

There are also significant concerns regarding procedural fairness and transparency where automated systems may alter supports, planning outcomes or payment processes without participants clearly understanding what information has been relied upon, how decisions have been reached or how those decisions can be challenged or reviewed.

This is particularly important given well-documented evidence internationally that automated systems can replicate structural inequities when trained on historically biased data.

The recent Robodebt Royal Commission also highlighted the harm that can occur when automated systems are used without proper transparency, oversight or consideration of people’s real-life circumstances.

Self-Determination, ACCOs and First Nations Governance

The reforms currently proceed without:

a funded First Nations Disability Forum
guaranteed First Nations governance structures
culturally validated assessment systems
guaranteed ACCO delivery pathways within replacement or foundational support systems

This is particularly concerning given governments have already committed to shared decision-making, co-design, capacity-building, indigenous workforce development, community control and partnership approaches through Closing the Gap with Aboriginal and Torres Strait Islander communities.

First Peoples Disability Network

The absence of funded and embedded First Nations disability governance structures risks reproducing the same exclusionary policy approaches that have historically failed Aboriginal and Torres Strait Islander people with disability.

Ministerial Decision-Making Powers

Disability support access should not become overly dependent on the priorities, ideology or policy position of individual ministers or the government of the day.

Governments change. Ministers change. Funding priorities change. The impacts of those decisions can last much longer for communities already struggling to access services.

The concentration of pricing and decision-making powers without sufficient safeguards or accountability mechanisms creates substantial long-term risk, particularly for communities already experiencing service inequity and thin markets.

There are also significant concerns regarding the extent to which some operational decisions may become difficult to meaningfully challenge or review in practice, particularly where key elements of planning and support allocation are increasingly determined through rules, automated systems or administrative mechanisms rather than individualized assessment processes.

Closing the Gap Agreement

The Explanatory Memorandum explicitly acknowledges the potential impacts on Closing the Gap outcomes.

Those impacts require far more serious consideration.

All Australian governments have committed through the National Agreement on Closing the Gap to fundamentally changing the way policies and services are designed, delivered and governed in partnership with Aboriginal and Torres Strait Islander peoples.

That commitment is not symbolic. It is a binding national reform agenda endorsed by the Commonwealth, states and territories, local government and the Coalition of Peaks.

The National Agreement commits governments to shared decision-making, strengthening community-controlled sectors, transforming government organisations and ensuring Aboriginal and Torres Strait Islander peoples are able to access services that are culturally safe, community-led and responsive to local needs.

Disability reform cannot be separated from those commitments.

Any reform that increases barriers to support, reduces trust in systems, centralises decision-making or weakens culturally safe access pathways risks undermining the objectives governments have already agreed to pursue under Closing the Gap.

The success of these reforms must therefore be assessed not only through administrative efficiency or fiscal outcomes, but through whether they uphold the commitments governments have already made to Aboriginal and Torres Strait Islander peoples under the National Agreement on Closing the Gap.

First Peoples Disability Network

Recommendations

Key recommendations include:

Delay implementation of restrictive eligibility, reassessment and funding measures until foundational and community-based supports recommended by the NDIS Review are operational and independently assessed as culturally safe and accessible.
Ensure all reassessment tools, functional capacity assessments and automated decision-making systems are independently culturally validated by First Nations-led researchers before implementation.
Maintain accessible and effective review and appeal rights for all participants, including access to culturally safe advocacy and legal assistance.
Remove provisions that allow treatment requirements to apply where treatment is inaccessible due to poverty, geography, racism, workforce shortages or systemic barriers.
Ensure participants are not denied meaningful access to supports because funding does not reflect the real cost of accessing services, particularly in regional and remote communities.
Ensure participants are not suspended, exited or disadvantaged due to communication barriers, housing instability, digital exclusion, cultural obligations or inability to maintain ongoing engagement with government systems.
Establish and fund permanent First Nations disability governance mechanisms, including the First Nations Disability Forum recommended by the Disability Royal Commission.
Ensure all reforms are independently assessed against Closing the Gap Priority Reforms, human rights obligations and cumulative impacts on Aboriginal and Torres Strait Islander people with disability.

Conclusion

FPDN supports meaningful reform of the NDIS. However, reforms that increase exclusion risks without appropriate safeguards will not create a fairer or more sustainable Scheme for First Nations people with disability.

The cumulative effect of these reforms risks intensifying exclusion for people who already experience substantial structural disadvantage because they increase reliance on systems and resources that are already inaccessible, inadequate or culturally unsafe for many communities.

The Government has already committed to shared decision-making, equitable access and community partnership through Closing the Gap and broader disability reform processes. Those commitments must now be reflected in how NDIS reform is designed and implemented in practice.

The success of the NDIS should not be measured solely by expenditure reduction or administrative efficiency. It should also be measured by whether disabled people can access support with dignity, equity, cultural safety and genuine inclusion.

First Peoples Disability Network

Accessibility Statement

If you encounter difficulties or need this document in an alternative format please contact redacted or by calling redacted

Information on this Statement Date issued: 2026 Policy contact: redacted

First Peoples

redacted Disability Network

redacted