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Guidelines on equal access to digital goods and services

Disability Rights

Contents

About this document

This is an update of the Australian Human Rights Commission’s (the Commission) World Wide Web Access: Disability Discrimination Act Advisory Note ver 4.1 (2014). This update builds upon the previous versions of the Commission’s Advisory Note to reflect changes in technology, its role within society, as well as national and international standards and policies that define how technology provides equal access for people with disability.

These Guidelines are being issued under section 67(1)(k) of the Disability Discrimination Act 1992 (Cth) (the Disability Discrimination Act) and section 11(1)(n) of the Australian Human Rights Commission Act 1986 (Cth). 
The Guidelines are not legally binding and should be read in conjunction 
with the Disability Discrimination Act.

They have been prepared in consultation with advisory groups made up of technical subject matter experts, users, and disability representative organisations.

These guidelines are available to download:

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Executive Summary

The Disability Discrimination Act 1992 (Cth) (Disability Discrimination Act) is a federal law that makes discrimination on the ground of disability unlawful in areas of public life. It aims to eliminate discrimination, as far as possible, against people with disability and to recognise that people with disability have the same fundamental rights as others.1

These Guidelines will assist organisations to meet their obligations under the Disability Discrimination Act when providing digital goods and services.

While the subject matter is by nature technical, effort has been made to lay out the requirements expected of organisations in simple terms. Links to detailed technical references are included.

Meeting the standards and guidelines discussed in this document will help organisations to meet their obligations under the Disability Discrimination Act. They are the minimum organisations should aim for. Best practice means that organisations should strive to avoid discrimination by ensuring they provide equal access to digital goods and services to everyone.

The Guidelines are organised into 3 Chapters:

  1. overview of the Disability Discrimination Act and how it applies to digital goods and services
  2. recommendations for organisations and business on how to provide equal access to digital goods and services
  3. standards and guidelines that apply in Australia.

About the Guidelines

The Australian Human Rights Commission (the Commission) has prepared the Guidelines in the exercise of its function under section 67(1)(k) of the Disability Discrimination Act.

The Guidelines are not legally binding and should be read in conjunction with the whole of the Disability Discrimination Act, and state and territory anti-discrimination laws. An organisation or individual may not be protected from a finding of unlawful discrimination if they claim that they conformed with, or relied on, the Guidelines. Organisations or individuals should seek their own independent legal advice if they have concerns regarding their compliance with the Disability Discrimination Act or with relevant state or territory anti-discrimination legislation.

However, in the view of the Commission, the Guidelines will help organisations act consistently with the Disability Discrimination Act.

The need for Guidelines

The use of digital technology is required to participate in almost every aspect of individual and community life. Technology now informs how we connect with family and friends, get an education, work, enjoy movies and music, cook a meal, seek medical services, access public services, manage personal finances, pay bills and shop.

The opportunity to take part in all aspects of everyday life on an equal basis with others can often depend on being able to access and use technology.

Most people will use a combination of digital and non-digital means to get things done. They might buy a product from an online shop and visit the same business in person. They might order groceries online but interact with a person when receiving the delivery or following up on a problem with the product.

Everyone has a right to be able to access goods and services. They have a legal right not to be discriminated against when they try to do so. This means that a person with disability should be able to complete the full task or enjoy the use of any good using technology that is readily available to them.

Examples

  • A person with disability should be able to utilise all the online services offered by their financial institution, at all times when it is available to other customers. This includes multi-factor identification requirements, error messages and any particular requirements for transactions such as needing to speak to a call centre to release a term deposit.
  • A person with disability should be able to complete an online purchase including understanding available products and options, delivery requirements, purchasing and receiving confirmation of purchase and updates on delivery progress.

Many people with disability face barriers when using digital technologies due to a lack of universal design. For example, many websites do not contain alternative text information for images or have poorly titled links that are required for navigation. This can make the website inaccessible for people who use screen readers. These barriers are often the result of ableist assumptions that influence decisions made when designing, developing and/or procuring digital goods and services. The impact of those decisions can exclude and discriminate against people with disability. This can mean a loss of independence and reduced participation in society, which in turn can lead to less choice and opportunity to fulfil other ambitions in life.

The availability of goods and services via the internet and other digital networks has the potential to provide equal access for people with disability, and to provide access more broadly, more economically and more quickly than is possible using other delivery methods. Equality of access to digital goods and services can enable autonomy and lifestyle choices. It also leads to greater equality of access to services such as health, education, employment and recreation. However, digital options do not always guarantee accessibility, nor does every new technology provide equal access by default.

Technology has evolved since the Disability Discrimination Act was introduced. The ways in which goods and services are accessed and developed has continued to change and we now predominantly operate in a digital environment. Accessibility standards have evolved as well. Irrespective of changes in technology, the fundamental questions under the Disability Discrimination Act are:

  • Does the way in which the good or service is provided discriminate against people because of disability?
  • What actions have been taken to eliminate discrimination?

These Guidelines will help to answer the above questions in the context of the provision of digital goods and services. They will assist by clarifying the requirements of the Disability Discrimination Act in this area and explain how compliance can be best achieved.

Who should read these guidelines?

This document is written for a broad audience. The key audience is people in organisations who have obligations under the Disability Discrimination Act to not discriminate against people because of disability when providing digital goods and services.

This includes: 

  • C-suite executives who are accountable for the quality of digital goods and services
  • organisation leaders such as managers, principals, Boards / Directors
  • creators of digital goods and services such as designers, developers, publishers and educators
  • operators of user content hosts such as social media platforms
  • suppliers or companies who build or sell digital goods and services
  • procurers of digital goods and services such as procurement professionals
  • employers who deploy digital technologies for use by staff
  • digital accessibility practitioners
  • ICT professionals and leaders
  • compliance professionals - generalists and specialists such as those working in Data Privacy, Corporate Affairs, Information Security and Human Resources
  • legal professionals working in or advising organisations.

The audience for these Guidelines also includes people with disability and their representative organisations, disability peak bodies, and advocates. The Guidelines will assist them with understanding and exercising their right to non-discrimination in the digital world.

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  • Acknowledgements

    The Australian Human Rights Commission thanks its partners, Intopia, and specifically Neil Jarvis: Strategy and Policy Lead, Intopia and Dr Andrew Arch: Principal Digital Accessibility Consultant, Intopia; Chair of Standards Australia’s ICT Accessibility Committee (IT40).

    The Commission thanks

    Early project panel contributing authors

    • Greg Alchin: Project Chairperson and lead author, Principal Accessibility Specialist, Service NSW, Founder of All Equal
    • Dr Manish Amin: Director, Centre for Inclusive Design, OZeWAI committee member
    • Cliff Edwards: Accessibility Specialist, UX Design - Services Australia, Accessibility Special, Sth Australian Government
    • Dr Scott Hollier: Director, Centre for Accessibility
    • Chris Leighton: UX and Accessibility Designer, University of Western Australia
    • Sean Murphy: Senior Digital System specialist (Accessibility), Telstra Digital Services, OZeWAI committee member
    • Sarah Pulis: Director and Accessibility Specialist, Intopia
    • Myfanwy Wallwork: Executive General Manager, Regulatory Compliance Global, LexisNexis Legal & Professional
    • Dr Andrew Arch: Principal Digital Accessibility Consultant, Intopia, Chair of Standards Australia’s ICT Accessibility Committee (IT40)
    • Suzanne Colbert: AM, GAICD, Strategic Advisor to Australian Network on Disability (AND) Former Chief Executive of AND
    • Matt Hawkins: Transformation Lead, Group Procurement ANZ Bank, Lead of AND’s Accessible Procurement Taskforce
    • Gisele Mesnage: Founder of The Digital Gap Initiative
    • Gerry Neustatl: Digital Accessibility & Inclusive Design Lead, Australian Broadcasting Corporation, OZeWAI committee member
    • Brigitta (Bri) Norton: UX Designer, Accessibility Specialist and Digital Strategist, Co-Chair of OZeWAI.org, the professional association for Australian digital accessibility specialists and organisations
    • Gian Wild: Founder, Owner and CEO of AccessibilityOz

    Expert advisory groups members

    • Tim McQueen: Digital Content Manager, Australian Human Rights Commission
    • Greg Alchin: Principal Accessibility and Inclusion Specialist, Service NSW
    • Andrew Normand: Web Accessibility Lead, University of Melbourne
    • Donna Purcell: Branch Manager Office of Participant Advocate, 
      National Disability Insurance Scheme
    • Brian Hardy: Independent Member Finance and Risk Committee, 
      Providing All Living Supports Inc
    • Erin Beel: Independent Consultant, Erin Beel Design & Accessibility
    • Lucy Serret: Head of User Experience and Design, BindiMaps
    • Matt Hawkins: Director Procurement, University of Melbourne
    • Allison Ravenhall: Principal Accessibility Specialist, Commonwealth Bank of Australia
    • Ross Mullen: Director, CANAXESS
    • Jack Fitzgerald: Assistant Director, Service Experience Standards Team, Digital Transformation Agency
    • Stuart Hill: Assistant Director of web and digital, Australian Public Service Commission
    • Darren Britten: National Assistive Technology Project Officer, Australia Disability Clearinghouse on Education and Training
    • David Swayn: Disability Policy Officer, Australian Communications Consumer Action Network
    • Glenn Mogford: Executive Design Director Digital, NAB
    • Carolina Pachioli: Digital Communications Lead, National Disability Services
    • Majella Knobel: Head of Access and Inclusion, Westpac
    • Laura Pettenuzzo: Inclusion Support Coordinator, Children and Young People with Disability Australia
    • Jess Schulz: Senior Communications Officer, Disability Advocacy Network Australia.

    The Commission is grateful to all individuals and organisations that participated by making submissions to the public consultation.

  • Forewords

    Rosemary Kayess, Disability Discrimination Commissioner

    We are part of the Digital Age, a time of rapid technological advancement and change. This has the ability and potential to be a catalyst for the social and economic inclusion of people with disability. Technology now plays a major role in everyday life in facilitating communication and transactions. 
    If that technology is accessible, then people with disability can be participants in all aspects of community life: civic and political, economic, social and cultural. 

    The central role that technology has in everyday life highlights the importance of this update of the Commission’s Guidelines on digital accessibility. The Guidelines reflect developments in contemporary digital environments and practices and encompass digital accessibility across a wide range of platforms beyond websites and web-based content.

    People with disability use a diverse range of smart and alternative communication devices. We rely on accessible websites and screen readers, on voice recognition technology, and on automated captioning, screen-in-screen technology to provide sign language interpretation. For many people with disability these are vital technologies enabling communication with others, learning and getting up-to-date information. In turn, the use of this technology is instrumental in enabling people with disability to participate in political and public life.

    We all need access to technology; it has become an essential element of how we live, work and interact. It has become central to our communication, economy, education, healthcare, and social dynamics and, as such, facilitates our enjoyment of fundamental human rights. However, we don’t all enjoy access to technology on an equal basis with others.

    Significant barriers arise from the lack of application of universal design principles and lack of focus on the diversity of end users. These barriers include inaccessible technologies that prevent children with disability from learning alongside their classmates, failure to provide accessible ICT at polling booths and essential services information portals that prevent people exercising their civil and political rights and accessing support in times of crisis. For many, their employment opportunities are compromised when the technologies required for work are inaccessible, or the online application processes are rendered inaccessible through use of security tools such as CAPTCHA. Our access to entertainment and cultural life is hindered by television programs, films, theatre not being captioned or audio described. And the often-prohibitive cost of assistive technology or its lack of availability for people who live in rural and remote areas hold us back.

    The Disability Discrimination Act prohibits and seeks to eliminate discrimination on the ground of disability in areas of public life. This includes those areas of public life that have a digital component, such as online learning, hybrid working arrangements, and essential services such as banking or grocery shopping. To achieve the promise of the Disability Discrimination Act, all technology needs to be accessible to people with disability. It’s not just about assistive technology or technology to enhance the lives of people with disability - it requires all technology to be designed with people with disability in mind and to be inclusive and responsive to the needs of people with disability so that everyone can enjoy the benefits of technology.

    The Guidelines on equal access to digital goods and services assists organisations to meet their obligations under the Disability Discrimination Act. I encourage providers of digital goods and services to understand the reasons for, and the benefits of universal accessibility.

    I would like to thank Intopia for contributing expertise and passion to
    the development of these Guidelines.

    Rosemary Kayess,
    Disability Discrimination Commissioner
    Australian Human Rights Commission

    Sarah Pulis, Director and Co-Founder of Intopia

    In an increasingly digital world, access to digital products and services is not a luxury but a fundamental right. Technology has the power to break down barriers and create opportunities for all. However, without the right approach and guidance, it can also reinforce inequities.

    Intopia was honoured to partner with the Australian Human Rights Commission to produce these Guidelines. The Guidelines provide clear and actionable advice that supports organisations to create digital experiences that are truly inclusive.

    We recognise that accessibility is an ongoing journey, one that evolves alongside technology and user needs. We want to acknowledge the advisors who generously gave their time and input into the guidelines – people with disabilities, those who will use the guidelines, and technical experts in 
    the field of accessibility.

    The guidance in this document doesn’t just support legal requirements—they represent a commitment to fairness, usability, and dignity. By embedding accessibility into the way organisations operate, they can foster innovation, enhance user engagement, and contribute to a more equitable society.

    We hope that these guidelines serve as a renewed catalyst for meaningful change, ensuring that no one is excluded from the digital world because of barriers that can and should be removed. Together, we can build an inclusive digital world - one that upholds the rights of individuals and strengthens our communities.

    Sarah Pulis,
    Director and Co-Founder
    Intopia

  • Glossary and definitions

    Ableism

    Ableism is the basis of how society understands what it means to be human. Disability is viewed as a deficit of the individual who does not meet the bodily, cognitive and mental attributes of ‘normal’ human beings. People with disability are devalued and seen as inherently vulnerable and in need of ‘fixing’ or ‘curing’. Ableism is deeply embedded in legal, policy and practice frameworks and in everyday individual and community attitudes. It results in inequality and discrimination and is the basis for special and segregated settings for the care, treatment and protection of people with disability. The belief that people with disability are incapable of being part of the community becomes self-evident, and the segregation and exclusion of people with disability from community life is unquestioned.

    Assistive Technology

    Equipment or devices that increase or maintain the functional capabilities of people with disability. In the context of digital access, it is hardware, software, and peripheral hardware that assist people with disability in accessing computers or other information technologies. Some examples include screen readers and refreshable Braille devices, alternative keyboards and mice, screen magnification, and voice recognition.

    Convention on the Rights of Persons with Disabilities (CRPD)

    An international instrument that codifies the human rights of people with disability. Countries like Australia that have ratified the CRPD should protect these rights in domestic legislation. Australia ratified the CRPD in 2008.

    Digital products

    Websites, apps, software, digital documents and any product with a 
    digital interface.

    Disability Discrimination Act 1992 (Cth)

    A federal law which makes it unlawful to discriminate on the grounds of a person’s disability in defined areas of public life.

    ICT (Information and Communications Technology)

    The diverse set of technological tools and resources used to transmit, store, create, share or exchange information. ICT covers all technical means used to handle information and aid communication. This includes both computer and network hardware, as well as their software.

    Internet

    The network that connects computers and devices all over the world. It can run over wires and over radio waves. The Web is one system that uses the internet along with email and mobile apps.

    Platform as a Service (PaaS)

    A type of cloud-based service where a third-party provider delivers an operating system and coding environments to users over the internet. An example of a PaaS is Google Cloud.

    Software as a Service (SaaS)

    Cloud-based services delivered over the internet providing productivity suites, recruitment and people management, invoicing and financial management, ecommerce, online or remote meetings, digital libraries, streaming services, video, and music authoring as well as simple engagement with social media platforms.

    Universal design

    An approach to designing environments in a way that they can be accessed, understood and used to the greatest extent possible by all people, see Universal Design (page 33).

    Web Content Accessibility Guidelines (WCAG)

    The applicable international standard for web accessibility. WCAG are also applicable to non-web documents, apps, software and digital interfaces. WCAG are updated from time-to-time and it is important to meet the requirements of the latest published version.

Endnotes

[1] Disability Discrimination Act 1992 (Cth) s3.

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