Website Accessibility in Australia: The DDA, WCAG 2.2 and What to Fix First

Website Accessibility in Australia: The DDA, WCAG 2.2 and What to Fix First

About 5.5 million Australians, 21.4% of the population, had disability in 2022 according to the Australian Bureau of Statistics. Among people aged 65 and over the figure was 52.3%. If your website is hard to use with a screen reader, a keyboard or low vision, you are turning away a large share of potential customers, and you may be exposed under the Disability Discrimination Act.

This guide explains how the law applies to websites, which standard to aim for, and where to start. It reflects official sources as at October 2026 and is general information, not legal advice.

What the law says

Section 24 of the Disability Discrimination Act 1992 makes it unlawful for anyone who provides goods, services or facilities, whether paid or free, to discriminate on the ground of disability, including in the terms on which they are provided or the manner in which they are provided. "Services" includes professional and trade services, banking, insurance, finance, entertainment, travel and government services, and discrimination includes failing to make reasonable adjustments.

The Australian Human Rights Commission says this applies to digital goods and services, and lists websites, e-commerce, apps, software, documents, AI chatbots, CAPTCHAs, two-factor authentication, QR codes and kiosks. There is a defence of unjustifiable hardship, but the business claiming it has to prove it, and the Commission notes the defence is weakened by long-standing standards, available expertise and accessibility features built into mainstream tools.

The cases that set the tone

• Maguire v Sydney Organising Committee for the Olympic Games (2000): a blind man complained that the Sydney Olympics website lacked text alternatives for images and had inaccessible results tables. The Commission found unlawful discrimination, rejected the hardship defence and ordered fixes. In a later decision, $20,000 compensation was awarded.
• Mesnage v Coles: Gisele Mesnage, who is blind, brought federal court proceedings in October 2014 over the Coles Online shopping site. The case settled in February 2015 with Coles agreeing to improve the site's accessibility.
• Innes and Mattiazzo v Commonwealth Bank: complaints about the inaccessible touchscreen "Albert" payment terminal went to court in March 2018 and settled about a year later, with CBA agreeing to upgrade the software and train merchants.

Most complaints never reach a court. They are resolved through the Commission's conciliation process, which is another reason many businesses do not realise how often accessibility issues are raised.

Which standard to aim for

In April 2025 the Commission published its Guidelines on equal access to digital goods and services, replacing advisory notes first issued in 1997. They say organisations should conform with WCAG 2.2 at a minimum of Level AA and consider appropriate Level AAA criteria. The guidelines are not legally binding and following them is not a guaranteed defence, but they are the clearest statement of what the Commission expects.

For government, the Digital Service Standard requires Commonwealth services to meet the latest version of WCAG, and AS EN 301 549:2024 is the Australian standard used in ICT procurement. If you sell to government, expect accessibility questions in procurement.

WCAG 2.2 became a W3C Recommendation on 5 October 2023 and was also published as the international standard ISO/IEC 40500:2025. WCAG 3 is still a working draft and the W3C says it is several years from completion, so WCAG 2.2 AA is the target for now.

What changed in WCAG 2.2

WCAG 2.2 keeps everything in 2.1, removes the obsolete 4.1.1 Parsing criterion, and adds nine new success criteria. Six of them are at Level A or AA, so they are part of the target:

• 2.4.11 Focus Not Obscured (Minimum), AA: sticky headers, cookie banners and chat widgets must not completely hide the element a keyboard user has focused.
• 2.5.7 Dragging Movements, AA: anything done by dragging, like sliders or reordering, needs a simple single-pointer alternative.
• 2.5.8 Target Size (Minimum), AA: buttons and links need a target of at least 24 by 24 CSS pixels, or enough spacing.
• 3.2.6 Consistent Help, A: help such as a phone number, contact link or chat should appear in the same place across pages.
• 3.3.7 Redundant Entry, A: do not make people re-enter information they already gave in the same process.
• 3.3.8 Accessible Authentication (Minimum), AA: logins should not depend on memory or puzzle tests without an alternative, such as allowing password managers and paste.

Fix these first

The WebAIM Million 2026 report tested the home pages of the top one million websites and found detectable WCAG failures on 95.9% of them, averaging 56.1 errors per page. Australian .au home pages averaged 56.6. Six error types made up 96% of everything detected, and they have topped the list for seven years:

• Low-contrast text (83.9% of home pages): check text and button colours against the 4.5:1 contrast ratio for normal text.
• Missing alternative text (53.1%): describe meaningful images, and mark decorative ones with empty alt text.
• Missing form labels (51%): every field needs a visible, programmatically linked label, not just placeholder text.
• Empty links (46.3%): icon-only links, such as social icons, need an accessible name.
• Empty buttons (30.6%): menu toggles, close buttons and carousel arrows need accessible names too.
• Missing document language (13.5%): set the page language, for example lang="en-AU".

Most of these live in shared templates, so fixing a header, footer or form component once can fix every page that uses it.

What automated checks miss

Automated tools catch only part of the picture. A real review also checks:

• that every part of the site works with a keyboard alone, with a visible focus indicator;
• that menus, modals, accordions and carousels announce themselves properly to screen readers;
• that form errors are explained in text, not only with colour;
• that videos have captions and audio content has transcripts;
• that PDFs, booking tools, chat widgets and payment steps from third parties are accessible, because customers do not separate your site from the tools you embed;
• that animation can be paused and respects reduced motion settings.

A practical plan

• Run an automated scan of your key templates: home, service, contact, booking and checkout pages.
• Fix the six common errors in shared components first.
• Test the main tasks, such as making an enquiry or booking, with a keyboard and a screen reader.
• Check third-party tools and ask vendors for their accessibility conformance reports.
• Publish an accessibility statement with a way for people to report problems, and respond when they do.
• Build accessibility checks into every new page and redesign, rather than treating it as a one-off audit.

Conclusion

Accessible websites are usually better websites: clearer, faster, easier to use on a phone and easier for search engines and AI tools to understand. When we design or rebuild a site, accessibility is part of the brief, and we can review an existing site for the issues above. If you want to know where yours stands, request a website and SEO review. For legal questions about your obligations, the Australian Human Rights Commission is the place to start.