Today, digital accessibility is truly global, and momentum continues to accelerate and expand across social, political, financial, and legal sectors. The synergy is powerful, and shifts in one region will often both mirror and inspire developments in other areas. It’s essential to monitor all impactful global developments accordingly.
This is especially true for regulatory activity. Australia has a longstanding commitment to accessibility, and we’re increasingly seeing harmonization on key themes and standards with Europe and other regions around the globe.
The history of accessibility in Australia
Australia has demonstrated a decades-long commitment to accessibility, with the 1992 Disability Discrimination Act (DDA) being a significant milestone. Other watershed moments include the Maguire v. Sydney Olympic Games Organising Committee case in 2000, which affirmed that the DDA applied to web accessibility, and which was resolved through an AUS$20,000 reward negotiated by the Australian Human Rights Commission (AHRC). In 2015, the Australian grocery store chain Coles agreed to make its online shopping site more accessible as a result of legal action.
In this post, we’ll explore the most recent updates to Australia’s regulatory landscape to understand what they mean for organizations doing business in Australia, as well as for the rest of the world. We’ll specifically focus on beneficial actions and outcomes associated with compliance.
Recent accessibility updates in Australia
Three major accessibility shifts occurred in Australia in 2025:
- The Australian Human Rights Commission (AHRC) affirmed WCAG 2.2 Level AA as the minimum standard.
- The AHRC guidelines clarified that accessibility obligations under the Disability Discrimination Act (DDA) extend to technologies such as SaaS platforms, AI tools, Internet of Things (IoT) devices, and mobile apps.
- The Digital Transformation Agency (DTA) introduced the Digital Experience Policy, which mandates that all new government websites and digital services must meet digital inclusion, digital access, and digital performance standards.
Together, these updates represent a comprehensive re-scoping of what digital accessibility is and entails.
Australia is unique in many ways when it comes to its expansive approach to digital accessibility, and as we’ll discuss later in the post, there is additional guidance around testing for EN 301 549 that you’re recommended to follow.
But first, let’s examine each of these updates in more detail.
Australia’s update to WCAG 2.2 Level AA
In April 2025, the AHRC announced new guidelines focused on meeting legal obligations under the 1992 Disability Discrimination Act (DDA), with a specific focus on digital products and services. As these changes are focused on driving compliance with the DDA, they cover public-facing digital services in both the public and private sectors. In other words, the guidelines apply to both business and government organizations.
Central to these guidelines is the recommendation that organizations align with WCAG 2.2 Level AA as the minimum accessibility benchmark, representing a significant change from WCAG 2.0, which had been the prevailing recommendation throughout the previous decade.
If you are not familiar, WCAG 2.2 AA contains 86 success criteria in total, including nine new additions beyond version 2.1. Of these, six apply at Levels A and AA, all of which are required for full WCAG 2.2 AA conformance. Together, these new additions address three areas of priority:
Pointer and keyboard usability. Three new criteria address how users interact with interfaces through keyboards and pointer devices:
- 2.4.11 Focus Not Obscured (Minimum): Level AA
- 2.5.7 Dragging Movements: Level AA
- 2.5.8 Target Size (Minimum): Level AA
These criteria are particularly relevant as product teams design for the full range of assistive technologies and input methods in the market today.
Cognitive accessibility. Two new criteria reduce the cognitive burden placed on users during authentication and multi-step processes:
- 3.3.8 Accessible Authentication (Minimum): Level AA
- 3.3.7 Redundant Entry: Level A
These specific criteria reflect the recognition that accessibility obligations extend to cognitive considerations, not just visual and motor ones.
Consistent navigation support. One new criterion ensures that help mechanisms appear in a predictable location across pages:
- 3.2.6 Consistent Help: Level A
This requirement supports users who rely on consistent page structure, including those using assistive technologies.
Australia’s alignment with WCAG 2.2 AA dovetails with developments in Europe, where a new update to EN 301 549 (version 4.1.1), anticipated later in 2026, is expected to include WCAG 2.2 AA.
In a recent article, Deque’s Chief Information Accessibility Officer, Glenda Sims, noted that the “EN standard goes far beyond just websites, including a wide range of ICT products and services such as websites, software, mobile apps, electronic documents, hardware interfaces, and communications technologies.” Regarding EN 301 549 v4.1.1’s pending inclusion of WCAG 2.2. Level AA, Glenda summarized Deque’s guidance on these new developments as follows:
“Deque recommends targeting EN 301 549 + WCAG 2.2 AA now. Doing so helps you avoid redundant remediation work when the formal update lands in 2026. If your accessibility strategy is still focused only on websites, it’s time to widen your lens. And if your roadmap doesn’t account for alignment with EN 301 549 and WCAG 2.2, that gap could become visible during procurement reviews, audits, or public reporting.”
The key takeaway here is, given that EN 301 549 does not yet cover 2.2, the best approach for your organization going forward is to test for both EN 301 549 and WCAG 2.2 AA.
Let’s now move on to the second key update, the AHRC’s broadened definition of accessibility.
New guidelines for digital products and services
As stated by the AHRC, the “new guidelines on equal access to digital goods and services build on previous Commission guidance to reflect advances in digital technologies such as artificial intelligence, facial recognition and other biometric technologies, mobile apps, social media, and self-service machines.”
The AHRC made clear its core motivation for introducing the new guidelines:
“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.”
In the foreword to the new guidelines, Rosemary Kayess, Disability Discrimination Commissioner, speaks to why these updates to the Disability Discrimination Act are so vital:
“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 new guidelines are arranged into three chapters:
- Overview of the Disability Discrimination Act and how it applies to digital goods and services.
- Recommendations for organizations and businesses on how to provide equal access to digital goods and services.
- Standards and guidelines that apply in Australia.
You can access the full guidelines online, but here are five actionable takeaways we’ve assembled for you:
- Understand the full scope of what the guidelines cover.
The AHRC guidelines clarify that accessibility obligations extend beyond websites to include SaaS and PaaS platforms, AI-generated services, CAPTCHAs, two-factor authentication, extended reality, QR codes, mapping applications, and digital interfaces to physical devices and IoT. Understanding the full scope of your obligations is the foundation of a strong and sustainable accessibility program.
- Put a formal plan in place when accessibility gaps exist.
An Alternate Access Plan documents how people with disabilities can access equivalent services while your remediation efforts are underway. Your plan should describe a comparable experience and be supported by a remediation roadmap with specific dates.
- Address accessibility early in your development cycle.
The later accessibility issues are identified in the development cycle, the more costly they are to fix. By embedding accessibility across ideation, design, development, testing, and maintenance, your organization can lower risk, reduce costs, and deliver digital experiences that are usable by everyone.
- Extend equal access responsibilities across your vendor ecosystem.
Your organization can contract out the provision of digital goods and services, but you cannot contract out your equal access responsibilities. Accessibility clauses and assurances should be included in every contract of service, protecting both the people you serve and your organization.
- Ensure biometric authentication always includes an accessible alternative.
Wherever your organization uses biometric methods—fingerprints, face ID, retinal scanning, or voice ID—you should ensure that alternative identification and control options are available. These methods can create barriers for people with disabilities who may not be able to provide such information easily, or at all.
As a reminder, these changes are focused on compliance with the DDA and accordingly apply to public-facing digital services in both the public and private sectors.
The third update we’re going to explore, the introduction of the Digital Experience Policy by the Digital Transformation Agency (DTA), focuses explicitly on government services.
The Digital Experience Policy
The Digital Experience Policy, mandated by the Australian government, came into effect on January 1, 2025, and is supported by four standards that form the core requirements for government services.
The motivation for establishing the new policy mirrors that of the AHRC guidelines, in that the government acknowledges the need to keep pace with evolving technologies:
“Over the past decade, digital government services have expanded rapidly, providing new ways for people and businesses to access information, complete tasks, and seek assistance. However, a history of siloed delivery and uneven digital maturity has created fragmented service experiences. A coordinated focus on digital experience helps address these challenges. It ensures that services are designed and delivered in a way that is user-friendly, inclusive, and efficient.”
The new policy contains four standards:
- Digital Service Standard: sets the requirements for designing and delivering digital government services.
- Digital Inclusion Standard: sets the requirements for inclusive and accessible digital government experiences.
- Digital Access Standard: sets the requirements for government agencies to reduce duplication of entry points, supporting unified access to digital government services for people and business.
- Digital Performance Standard: sets the approach for monitoring government digital service performance and using insights to drive ongoing improvement.
You can find additional details about what the policy applies to on the Australian government website, but per the general guidance provided by the agency, the policy applies to informational and transactional digital services that are:
- subject to the requirements of the Investment Oversight Framework (IOF)
- new or replacement public-facing services
- new staff-facing services
- all existing public-facing services
What your business needs to do, and why
Given the rigor and comprehensive nature of Australia’s new policies and guidelines, it is essential that your organization take a proactive approach to digital accessibility, with a focus on four essential practices:
Shift left
Being proactive and shifting left means incorporating accessibility practices early in design and development and catching accessibility issues sooner. By shifting left, your organization will:
- Save money: Fixing defects after they reach production is costly.
- Increase velocity: Catching defects sooner means less time spent fixing them later, which in turn allows increased velocity towards new features.
- Create better products: Accessible products are better for all customers.
Shifting left to address accessibility issues early is efficient and cost-effective. Fixing those defects after they reach production can result in significant delays and far higher costs, as well as potential consumer complaints and potential regulatory inquiry.
Automate testing
With automated and AI-guided testing, design, development, and QA teams can find and fix up to 80% of issues by volume without needing deep accessibility expertise. That means fewer reworks, smoother handoffs, and fewer blockers down the line.
Provide role-specific training and tools
By providing training for individual roles across the software development lifecycle (SDLC), you’ll help your teams maintain momentum even when faced with more challenging problems. By providing specialized tools tailored to the unique needs of different roles, you can help ensure that everyone continues to achieve their specific goals. For example:
- Designer: Avoid creating defects.
- Developer: Get instant code feedback.
- Tester: Standardize defect management.
- Product owner: Visualize progress.
- Accessibility program manager: Monitor performance.
Continuously monitor regulations
Your organization must continuously monitor the latest regulatory changes so it can swiftly adapt and maintain compliance. Your accessibility policy should automatically trigger an efficient and effective response when changes do occur. The updates we’ve highlighted in this article are just one example of how the regulatory and policy landscape can quickly evolve. Continuous monitoring is your most strategic way to ensure you stay ahead of changes that can impact your organization and introduce legal, financial, and reputational risk for your company.
The benefits of acting swiftly and proactively
As digital accessibility regulations and policies continue to evolve across the global stage, organizations must build and maintain sustainable accessibility programs to stay ahead. Depending on your current state of program maturity, your efforts in this regard will vary in complexity and investment. The good news is that the benefits of compliance and of offering accessible products and services are wide-ranging—in Australia and globally. These benefits include:
- Expanded audience reach. You can successfully engage 5.5 million Australians with disabilities by aligning with WCAG 2.2.
- Global alignment. By aligning with multi-national standards such as the EAA, you can open doors to broader markets.
- Brand leadership. A focus on advanced digital accessibility solutions can drive cross-functional innovation, help you outperform competitors, and build lasting customer loyalty.
- Reduced risk. Compliance with applicable regulations and policies, and conformance with relevant standards, can help limit your exposure to damaging legal, financial, and reputational risks.
Australia continues to take a leadership role in global digital accessibility, and whether your organization is in Australia, doing business with Australia, or simply keeping pace with global developments, now is the ideal time to ensure you’re taking the right steps to maintain long-term compliance and achieve your accessibility goals.
Contact Deque today for expert guidance on ensuring you have the right strategy and tools in place.
