Website accessibility in Australia: the DDA and WCAG for business websites

Many Australians use websites with screen readers, keyboards, magnification, captions or voice control. If your site does not work with these tools, some customers cannot buy from you or contact you. This guide explains how the Disability Discrimination Act 1992 (DDA) applies to business websites, what the Australian Human Rights Commission (AHRC) currently recommends, why WCAG 2.2 Level AA is the practical target, and how to check your own site. It is general information, not legal advice; if you have concerns about your obligations, the AHRC suggests getting independent legal advice.

Does the Disability Discrimination Act apply to your website?

The DDA is a federal law that makes disability discrimination unlawful in areas of public life. Section 24 makes it unlawful for a person who provides goods or services, or makes facilities available, whether for payment or not, to discriminate on the ground of disability by refusing to provide them, in the terms or conditions on which they are provided, or in the manner in which they are provided. The Act's definition of services includes the services of any profession or trade.

The AHRC's guidelines apply this to digital goods and services. The key questions, it says, are whether the way a service is provided discriminates because of disability, and what has been done to eliminate that discrimination. One of its examples is a person with disability being able to complete an online purchase, from choosing products to receiving delivery updates.

Under section 5 of the DDA, failing to make reasonable adjustments for a person with disability can itself be discrimination, where that failure means they are treated less favourably.

What does the AHRC say about WCAG?

For years the AHRC's web guidance was its World Wide Web Access: Disability Discrimination Act Advisory Notes. Version 4.1, from 2014, recommended WCAG 2.0 Level AA. It is now archived, and the Commission noted in 2024 that it was no longer current.

In April 2025 the AHRC published the replacement: Guidelines on equal access to digital goods and services, issued under section 67(1)(k) of the DDA. They are not legally binding, and relying on them does not by itself protect an organisation from a finding of unlawful discrimination, but in the Commission's view they will help organisations act consistently with the DDA.

On standards, the guidelines say:

• WCAG is the accepted international standard for web accessibility, and also applies to documents, apps and software.
• Organisations should conform with WCAG 2.2 at a minimum of Level AA, and consider appropriate Level AAA criteria such as video transcripts and section headings.
• It is important to meet the latest published version of WCAG.
• The applicability of WCAG under the DDA was upheld in the Commission's decision in Maguire v Sydney Organising Committee for the Olympic Games (2000).

What applies to government websites?

The Australian Government's Digital Service Standard is mandatory for digital services created by federal departments and agencies. Its Criterion 3, Leave no one behind, requires agencies to comply with the DDA and the latest version of WCAG. State and territory governments have their own accessibility commitments.

A private business is not bound by these standards, but they show the benchmark the public sector works to.

Why is WCAG 2.2 AA the practical target?

The Web Content Accessibility Guidelines are published by the World Wide Web Consortium (W3C). WCAG 2.2 became a W3C Recommendation on 5 October 2023 and is built on four principles: content must be perceivable, operable, understandable and robust. Each success criterion has a level of A, AA or AAA, and Level AA conformance means a page satisfies all the Level A and Level AA success criteria.

WCAG 2.2 added nine success criteria to WCAG 2.1 and removed one, 4.1.1 Parsing. New AA criteria include:

• Focus Not Obscured (Minimum): when an item receives keyboard focus, it must be at least partly visible, not hidden behind a sticky header or cookie banner.
• Target Size (Minimum): pointer targets such as buttons should be at least 24 by 24 CSS pixels, with some exceptions.
• Dragging Movements: anything done by dragging, such as a slider, needs a simple pointer alternative, such as tapping or clicking.
• Accessible Authentication (Minimum): no step in logging in should require a cognitive function test, such as remembering a password or solving a puzzle, unless an alternative method or a mechanism to help the user is available.

What should your accessibility checklist cover?

No checklist replaces a proper audit, but these checks catch many common problems:

• Keyboard: every link, menu, form and checkout step works without a mouse, with a visible focus indicator.
• Colour and contrast: normal text has a contrast ratio of at least 4.5:1 against its background, and colour is never the only way information is shown.
• Images: meaningful images have accurate alternative text; the AHRC names missing alt text and poorly titled links as common barriers.
• Forms: every field has a visible label, and error messages explain what went wrong and how to fix it.
• Login and checkout: people can paste passwords and use password managers, and any CAPTCHA has an accessible alternative.
• Video and audio: pre-recorded video has accurate captions, and audio has a transcript.
• Zoom and mobile: content reflows when zoomed, and buttons are large enough to tap.
• Documents: the AHRC says PDFs cannot be made fully accessible, especially on mobile. Publish key information as web pages, and make any PDFs meet PDF/UA (AS ISO 14289.1).

Should you use an accessibility overlay?

Overlays are widgets that promise to make a site accessible or compliant automatically. Be cautious. The W3C says no tool alone can determine whether a site meets accessibility standards, and the AHRC's guidelines call for accessibility to be considered throughout design, development and testing rather than added at the end. Fixing the underlying code and content is the dependable route.

If you use third-party booking or payment tools, note the AHRC's point that organisations can contract out digital services but not their equal access responsibilities. Ask vendors for evidence of accessibility testing.

How do accessibility complaints work?

A person who experiences disability discrimination can make a free, written complaint to the AHRC. The Commission is not a court and cannot decide that discrimination has happened. It usually tells the organisation about the complaint, asks for its response and, where appropriate, invites both sides to conciliation, an informal and confidential process. Outcomes can include an apology, a change to a policy or practice, staff training or compensation. If a complaint is not resolved, the person can take it to the federal courts.

Under the DDA, discrimination in providing goods and services is not unlawful if avoiding it would impose unjustifiable hardship. All relevant circumstances are considered, including the benefit or detriment to the people concerned and the expenditure required, and the business claiming hardship must prove it. The DDA also lets organisations prepare Disability Action Plans, and an action plan given to the AHRC is one of the circumstances considered when deciding whether a hardship is unjustifiable.

Where should you start?

Test your key journeys first: finding a service, contacting you, booking and checking out. Combine automated checks with keyboard, zoom and screen reader testing and, where you can, feedback from people with disability. Fix the highest-impact issues and re-test after redesigns.

If you would like help, our website accessibility audit checks a site against WCAG 2.2 AA and lists fixes in priority order, and our website development for Australian businesses page explains how we build accessibility in from the start.

Sources

• Federal Register of Legislation: Disability Discrimination Act 1992
• AHRC: Guidelines on equal access to digital goods and services (2025)
• AHRC: Standards and Guidelines on digital accessibility
• AHRC: How to provide equal access to digital goods and services
• AHRC: World Wide Web Access: Disability Discrimination Act Advisory Notes ver 4.1 (2014), archived
• AHRC: Disability discrimination complaints
• AHRC: Conciliation: How it works
• digital.gov.au: Digital Service Standard, Criterion 3: Leave no one behind
• W3C: Web Content Accessibility Guidelines (WCAG) 2.2
• W3C WAI: What's New in WCAG 2.2
• W3C WAI: Evaluating Web Accessibility Overview