WCAG Requirements for Australian Government Websites: Every Jurisdiction Compared (2026)

Last reviewed 10 November 2026 (AEST). This is general information, not legal advice.

If you build or buy a digital service for an Australian government, the level to work to is WCAG 2.2 AA. Australia has no single digital accessibility law for government. Every agency sits under the Disability Discrimination Act 1992, and each of the nine governments adds its own policy, standard and disability plan. This guide is for public servants, product owners, content designers and procurement teams. It sets out what each government asks for today and what that means for the services you build and buy.

What do Australian governments require for digital accessibility?

Yes, every Australian government requires accessible digital services. The Disability Discrimination Act 1992 applies to all of them, and the Commonwealth, states and territories add WCAG policies at Level AA. Build to WCAG 2.2 AA, test with real people including people with disability, publish in HTML first, write plainly and put the requirement in contracts. As at 10 November 2026.

That approach meets or exceeds every current written policy we could read (the ACT's policy is not public). Here is the position in each area.

• The legal floor is the same everywhere. The Disability Discrimination Act 1992 applies to every Australian government and council. The Australian Human Rights Commission's April 2025 Guidelines on equal access to digital goods and services set the benchmark. Organisations should conform with WCAG 2.2 at a minimum of Level AA.
• The Commonwealth has the most structured regime. The Digital Experience Policy has been mandatory since 1 January 2025. Its Digital Service Standard and Digital Inclusion Standard require "the latest version" of WCAG. The Style Manual says WCAG 2.2 is current and agencies should meet Level AA.
• States and territories are uneven. Victoria and NSW name WCAG 2.2 AA. Queensland, Western Australia and Tasmania require the latest or current WCAG at AA. South Australia's 2019 policy still sets WCAG 2.0 or 2.1 AA, and the Northern Territory's public statement still refers to WCAG 2.0.
• Disability plans carry most of the reporting. NSW, Victoria, Queensland, WA, SA, Tasmania and the ACT all require government bodies to have some form of disability inclusion or action plan. WA requires agencies to report website accessibility every year through theirs.
• Testing with people is in the rules. The Commonwealth, NSW, Queensland and WA all ask for testing with users, including people with disability or people who use assistive technology. Automated tools are described as a supplement, not a substitute.
• Procurement counts. The Commonwealth Procurement Rules require tenders to show they can meet an applicable standard, and contracts to contain evidence of it. AS EN 301 549 is the Australian standard for ICT accessibility. NSW, SA and Victoria all put accessibility requirements into supplier contracts.

A policy pinned to an older WCAG version is a floor, not a defence. A government body that excludes a person with disability from a service can face a complaint under the Act. Its own policy does not change that.

How do the Commonwealth, states and territories compare?

Yes, they all set Level AA, but the WCAG version differs. Victoria and NSW name WCAG 2.2. The Commonwealth, Queensland and WA require the latest WCAG, which is 2.2. South Australia names 2.0 or 2.1, the Northern Territory 2.0, and Tasmania states no version. The ACT's policy is not public. As at 10 November 2026.

What this means for your team

Government services exist for everyone, and these policies are there to make sure everyone can use them. WCAG 2.2 AA gives every agency the same measurable floor, and it should be met. But the Digital Service Standard, NSW, Queensland and WA go further. They ask for evidence that real people, including people with disability, can use the service before launch and after major changes. That is the point of the policy, and a scan alone can't show it. A short study with people who are blind, have low vision, are Deaf, are neurodivergent, are over 65 or have limited English shows whether people can finish the job. It also gives you recordings and findings to file with your accessibility action plan.

Conformance and a legal obligation matter. WCAG and the laws behind it exist because people with disability met enormous barriers and had to fight for these protections. That work is respected and acknowledged.

See Me Please also firmly believes that no organisation sets out to shut out people with disability. Most teams have no idea how much friction people face. Online, that friction is largely invisible. Analytics can show that users abandon a form, but not who left or why. Without seeing who is affected, designers and engineers struggle to fix the cause. Teams are often unaware of the problem, or working within real constraints.

Accessibility is also complex, and too many people play down how hard some barriers are to fix. Some are a quick change. Others mean rethinking a whole journey, a platform or what you buy from suppliers. There is little on offer, anywhere in the world, to build accessibility capability inside teams. Most organisations still depend on handing the work to specialist consultants, often at high cost.

See Me Please is a technology company headquartered in Sydney, Australia, whose platform tests digital services with real people from six perspectives.

Show your next release works for everyone it serves

Does the Disability Discrimination Act apply to government websites?

Yes. The Disability Discrimination Act 1992 applies to the Commonwealth, state and territory governments and local councils. Excluding a person with disability from information or a service can be unlawful discrimination. The Australian Human Rights Commission's 2025 Guidelines say organisations should conform with WCAG 2.2 at a minimum of Level AA. As at 10 November 2026.

Disability Discrimination Act 1992 (Cth)

The Act makes it unlawful to discriminate on the ground of disability in areas of public life. These include providing goods, services and facilities, and running Commonwealth laws and programs. The Style Manual puts it plainly for Commonwealth content. Failing to provide equal access to government services, including information, can be a failure of obligation under the Act.

In April 2025 the Australian Human Rights Commission published its Guidelines on equal access to digital goods and services. They are issued under the Act and replace the Commission's earlier World Wide Web Access advisory notes. The Guidelines say the latest version is WCAG 2.2, released in October 2023. Organisations should conform with WCAG 2.2 at a minimum of Level AA. They should also consider suitable AAA criteria, such as video transcripts, clear links and section headings.

The Guidelines also say AS EN 301 549 should be required for any ICT procurement. They recommend testing digital products with a range of people with disability, including people who rely on assistive technologies. The Guidelines are not law, but they are the most current national statement of what "equal access" means for digital services.

State and territory anti-discrimination law

Each state and territory also has its own anti-discrimination or equal opportunity law. Several have disability-specific Acts that create planning duties for government bodies. Victoria's requirements, for example, cite the Disability Act 2006, the Equal Opportunity Act 2010 and the Charter of Human Rights and Responsibilities Act 2006.

Australia's Disability Strategy 2021 to 2031

Australia's Disability Strategy is the national plan agreed by all Australian governments. It was reviewed and updated in 2024, and the 2024 update is the current version. State and territory disability plans, and many agency plans, describe themselves as implementing it.

The UN Convention on the Rights of Persons with Disabilities

Australia ratified the Convention on 17 July 2008. Article 9 (accessibility) and Article 21 (freedom of expression and access to information) are the articles most often cited in Australian digital policy. Both the Style Manual and South Australia's policy refer to the Convention as part of the framework behind their requirements.

For the position in Europe and the UK, see our guide to EU and UK digital accessibility laws.

What does the Commonwealth require?

Since 1 January 2025, the Digital Experience Policy has been mandatory for Australian Government digital services. Its standards require "the latest version" of WCAG, and the Style Manual says agencies should meet WCAG 2.2 AA. That AA expectation is assembled from the Style Manual and agency statements, not written as one line of policy. As at 10 November 2026.

The Digital Experience Policy

The Digital Experience Policy, run by the Digital Transformation Agency (DTA), is mandatory and came into effect on 1 January 2025. It is supported by four standards:

• Digital Service Standard: how digital government services are designed and delivered.
• Digital Inclusion Standard: inclusive and accessible digital government experiences.
• Digital Access Standard: fewer duplicated entry points, so people can find and reach services.
• Digital Performance Standard: monitoring and improving service performance.

The policy applies to informational and transactional services subject to the Investment Oversight Framework. It also covers new or replacement public-facing services, new staff-facing services and all existing public-facing services. Staff-facing services include intranets and case management systems, so internal tools are covered (services covered).

The DTA says reporting applies to services with more than 50,000 end-to-end transactions or page visits a year. Exemptions are possible for specific requirements, but not at a "whole of policy" level. The policy does not apply to state or territory services, although the DTA encourages agencies outside its scope to adopt the standards.

The Digital Service Standard and "Leave no one behind"

The current Digital Service Standard is version 2.0, released by the DTA in December 2023. It has ten criteria. Criterion 3, "Leave no one behind", replaced version 1's "Make it accessible" criterion and is the main accessibility criterion.

To meet it, agencies need to understand the diversity of their users and implement a feedback mechanism. They must also comply with legislation and standards, including the Disability Discrimination Act, the latest version of WCAG and the Style Manual. The guidance asks for "human-validated multilingual support for critical information". It also asks agencies to test across devices before launch, design for low bandwidth and offer pathways for people who cannot use digital services.

Which WCAG level? The DTA's pages for both standards say "the latest version of the Web Content Accessibility Guidelines" but name no level. The level comes from the Style Manual, which the standards make mandatory. It says WCAG 2.2 is current and agencies should "meet WCAG level AA, but aim higher". Services Australia and myGov both state a target of WCAG 2.2 Level AA. In practice the Commonwealth expects WCAG 2.2 AA, but that is assembled from these sources rather than written as a single line in the policy.

The Digital Inclusion Standard

The DTA describes the Digital Inclusion Standard as an extension of Criterion 3. It has five criteria: embrace diversity, motivate digital use, protect users, make it accessible, and provide flexibility and choice. It applied from 1 January 2025 to new and replacement public-facing and staff-facing services, and from 1 January 2026 to all existing public-facing services.

Criterion 4, "Make it accessible", is the most practical part of the Commonwealth framework for delivery teams. It asks agencies to use proper headings, descriptive links and alternative text, and to offer accurate multilingual support. Services must work with keyboards, voice commands and screen readers. Agencies must also include accessibility in procurement and train their teams.

The Australian Government Style Manual

The Style Manual is the Commonwealth's writing and content standard. The Digital Service Standard and Digital Inclusion Standard both require agencies to follow it. Its "Accessible and inclusive content" section covers these areas:

• Agency responsibilities: accessibility is "a mandatory standard for government agencies". Agencies should test content against WCAG success criteria, meet Level AA and aim higher. They should include an accessibility statement explaining how far a service complies with WCAG. For procurement, it points to AS EN 301 549. (Page updated 15 December 2023.)
• Literacy and access: writing to an Australian year 7 level makes content usable for most people. Teams should do user research before writing and make sure users with low literacy have equal access. (Updated 23 July 2024.)
• Disability and neurodiversity: use person-first language ("people with disability") unless user research says otherwise. Engage with people through user research to learn individual or community preferences.
• Aboriginal and Torres Strait Islander peoples: respectful language depends on proper consultation, and naming is often more respectful when specific. Working with content experts such as a First Nations editor or liaison officer is invaluable. (Updated 7 March 2025.)
• Easy Read: a format for people who are not familiar with English, or who have low literacy or learning disability.
• PDF: "Create content in HTML pages instead of PDFs." Only create PDFs if research shows a specific need. Then also provide the content in another accessible format. (Updated 28 October 2026.)

Procurement: the Commonwealth Procurement Rules and AS EN 301 549

For procurement teams

The Commonwealth Procurement Rules (in effect from 17 November 2025) cover "Standard verification" at paragraphs 7.27 and 7.28. Where a standard applies, tender responses must show the capability to meet it, and contracts must contain evidence of it. During the contract, entities must make reasonable enquiries about compliance, including "periodic auditing by an independent assessor". The DTA's Digital Sourcing Consider First Policy, Principle 5.1, links this to AS EN 301 549. That is the Australian standard for accessibility of ICT products and services. Name AS EN 301 549 and WCAG 2.2 AA in your tender, ask for conformance evidence and plan for independent checks.

The Rules do not name an accessibility standard themselves. Paragraph 10.10 asks entities to base specifications on international standards where they exist. Consider First Principle 5.1 says investments must be designed for all users, including people with disability and older people. Where AS EN 301 549 applies, tender responses must demonstrate capability to meet it.

The Australian Government Architecture lists WCAG as a mandatory standard. It calls WCAG "a requirement of" the Digital Service Standard, the Digital Inclusion Standard, the Consider First Policy and the Commonwealth Procurement Rules, among others.

The Consider First page still cites older paragraph numbers and the 2020 edition of AS EN 301 549. The Human Rights Commission's 2025 Guidelines refer to AS EN 301 549:2024. Check which edition your tender documents name.

Services Australia and myGov

Services Australia says its website aims to meet WCAG 2.2 Level AA. It provides free interpreters, including Auslan interpreters, and transcripts for all video and audio on its website. Most documents are available in an alternative format. myGov says it aims to meet WCAG 2.2 Level AA at a minimum and AAA where possible (page last updated 5 November 2025).

Since 1 January 2025, the Digital Access Standard has applied to new Commonwealth services for individuals that suit myGov. They must consider connecting to existing access points.

Disability plans and audits

The old Commonwealth Disability Strategy has been replaced by Australia's Disability Strategy 2021 to 2031. The DTA's guidance also points agencies to the Disability Services and Inclusion Act 2023 (Cth). We did not find a Commonwealth rule requiring every agency to publish a disability inclusion plan, as several states do. Accountability runs mainly through the Digital Experience Policy's compliance framework.

We also did not find an Australian National Audit Office performance audit focused on the digital accessibility of Commonwealth services.

What do the states and territories require?

Yes, every state and territory we checked sets a WCAG policy at Level AA, but versions differ. Victoria and NSW name WCAG 2.2. Queensland and WA require the latest version. Tasmania names no version, South Australia names 2.0 or 2.1, and the Northern Territory names 2.0. The ACT's policy text is not public. As at 10 November 2026.

New South Wales

Standard: Digital NSW's Accessibility and Inclusivity Toolkit says NSW Government digital products and services need to meet AS EN 301 549. Websites, web content and apps need to meet the current version of WCAG to Level AA. The requirement applies to internal and external products.

The NSW Design Standards describe themselves as "a single source of truth for effective design and delivery across NSW Government". The text we read does not say they are mandatory. Under the principle "Make it for everyone", they go further:

• comply with WCAG 2.2 at Level AA (AAA where achievable);
• test with assistive technologies such as screen readers and voice recognition;
• include people with disability, language barriers, diverse cultural backgrounds and learning differences;
• write in plain language and provide alternatives to written English where possible;
• make sure funding supports recruiting and testing under-represented groups.

Design system: the NSW Design System (version 3.28.2 when read) says its components have been updated to align with WCAG 2.2 Level AA. It adds that compliance depends on how components are used.

Older text: the 2012 circular C2012-08, which required WCAG 2.0 AA by the end of 2014, is archived. Agency pages quoting WCAG 2.0 are out of date.

Disability planning: the Disability Inclusion Act 2014 covers all NSW Government departments, some other agencies and all local councils. Each must develop a Disability Inclusion Action Plan. Departments needed one by 1 December 2015 and councils by 1 July 2017. Section 12 requires a copy to go to the Disability Council NSW. The Toolkit notes that accessibility is also a requirement of the whole-of-government NSW Disability Inclusion Plan.

Victoria

Standard: Victoria's digital accessibility requirements say that "all digital content and websites must, at a minimum, meet the current WCAG version Level AA. As of January 2025, this is WCAG 2.2." Agencies are encouraged to aim for AAA where possible. (Page updated 27 August 2025.)

The Victorian Government accessible communications policy (Department of Premier and Cabinet, 25 August 2025) applies to all Victorian Public Service and special bodies. It says the WCAG requirement extends to suppliers and vendors developing digital materials. Staff are responsible for making sure contracts include it.

Content rules: Victoria's standards for accessible content are among the most specific in the country:

• All Victorian Public Service and special bodies will adopt the international plain language standard, ISO 24495-1:2023.
• All information must be below a Year 8 readability level as far as practicable.
• All new videos must include closed captions, and auto-generated captions must be checked before publishing.
• All documents must have a web page equivalent. Avoid PDFs except for print items such as posters.
• If requested, a publication must be available in alternate formats, including audio, braille, large print or Easy Read.

Platform: many departments publish through the Single Digital Presence platform. The Department of Government Services runs site-wide design and functionality, and departments are responsible for their content.

Disability planning: section 38 of the Disability Act 2006 requires public sector bodies to prepare disability action plans. These address four outcome areas, including reducing barriers to accessing goods, services and facilities.

Queensland

Policy and standard: the Queensland Government's Digital services policy is version 1.0.1, mandated and effective from January 2022 (page last updated 24 September 2026). It applies to all departments and certain statutory bodies, with state schools and TAFE currently excepted. It requires digital services to meet all 13 criteria of the Queensland Digital service standard.

Criterion 9, "Make digital services accessible": the minimum is the latest version of WCAG at Levels A and AA. Teams must also:

• publish content in HTML first and provide an alternative for non-HTML formats;
• make PDFs, Word documents, images, video and audio accessible;
• write in plain language with a reading age below grade 9;
• develop a digital services accessibility plan;
• test design, code and content regularly.

Before launching publicly, teams should be able to show evidence of WCAG conformance. They should also show "evidence of usability testing, including users with low level digital skills, people with disability, and people from different cultural and linguistic backgrounds". (Page updated 19 August 2025.)

Reporting: departments must submit a department-endorsed digital services accessibility plan every year by 31 October.

Older standards still listed: the Consistent User Experience Standard v3.0 (approved December 2010) still lists WCAG 2.0 as a related document. The online standards page lists WCAG 2.1. Criterion 9's "latest version" is the safer reading.

Disability planning: under the Disability Services Act 2006 (Qld), each department must develop a disability service plan. Plans align to Queensland's Disability Plan 2022 to 2027.

Western Australia

Standard: the Accessibility and Inclusivity Standard is a mandatory part of the Digital Services Policy Framework. It was first published on 11 March 2024 and last updated on 6 August 2026. It applies to all agencies, statutory authorities and government trading enterprises. It covers public websites, intranets, extranets, web and mobile apps, social media and advertising campaigns. Its requirements include:

• all digital content must adopt the latest WCAG standard to AA level;
• content must be provided in the most useful and accessible format for the community;
• services must allow for assistive technologies;
• agencies must test and review services at regular intervals, before and after a major release;
• agencies must report on website accessibility levels every year through their Disability Access and Inclusion Plan.

The standard has no exemption process: each agency accepts the risk of not meeting it. Third-party content about government-funded programs must also meet the requirements if it is "government information".

Disability planning: the Disability Services Act 1993 (WA) requires state and local governments to develop and implement a Disability Access and Inclusion Plan (DAIP).

South Australia

Policy: the Online Accessibility Policy is mandatory across government and was first authorised on 16 May 2019. It applies to all new or significantly upgraded online applications. These include websites, intranets, native apps, online documents, forms, closed client systems, multimedia and non-web software. It requires conformance with WCAG 2.0 Level AA (or WCAG 2.1 Level AA) at a minimum. We found no newer version naming WCAG 2.2.

Other requirements: PDF alone is not an accessible enough format, and HTML should be the default. Procurement documents must state the accessibility requirements, vendors must provide evidence, and contracts must include the vendor's commitment. The policy is itself published in Easy Read, supported by the Online Accessibility Toolkit.

Disability planning: under the Disability Inclusion Act 2018 (SA), each State authority must prepare and publish a Disability Access and Inclusion Plan. It must report on the plan every year. DAIPs must include strategies to help people with disability access information and communications. The policy suggests agencies report evidence of WCAG compliance and of directly engaging people with disability.

Tasmania

Policy: the Tasmanian Government Communications Policy (last updated September 2024) covers agencies managing government websites and portals. They must make published information accessible "in accordance with WCAG level AA accessibility requirements". It does not name a WCAG version. The whole-of-government site tas.gov.au says it aims to comply with WCAG 2.1 Level AA.

Disability planning: the Disability Rights, Inclusion and Safeguarding Act 2024 commenced on 1 July 2025. The Head of the State Service described inclusion planning as something "all Tasmanian Government agencies and Government Business Enterprises are required to complete".

We did not find a separate published Tasmanian digital service standard or design system.

Australian Capital Territory

Policy: we could not find the ACT Government Web Accessibility Policy on a public ACT Government site. The ACT Government website accessibility statements we read, such as act.gov.au's, cite WCAG 2.1, some at Level A and in parts AA. We could not confirm the policy's WCAG level against its text.

Disability planning: the Disability Inclusion Act 2024 (ACT) commenced on 17 March 2025. Each public sector entity must make a disability inclusion plan with actions to reduce, remove and prevent barriers to accessibility. It must consult people with disability, families and carers and disabled people's organisations in developing it. It must publish the plan on an ACT Government website and review it at least every five years. The Disability Inclusion Regulation 2025 sets minimum content for the plans.

Northern Territory

Policy: the NT Government's public accessibility page says it has endorsed WCAG 2.0. It is working towards making all websites and web content meet WCAG 2.0 Level AA. The Digital Territory website standards list "Accessible" as a principle. They require plain English, approved content management systems, content of five pages or less in HTML, and testing aligned to the NTG website testing guideline. They do not name a newer WCAG version.

We did not find NT legislation requiring government agencies to prepare disability inclusion or action plans. The Commonwealth Disability Discrimination Act still applies in full.

Do local councils have to meet these rules?

Yes, councils are covered by the Disability Discrimination Act 1992 like every other government. Councils do not generally have a state-mandated WCAG policy. Whether they must also keep a disability plan depends on the state. NSW, Western Australia and South Australia require one, and many Victorian councils publish one. As at 10 November 2026.

• NSW: all councils must have a Disability Inclusion Action Plan (in place since 1 July 2017).
• Western Australia: the Disability Services Act 1993 requires local governments to develop and implement a DAIP.
• South Australia: State Government agencies and local government were required to develop DAIPs under the Disability Inclusion Act 2018.
• Victoria: many councils publish disability action plans aligned with section 38 of the Disability Act 2006.
• Queensland, Tasmania and the Northern Territory: we did not confirm a statutory council-level planning duty in the sources we read. The ACT has no separate local government.

The Australian Local Government Association's Disability Inclusion Guide for Local Government was updated and relaunched in 2026. The Australian Government supported it under Australia's Disability Strategy. It covers engagement and communication, procurement and disability inclusion planning.

What content and language rules apply?

Yes, every jurisdiction that publishes content guidance asks for plain language, and most say HTML first. The Commonwealth Style Manual aims for an Australian year 7 reading level, Victoria below Year 8 and Queensland below grade 9. Victoria also requires captions on all new videos and Easy Read on request. As at 10 November 2026.

Plain language

The measures differ:

• Commonwealth Style Manual: aim for an Australian year 7 reading level.
• Victoria: below Year 8 as far as practicable, and adoption of ISO 24495-1:2023.
• Queensland: reading age below grade 9 unless there is a clear need for technical language.
• NSW and NT: plain language or plain English, without a stated reading level in the pages we read.

Easy Read

The Style Manual and Victoria both treat Easy Read as different from plain language. Easy Read combines simple text with layout and images. It is for people who are not familiar with English, have low literacy or have an intellectual or learning disability. Victoria requires Easy Read to be available on request, and South Australia publishes its accessibility policy itself in Easy Read. The Style Manual recommends using Easy Read experts and checking with users first.

Auslan, interpreting and translated content

Services Australia provides free Auslan interpreters. TIS National (131 450 within Australia) delivers the Free Interpreting Service for the Australian Government. We found no rule in any jurisdiction requiring Auslan versions of digital content.

On translation, the DTA asks for "human-validated multilingual support for critical information" and accurate translations that keep the same level of accessibility. Queensland expects a plan to include translation for non-English-speaking audiences, as appropriate. It also expects evidence of including culturally and linguistically diverse communities in design. NSW asks teams to provide alternatives to written English where possible. Machine translation widgets, which some state sites offer, do not meet the "human-validated" test for critical information.

Aboriginal and Torres Strait Islander languages and protocols

The Style Manual's guidance is the most detailed national reference. Respectful language depends on consultation with the specific peoples involved, and there are very few hard rules. Naming and cultural protocols must be respected, for example around the names and images of people who have died. We did not find a digital standard in any jurisdiction that sets requirements for content in Aboriginal or Torres Strait Islander languages.

Accessible documents, alt text and captions

• HTML first: the Commonwealth (Style Manual), Victoria, Queensland and South Australia all say to publish in HTML first and treat PDFs as secondary. Victoria says every document must have a web page equivalent. The NT standard asks for content of five pages or less to be in HTML.
• Alt text: Victoria requires it for images that convey meaning, and the Commonwealth Digital Inclusion Standard names it.
• Captions and transcripts: Victoria requires closed captions on all new videos. Services Australia provides transcripts for all its video and audio. The Human Rights Commission recommends video transcripts as an AAA criterion worth adopting.

Do agencies have to publish accessibility statements?

Yes, for Commonwealth agencies. The Commonwealth Style Manual says agencies should include a page explaining how far a service complies with WCAG. No state prescribes a statement template that we found. Reporting usually runs through disability inclusion or access plans, and WA requires agencies to report website accessibility every year through theirs. As at 10 November 2026.

Only the Commonwealth's Style Manual asks for a statement explaining WCAG conformance. Victoria's "accessibility statement" is a line offering other formats. WA is the only jurisdiction we found that ties website accessibility reporting to a statutory disability plan every year.

Do Australian government standards require testing with people with disability?

Yes, in four jurisdictions. The Commonwealth Digital Service Standard's Criterion 3 asks agencies to "evaluate the service with users who depend on assistive technology". Queensland's Criterion 9 asks for "evidence of usability testing, including… people with disability" before public launch. NSW and WA also ask for testing. As at 10 November 2026.

What the rules say about testing with people

• Digital Service Standard, Criterion 3: agencies should "validate the effectiveness of solutions with real-world users" and "evaluate the service with users who depend on assistive technology".
• Digital Inclusion Standard, Criterion 4: "use automated accessibility testing where appropriate, in addition to testing services with real people", and test assistive technologies with users.
• Style Manual: as part of user research, test content to gain "input from the users you're designing for" and views from diverse and representative users. Each agency needs to make its own assessment of whether content reaches Level AA.
• Queensland Criterion 9: before public launch, show "evidence of usability testing, including users with low level digital skills, people with disability, and people from different cultural and linguistic backgrounds".
• NSW Design Standards: test with assistive technologies, include people with disability, and fund recruitment and testing of under-represented groups.
• WA, SA and the Human Rights Commission: WA requires testing before and after major releases. SA and the Commission recommend usability testing with people with disability, including assistive technology users.

Automated and manual testing

The guidance treats automated tools as a starting point. The Commonwealth's wording ("in addition to testing services with real people") is the clearest. Victoria recommends site analysis tools such as Siteimprove and Acquia Optimize for monitoring. The NSW Design System warns that compliant components do not guarantee a compliant product. None of the jurisdictions suggests that an automated scan alone shows conformance.

Conformance tells you the service meets the standard. Usability tells you whether a blind resident can pay their rates online. Both matter, and our guide to accessibility and usability explains how they fit together.

What counts as evidence

A defensible evidence file in 2026 would include:

• a WCAG 2.2 AA audit covering the full user journey, manual and automated;
• records of usability testing with people with disability, including assistive technology users;
• evidence of testing with people with low digital skills and from culturally and linguistically diverse communities (Queensland names both);
• supplier conformance evidence against AS EN 301 549 or WCAG;
• a published accessibility statement with a feedback route.

If you are comparing ways to test with people, see how See Me Please compares with Fable.

What should your team do next?

Yes, there is a clear path. Work to WCAG 2.2 AA, check which standards apply to your service, and write accessibility into procurement. Publish in HTML, write plainly, caption video and plan language access. Then test with people, publish an accessibility statement and feed the evidence into your disability plan. As at 10 November 2026.

1. Set the bar at WCAG 2.2 AA, whatever your jurisdiction's text says. It meets every current policy we could read and the Human Rights Commission's guidance.
2. Check which standards apply to your service using the comparison table above.
3. Write accessibility into procurement. Name AS EN 301 549 and WCAG 2.2 AA, ask for conformance evidence, and include contract terms and periodic independent checks. The Commonwealth Procurement Rules now require these for applicable standards.
4. Publish in HTML first. Use PDFs only where there is a specific need, and always provide an accessible alternative.
5. Write to a measured reading level: year 7 (Commonwealth), below Year 8 (Victoria) or below grade 9 (Queensland).
6. Caption every new video and provide transcripts. Check auto-captions before publishing.
7. Plan language access. Use human-validated translation for critical information, offer Easy Read where your users need it, and point people to TIS National (131 450).
8. Test with people, including people with disability, assistive technology users, people with low digital skills and people from culturally and linguistically diverse backgrounds. Use automated tools for coverage, not as proof. Record what you tested and changed.
9. Publish an accessibility statement that explains your WCAG conformance, known gaps and how to ask for another format.
10. Feed your evidence into your agency's disability plan and reporting (DIAP, DAIP, disability service plan or Commonwealth compliance reporting).

Where does this leave government teams?

Yes, Australian governments agree on the direction: accessible by default, tested with real people, written plainly and bought from suppliers who can prove it. They do not yet agree on the wording, so teams in different jurisdictions read different WCAG versions. WCAG 2.2 AA is the working national benchmark. As at 10 November 2026.

• Law: the Disability Discrimination Act applies to every government and council, and no policy lowers that floor.
• Standard: WCAG 2.2 AA is the working national benchmark.
• Older texts: South Australia and the Northern Territory still name WCAG 2.0, and the ACT's policy is not public.
• Commonwealth deadlines: all have passed, the last on 1 January 2026.
• Testing: testing with people with disability is a written expectation at Commonwealth level and in NSW, Queensland and WA, and a recommendation in SA.

The practical response is to work to WCAG 2.2 AA and keep evidence beyond a scan. Record who you tested with, what they found and what you fixed. That is what the Commonwealth, Queensland, NSW and WA policies ask for. It is also what will matter if a person with disability makes a complaint. Meet the standard, then check it works for the people the policies were written for.

How did we check these requirements?

On 9 and 10 November 2026, we read the live official page for every policy, standard and Act named here. Where a page shows a "last updated" date, we give it. Where we could not find an official current text, or a page names no WCAG version or level, we say so. Correct as at 10 November 2026.

Policy pages in this area change without much notice. Several still carry older wording alongside newer requirements, so treat every date and version number as correct when read, not correct forever. Primary sources come first: policy pages, legislation, the Style Manual and the Australian Human Rights Commission's Guidelines. We did not rely on independent research or commentary for any claim. This guide describes requirements, which we sourced directly from governments.

Frequently asked questions

Is website accessibility a legal requirement for Australian government agencies?

Yes. The Disability Discrimination Act 1992 applies to Commonwealth, state, territory and local governments. Excluding people with disability from information or services can be unlawful discrimination. The Commonwealth and most states also have mandatory policies that set a WCAG standard for government digital services (as at 10 November 2026).

What WCAG level do Australian government websites need?

As at 10 November 2026, Level AA, and WCAG 2.2 AA meets or exceeds every current written policy we could read. The Commonwealth Style Manual, Victoria and NSW identify WCAG 2.2 as current, and Queensland and WA require "the latest" WCAG at AA. South Australia's 2019 policy names WCAG 2.0 or 2.1 AA. The Australian Human Rights Commission's April 2025 Guidelines recommend WCAG 2.2 AA as the minimum.

What is the Digital Experience Policy and who does it apply to?

Since 1 January 2025, it has been the DTA's mandatory policy for Australian Government digital services, with four supporting standards. It covers new and replacement public-facing services, new staff-facing services and all existing public-facing services, but not state or territory services. Its Digital Inclusion Standard has applied to all existing public-facing services since 1 January 2026.

Does the Digital Service Standard require testing with people with disability?

Yes. Criterion 3, "Leave no one behind", asks agencies to validate solutions with real-world users and to evaluate services with users who depend on assistive technology. The Digital Inclusion Standard adds that automated testing should be used in addition to testing with real people.

Which standard applies to government ICT procurement?

Since 17 November 2025, the Commonwealth Procurement Rules have required tenders to show they can meet an applicable standard. Contracts must contain evidence of it. The DTA's Consider First Policy links this to AS EN 301 549, the Australian standard for accessibility of ICT products and services.

Does WCAG conformance make a government service accessible?

No, not on its own. WCAG is the foundation, and the Style Manual notes it has limits for people with cognitive and learning disabilities. That is why the Commonwealth, Queensland and NSW also ask for testing with real users, including people with disability.

Do government agencies have to publish accessibility statements?

Yes, for Commonwealth agencies: the Style Manual says they should include a page explaining how far a service complies with WCAG. Most states do not prescribe a template, and reporting often runs through disability plans. WA requires annual reporting of website accessibility through each agency's DAIP.

Should government content be published as PDF?

No, not as the main format. The Style Manual says to create content in HTML pages instead of PDFs, and Victoria requires every document to have a web page equivalent. Queensland and South Australia also say HTML should come first.

Who enforces digital accessibility in Australian government?

As at 10 November 2026, no jurisdiction we checked has a dedicated digital accessibility regulator. People can complain to the Australian Human Rights Commission under the Disability Discrimination Act. State human rights and equal opportunity bodies handle complaints under state law. Each government's digital agency manages policy compliance, for example the DTA for the Commonwealth.

About See Me Please

See Me Please is a technology company headquartered in Sydney, Australia. Its platform runs accessibility and usability testing with real people: each project puts a digital service in front of 18 paid participants from six perspectives (Blind, Low vision, Deaf, Neurodivergent, Over-65, Limited English), drawn from a panel of more than 300 testers in Australia, New Zealand, the UK and Ireland, with findings in five business days. More than 40 organisations are customers.

On our platform, See Me Please holds more than 3,200 session recordings and 7,800 tracked findings, across 26 projects for 18 organisations in Australia, the UK and Ireland (as at 10 November 2026).

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References

Primary legislation, policy and government sources, read 9 to 10 November 2026.

• Digital Transformation Agency, Digital Experience Policy
• Digital Transformation Agency, Digital Service Standard and Criterion 3: Leave no one behind
• Digital Transformation Agency, Services covered by the Digital Service Standard
• Digital Transformation Agency, Digital Inclusion Standard, services covered and Criterion 4: Make it accessible
• Digital Transformation Agency, Digital Access Standard transition approach
• Australian Government Architecture, Web Content Accessibility Guidelines (WCAG) and Consider First Principle 5.1 Accessibility
• Department of Finance, Commonwealth Procurement Rules (17 November 2025)
• Australian Government Style Manual, Agency responsibilities and commitments, Literacy and access, Design for accessibility and inclusion, Disability and neurodiversity, Aboriginal and Torres Strait Islander peoples, Easy Read, PDF
• Australian Human Rights Commission, Guidelines on equal access to digital goods and services (April 2025)
• Department of Social Services, Australia's Disability Strategy 2021 to 2031 and Disability Inclusion Guide for Local Government updated
• Department of Social Services, UN Convention on the Rights of Persons with Disabilities
• Services Australia, Accessibility; myGov, Accessibility
• TIS National, Contact us
• Digital NSW, Design Standards and Accessibility and Inclusivity Toolkit: Your responsibilities
• NSW Government, About the NSW Design System and C2012-08 NSW Government Website Management (archived)
• NSW Department of Communities and Justice, Disability Inclusion Action Plans
• Victorian Government, Digital accessibility requirements, Accessible communications policy and Standards for accessible content
• Victorian Public Sector Commission, Regulatory and policy context (section 38, Disability Act 2006)
• Queensland Government, Digital services policy, Digital service standard, Make digital services accessible and Consistent User Experience Standard v3.0
• Queensland Department of Families, Seniors, Disability Services and Child Safety, Disability service plans
• Government of Western Australia, Accessibility and Inclusivity Standard
• Government of South Australia, Online Accessibility Policy
• Tasmanian Government, Communications Policy requirements for websites, tas.gov.au accessibility and Commencement of the Disability Rights, Inclusion and Safeguarding Act 2024
• ACT Parliamentary Counsel, Disability Inclusion Act 2024 (A2024-44), republication 1
• ACT Government, example act.gov.au accessibility statement
• Northern Territory Government, Accessibility and Website standards