Accessibility Requirements

Australian Requirements for Digital Products, Procurement and ICT Suppliers.

Australia has clear legal and policy requirements that mandate accessibility across digital products, ICT procurement, and the suppliers who provide technology to government. These obligations are driven by the Disability Discrimination Act (DDA) and enforced through procurement frameworks that require conformance with AS EN 301 549 (PDF), Australia's official accessibility standard for ICT. For suppliers, accessibility is no longer optional — it is a contractual, legal, and competitive requirement.

1. Accessibility as a Legal Obligation Under the DDA

Under the Disability Discrimination Act, all digital products and services must be accessible and inclusive for people with disability. Government guidance states that all digital products should be accessible and inclusive for all users, including websites, software, infrastructure systems, and digital services. This obligation applies to both public‑facing services and internal workplace systems. Overview of the Disability Discrimination Act (1992)

The DDA requires organisations to remove barriers that prevent equal access. In practice, this means digital products must work effectively in the ways that people with disablities use them. This includes compatibility with assistive technologies, keyboard navigation, screen readers, and other accessibility features. The DDA is enforced through legal channels, and organisations that fail to meet accessibility requirements risk legal action, reputational damage, and loss of business.

2. AS EN 301 549 — Australia’s Mandatory ICT Accessibility Standard

Australia formally adopted AS EN 301 549 in 2016 as the national accessibility standard for ICT procurement. It is now embedded in federal and state procurement policies and used to assess the accessibility of any acquired technology.

AS EN 301 549:

  • Defines accessibility requirements for websites, mobile apps, software, hardware, documents, multimedia, and ICT interfaces.
  • Includes Functional Performance Statements covering users who are blind, have low vision, are deaf or hard of hearing, have limited mobility, are neurodiverse, or experience seizures.
  • Is built largely on the Web Content Accessibility Guidelines (WCAG). Government guidance confirms that much of the standard is based on WCAG, and NSW requires at least WCAG 2.0 AA for government websites.

3. Accessibility Requirements in ICT Procurement

Australian governments require accessibility to be included in all ICT procurement processes. NSW and Queensland both mandate the use of AS EN 301 549 when buying ICT products and services.

Procurement teams and ICT buyers must:

  • Include accessibility requirements in RFPs and contracts.
  • Use AS EN 301 549 to define functional and technical accessibility criteria.
  • Require suppliers to provide verifiable evidence of compliance.
  • Ensure purchased products remain accessible across versions and updates.

Government guidance notes that even major vendors may not meet all accessibility requirements and that accessibility can vary between product versions — making evidence essential.

4. Supplier Responsibilities and Evidence Requirements

ICT Suppliers selling digital products into government must demonstrate how their products meet AS EN 301 549. This includes software, SaaS platforms, websites, apps, hardware, and any ICT with a user interface.

Suppliers are expected to provide:

Suppliers who cannot demonstrate accessibility risk losing tenders or being excluded from procurement panels. Use this ICT Supplier Self-Assessment Checklist to assess your accessibility readiness and discover areas for improvement.

5. What This Means for Digital Product Teams

To meet legal and procurement requirements, digital product teams must:

  • Design and build to WCAG‑aligned standards.
  • Test with assistive technologies.
  • Ensure documents, multimedia, and UI components meet accessibility requirements.
  • Maintain accessibility across releases and product versions.

Accessible design is now a baseline expectation for any organisation delivering digital services in Australia.

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