What are the AHRC Guidelines on equal access to digital goods and services?

Published by the Australian Human Rights Commission in April 2025, the Guidelines explain how the Disability Discrimination Act 1992 applies to digital products and services. They replace the World Wide Web Access Advisory Notes the Commission had maintained since the early 2000s, set WCAG 2.2 Level AA as the minimum benchmark, and extend expectations beyond websites to mobile apps, SaaS platforms, kiosks, AI systems and wearables.

Which standards do the AHRC guidelines endorse?

WCAG 2.2 at a minimum of Level AA, with consideration of appropriate Level AAA criteria. For the full range of digital products including hardware, AS EN 301 549:2024, noting that where it references WCAG 2.1, WCAG 2.2 should be used instead. Also ATAG 2.0 for authoring tools, WAI ARIA 1.2, EPUB 3.3 for digital publications, and AS ISO 14289.1 (PDF/UA) for PDFs.

What do the AHRC guidelines expect organisations to actually do?

The Guidelines describe good practice steps for avoiding discrimination, including building accessibility requirements into procurement and tender documentation, publishing an accessibility statement that explains how standards have been met, and providing accessible ways for people with disability to get in touch when they encounter barriers. Combined with the WCAG 2.2 AA benchmark, the practical program is an independent audit, remediation by severity, a public statement and a working feedback channel.

Australia WCAG 2.2 Guide

The AHRC digital accessibility guidelines, explained

Q: What changed from the 2014 Advisory Notes?

Three big shifts. The benchmark moved from WCAG 2.0 AA to WCAG 2.2 AA, with encouragement to adopt useful Level AAA criteria. The scope widened from websites to the full digital landscape: mobile apps, social media, SaaS, AI and biometric systems, self service machines, kiosks and wearables. And the audience widened from web teams to providers of digital goods and services, hardware and software suppliers, and employers deploying digital technology. The 2014 Advisory Notes are now archived and marked as no longer current.

In April 2025 the Australian Human Rights Commission reset the national benchmark for digital accessibility. Here is what the Guidelines on equal access to digital goods and services say, what changed, and what to do about it.

Quick answer

What are the AHRC digital accessibility guidelines?

The Guidelines on equal access to digital goods and services (PDF), published by the Australian Human Rights Commission in April 2025, explain how the Disability Discrimination Act 1992 applies to digital products and services. They replace the Commission's 2014 Advisory Notes, set WCAG 2.2 Level AA as the minimum benchmark, and extend expectations well beyond websites: mobile apps, SaaS platforms, kiosks, AI systems and wearables are all in scope. They are not legally binding, but the Commission can consider them when handling complaints, which makes them the closest thing Australia has to an official definition of digital accessibility compliance.

Where the guidelines came from

For over a decade, the Commission's position on digital access lived in the World Wide Web Access: Disability Discrimination Act Advisory Notes, last revised as version 4.1 in 2014. Those notes told organisations to meet WCAG 2.0 AA. They served their purpose, but by the mid 2020s they described a web that no longer existed: no mobile apps, no SaaS, no AI. The Commission has now archived them and marks them as no longer current.

The 2025 Guidelines are the formal replacement. They are issued under section 67(1)(k) of the Disability Discrimination Act and section 11(1)(n) of the Australian Human Rights Commission Act. Like the Advisory Notes before them, they do not have direct legal force, but the Commission and other anti discrimination agencies can take them into account when dealing with complaints lodged under the DDA. If a complaint about your product reaches conciliation, the Guidelines are the reference point for what you should have done.

What changed from the 2014 Advisory Notes

The benchmark moved to WCAG 2.2 Level AA. The Guidelines say organisations should conform with WCAG 2.2 at a minimum of Level AA, and should consider appropriate Level AAA success criteria such as video transcripts, audio contrast, clear links and section headings. Where an industry code sets a lower floor, the Commission still recommends WCAG 2.2 AA.
The scope is the whole digital landscape. Websites remain in scope, joined by mobile apps, social media, SaaS platforms, AI and biometric systems including facial recognition, self service machines and kiosks, and wearables and other connected devices.
The audience is wider than web teams. The Guidelines address providers of digital goods and services, hardware and software suppliers, employers deploying digital technology in the workplace, and the compliance professionals who advise them.

The standards the guidelines endorse

The Guidelines anchor to a family of standards rather than WCAG alone:

WCAG 2.2, minimum Level AA for web content and anything evaluated like it.
AS EN 301 549:2024, the Australian ICT accessibility standard, for the full range of digital products including hardware. The Commission notes that where it references WCAG 2.1, WCAG 2.2 should be used instead.
ATAG 2.0 for authoring tools, WAI ARIA 1.2 for rich interfaces, EPUB 3.3 for digital publications, and AS ISO 14289.1 (PDF/UA) for PDF documents.

For most organisations the practical reading is simple: web content is measured against WCAG 2.2 AA, documents against PDF/UA as well, and procured ICT against AS EN 301 549. Our standards overview explains how these fit together.

What the guidelines expect you to do

Beyond the technical benchmark, the Guidelines describe good practice steps for avoiding discrimination. The recurring themes:

Buy accessible. Build accessibility requirements into procurement and tender documentation, so inaccessible products do not enter the estate in the first place.
Say where you stand. Publish an accessibility statement that explains how standards have been met.
Keep a door open. Provide accessible ways for people with disability to get in touch when they encounter barriers, and act on what comes through.

None of this is onerous, and all of it is exactly what a respondent ends up doing under a complaint anyway. Doing it before a complaint is cheaper and looks considerably better.

What to do now

ExceedAbility maps engagements directly to the Guidelines' expectations: an independent WCAG 2.2 AA audit establishes where you stand, document remediation covers the PDF/UA obligations, a VPAT or Accessibility Conformance Report gives procurement teams the evidence they ask for, and organisational uplift builds the capability so conformance survives the next release. If you are unsure whether the Guidelines change anything for your organisation, the answer fits in a 20 minute conversation.

Common questions about the AHRC guidelines

Plain answers to what organisations ask us most often.

Are the AHRC guidelines legally binding?

No. They are issued under section 67(1)(k) of the Disability Discrimination Act and state that they are not legally binding. Their weight comes from use: the Commission can consider them when handling discrimination complaints, so they function as the official yardstick for what reasonable digital accessibility looks like in Australia.

Do the guidelines apply to mobile apps and SaaS products?

Yes. The 2025 Guidelines explicitly cover mobile apps, social media, SaaS platforms, AI and biometric systems, self service machines and kiosks, and wearables, alongside websites. If people use it to access a good or service, the Disability Discrimination Act framework applies to it.

We built to WCAG 2.0 or 2.1 under the old Advisory Notes. Are we still covered?

The 2014 Advisory Notes are archived and marked as no longer current, and the benchmark is now WCAG 2.2 Level AA. The good news is that WCAG is backwards compatible: content conforming to 2.2 also conforms to 2.0 and 2.1. A gap assessment against the criteria added in 2.1 and 2.2 is usually a modest piece of work. Our WCAG levels comparison explains the differences.

How does ExceedAbility help with the guidelines?

We audit against WCAG 2.2 AA and PDF/UA, remediate documents and support code fixes, produce VPATs and Accessibility Conformance Reports for procurement, and run uplift programmes that embed the guidelines' good practice steps: accessible procurement, public statements and working feedback channels. Reach us at [email protected].

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