Does my business website need to meet accessibility standards in Australia? WCAG 2.2 and the law

What the Disability Discrimination Act and the Australian Human Rights Commission say about websites, what WCAG 2.2 Level AA asks for in plain words, and how accessibility is built into a CatalystHub Specialist website.

By Vish Rathnayaka 6 November 2026 10 min read

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Australia’s Disability Discrimination Act 1992 makes it unlawful to discriminate against someone because of their disability when you provide goods or services, and that includes the way you provide them. The Act does not mention websites. The Australian Human Rights Commission’s guidelines on digital goods and services (April 2025) are written to help organisations meet their obligations under the Act, and they say organisations should conform with WCAG 2.2 at Level AA at a minimum. WCAG stands for the Web Content Accessibility Guidelines, the web standard for making sites usable by people with disabilities. Every CatalystHub Standard build includes WCAG 2.2 AA accessibility, and our Specialist build from $1,500 includes everything in Standard.

This guide is general information, not legal advice. For your own situation, read the Act and the Commission’s guidelines (linked at the end) or talk to a lawyer.

What the Disability Discrimination Act says

One of the Act’s aims is to remove, as far as possible, discrimination against people with disability in providing goods, facilities, services and land (section 3).

Section 24 is the part that matters for a business. It says it is unlawful for anyone who provides goods or services, “whether for payment or not”, to discriminate against a person because of their disability:

  • by refusing to provide the goods or services
  • in the terms or conditions they’re provided on
  • in “the manner in which” they’re provided.

Reasonable adjustments (section 5(2)). Not making a reasonable adjustment for a person can itself count as discrimination, if it means the person is treated less favourably than someone without the disability would be.

Unjustifiable hardship (section 11). A business can argue that a change would cause it “unjustifiable hardship”, meaning the cost or burden would be too much. To decide, all the circumstances are weighed, including the benefit or harm to everyone involved, the effect of the person’s disability, the business’s finances and the cost of the change, and any help available to the business. The business making the claim has to prove it.

Who counts as having a disability. The Act uses a broad definition. It starts with total or partial loss of a person’s bodily or mental functions, or of a part of the body, and goes on from there (section 4).

Disability standards. The Act lets the Minister make disability standards for particular areas (section 31). When we checked on 6 November 2026, we didn’t find one for websites.

What the Australian Human Rights Commission says

The Australian Human Rights Commission (the AHRC) published its “Guidelines on equal access to digital goods and services” in April 2025. They update its earlier World Wide Web Access: Disability Discrimination Act Advisory Notes. The Commission says:

  • “These Guidelines will assist organisations to meet their obligations under the Disability Discrimination Act when providing digital goods and services.”
  • “Organisations should conform with WCAG 2.2 at a minimum Level AA and consider appropriate Level AAA success criteria such as video transcripts, audio contrast, clear links and section headings.”
  • Organisations can contract out digital goods or services, but they “cannot contract out their equal access responsibilities”.

In plain words: if a web designer builds your site, or another company runs your booking system, the responsibility for equal access still sits with you.

How many Australians have disability

The ABS, Australia’s national statistics agency, found that in 2022, 5.5 million Australians (21.4%) had disability, up from 17.7% in 2018. Those figures were released on 4 July 2024.

The Digital Service Standard for Australian Government agencies

Australian Government agencies work under the Digital Service Standard. Its Criterion 3, “Leave no one behind”, says agencies must comply with the Disability Discrimination Act 1992 and the latest version of WCAG. It applied to new and replacement public-facing services from 1 July 2024, and to existing ones from 1 July 2025. It covers Australian Government agencies, not private businesses.

What WCAG 2.2 is

WCAG is published by the W3C, the international group that sets web standards. In its own words, WCAG 2.2 “defines how to make web content more accessible to people with disabilities”. That covers blindness and low vision, deafness and hearing loss, limited movement, speech disabilities, photosensitivity (sensitivity to flashing light), and combinations of these.

  • Three levels. Each rule (a “success criterion”) has a level: A (the lowest), AA, or AAA (the highest). Level AA means a page meets every Level A and Level AA rule.
  • Dates. WCAG 2.2 was first published as a W3C Recommendation (a finished web standard) on 5 October 2023. The current version is dated 12 December 2024.
  • What’s new. WCAG 2.2 adds 9 success criteria to WCAG 2.1, and removes one old rule, 4.1.1 Parsing, as obsolete.
  • Older versions. A site that meets WCAG 2.2 also meets WCAG 2.0 and WCAG 2.1.
  • WCAG 3. The W3C says WCAG 3 is an incomplete draft and isn’t expected to be a finished standard for a few more years. WCAG 2 won’t be deprecated (retired) for several years after WCAG 3 is finalised.

What WCAG 2.2 Level AA asks of a business website

These are some of the rules a typical business website runs into. The number is the rule’s number in WCAG 2.2.

RuleLevelWhat it means in plain words
1.1.1 Non-text ContentAImages and other non-text content have a text alternative. On a website this is usually alt text: a short written description that a screen reader (software that reads the page aloud) can read out.
1.2.2 Captions (Prerecorded)ARecorded videos with sound have captions.
1.4.3 Contrast (Minimum)AAText has a contrast ratio of at least 4.5:1 against its background, with some exceptions. The contrast ratio measures how much the text stands out from the colour behind it.
1.4.4 Resize TextAAPeople can enlarge text up to 200% without losing any content or features, and without special software.
2.1.1 KeyboardAEverything on the site works with a keyboard alone.
2.4.7 Focus VisibleAAWhen someone moves through the page with a keyboard, they can see where they are.
2.4.11 Focus Not Obscured (Minimum)AANew in 2.2. The item the keyboard is on isn’t completely hidden behind something else.
2.5.8 Target Size (Minimum)AANew in 2.2. Buttons and links are at least 24 by 24 CSS pixels (the unit web designers use to size things on screen), with some exceptions.
3.3.8 Accessible Authentication (Minimum)AANew in 2.2. Logging in doesn’t require a memory or puzzle test, such as remembering a password or solving a puzzle, unless there’s another way to do it.

Two more rules decide what “meeting Level AA” covers. Conformance applies to full pages only, and a page can’t conform if part of it is left out. And in a process that runs over several pages, like a booking or a checkout, every page in the process has to conform. So a booking engine or payment step inside your website counts too, even if another company supplies it.

WCAG 2.2 AA accessibility in a CatalystHub build

Our Specialist build is from $1,500 including GST, one-off, for up to 15 pages. It includes everything in our Standard build, and the Standard build includes WCAG 2.2 AA accessibility. On top of that, the Specialist build adds:

  • More advanced custom design.
  • Custom industry design.
  • Industry compliance baked in (AHPRA, ACCC, GST display rules). AHPRA is the Australian Health Practitioner Regulation Agency and the ACCC is the Australian Competition and Consumer Commission.
  • Integrations included: booking engines, Google Business schema (code that tells Google your business details) and capability PDFs (a downloadable document that sums up what your business does). If you already have a capability PDF, we put it on your site free; creating a new one is a separate job, quoted separately. Booking and payment tools come from other companies, so we talk through which one suits you, and how well it works for people with disability, on the call.
  • Unlimited revisions.
  • A care plan is available from $79 a month.

On our pricing page, the accessibility line in the build reads “Keyboard-usable, screen-reader-friendly, contrast-checked. Tested, not assumed.” Accessibility is also on our launch checklist, next to a Lighthouse performance pass and a link-and-form audit. Lighthouse is Google’s speed score, an automated check of how fast and well a page runs. Our builds aim for Lighthouse 95+ on mobile and load in under a second on 4G. Our own accessibility statement shows how we test this website.

If you need a smaller site, our Standard build is $500 and includes the same WCAG 2.2 AA accessibility.

Planning a bigger site? Bigger builds are kept to the same accessibility standards. We price them at about $100 a page up to 15 pages, and a lower price per page above 15. Blog posts and news articles don’t count toward the page total, and privacy and terms pages generally don’t either. As a guide, 10 pages is about $1,000, 20 pages about $1,900 and 30 pages about $2,500. The exact price is fixed in writing on a 30-minute call before you pay, and for builds over 15 pages the timeline is agreed in writing on that call too. Revisions are unlimited until you’re 100% happy, and hosting is usually free, confirmed in your quote. We’re not tied to one platform: WordPress is available on request. For more detail, see what a website costs by number of pages.

Start a Specialist build or compare every package.

Frequently asked questions

Is WCAG the law in Australia? The Disability Discrimination Act doesn’t mention websites. It makes it unlawful to discriminate because of disability in the way goods and services are provided. The Australian Human Rights Commission’s guidelines, written to help organisations meet their obligations under the Act, say organisations should conform with WCAG 2.2 at Level AA at a minimum.

Is there a disability standard for websites? The Act lets the Minister make disability standards for particular areas. When we checked on 6 November 2026, we didn’t find one for websites.

My web designer built the site. Isn’t accessibility their problem? The Commission says organisations can contract out digital goods or services, but they “cannot contract out their equal access responsibilities”.

Does WCAG 2.2 replace WCAG 2.1? WCAG 2.2 adds 9 rules to WCAG 2.1. A site that meets WCAG 2.2 also meets WCAG 2.0 and WCAG 2.1.

Should I wait for WCAG 3? The W3C says WCAG 3 is an incomplete draft that isn’t expected to be finished for a few more years, and that WCAG 2 won’t be retired for several years after WCAG 3 is finalised.

Sources

All read on 6 November 2026.

Home page of the Aesir Legal website on a laptop screen
Home page of the Aesir Legal website on a phone screen
Recent build: Aesir Legal, Perth law firm (opens in a new tab)

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