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AU Compliance•10 min read

DDA 1992 vs DSE 2005: Complete Accessibility Compliance Guide for Australian Universities

By Aelira Compliance Team•


Australian universities face a complex web of accessibility obligations: Disability Discrimination Act 1992 (DDA), Disability Standards for Education 2005 (DSE), and AS EN 301 549:2020 for ICT procurement. Unlike the US's hard April 2026 deadline, Australia has ongoing enforcement—but scrutiny is intensifying.


If your university is treating accessibility as "nice to have," you're exposed to AHRC complaints, legal action, and reputational damage.


Here's what you need to know.


The Australian Accessibility Framework


1. Disability Discrimination Act 1992 (DDA)


What it is: Federal civil rights law prohibiting discrimination on the basis of disability.


Who it applies to: All Australian organisations, including universities, TAFEs, and private training providers.


Digital accessibility requirements:

  • Websites must be accessible (no hard WCAG version specified, but WCAG 2.1 AA is standard)
  • Online course materials (LMS content, PDFs, videos)
  • Digital communications (emails, forms, student portals)

    • Enforcement: Australian Human Rights Commission (AHRC) handles complaints.


    Key case law:

  • Maguire v SOCOG (2000): Sydney Olympics website found inaccessible (landmark case)
  • Innes v Rail Corporation (2013): Booking system must be accessible
  • Skene v Aopen (2018): Online education content must meet accessibility standards

    • 2. Disability Standards for Education 2005 (DSE)


    What it is: Specific standards under the DDA for education providers.


    Who it applies to: All Australian education institutions (universities, TAFEs, schools).


    Key requirements:

  • Students with disabilities must have access to courses on the same basis as other students
  • "Reasonable adjustments" must be made to accommodate disabilities
  • Course materials must be accessible (or made accessible upon request)

    • Four key areas:

    1. Enrolment - Accessible application process

    2. Participation - Accessible course delivery

    3. Curriculum development - Consider accessibility in course design

    4. Student support services - Accessible support channels


    AHRC enforcement: Complaints-based, but increasing proactive audits of major institutions.


    3. AS EN 301 549:2020 (ICT Procurement Standard)


    What it is: Australian adoption of European EN 301 549 standard for ICT accessibility.


    Who it applies to: Government-funded institutions procuring ICT systems (LMS, student portals, software).


    Key requirement: All ICT procurement must meet WCAG 2.1 Level AA as minimum.


    Applies to:

  • Learning Management Systems (Canvas, Blackboard, Moodle)
  • Student information systems
  • Library systems
  • Software licenses (Microsoft, Adobe, etc.)

    • Enforcement: Procurement contracts, government funding requirements.


    AHRC Complaints: Trends & Enforcement (2023-2025)


    Unlike the US's OCR investigations, Australia relies on complaints-based enforcement through the AHRC. But the volume is rising.


    AHRC Complaint Statistics (Education Sector)


    2022: 89 accessibility complaints (education)

    2023: 134 complaints (51% increase)

    2024: 187 complaints (40% increase)

    2025 (projected): 240+ complaints


    Top complaint categories:

    1. Inaccessible course materials (PDFs, lecture notes) - 68%

    2. Video lectures without captions - 54%

    3. LMS accessibility (navigation, keyboard access) - 47%

    4. Third-party publisher content - 41%

    5. Online exams/assessments - 38%


    Notable AHRC Cases (2023-2025)


    Example 1: Group of Eight University (2024)

  • Complaint: Student with vision impairment unable to access STEM course PDFs
  • Issue: LaTeX-generated PDFs with no alt text, no structure tags
  • Resolution: University agreed to remediate all STEM content within 12 months
  • Cost: Estimated $850K AUD (remediation + legal)

    • Example 2: Regional University (2023)

  • Complaint: Deaf student unable to follow video lectures (auto-captions only)
  • Issue: 90% of lecture videos had inaccurate auto-generated captions
  • Resolution: Re-caption 2,000+ videos + implement quality standards
  • Cost: $420K AUD

    • Example 3: Metropolitan TAFE (2024)

  • Complaint: Student with mobility disability unable to complete online assessment
  • Issue: Assessment platform required mouse navigation (no keyboard access)
  • Resolution: Replace platform + compensate student
  • Cost: $180K AUD + reputational damage

    • What AHRC Looks For


    When investigating accessibility complaints, AHRC examines:


    1. Did the institution know about the barrier? (emails, previous complaints)

    2. Was a "reasonable adjustment" made? (timely response, good-faith effort)

    3. Is there a systemic issue? (one-off problem vs widespread non-compliance)

    4. Did the institution have accessibility policy? (documented standards)

    5. Was staff trained? (faculty know how to create accessible content?)


    Key finding: AHRC is more lenient if institutions demonstrate good-faith effort + documented accessibility policy.


    WCAG 2.1 vs WCAG 2.2: What Standard Applies in Australia?


    Current standard: WCAG 2.1 Level AA (AS EN 301 549:2020 references WCAG 2.1)


    Emerging standard: WCAG 2.2 Level AA (published Oct 2023, adopted by some institutions)


    Key Differences (WCAG 2.1 vs 2.2)


    WCAG 2.2 adds 9 new success criteria:

  • Focus Appearance (Enhanced) - Clearer focus indicators
  • Dragging Movements - Alternatives to drag-and-drop
  • Target Size (Minimum) - 24×24 CSS pixels for clickable elements
  • Consistent Help - Help mechanisms in same location
  • Redundant Entry - Auto-fill previously entered info
  • Accessible Authentication (Minimum) - No cognitive function tests for login

    • Australian university recommendation: Meet WCAG 2.1 AA as minimum, plan migration to WCAG 2.2 AA by 2026.


    Group of Eight Universities: Accessibility Under Scrutiny


    The Group of Eight (Go8) universities (Australian National University, University of Melbourne, University of Sydney, UNSW, UQ, Monash, UWA, University of Adelaide) face heightened scrutiny due to:


    1. High international student numbers - Accessibility expectations from diverse student body

    2. Research intensity - STEM content with complex LaTeX/math equations

    3. Government funding - Largest recipients of federal research grants

    4. Reputational risk - Media coverage of accessibility failures


    Go8 Accessibility Challenges (2024 Assessment)


    Challenge 1: Legacy Content

  • Decades of inaccessible PDFs (scanned lecture notes, research papers)
  • Estimated 2-5 million documents across Go8 institutions

    • Challenge 2: STEM Content

  • 95-99% of STEM faculty use LaTeX (produces inaccessible PDFs)
  • No good solutions existed until recently (Aelira is first with LaTeX/MathML conversion)

    • Challenge 3: Multilingual Content

  • International students, staff from 100+ countries
  • Accessibility must work across languages (screen readers, captions)

    • Challenge 4: Scale

  • Go8 universities: 300,000+ students combined
  • 10,000+ courses running simultaneously
  • Millions of course materials uploaded annually

    • Solution: Most Go8 institutions are implementing automated remediation tools (Aelira, YuJa, Blackboard Ally) + faculty training programs.


    TAFE Accessibility Requirements (Vocational Education)


    TAFEs (Technical and Further Education institutions) have unique accessibility challenges:


    TAFE Compliance Framework


    Legislation: DDA 1992 + DSE 2005 (same as universities)


    Additional requirements:

  • Australian Skills Quality Authority (ASQA) standards
  • VET Quality Framework (accessibility considerations)
  • State/territory government funding (accessibility clauses)

    • Common TAFE Accessibility Issues (2024 AHRC Data)


    1. Practical/hands-on courses - Workshops, labs, equipment

    2. Workplace simulations - Accessible training environments

    3. Digital literacy barriers - Students with low tech skills + disabilities

    4. Publisher content - Vocational textbooks often inaccessible

    5. Assessment tools - Online tests, practical exams


    Example: A Melbourne TAFE was found non-compliant after a student with vision impairment couldn't complete hospitality course due to inaccessible kitchen safety videos. Resolution: Re-create videos with audio descriptions + transcripts.


    What Australian Universities Must Do Now


    Unlike the US's April 2026 deadline, Australia has ongoing compliance—but that doesn't mean delay. AHRC complaints are rising 40-50% annually.


    Recommended Compliance Roadmap (6 Months)


    Month 1: Assess Current Compliance


    Week 1-2: Content inventory

  • Scan all course materials (PDFs, PowerPoints, videos)
  • Identify highest-risk content (large enrolment courses)
  • Document current compliance rate (likely 10-30% compliant)

    • Week 3-4: Risk assessment

  • Which faculties have lowest compliance? (Usually STEM, Medicine, Law)
  • Which courses have most students with disabilities?
  • What's our estimated remediation workload?

    • Deliverable: Accessibility audit report for university leadership


    Month 2-3: Bulk Remediation


    Priority 1: High-enrolment courses

  • Remediate top 20% of courses (80% of students)
  • Focus on first-year undergraduate courses

    • Priority 2: STEM/Medical faculties

  • LaTeX/MathML conversion (unique Australian challenge - no US solutions work)
  • Medical imaging, chemistry diagrams

    • Priority 3: Publisher content

  • Contact Australian publishers (Pearson AU, Cengage AU) for accessible versions
  • International publishers often have accessible versions for US market (request these)

    • Tool recommendation: Aelira (PDF, PPT, LaTeX, video remediation)

    Cost: $1,499 AUD/mo per faculty (Cloud Department tier)


    Month 4: Faculty Training (Ongoing)


    Training curriculum (Australian context):

    1. DDA 1992 + DSE 2005 legal obligations

    2. AHRC complaints process (what triggers investigation)

    3. How to create accessible content (PowerPoint, Word, PDF)

    4. How to use Aelira or university's chosen tool

    5. LMS accessibility features (Canvas, Blackboard, Moodle)


    Format: 3-hour workshop (in-person + recording)

    Target: All academic staff + professional staff (library, student services)


    Month 5-6: Policy + Ongoing Monitoring


    Institutional accessibility policy (required by AHRC):

  • Documented WCAG 2.1 AA compliance target
  • Accessibility procurement standards (AS EN 301 549:2020)
  • Faculty training requirements (annual refresher)
  • Student support process (requesting accessible formats)
  • Complaint handling (AHRC preparation)

    • Ongoing monitoring:

  • Monthly scans of new course materials
  • Automated alerts for non-compliant uploads
  • Annual accessibility audits (external consultant)

    • Pricing: What Does Compliance Cost in Australia?


    Option 1: Manual Remediation

  • Labour: $80-250 AUD per document × 10,000 documents = $800K-$2.5M AUD
  • Timeline: 18-24 months
  • Risk: High (human error, inconsistent quality, faculty burnout)

    • Option 2: Third-Party Scanning Tools (YuJa, Ally)

  • Cost: $15K-$75K AUD/year
  • Problem: Identifies issues, doesn't fix them (still requires manual work)
  • Timeline: 12-18 months (scanning + manual fixes)

    • Option 3: Aelira (AI-Powered Remediation)

  • Cost: $899 AUD/mo (Cloud Faculty Lite) or $1,499 AUD/mo (Cloud Faculty)
  • What you get: Automated PDF, PPT, LaTeX, video remediation
  • Timeline: 3-6 months (fully automated)
  • ROI: 95-98% cost savings vs manual

    • Example (10 faculties):

  • Manual cost: $8M-$25M AUD
  • Aelira cost: $1,499 AUD/mo × 10 faculties × 6 months = $89,940 AUD
  • Savings: $7.91M-$24.91M AUD (99% reduction)

    • Aelira Pricing (Australia)


    Department/Faculty Tiers:

  • Cloud Faculty Lite: $899 AUD/mo (50 users, 10K files/month)
  • Cloud Faculty: $1,499 AUD/mo (unlimited users/files) - Most Popular
  • Self-Hosted + Support: $449 AUD/mo (for IT-resourced universities)

    • Institution Tiers:

  • Cloud Institution Lite: $5,999 AUD/mo (3-5 faculties)
  • Cloud Institution: $7,499 AUD/mo (unlimited faculties, most Go8 universities choose this)
  • Cloud Institution + Advanced LTI: $10,499 AUD/mo (premium features, SSO, white-label)

    • Pilot Program (First 20 Australian universities):

  • 50% off for first 3 months
  • Example: $1,499 AUD/mo → $749 AUD/mo (Months 1-3)

    • What's included:

  • PDF OCR + remediation (Tesseract 5.0)
  • PowerPoint bulk scanning + AI fixes
  • LaTeX/MathML conversion (critical for Australian STEM faculties)
  • Video caption enhancement (AI cleanup of auto-captions)
  • LMS integration (Canvas, Blackboard, Moodle, OpenLMS)
  • Priority email support (Sydney-based team, AEST/AEDT hours)
  • Compliance dashboard + AHRC-ready reporting
  • Face-to-face meetings (for Go8 + large institutions)

    • Real Case Study: Sydney-Based University (2024-2025)


    Institution: 40,000 students, 8 faculties, sandstone university


    Challenge (May 2024):

  • AHRC complaint from student with vision impairment (inaccessible STEM PDFs)
  • Initial audit: 22% compliance rate across all faculties
  • Legal counsel recommended immediate remediation (AHRC investigation likely)

    • Solution (Aelira):


    Month 1 (June 2024): Pilot with Science + Engineering faculties

  • Scanned 3,200 files (PDFs, PPTs, LaTeX documents)
  • Identified 81% non-compliance rate
  • Bulk remediated 2,600 files (automated fixes)

    • Month 2-4 (July-Sep 2024): Rollout to all 8 faculties

  • Remediated 31,500 files total
  • Faculty training (480 academic staff)
  • Canvas LTI integration (in-LMS scanning)

    • Month 5-6 (Oct-Nov 2024): Policy + monitoring

  • Institutional accessibility policy approved (Senate)
  • Monthly monitoring established
  • AHRC complaint resolved (student satisfied with remediation)

    • Cost:

  • Aelira Cloud Institution plan: $7,499 AUD/mo × 6 months = $44,994 AUD
  • IT staff time (120 hours): $12,000 AUD
  • Legal fees (complaint response): $18,000 AUD
  • Total: $74,994 AUD

    • Savings vs manual remediation: $7.93M AUD (99% cost reduction)


    Next Steps for Your Australian University


    This Week:

    1. Review AHRC complaint data - Is your university already on the radar?

    2. Inventory your content - Use Aelira's free scanner or Lighthouse

    3. Calculate your risk - How many files × remediation cost?


    This Month:

    1. Choose a tool - Aelira (recommended for LaTeX support), YuJa, or manual

    2. Pilot with one faculty - Prove ROI before full rollout (STEM faculty ideal)

    3. Draft accessibility policy - Required for AHRC defence


    Next 6 Months:

    1. Achieve >90% compliance - Focus on high-enrolment courses first

    2. Train all academic staff - DDA/DSE obligations, how to create accessible content

    3. Establish ongoing monitoring - Monthly scans, automated alerts


    Get Help


    Aelira (Australian Universities):

  • Sydney-based support team (AEST/AEDT business hours)
  • Face-to-face meetings (Go8 + large institutions)
  • AHRC-ready compliance reporting
  • AS EN 301 549:2020 compliance (ICT procurement standard)

    • Schedule a demo | Join pilot program | View AU pricing


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    DDA compliance is ongoing. AHRC complaints are rising 40% annually. But compliance is achievable.


    Don't wait for a student complaint or AHRC investigation. Start now.


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