The legal framework in brief
The Australian Human Rights Commission published its Guidelines on equal access to digital goods and services in April 2025, updating its 2014 advisory note on web access [1]. The Commission says the guidelines are issued under section 67(1)(k) of the Disability Discrimination Act to help organisations meet their obligations, that they are not legally binding, and that they should be read alongside the Act and state and territory anti-discrimination laws [1].
On standards, the Commission does not lock organisations to one version. It identifies WCAG as the applicable international standard and advises that "it is important to meet the requirements of the latest published version" [1]. The latest published version is WCAG 2.2 [2]. The Commission describes the standards it lists as the minimum organisations should aim for [1].
The case everyone cites
Website accessibility has been tested under the DDA before. In Maguire v SOCOG, Bruce Maguire, who is blind and uses a refreshable braille display, complained to what was then the Human Rights and Equal Opportunity Commission about the official Sydney 2000 Olympic Games website. The W3C's case study records that images lacked text alternatives, a key index page could not be reached from the schedule page, and results tables were not available in an accessible form; the Commission found the site discriminatory and ordered $20,000 in damages [3]. It was a large organisation and a famous event, but the barriers involved are the ones still found on small business sites today.
What WCAG 2.2 added
WCAG 2.2 builds on 2.1. Digital NSW lists the new success criteria [4]. The Level A and AA ones, which are within the AA target most organisations use, are:
| Criterion | Level | In plain terms |
|---|---|---|
| 2.4.11 Focus Not Obscured (Minimum) | AA | The item a keyboard user is on is not hidden behind a sticky header or cookie banner |
| 2.5.7 Dragging Movements | AA | Anything done by dragging can also be done with a single click or tap |
| 2.5.8 Target Size (Minimum) | AA | Buttons and links are large enough, or spaced enough, to tap reliably |
| 3.2.6 Consistent Help | A | Help options such as phone and contact links appear in the same place on each page |
| 3.3.7 Redundant Entry | A | People are not asked to type the same information twice in one process |
| 3.3.8 Accessible Authentication (Minimum) | AA | Logins do not rely on memory or puzzle tests without an alternative |
The checks that matter most on a firm website
Text and contrast
Body text and button labels need a contrast ratio of at least 4.5:1 against their background, and large text at least 3:1, under success criterion 1.4.3 [2]. Gold or bronze text on cream can fail, so measure it rather than judging by eye. Check every colour pairing in the design, not just the main text.
Headings and structure
One H1 per page, then H2 and H3 in order. Screen reader users jump between headings to find the part of a practice area page they need.
Forms
Every field needs a visible label, errors need to say what went wrong next to the field, and required fields must be marked in text. Avoid puzzle-style CAPTCHAs; a hidden honeypot field and rate limits stop most spam without blocking anyone.
Keyboard use
Every link, button, menu and accordion must work with a keyboard, with a visible focus outline. Test mobile menus and FAQ accordions in particular, because they rely on scripts.
Images and video
Meaningful images need text alternatives that say what matters about them; decorative images should be hidden from screen readers. Video needs captions, and an introductory video from a partner needs a transcript.
Documents
PDFs of fee guides, checklists or newsletters can be hard or impossible to read with assistive technology unless they are properly tagged. Publish the content as a web page where you can, and make any PDF properly tagged.
Tap targets and zoom
Text should resize to 200 per cent without content or function being lost (criterion 1.4.4) [2], and tap targets should meet the WCAG 2.2 minimum size [4].
The office itself
Website accessibility is about the website, but readers with disability also want to know whether they can get into your office. Add a short access note to each office or contact page: step-free entry, lifts, accessible parking nearby, and whether you can meet by phone or video instead.
Publishing an accessibility statement
An accessibility statement tells readers what standard you aim for, what you know does not yet meet it, and how to contact the firm if something is a barrier. It also signals that you take the issue seriously. Keep it honest: say "we aim to meet WCAG 2.2 Level AA" rather than claiming full conformance you have not tested.
Testing without a big budget
- Run each page template through an automated checker. Automated tools catch only some issues, but they are a quick start.
- Use the whole site with a keyboard only.
- Try the main pages with a screen reader: VoiceOver on Mac and iPhone, or NVDA on Windows, which is free.
- Zoom to 200 per cent and check nothing breaks.
- Ask someone who uses assistive technology to try your enquiry form, and pay them for their time.
Questions people ask
Is WCAG compliance a legal requirement for Australian law firms?
There is no single law that says "meet WCAG". The Disability Discrimination Act prohibits disability discrimination in providing services, and the Human Rights Commission's guidelines, which are not legally binding, advise meeting the latest version of WCAG as the way to show equal access.
Which WCAG level should a law firm aim for?
Level AA of WCAG 2.2 is the practical target. It includes the Level A criteria and covers the barriers people meet most often.
Do accessibility overlay tools fix a website?
Overlays that add a toolbar or claim to fix a site automatically do not replace accessible design and code. Fixing the underlying templates is the reliable approach.
Sources
Checked on 29 October 2026. Labels show what kind of source each one is.
- Regulator Guidelines on equal access to digital goods and services, Australian Human Rights Commission. April 2025.
- Standards body Web Content Accessibility Guidelines (WCAG) 2.2, W3C.
- Standards body Sydney Olympics Website: A Cautionary Tale of Inaccessibility, W3C Web Accessibility Initiative. Archived case study.
- Government WCAG 2.2 is finally here: Here's what you need to know, Digital NSW. 20 October 2023.