WCAG accessibility requirements for Australian not-for-profits
Australian charities have legal obligations around website accessibility. This guide explains what those obligations are, what WCAG 2.1 AA requires in plain English, and what to do if your site does not currently meet the standard.
The legal obligations
Website accessibility for Australian not-for-profits is not a courtesy — it is a legal requirement. Under the Disability Discrimination Act 1992 (DDA), organisations have an obligation to ensure their services are reasonably accessible to people with disability. Digital services, including websites, are covered by this obligation.
The Australian Human Rights Commission has confirmed that the DDA applies to websites. Any person in Australia can lodge a formal complaint at no cost. If a complaint proceeds, the organisation may face remediation orders, compensation requirements, and legal costs.
For not-for-profits serving vulnerable communities — particularly community legal centres, mental health services, disability support organisations, and aged care providers — the duty of care is particularly strong. Your website is often the first point of contact. An inaccessible website can prevent the people you exist to serve from finding you.
Federal government agencies are required to meet WCAG 2.1 AA under the Digital Service Standard. While this specific standard does not directly bind private organisations, it sets the baseline for what “reasonable accessibility” means in practice — and courts and the Human Rights Commission use it as a reference point.
What WCAG 2.1 AA actually means
WCAG — the Web Content Accessibility Guidelines — is an internationally recognised technical standard developed by the W3C. Version 2.1, Level AA is the current accepted benchmark for Australian websites.
It is built around four core principles. Content must be:
Perceivable
Information must be presentable to users in ways they can perceive — including people who cannot see, hear, or distinguish colours.
Operable
All functionality must be operable without requiring a mouse — keyboard navigation, voice control, and switch access must all work.
Understandable
Content and navigation must be understandable — clear language, predictable behaviour, and helpful error messages.
Robust
Content must be robust enough to be reliably interpreted by assistive technologies, including screen readers and voice software.
In practical terms, meeting WCAG 2.1 AA means your website can be used by people who rely on screen readers, keyboard navigation only, high-contrast display settings, captions for video content, and other assistive technologies.
The most common accessibility failures on nonprofit websites
These are the issues found most frequently when auditing community organisation and charity websites in Australia.
Images without alternative text
Every meaningful image on a website needs descriptive alt text so that screen reader users can understand what it conveys. Decorative images should have empty alt attributes so screen readers skip them. This is one of the most pervasive failures — and one of the easiest to fix.
Insufficient colour contrast
WCAG 2.1 AA requires a contrast ratio of at least 4.5:1 for normal text and 3:1 for large text. Many websites use light grey text on white backgrounds, or coloured text on coloured backgrounds, that falls well short of this threshold. People with low vision or colour blindness are disproportionately affected.
Forms without accessible labels
Contact forms, referral forms, and donation forms frequently have fields with placeholder text but no properly associated labels. Screen readers cannot convey what a field is for if the label is missing or incorrectly associated.
Keyboard traps and missing focus indicators
Many website components — modal dialogues, dropdown menus, interactive maps — trap keyboard users or fail to show a visible focus indicator. A keyboard user who cannot see where focus is cannot navigate the site.
Videos without captions
Any pre-recorded video with speech or meaningful audio requires captions. Auto-generated captions from YouTube do not reliably meet the accuracy standard required.
Incorrect heading structure
Screen reader users navigate pages by heading. A page that skips from H1 to H4, or uses headings for visual styling rather than semantic structure, is very difficult to navigate.
- Missing or unhelpful alt text on images
- Text contrast below 4.5:1 ratio
- Form fields without properly associated labels
- No visible keyboard focus indicator
- Video content without captions or transcripts
- Broken heading hierarchy (H1, H2, H3 out of sequence)
- Links that say “click here” or “read more” without context
- PDFs that are not tagged for screen reader access
How to test your website’s accessibility
A meaningful accessibility assessment requires both automated tools and manual testing. Automated tools alone catch approximately 30–40% of WCAG failures — the rest require human review.
Automated tools (free)
- WAVE (wave.webaim.org) — browser-based tool that highlights errors and warnings directly on the page
- Axe — browser extension for Chrome and Firefox, widely used by developers
- Google Lighthouse — built into Chrome DevTools, includes an accessibility score
- Colour Contrast Analyser — desktop tool from TPGi for checking contrast ratios
Manual checks you can do now
- Tab through your entire website using only a keyboard — can you reach everything?
- Turn off your monitor and try to navigate using a screen reader (NVDA for Windows is free; VoiceOver is built into Mac and iPhone)
- Zoom your browser to 200% — does the layout break or does text overflow?
- Check that every form field has a visible, accurate label
- Review your heading structure — does it flow logically from H1 through H2 and H3?
- Try our free Accessibility Audit tool Check Your Website’s Accessibility
Marzipan’s Digital Capacity Diagnosis includes an accessibility assessment as one of its six core areas. It covers automated testing, manual review of common failure points, and a plain-English summary of issues with a prioritised remediation plan. Learn more.
What remediation involves
The approach to fixing accessibility issues depends on their nature and severity. Some can be resolved quickly by whoever manages your website content; others require developer involvement.
Content-level fixes (no developer needed)
- Adding alt text to existing images
- Correcting heading structure in page content
- Replacing non-descriptive link text (“click here”) with meaningful descriptions
- Adding transcripts to audio content
Template and theme-level fixes (developer required)
- Correcting colour contrast in CSS
- Adding visible focus indicators to interactive elements
- Fixing form label associations
- Resolving keyboard trap issues in navigation components
- Adding ARIA roles and landmarks to improve screen reader navigation
For organisations with older websites, remediation is sometimes more cost-effective as part of a broader rebuild. For newer sites, targeted fixes are usually sufficient. A proper assessment is the most useful first step — without one, it is difficult to prioritise.
Accessibility as ongoing practice
Accessibility is not a project that ends. A website that passes an audit today can develop regressions within months — when a new plugin is installed, a template is updated, or a content editor adds images without alt text.
Organisations that treat accessibility as a one-time remediation exercise consistently find themselves with recurring issues. The most effective approach is to embed accessibility into ongoing website governance: regular automated scans, periodic manual reviews, and training for anyone who adds content to the site.
For not-for-profits without an in-house digital team, this is one of the areas where digital stewardship adds the most consistent value — handling ongoing monitoring and catching regressions before they become complaints.
Not sure where your site stands?
A Digital Capacity Diagnosis includes a plain-English accessibility assessment — what the issues are, how serious they are, and what to do about them. $1,500 + GST.
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