If you look after a council, state agency or community organisation website in Queensland, the accessibility target is now clear: WCAG 2.2 Level AA. Here’s what changed, which rules actually apply to you, what’s new in WCAG 2.2, and how to find out where your website stands.
The short answer: Queensland councils, agencies and not-for-profits should aim for WCAG 2.2 Level AA. The Australian Human Rights Commission’s 2025 guidelines recommend it as the minimum under the Disability Discrimination Act, and Queensland Government departments must meet the latest version of WCAG at Levels A and AA. Councils aren’t bound by the state’s ICT policies, but they are covered by the Disability Discrimination Act and Queensland’s Human Rights Act.
What is WCAG 2.2?
The Web Content Accessibility Guidelines (WCAG) are the international standard for accessible websites, published by the World Wide Web Consortium (W3C). Version 2.2 became a W3C Recommendation on 5 October 2023, with an updated edition in December 2024. It added nine new success criteria, six of them at Levels A and AA, and removed one (4.1.1 Parsing) that modern browsers had made obsolete.
Importantly, it’s backward compatible. The W3C says content that conforms to WCAG 2.2 also conforms to WCAG 2.1 and 2.0. So if your current target is WCAG 2.1 AA, moving to 2.2 AA means adding six criteria, not starting again.
What changed in 2025
In April 2025 the Australian Human Rights Commission published its Guidelines on equal access to digital goods and services, an update of its long-standing advisory note on web access. On the standard, it’s direct: “Organisations should conform with WCAG 2.2 at a minimum Level AA”.
The guidelines aren’t legally binding on their own. But they set out the Commission’s view of how to meet your obligations under the Disability Discrimination Act 1992, which is the law a complaint would be made under. In practice, WCAG 2.2 AA is now the benchmark your website will be measured against.
Which rules apply to Queensland councils?
There’s no Queensland law that names a WCAG version for councils. Instead, two pieces of legislation do the work.
The Disability Discrimination Act 1992
Section 24 makes it unlawful to discriminate against a person with disability when providing goods or services, “whether for payment or not”. The Act’s definition of services expressly includes services “of the kind provided by a government, a government authority or a local government body”. A council website that lets residents pay rates, report issues, apply for permits or find information is providing a service.
Queensland’s Human Rights Act 2019
Local governments, councillors and council employees are “public entities” under section 9 of the Human Rights Act 2019 (Qld). Section 58 requires public entities to act and make decisions in a way that’s compatible with human rights. Relevant rights include equality before the law (section 15) and the freedom to seek, receive and impart information (section 21). A website that shuts some residents out makes that harder to show.
Queensland Government policy: state agencies, not councils
State departments and statutory bodies must meet the latest version of WCAG at Levels A and AA under the Queensland Government’s Digital services policy, and submit accessibility plans by 31 October each year. If you’ve seen a For Government page that lists WCAG 2.1, it’s an older page. The current guidance, Digital accessibility in Queensland (updated May 2026), says “latest version”, which today means WCAG 2.2.
These policies don’t formally apply to councils. But your residents use state and council services side by side, so the same standard is the sensible target.
What about the federal Digital Experience Policy?
You may have seen the Australian Government’s Digital Inclusion Standard, part of the Digital Experience Policy that took effect on 1 January 2025. It applies to non-corporate Commonwealth entities, not to state or local government. It’s a useful reference, but it isn’t what governs a Queensland council website.
Not-for-profits and community organisations
The Disability Discrimination Act covers you too, because section 24 applies whether or not you charge for a service. If you deliver services on behalf of government, you may also be performing public functions under Queensland’s Human Rights Act.
What’s new in WCAG 2.2: six criteria to check
If your site was built to WCAG 2.1 AA, these are the new Level A and AA requirements to test, and where they usually trip up council and community websites.
- Focus Not Obscured (Minimum), 2.4.11, AA. When someone tabs through a page, the item they’re on can’t be completely hidden behind a sticky header, chat widget or cookie banner.
- Dragging Movements, 2.5.7, AA. Anything that needs dragging, like a map, slider or drag-and-drop upload, needs a simple click or tap alternative.
- Target Size (Minimum), 2.5.8, AA. Buttons and links need to be at least 24 by 24 CSS pixels, or spaced so they’re easy to hit. Social icons, pagination and close buttons are common failures.
- Consistent Help, 3.2.6, A. If you offer help on multiple pages, like a phone number, contact link or chat, keep it in the same place on each page.
- Redundant Entry, 3.3.7, A. In multi-step forms, don’t make people type the same information twice. Fill it in for them or let them select it.
- Accessible Authentication (Minimum), 3.3.8, AA. Signing in can’t depend on remembering or retyping something, or solving a puzzle, without help. Supporting password managers and copy and paste is the usual fix.
Why it matters for your community
In 2022, 5.5 million Australians, or 21.4% of the population, had disability, according to the Australian Bureau of Statistics. The Queensland Government puts the figure at about 1.2 million Queenslanders. Add older residents, people with a temporary injury and anyone using a phone in bright sunlight, and accessibility affects far more of your community than most people expect.
As rates, bins, permits and consultations move online, an inaccessible page doesn’t just look bad. It stops people doing things they’re entitled to do.
How to check where your website stands
- Run an automated check. Our free accessibility compliance check tests any page against the WCAG 2.2 AA checks that can be automated, in about a minute. If it finds failures, that page doesn’t comply.
- Know the limits of automated testing. When the UK Government Digital Service tested ten free tools on a page with 143 known barriers, the best single tool found around 40% of them, and 29% weren’t found by any tool. Deque, which makes the axe testing engine, reports its tool finds 57% of issues by volume. Either way, a lot is left for a person to find.
- Try your site with a keyboard. Put the mouse away and press Tab. Can you reach every link, menu and form? Can you always see where you are?
- Listen to a key page. Turn on VoiceOver (built into Mac and iPhone) or NVDA (free for Windows) and try paying a bill or lodging a request.
- Don’t forget documents. Agendas, minutes, plans and forms published as PDFs need to be accessible too, or available in an accessible format.
- Get a full audit and a plan. A proper WCAG 2.2 AA audit tests your key templates and journeys and gives you a prioritised fix list. Many organisations also publish an accessibility statement explaining what they’ve tested and how people can get help.
Commissioning an audit or a new website?
Write “WCAG 2.2 Level AA” into the brief, and ask suppliers how they test: which tools, which screen readers, and whether they fix the issues or only report them.
On procurement, the Local Government Regulation 2012 thresholds for medium and large contracts rose on 12 December 2025, to $21,000 and $280,000 (excluding GST), and are now indexed each year. Medium-sized contracts generally need written quotes first, unless an exception applies, such as an LGA arrangement like Local Buy or a register of pre-qualified suppliers. Check your council’s procurement policy for the current figures.
Frequently asked questions
Do Queensland councils have to meet WCAG 2.2?
No Queensland law names WCAG 2.2 for councils. But councils are covered by the Disability Discrimination Act, and the Australian Human Rights Commission recommends WCAG 2.2 Level AA as the minimum way to meet it. Councils are also public entities under Queensland’s Human Rights Act. WCAG 2.2 AA is the standard your website would be measured against.
Is WCAG 2.1 still good enough?
WCAG 2.2 builds on 2.1, so a site that meets 2.1 AA is most of the way there. To meet 2.2 AA you need to add six criteria: focus not obscured, dragging movements, target size, consistent help, redundant entry and accessible authentication.
Can an automated tool tell us we’re compliant?
It can tell you when you’re not. If an automated check finds a failure, the page doesn’t meet WCAG 2.2 AA. If it finds none, you still need keyboard, screen reader and document testing by a person before you can say the site complies.
Do PDFs and documents need to be accessible?
Yes, in practice. Documents on your website are part of the information and services people need to use, and WCAG includes specific techniques for accessible PDFs. If a document can’t be made accessible, offer the same information in an accessible format.
Find out where your website stands
Run our free instant accessibility compliance check on any page of your website. For the full picture, IDM’s senior Brisbane team audits your key templates against WCAG 2.2 AA with automated, keyboard and screen reader testing, then fixes the issues. Book a free scoping call or see how we work with councils and government agencies.
Sources
- Australian Human Rights Commission, Guidelines on equal access to digital goods and services (April 2025)
- Disability Discrimination Act 1992 (Cth), sections 4 and 24
- Human Rights Act 2019 (Qld), sections 9, 15, 21 and 58
- Queensland Government, Digital accessibility in Queensland (updated May 2026)
- Digital Transformation Agency, Digital Inclusion Standard: transition approach
- W3C, Web Content Accessibility Guidelines (WCAG) 2.2
- Australian Bureau of Statistics, 5.5 million Australians have disability (July 2024); Queensland Government, Disability statistics
- UK Government Digital Service, What we found when we tested tools on the world’s least-accessible webpage (2017); Deque, Automated testing study (2021)
- Queensland Government, Empowering councils regulation (procurement thresholds)
This article is general information, not legal advice. Sources current as at October 2026.
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