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Checklist · Accessibility

The website accessibility checklist for Australian small businesses.

What the Disability Discrimination Act and WCAG 2.2 AA mean for a small business website, the checks you can run yourself in an hour, and the free tools that find most problems. General information, not legal advice.

Go to the checklistFree testing tools

Written by Rifat Hasan Rafi, founder of SIX9 Design · Last reviewed 13 October 2026

The rules

What the Act, the advisory notes and WCAG each do

Three things get mixed up. One is law, one is the Commission's guidance on the law, and one is a technical standard.

What it isWhat it saysWhat it means for you
Disability Discrimination Act 1992Unlawful to discriminate against a person with disability in providing goods, services and facilitiesYour website is part of how you provide a service, so it is covered; complaints go to the Human Rights Commission
AHRC web access advisory notesThe Commission's view on how the Act applies online, pointing to WCAG as the benchmarkNot law itself, but what the Commission would weigh in a complaint; last revised 2014 with an update under way
WCAG 2.2, Level AAThe W3C's testable success criteria: perceivable, operable, understandable, robustThe practical checklist to build and test against; Level AA is the usual target

The checklist

Twelve checks for a small business website

Run them on your home page, your main service page and your contact or booking page. Each one maps to WCAG 2.2 AA.

  1. Use the whole site with the keyboard only
    Tab through every page. You should reach every link, button, menu and form field, see where you are at all times, and never get stuck. Keyboard traps and invisible focus are the most common serious failures.
  2. Every meaningful image has alt text
    Describe what the image shows or does, in a sentence. Decorative images get empty alt text so screen readers skip them. Logos say the business name.
  3. Colour contrast passes
    Normal text needs a 4.5:1 contrast ratio against its background, large text 3:1. Light grey on white, and white text on pale brand colours, usually fail.
  4. Headings are real headings, in order
    One H1 per page, then H2 and H3 in a logical outline. Headings made by making text bold and bigger do not count.
  5. Form fields have visible labels
    A label next to every field, not just placeholder text that disappears, and clear error messages that say which field is wrong and why.
  6. Links say where they go
    “Read our pricing” rather than “click here”. Screen-reader users often jump through a list of links out of context.
  7. Text can be resized and the page still works
    Zoom the browser to 200% on a phone and a laptop. Nothing should overlap, disappear or need horizontal scrolling.
  8. Nothing relies on colour alone
    Required fields, errors and chart data need an icon, label or pattern as well as a colour.
  9. Video has captions and audio has a transcript
    Captions for the deaf and hard of hearing, transcripts for anyone; auto-captions need checking.
  10. No content flashes, moves or auto-plays without a pause control
    Carousels, background video and animations need a pause or stop, and nothing should flash more than three times a second.
  11. PDFs and menus are readable, or the content is on the page
    A scanned PDF or a menu as an image is invisible to a screen reader. Put the content on the page as text, or make the PDF tagged and accessible.
  12. Target sizes and focus are usable on a phone
    WCAG 2.2 adds minimum target sizes and visible focus requirements. Tap targets should not be tiny or crowded, and focus should never be hidden behind sticky headers.

Testing

Free tools that find most problems

Automated tools find roughly a third of WCAG issues. The keyboard and a screen reader find the rest.

  • The W3C Easy Checks: a first review anyone can do in an hour, no tools required.
  • Lighthouse in Chrome DevTools: an accessibility score and a list of automated failures per page.
  • The axe DevTools or WAVE browser extensions: more detailed automated checks with the failing element highlighted.
  • A contrast checker for your brand colours before they go on the site.
  • A screen reader you already have: VoiceOver on a Mac or iPhone, Narrator on Windows, TalkBack on Android. Try to book, enquire or buy with your eyes closed.
Overlay widgets and “accessibility” toolbars added with one line of script do not make a site compliant and can make it worse for screen-reader users. The Overlay Fact Sheet explains why. Fix the pages instead.

After launch

What drifts after launch, and who owns it

A site that launches accessible can fail a year later. These are the usual causes.

  1. New images without alt text
    Every photo added through a CMS or a gallery needs a description at the time it is uploaded.
  2. PDF menus, price lists and forms
    Uploading a PDF is faster than updating a page, and it is the most common accessibility regression on small sites.
  3. Embedded widgets
    Booking tools, review carousels and chat bubbles come with their own accessibility, good or bad. Test them in the page, not just the page.
  4. Brand refreshes
    A new colour palette can quietly fail contrast. Check it before it goes live.
  5. Videos without captions
    Social clips re-used on the website need captions on the website too.

Sources

Where this checklist comes from

The law, the Commission's guidance and the W3C standard, with the testing guides this page follows.

Sources

  1. Australian Human Rights Commission — World Wide Web Access: Disability Discrimination Act advisory notes · checked 13 October 2026
  2. Disability Discrimination Act 1992 (Cth) — Federal Register of Legislation · checked 13 October 2026
  3. W3C — Web Content Accessibility Guidelines (WCAG) 2.2 · checked 13 October 2026
  4. W3C Web Accessibility Initiative — Easy Checks: a first review of web accessibility · checked 13 October 2026
  5. Overlay Fact Sheet — why accessibility overlays do not fix a website · checked 13 October 2026
Every SIX9 Design website is designed and tested against WCAG 2.2 AA before launch. We do not issue compliance certificates or legal advice; if you need an independent audit, we can prepare the site for one. See the small business website checklist.

Does the Disability Discrimination Act apply to a small business website in Australia?

Yes, in general. The Disability Discrimination Act 1992 makes it unlawful to discriminate against a person with disability in providing goods, services and facilities, and the Australian Human Rights Commission's advisory notes say that applies to websites and other online services, whatever the size of the business. There is no small-business exemption, although what is reasonable depends on the circumstances.

Is WCAG legally required in Australia?

Not by a specific private-sector law. The Act sets the duty not to discriminate; the Commission's advisory notes point to the W3C's Web Content Accessibility Guidelines as the benchmark for meeting it, and WCAG 2.2 at Level AA is the current version most organisations aim for. Government websites follow WCAG under the Digital Service Standard. The advisory notes were last revised in 2014 and the Commission has said an update is in progress, so check the current version.

Has an Australian business actually been found liable over a website?

Yes. In Maguire v Sydney Organising Committee for the Olympic Games (2000), the Commission found the Sydney 2000 Olympics website discriminated against a blind user because parts of it could not be used with a screen reader, and awarded damages. It remains the case most Australian guidance refers to.

What should an accessibility statement on my website say?

Which standard you aim for (for example WCAG 2.2 AA), what you have tested, any known limitations and how to contact you if someone cannot use part of the site. Keep it honest: a statement that claims full compliance you have not checked is worse than none.

Does an accessible website also help with Google?

Usually, because the same work overlaps: text alternatives for images, real headings, readable text, descriptive links, fast pages that work on a phone. Accessibility is not a ranking factor by name, but the pages that meet it tend to be the pages search engines can read and users stay on.

Do NDIS providers, clinics and aged-care services have extra obligations?

Their customers are more likely to rely on accessibility, and the NDIS Practice Standards and health-sector rules expect accessible information, so the business case is stronger even where the legal duty is the same. Our NDIS provider website checklist covers plain language, Easy Read and the complaints path those providers need.

What does SIX9 Design build in, and what stays my responsibility?

Every website we build is designed and tested against WCAG 2.2 AA: keyboard navigation, colour contrast, text alternatives, headings, form labels, focus states and responsive text, for A$169, A$299 or A$449 once. We do not issue compliance certificates or legal opinions, and content you add after launch, such as images without alt text, PDFs or videos without captions, is yours to keep accessible.

Keep exploring

Related pages

Small business website checklistPages, trust signals, legal basics and launch checksNDIS provider website checklistPlain language, Easy Read, registration wording and complaintsGoogle Business Profile checklistThe free map listing that pairs with your websiteHow to write a service pageHeadings, proof and one next step, in the right orderWeb design MelbourneWebsites built and tested against WCAG 2.2 AAWebsite cost guideBuild, content and running costs explained
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