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Website accessibility obligations for Australian design practices

The Disability Discrimination Act 1992 applies to websites, and the Australian Human Rights Commission points to WCAG 2.1 Level AA. Image-led portfolio sites are the most exposed.

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Accessibility is usually filed under public sector compliance, which is why most private design studios have never looked at it. That filing is wrong. The Disability Discrimination Act 1992 is Commonwealth law applying to the provision of goods, services and facilities, and the Australian Human Rights Commission has long taken the position that this extends to the web.

The Commission's advisory notes on web access point to the Web Content Accessibility Guidelines, with Level AA of WCAG 2.1 as the working benchmark. Government bodies are held to it directly. Private businesses are not exempt from the underlying obligation simply because no one has raised it with them.

Why design portfolios are unusually exposed

The aesthetic conventions of this industry work against accessibility more than almost any other sector's. The features that make a studio site look considered are frequently the ones that make it unusable:

  • Low-contrast typography. Light grey on white is the house style of the entire profession, and it routinely fails the contrast ratios in WCAG.

  • Images carrying all the information. A portfolio is a wall of pictures. Without alt text, a screen reader announces nothing — or reads out a filename.

  • Text baked into images. Project titles set inside a JPEG cannot be resized, recoloured, translated or read aloud. They are also invisible to search engines.

  • Custom galleries and lightboxes. Bespoke interactions frequently cannot be operated by keyboard, and trap focus once opened.

  • Scroll-driven animation. Content that only appears on scroll can be unreachable, and motion can be actively harmful for vestibular disorders. WCAG expects reduced-motion preferences to be respected.

  • Video without captions. Studio films and walkthroughs need captions, and any information carried only in the visuals needs an equivalent.

Where to start, in order of return

  1. Colour contrast. Usually the largest number of failures and the cheapest to fix — it is a decision in the design tokens, not a rebuild.

  2. Alt text on every meaningful image. Describe the project and what matters about it. Decorative images should be marked as decorative rather than given filler text.

  3. Keyboard operation. Put the mouse away and try to complete an enquiry form. Everything must be reachable, focus must be visible, and it must not get stuck.

  4. Heading structure. One H1 per page, headings in order, describing the content rather than chosen for their size.

  5. Forms. Real labels on every field, errors described in text rather than by colour alone, and error messages that say what to do.

  6. Captions on video. Automatic captions edited for accuracy are acceptable. Unedited automatic captions frequently are not.

The overlap with search performance is not a coincidence

Search engines and assistive technology parse a page in structurally similar ways: both rely on the document outline, both read alt text, both need text to be text.

So the accessibility fixes above are, almost item for item, technical SEO fixes. Alt text gives image search something to index. Heading hierarchy tells a crawler what the page is about. Text that is genuinely text is text that can rank. A studio that does this work is not choosing between compliance and visibility — it is buying both with the same effort.

If the only description of your best project is burned into a JPEG, then neither a screen reader nor a search engine knows the project exists.

Automated testing finds some of it

Automated tools catch contrast failures, missing alt attributes and missing form labels reliably, and they are worth running in your build. But they cannot judge whether alt text is meaningful, whether focus order makes sense, or whether a custom gallery is genuinely operable.

Keyboard-only navigation of your own site is the single most informative test available, it costs nothing, and most studios have never performed it.

Commercial and public tender implications

Practices pursuing government or institutional work should note that accessibility requirements frequently appear in procurement. Being able to state a WCAG conformance target, and to show that the studio's own website meets it, is a credibility question as much as a compliance one — an inaccessible website is a poor argument for a practice claiming to design for people.

This article is general information, not legal advice. The Australian Human Rights Commission publishes advisory notes on web access, and the W3C publishes the guidelines themselves.

Sources

  1. Disability Discrimination Act 1992 (Cth)Australian Government
  2. World Wide Web Access: Disability Discrimination Act Advisory NotesAustralian Human Rights Commission
  3. Web Content Accessibility Guidelines (WCAG) 2.1World Wide Web Consortium (W3C)
AccessibilityWCAGWeb standards