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Accessibility by design: The ACSES Insights report in Disability in Higher Education

The team at ADCET were pleased to see the ACSES Insights Report on Disability in Higher Education, Stage 1, a landmark report that will give critical longitudinal insights into progress of the sector on accessibility by design. The report gives universities a practical view of what students with disability can see before they enter, and while they try to navigate, institutional systems. The inaugural report provides a useful stock take of public information about disability and accessibility, without completing a full audit of each universities internal practice.

At first read, it’s apparent that there is ongoing sector wide systemic access by design issues for a rapidly growing proportion of the student cohort. As the report flags, domestic students with disability increased by 142 per cent between 2014 and 2024, compared with 5 per cent growth across all domestic students.  The report also notes that the profile of disability is changing, with substantial disclosure of mental health, neurological and neurodivergent conditions and profiles.

For universities, it’s fair and safe to suggest shifting the conversation away from individual accommodations and reasonable adjustments as the primary response, and towards the quality of the systems and policy design & implementation students encounter every day. ADCET has been leading initiatives in this space, particularly in the last decade and in this article, we’ll share some of the resources we think will help move the needle upward.

Is it a legal problem, a systems problem, or both?

The report findings don’t necessarily show a direct failure to meet legal obligations to students, but it does contain strong signals of policy and systems failure around accessibility which may leave institutions increasingly exposed to legal challenge. Most universities have identifiable disability services information, and all universities reviewed had policy guidance mediating reasonable adjustments, likely in alignment with meeting their obligations under the Disability Discrimination Act. However, if the ‘front door’ isn’t accessible and you need to ask for it to be fixed in 2026, isn’t this a serious problem?

The signals of procurement, document authorisation and other high-level accessibility by design policy issues are apparent in the report:

  • 16 per cent of universities made a transparent commitment to WCAG 2.2 AA in their web accessibility statements
  • 21 per cent had no critical or serious homepage issues detected by automated testing.
  • Across 118 reviewed cornerstone PDF documents, only 7 per cent met PDF/UA requirements and 3 per cent met WCAG 2.2 AA
  • Disability was referenced on only 7 per cent of main admissions pages and 14 per cent of selected course pages
  • 0% of universities referenced autism and/or neurodivergence on their primary admissions pages or selected courses pages
  • Universal Design for Learning appeared on only 12 per cent of disability services webpages.
  • 0% had high-level policy frameworks that reference disability
  • 23 per cent of published procurement policies and 23 per cent of physical infrastructure policies referenced disability.
  • Curriculum frameworks performed only slightly better, with 21 per cent referencing disability, even though every university had policy guidance on reasonable adjustment.

Overall, this suggests that disability is visible where individual support is managed, but less visible in the documents that shape institutional design.

Shift accessibility upstream into ICT procurement and authorisation workflows

Two of the strongest system levers to fix the issues put forward in ACSES’ report are procurement, and internal approval policies relating to design and release of content (approvals). Once a learning platform, assessment tool, student management system, video platform, library interface or AI-enabled service is bought and embedded, accessibility problems become expensive, slow and politically difficult to fix. Once a document is created and approved, it sits, but if it’s built properly in the first instance and reviewed and remediated periodically, it remains accessible. It’s worth noting that ADCET also grapples with this issue, with two decades of archives, but certainly for new and recently approved content, universities can put in place strict protocols to ensure accessibility.

Universities could make forward steps on this using existing guidance. ADCET’s Accessible ICT Procurement Guide for tertiary education providers is a timely, ready, and useable resource to help move these reports findings upward for the sector in the next iteration. The resource was developed by ADCET, the NDCO Program, Intopia and CAUDIT, and it gives practical guidance for building accessibility into ICT procurement policies, procedures and practice. It includes example policy approaches, contract clauses, testing procedures, guidance on existing software and hardware, and advice on reviewing VPATs and Accessibility Conformance Reports.

Note: The ADCET procurement guide remains valuable as a process and governance resource, but the page still references WCAG 2.1, current at the time of creation. Since then, the Australian Human Rights Commission has released Guidelines on equal access to digital goods and services, and its standards guidance points organisations to WCAG 2.2 where appropriate and to AS EN 301 549:2024 for ICT products and services.

Universities should use the ADCET Accessible ICT Procurement guide to structure procurement practice, while aligning technical requirements with the current AHRC guidance and current versions of relevant standards.

Treat UDL as curriculum governance, not optional interest

The ACSES finding that only 12 per cent of disability services webpages referenced UDL should concern teaching and learning leaders. UDL should not sit only with disability services, nor should it depend on enthusiastic individual teachers, practitioners or leaders. It belongs firmly embedded in curriculum governance, course review, learning design, assessment approval, LMS templates and staff development.

ADCET hosted the inaugural national UDL symposium for the sector in 2023 to get the conversation moving and has since developed resources and advocated for systemic improvement, connecting educators and professionals on the topic. Our Universal Design for Learning hub contains resources, guidance, podcasts, webinars, literature and eLearning to support sector adoption. 

This includes:

  • The free UDL in Tertiary Education eLearning course gives staff a structured entry point and provides access to resources, checklists, templates, learning design material, professional learning and peer conversations. Institutions can also embed the SCORM files into their own systems to track staff completion.
  • The ADCET UDL Studio is a fortnightly 1 hour online drop-in session for those interested in and working with Universal Design for Learning (UDL) to make education more accessible. It is a space to bring real life queries and explore practical solutions to support and foster UDL in Australia.
  • The UDL Resources collection, including Podcasts, Webinars, Checklists and Templates, Case Studies and more.
  • Or why not join us for the ADCET UDL Symposium 2026!

Use ADCET Assist for practical implementation planning

Several ACSES findings point to implementation gaps rather than lack of intent. Staff may accept the need for accessible documents, accessible multimedia, inclusive course design or assistive technology, but still need help turning that expectation into day-to-day practice. This is where ADCET Assist should be promoted more strongly by institutions and their leaders.

ADCET Assist is a free service for educators and disability support staff in Australian tertiary education. It offers one-to-one and small group online sessions on digital accessibility, inclusive teaching and assistive technology. Examples of previous ADCET assist sessions include assistive technology options, generative AI for student learning, AI and assistive technology in supporting neurodivergent students, accessible mathematics and STEM subjects, creating accessible emails, creating inclusive teaching materials, inclusive unit and course design, LMS accessibility, captioning and accessible eLearning resources.

Connect leaders with current sector practice

One of the risks the ADCET team discussed about the sector responding to the ACSES report is that each university tries to solve the same problems alone, redistributing limited local capacity in uncertain staffing environments and deploying uneven internal expertise. ACSES identifies sector-wide issues, so the response should also use sector-wide learning with a focus on a systems response, working together to build solutions once and then share and duplicate.

ADCET runs Communities of Practices designed to connect, engage and inform and share expertise.  The communities are opportunities for tertiary staff with a shared concern or interest to interact regularly, exchange information, and improve knowledge and skills. Current communities include Assistive Technology, Disability Managers (University), Supporting Neurodivergent Students in Tertiary Education, and Universal Design for Learning.

Webinars relevant to the ACSES report

ADCET’s webinar and podcast archive contains recent, relevant information that speak directly to admissions, disability service capability, neurodivergence, accessibility and UDL implementation.