The verdict in three sentences
A community housing provider managing 12,000 homes in Sydney is exposed to complaints under the Disability Discrimination Act 1992 if its website excludes tenants with disabilities, and WCAG 2.2 level AA is the benchmark the Australian Human Rights Commission and government funders refer to. A WCAG audit on a sample of 20 pages costs in 2026 roughly 4,500 to 8,000 AUD, and remediation 8,000 to 25,000 AUD depending on the site's condition, whose initial conformance typically sits between 40 and 60%. The right order is simple: audit, publish an honest accessibility statement, fix priority tenant journeys, then re-audit.
What the obligation means in practice for a housing provider
WCAG 2.2 contains 86 success criteria, 55 of which apply at levels A and AA. For a social landlord, the most exposed journeys are tenant ones: housing application, rent payment, repair request, downloading a rent statement. Many tenants are older or living with a disability, which makes the issue very concrete.
| Requirement | Expected content | Risk if missing |
|---|---|---|
| Accessibility statement | Conformance level, known issues, contact | Weak position in a DDA complaint |
| Footer link | Accessibility page reachable from every page | Tenant complaints |
| Multi-year roadmap | 3-year strategy, published or shared with funders | Funding and regulatory scrutiny |
| Annual action plan | Fixes and training planned for the year | Weak evidence of reasonable steps |
| Accessible contact channel | Form or email to report a barrier | Escalation to the AHRC |
| Complaint pathway | Link to the Australian Human Rights Commission | Incomplete statement |
Cost of the audit and remediation in 2026
Estimates on the Australian market from specialist accessibility consultancies and web agencies, for a housing provider site of about 150 pages.
| Item | 2026 range (AUD) | Detail |
|---|---|---|
| Initial WCAG 2.2 audit on 20 pages | 4,500 to 8,000 | Criteria A and AA, detailed report |
| Statement and roadmap drafting | 1,200 to 2,300 | Statement, 3-year roadmap, annual plan |
| Template technical fixes | 4,500 to 12,000 | Contrast, keyboard navigation, headings, ARIA |
| Tenant form fixes | 2,300 to 6,000 | Labels, errors, input help |
| PDF remediation (statements, guides) | 800 to 4,500 | Depending on document volume |
| Remediation total | 8,000 to 25,000 | Excluding redesign |
| Verification audit | 2,300 to 3,800 | Measures the new rate |
| Content editor training (1 day) | 1,400 to 2,300 | Accessible writing and publishing |
| Common failure | Share of sites affected (estimate) | Fix effort |
| Insufficient colour contrast | 80% | Low, on the brand palette |
| Images without meaningful alt text | 75% | Low to medium, content |
| Forms without associated labels | 65% | Medium, development |
| Keyboard navigation impossible (menus, modals) | 55% | Medium to high |
| Inconsistent heading structure | 70% | Low, templates |
| Untagged PDFs | 85% | High if many documents |
Planning over three years without blowing the budget
Most providers start at 40 to 60%. Aiming for 100% in one go is expensive; a realistic roadmap spreads the effort. Year 1: audit, statement, template and tenant form fixes, reaching 75 to 85%. Year 2: PDF documents, editorial content, team training. Year 3: verification audit and accessibility built into every new development, especially the tenant portal.
Mini case study
James, communications director of a 12,000-home housing provider in Sydney (illustrative persona), starts from an audit at 52% conformance. He budgets 6,000 AUD for the audit, 1,800 AUD for the statement and roadmap, 14,000 AUD of fixes in year one, then 3,000 AUD for a verification audit: 24,800 AUD in total, about 2.07 AUD per home. Compared with the legal costs and reputational damage of a single conciliated DDA complaint, often tens of thousands of dollars, the investment is modest, before counting fewer calls to customer service once the repair request form works for everyone.
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FAQ
Can we publish a statement if the site is not compliant?
Yes, and it is expected: the statement shows the real level, for example partially conformant at 52%, and lists known issues. Having no statement and no plan is the weak position, not an honest low score with a roadmap.
How many pages should be audited?
A representative sample of 15 to 25 pages is usually enough, including home, contact, tenant journeys and forms. A 20-page audit costs 4,500 to 8,000 AUD.
Do we need to rebuild the site to comply?
Not necessarily: fixing templates and forms often gains 20 to 30 conformance points. A rebuild is justified if the CMS cannot produce compliant code.
Are PDFs in scope?
Yes, rent statements, tenant guides and downloadable reports must be accessible or have an alternative. It is often the longest item, 800 to 4,500 AUD depending on volume.
What is new in WCAG 2.2 compared with 2.1?
WCAG 2.2 adds 9 success criteria, including minimum target size, focus not obscured and accessible authentication. A site conformant with 2.2 AA also meets 2.1 AA.
Let's scope your project. Send us your website address and compliance deadlines to receive a WCAG audit scope, an indicative remediation budget and a 3-year roadmap. Detailed quote within 48 h. WhatsApp +221 77 596 93 33.
Mohamed Bah
Fondateur, Kolonell
Passionate about digital and entrepreneurship in Africa, Mohamed has been helping Sénégalese businesses with their digital transformation since 2020. Founder of Kolonell, he believes every SME deserves a professional and accessible online présence.
