On this page you can read submissions that we have made to Federal and State governments, Senate Inquiries and to other government and non-government agencies to advocate for issues affecting people who are blind or vision impaired.

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Access to Information

Review of Accessibility Strategy for the Royal Commission into Violence, Abuse, Neglect and Exploitation of People with Disability

August 2019

The options provided for people to contribute submissions to the Royal Commission must be flexible. As well as being able to submit electronically, there must also be a dedicated phone line for people to make submissions by phone, as well as to submit by post and in a person’s preferred format. These options must be widely advertised and communicated to both the disability and broader community.

Read more from the review here.

TGA Medicine Labelling and Packaging Review

Clear, accessible information on medication is important for all consumers. For someone who is blind or vision impaired, that clear, accessible information is critical to ensure that the right medication is being taken at the right dosage

Read BCA’s 2012 submission Medicine Labelling and Packaging Review (Word doc).

Aged Care

Royal Commission into Aged Care Quality and Safety (2019) Submission

October 2019

Vision impairment is predicted to become the most prominent health issue within the population of older Australians. People who are blind or vision impaired can live rich and active lives and make meaningful contributions to their communities; however the extent to which people are able to actively and independently participate in community life does rely on facilities, services and systems that are available to the public being designed in a way that makes them inclusive of the needs of all citizens.

Read the full submission.

Submission to The Aging and Disability Commission – Disability Advocacy Review

October 2019

A commitment by government to continue providing advocacy funding is essential to the wellbeing of all people with disabilities. Advocacy is essential not only to prevent instances of blatant discrimination or neglect. It is necessary to highlight issues which are unintentionally overlooked by government, which will inevitably occur. Advocacy services should therefore be funded to provide advocacy in its purest form, and not be expected to couch grant applications in terms which governments feel comfortable with.

Read the full submission here.

Discussion paper: Streamlined Consumer Assessment for Aged Care

February 2019

Based on feedback from previous reviews, from individual member cases, and in line with views from the sector, we made a submission on the Streamlined Consumer Assessment Process for Aged Care in February 2019.

BCA recommends disability being a special needs group in the Aged Care Act, assessments to be holistic and individualised, stronger referral processes in place, and for Assistive Technology to be available independently from the Aged Care system.

Read the submission here (Word doc)

Aged Care Legislative Review

A robust and responsive aged care system is core to the needs of Australians who are blind or vision impaired. According to Vision 2020 Australia, around 80% of vision loss in Australia is caused by conditions that become more common as people age. This raises a number of implications for Australia’s aging population, with one in every four Australians projected to be 65 years of age or older by the year 2056.

BCA asserts that older Australians who are blind or vision impaired, when provided with the appropriate support, can continue to lead full and active lives and make valuable contributions to their communities. To this end, we welcome the opportunity to contribute to the review of Aged Care services in Australia and thank the Aged Care Sector Committee for providing us with this opportunity.

Read our Aged Care Legislative Review Submission here (Word doc 117kb)

Audio Description on Commercial TV

Securing a permanent audio description service for Australians who are blind or vision impaired has remained one of our top priorities for many years now.

Keep up to date with our campaigns for audio description on commercial TV, audio description in cinemas and on DVDs, the digital switchover and all things media access. Read more here.

Banking and Finance

Submission to the Royal Commission into Misconduct in the Banking, Superannuation and Financial Services Industry

Posted: 21 August 2018

BCA’s submission to the Royal Commission into Misconduct in the Banking, Superannuation and Financial Services Industry focuses on two Clauses in particular that hold relevance to the issues faced by people who are blind or vision impaired. These are:

  • Whether any conduct, practices, behaviour or business activities by financial services entities fall below community standards and expectations.
  • The adequacy of forms of industry self-regulation, including industry codes of conduct; to identify, regulate and address misconduct in the relevant industry, to meet community standards and expectations and to provide appropriate redress to consumers.

Touch screen EFTPOS devices are inherently inaccessible to people who are blind, and to many more who are vision impaired, and this submission specifically addresses this issue.

Read the submission here (Word doc)

Disability Service Standards

Draft National Standards for Disability Services

Read BCA’s Draft National Standards for Disability Services submission (Word doc) about the Draft National Standards for Disability Services.

Our 2012 submission includes recommendations for service provider information accessible formats, independent dispute resolution processes, proportional representation of people with disability on boards and mentoring opportunities, in addition to the provision of high quality services.

Dog Guides and Assistance Animals

Australian Dental Association on regarding assistance animals

Read BCA’s Australian Dental Association submission (Word doc) on access to treatment rooms for persons accompanied by assistance animals.

This submission aims to address the high level of discrimination that still occurs in dental settings and will help to inform the Australian Dental Association’s revised disability policy.

Domestic and Family Violence

National Women’s Branch Submission on Violence Against Women

This submission was prepared by the National Women’s Branch on behalf of BCA, in response to a call for submissions from the United Nations Special Rapporteur on Violence Against Women. The submission highlights issues specific to violence against women who are blind and vision impaired.

Read our Submission of input on violence against women here.

Further to this, you can also read BCA’s recommendations arising from the submission.


Submission to Inquiry of All Aspects of the Federal Election

September 2019

BCA has been involved on an ongoing basis in advocating for an accessible and fully independent system for voting in Australian federal and state elections. Our position is based on extensive feedback and consultation within the sector and we believe that a system should be implemented which allows people with disability to exercise their democratic right of citizenship in voting in elections in a 100% secret, independent and verifiable system which is based on the iVote system used in both NSW and WA elections.

Read the full submission here.

Blindness Sector Submission to the NSW Electoral Commission following the NSW Election in March 2019

Following the March 2019 election, feedback was sought from members of the Blind and Vision Impaired community regarding their experience using iVote to cast their vote. 34 people provided feedback. While we recognise this is a small sample size we believe it is sufficient to identify aspects of iVote that could be improved to improve its usability in future elections.

Read the submission here.


Response to Issues Paper: Employment

August 2020

According to a survey conducted by the World Blind Union, the employment percentages were 62.39% currently employed, 14.32% not currently employed but employed within two years, and 31.67% unemployed long-term. Why are the unemployment figures this high? This submission highlights the barriers to employment which reflect negative assumptions and attitudes, and addresses the questions raised in the Disability Royal Commission (DRC) Issues Paper on Employment, providing evidence through procured case studies to answer the questions pertaining to people who are blind or vision impaired seeking or participating in employment.

Read the full submission here.

Review of Disability Employment Services Framework

The unemployment rate of people who are blind or vision impaired is still four times the national average, and current approaches to this problem are failing. A survey conducted by BCA between October 2013 and April 2014 found that only 35 per cent of respondents had been successful in gaining employment through a disability employment service. We believe disability employment services could be achieving far better outcomes for people who are blind or vision impaired and welcome the opportunity to provide feedback to inform the review of the disability employment services framework.

Read our Review of DES Framework Submission here (Word doc)

A New System for Better Employment and Social Outcomes

August 2014

Work is the cornerstone of social inclusion. It generates wages, less reliance on welfare, dignity, a sense of purpose and productivity. Given the long-term unemployment, or under-employment experienced by many Australians who are blind or vision impaired, we believe that a shift in the current system is necessary to ensure systemic change. These reforms should be underpinned by a sustainable welfare system that is targeted towards those in need and that guarantees that no Australian will be worse off or left behind as a result of the changes.

Read BCA’s submission: A New System for Better Employment and Social Outcomes (Word doc)

Blind Citizens Australia Employment Submissions

BCA released a report for the then Department of Families, Housing, Community Services and Indigenous Affairs focusing on the employment of people who are blind or vision impaired.

Read the Employment paper here (Word doc).

Inquiry into improving the employment participation of people with disability

Take a look and read our submission on improving employment participation (Word doc) to the 2013 Inquiry which outlines the barriers experienced by people who are blind or vision impaired in gaining meaningful employment and career progression.

Recommendations of how the Australian government can meet their national and international obligations and practical solutions to improve employment are included in this submission.

Health and Emergencies

Response to Issues Paper: Emergency Planning and Response

July 2020

BCA responded to the Issues Paper: Emergency Planning and Response, which also incorporates feedback and recommendations specifically on education from the South Pacific Educators in Vision Impairment (SPEVI Inc). The paper focuses namely on the Black Summer bushfires of 2019-2020 and the COVID-19 pandemic.

Read the full submission here

Submission to Senate Select Committee on COVID-19

May 2020

BCA made a submission responding to the Senate Select Committee on COVID-19. There have been significant and wide-ranging issues faced by people who are blind or vision-impaired during the pandemic, including access to information and essential support services, access to food and nutrition, healthcare and housing, income security, education, community participation and social isolation and more.

Read the full submission here.

National Disability Insurance Scheme

Review of the NDIS Act and the new NDIS Participant Service Guarantee

October 2019

This review covers a number of issues experienced by BCA members, as well as recommendations, in relation to the National Disability Insurance Scheme’s processes, particularly those around planning and plan reviews.

Read the full review here.

Joint Standing Committee on the National Disability Insurance Scheme: NDIS Planning

September 2019

Consultation with BCA members over several years, as well as more focussed consultation for this inquiry, identified several broad concerns with current NDIS Planning. This submission includes individual experiences and concerns from members; collated feedback from a couple of BCA’s state-based branches; and a series of recommendations for change.

Read the submission here.

Submission to the Productivity Commission’s position paper on NDIS costs

Further to BCA’s submission to the Productivity Commission issues paper in March 2017 (below), we thank the Commission for prioritising a number of issues that were raised. This latest submission focuses on those aspects of our March submission that were not adequately addressed in the Productivity Commission’s position paper, but continue to compromise the independence, participation and dignity of many people who are blind or vision impaired. These issues relate to the support needs of people with disability aged 65 or over, and the interfacing arrangements between the NDIS and the aged care system.

Read the submission here.

Submission to the Productivity Commission on the Costs of the NDIS

The Productivity Commission released a consultation paper asking a range of questions about the costs associated with rolling out the NDIS, with a focus on how costs could be reduced and how the NDIS could be run in the most cost-efficient manner. BCA has responded with a submission stating that it is not appropriate to view the effectiveness of the NDIS purely through the lens of economics and costs. We have also argued for the continuation of block funding for services such as braille production and library services, orientation and mobility and adaptive technology training. For example, it is not appropriate for people to be required to calculate how much orientation and mobility they will need in their plan, because this could change suddenly. We have taken this opportunity to discuss the benefits of ensuring that quality NDIS plans are implemented for consumers in the first place.

Read the submission here.


The Australian Government commissioned an independent review of the National Disability Insurance Scheme Act 2013 (Cth) (NDIS Act), as required under Section 208 of the NDIS Act. In accordance with this legislative requirement, Disability Ministers had agreed that Ernst & Young (EY) conduct the review.
The purpose of the review is to assess the operation of the legislative framework (comprising the NDIS Act and the NDIS Rules) and develop recommendations as to whether any improvements can be made to better support the objectives and principles of the NDIS Act.

The Blind Citizens Australia submission to the discussion paper can be found here: BCA NDIS ACT Review October 2015 (Word doc)


Payments, Benefits and Allowances

Mobility Allowance Legislative Amendment November 2016

BCA was pleased to have the opportunity to comment on the amendment to legislation which would see the mobility allowance be transitioned into the NDIS, as part of the support available under that scheme. There are, however, some grave concerns that need to be addressed fully, so that the wellbeing of people who are blind or vision impaired who are not eligible for the NDIS will be assured. These changes will affect people with other types of disability who are not eligible for the NDIS in similar ways.

Read our Mobility Allowance Legislative Amendment Submission November 2016 (Word doc)

BCA Submission – DSP Impairment Table Review 2010

Approximately 90% of Blind Citizens Australia members are people who meet the criteria of legal blindness, many of whom receive the Disability Support Pension (Blind) or Age Pension (Blind). This high proportion is due to our membership classification, which until 2006, only permitted full membership to people who are legally blind, with people who are vision impaired or sighted able to join as associate members of the organisation. We therefore caution that our comments may not be reflective of the full and varying needs of people experiencing each visual condition.

In preparation for this review, we spoke with a number of orthoptists and professionals who work with people on the cusp of legal blindness or who have vision conditions which impacts on their daily living skills. Agencies included Royal Society for the Blind in South Australia, Centre of Eye Health in NSW (an initiative between Guide Dogs NSW/ACT and University of NSW) and Vision Australia.

This DSP Impairment Table Review (Word doc) submission supplies recommendations on a number of standards and tests which can be used to provide more effective assessments.


Submission to NSW Point to Point Independent Review

May 2020

A major point in the terms of reference for the NSW Point to Point Independent Review is to “examine the impact of the point to point reforms to date and advise if further structural adjustments are needed to ensure the long term viability of the sector and to realise positive customer outcome.” In this respect, this submission explores the experiences of people who are blind or vision-impaired in NSW in regards to using taxi and rideshare services, and whether the point to point reforms to date have achieved increased levels of accessibility or whether there are still outstanding issues. This submission was also provided to the Senate Inquiry about NSW Operation of the Point to Point Transport Act (Taxi and Vehicle Hire) 2016.

Read the full submission here.

Submission to Inquiry about electric buses in regional and metropolitan public transport networks in NSW

December 2019

A trial of electric buses will be commencing in Sydney’s inner west. Historically, the switch to electric rather than traditional, diesel buses has been driven by the desire for more economical and environmentally-friendly options for public transit. BCA would like to address the issues relating to electric or hybrid vehicles and their silent nature, which will cause significant safety issues for pedestrians who are blind or vision impaired.

Read the full submission here.

Review of the Disability Standards for Accessible Public Transport

Update: March 2019

Submission to the Third Review of the Disability Standards for Accessible Public Transport 2002

BCA’s overarching view is that accessibility to public transport has improved in some areas in Australia since the second review in 2012, particularly in metropolitan areas. However, there is still substantial work to be done to ensure the right to accessible public transport for people with disability is recognised. This is particularly relevant to rural and regional areas where accessible public transport has not improved as much as metropolitan areas (if at all) and demonstrates the inconsistency of the application of the Transport Standards across Australia.

We are concerned that while there are some stated targets for the Transport Standards, there is no stated accountability, measurements or penalties for not meeting those targets.

All Australians want to be able to travel safely and independently. For people who are blind or vision impaired, being able to travel in their local area or between towns and cities keeps people connected and social which has long term benefits for them and the community. This also has broader benefits for older Australians, particularly given Australia is an ageing population. A consistent, national approach to accessibility of public transport across all areas of Australia – rural, regional and metropolitan – must be paramount.

October 2018

The Department of Infrastructure, Regional Development and Cities has released the Issues Paper for the Third Review of the Disability Standards for Accessible Public Transport 2002 (Transport Standards). The Transport Standards were the first standards made under the Disability Discrimination Act 1992 (DDA) and commenced in October 2002. The Transport Standards were made to enable public transport operators and providers to remove discrimination from public transport services by providing specific details about the standards they need to meet.

BCA sought feedback on the experience of public transport for people who are blind or vision impaired, particularly over the last 5 years since the previous review of the Transport Standards in 2012.

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