NDIS Amendment Bill 2026 Submission: WAFA Calls for Stronger Safeguards, Co-Design, and Assistance Animal Reform

WAFA Submission on the NDIS Amendment Bill 2026

The Working Animals Federation of Australia (WAFA) welcomes the opportunity to respond to the National Disability Insurance Scheme Amendment (Securing the NDIS for Future Generations) Bill 2026.

While WAFA recognises the importance of ensuring long-term sustainability of the NDIS, the proposed reforms introduce significant structural changes that risk undermining the rights, autonomy, and wellbeing of people with disability if implemented without stronger safeguards and genuine co-design.

This submission is informed by disability-led practice, sector expertise, and lived experience across psychosocial disability, assistance animal systems, allied health, and community support environments.

Australia’s obligations under the UN Convention on the Rights of Persons with Disabilities (CRPD) require that reforms strengthen inclusion, participation, and human rights protections—not reduce them.

Key Concerns with the NDIS Amendment Bill 2026

WAFA raises concerns that the Bill introduces reform at a pace and scale that exceeds the readiness of supporting systems. A central issue is the lack of genuine co-design with people with disability and representative organisations, particularly those most impacted by psychosocial disability, communication barriers, or intersectional disadvantage.

The Bill also relies heavily on future delegated legislation rather than clear primary law, creating uncertainty about how key decisions will be implemented. At the same time, eligibility tightening is proposed before foundational supports are operational, increasing the risk that people will fall through gaps in service systems and be pushed into crisis supports or informal care arrangements.

There are also significant concerns about reduced safeguards in the needs assessment process, increased administrative discretion, and the potential for increased institutionalisation, isolation, and service exclusion.

Definition of “NDIS Support” and Human Rights Concerns

WAFA is concerned that the proposed definition of “NDIS support” does not fully reflect the breadth of rights protected under the CRPD. In practice, supports under the NDIS are not only clinical or functional—they are also foundational to participation in community life, employment, parenting, safety, and justice.

For many people with disability, supports that appear “everyday” in nature are in fact essential disability supports. These include assistance that enables independence in the home, participation in community life, and the ability to avoid institutionalisation or dependence on crisis systems.

Without explicit recognition of these broader functions, there is a risk that people will lose access to supports that are essential to their dignity and independence.

Why This Matters for Assistance Animal Handlers

These reforms are particularly relevant to assistance animal handlers because assistance animals sit at the intersection of disability support, human rights, housing, mobility, mental health, and community access.

For many people with disability, an assistance animal is not a lifestyle choice or optional support—it is a critical functional intervention that enables daily living. Assistance animals can provide task-based support that reduces reliance on paid carers, prevents crisis escalation, supports psychosocial recovery, and enables safe participation in public life.

However, assistance animal systems are also one of the most inconsistently interpreted areas of the NDIS. When eligibility rules tighten, assessment frameworks change, or integrity systems shift without clear standards, assistance animal users are often disproportionately affected. This can result in loss of funding for legitimate working animals, increased scrutiny without consistent benchmarks, or delays in access to essential supports.

At the same time, inconsistent regulation creates risks where untrained or unsuitable animals are incorrectly funded as assistance animals, which undermines public confidence and can negatively affect access rights for legitimate handlers. Strong, consistent standards are therefore essential not only for integrity, but also for protecting the rights of trained assistance animal teams.

For these reasons, WAFA considers assistance animal policy reform inseparable from broader NDIS integrity, assessment, and human rights reform. Any changes to funding, eligibility, or compliance frameworks will directly impact assistance animal handlers’ ability to live independently, access education and employment, and participate safely in the community.

Foundational Supports and Sequencing Risks

A key concern with the Bill is the sequencing of reforms. Eligibility tightening is proposed before foundational supports are operational across all jurisdictions.

This creates a structural risk where people are removed from the NDIS without equivalent alternative supports in place. For many individuals, particularly those with psychosocial or fluctuating disability, this would not result in independence but in increased reliance on crisis services, hospitals, homelessness systems, or unpaid family care.

Effective reform requires sequencing that ensures no reduction in support occurs before replacement systems are fully operational and tested.

NDIS Needs Assessment Framework

WAFA has significant concerns regarding the proposed needs assessment framework. While assessment reform is necessary in principle, safeguards around fairness, transparency, and participant rights must be strengthened.

Participants must have the ability to review assessment findings, correct errors, and contribute additional information before decisions are finalised. Assessments must also be grounded in trauma-informed, culturally safe, and disability-informed practice to prevent systemic bias or misinterpretation of need.

Without these safeguards, there is a risk that assessment processes may inadvertently reproduce inequity rather than address it.

Psychosocial Disability and Mental Health Impacts

The Bill also raises serious concerns for people with psychosocial disability. Proposed reductions in social and community participation supports may lead to increased isolation, relapse, hospitalisation, and crisis escalation.

For many participants, these supports are not supplementary—they are essential components of recovery and stability. Removing or reducing them without adequate alternatives risks increasing long-term system costs and reducing individual wellbeing and safety.

Plan Management, Choice and Control

WAFA is concerned about the expansion of administrative discretion in plan management decisions. Participant choice and control are core principles of the NDIS and must not be weakened through broad or undefined override powers.

Participants, particularly those experiencing vulnerability or coercion, must retain meaningful autonomy wherever it is safe to do so. Any restrictions must be transparent, reviewable, and subject to strong procedural safeguards.

Fraud, Misuse, and Integrity Safeguards

WAFA supports strong integrity systems within the NDIS, however these systems must be fair, balanced, and evidence-based. Current concerns include situations where participants are required to demonstrate non-delivery of services despite limited access to records or clear evidentiary disadvantage.

Integrity frameworks should not shift investigative burden onto participants. Instead, they must prioritise provider accountability, transparent investigation processes, and accessible complaints mechanisms that do not retraumatise participants.

Assistance Animal Integrity and Regulatory Gaps

WAFA identifies assistance animal funding and assessment as a high-risk integrity area due to inconsistent application of standards, limited verification processes, and unclear national benchmarks.

This inconsistency can result in both under-regulation of unsuitable animals and over-scrutiny of legitimate assistance animal teams, depending on interpretation. Both outcomes are harmful. They undermine trust in the system, create inequity, and risk compromising safety and access rights.

Clear, consistent national standards are required to ensure that assistance animals funded under the NDIS meet appropriate functional, behavioural, and welfare thresholds.

WAFA Assistance Animal Standards Framework

WAFA maintains a comprehensive suite of national frameworks designed to support best practice in assistance animal training, assessment, and governance.

These frameworks are aligned with internationally recognised standards including Assistance Dogs International (ADI) and the International Guide Dog Federation (IGDF), while also adapting these models for Australian disability contexts and self-training pathways.

WAFA frameworks prioritise functional task-based assessment, humane and non-aversive training methods, animal welfare standards, and clear public access readiness criteria. Despite this, there is limited evidence that these frameworks have been systematically embedded within NDIA processes.

System Improvements Required

WAFA recommends strengthening integrity and governance systems to include provider accountability for billing accuracy, trauma-informed complaint pathways, recognition of contextual evidence, protection from retaliatory impacts, and transparent investigation outcomes.

For assistance animals specifically, WAFA recommends formal adoption of recognised international standards, clearer national definitions separating pets from assistance animals, and stronger post-funding verification mechanisms.

Summary of Recommendations

WAFA provides 30 recommendations covering co-design, consultation, human rights protections, psychosocial disability, assessment safeguards, provider stability, integrity systems, and assistance animal reform.

These include the formal recognition of established international assistance animal standards and the requirement for WAFA accreditation membership for NDIS-funded assistance animal providers.

Conclusion

WAFA supports sustainable reform of the NDIS, but not at the expense of human rights, participant autonomy, or community inclusion.

Assistance animals, psychosocial supports, and community-based disability services are not peripheral components of the NDIS—they are central to independence, participation, and dignity.

Reforms must therefore be co-designed, evidence-based, and implemented with full consideration of their real-world impacts on people with disability.

WAFA urges the Committee to ensure that all legislative changes strengthen, rather than weaken, the rights and safety of people with disability across Australia.

WAFA’s full submission can be viewed on the Australian Parliament House website as part of the official inquiry process.