How to write an Alternate Access Plan
Every accessibility deadline arrives with a list of failures you have not fixed. The honest question is not whether you are fully compliant, because almost nobody running a service of any size is. It is what happens to the person who hits the barrier today, while the fix sits in a backlog.
There is a name for the document that answers that, and it is not one I made up.
Where the term comes from
The Australian Human Rights Commission defines it, in Chapter 2 of its April 2025 Guidelines on equal access to digital goods and services:
An Alternate Access Plan is a document that describes how information and services will be made available to individuals with disability until they can be made accessible. The plan does not require the person to have an identical experience but should offer an experience that can provide a similar service as that gained by people who do not have disability.
The AHRC frames it as a risk treatment and a form of reasonable adjustment. Not as a substitute for fixing the barrier.
Most agencies do not have one, and the reason is simple: the Commission only named the artefact in April 2025. What they have instead is an accessibility statement saying they are working towards compliance, which tells the person who cannot submit the form precisely nothing.
Why it matters legally
Under the Disability Discrimination Act 1992, inaccessible digital services can be unlawful discrimination. There is an unjustifiable hardship defence, and the burden of proving it sits with the organisation, not with the person who could not use the service.
Then there is Maguire v Sydney Organising Committee for the Olympic Games (No 2) [2000] HREOCA 31. The Commission found that information on a website is a service within the meaning of the Act, and that SOCOG had directly discriminated. It is a HREOC determination rather than a court judgment, so treat it as persuasive rather than binding.
On the standard, be careful how you phrase it. The AHRC's guidelines say organisations "should conform with WCAG 2.2 at a minimum Level AA". That is a recommendation, and the Commission is explicit that the guidelines are not legally binding: an organisation "may not be protected from a finding of unlawful discrimination if they claim that they conformed with, or relied on, the Guidelines".
Conformance is evidence that you acted reasonably. It is not a defence, and nobody should tell your executive otherwise.
For the Australian Government standards position, the instrument is Criterion 4 of the Digital Inclusion Standard. It requires compliance with three instruments: the Disability Discrimination Act 1992, the latest version of WCAG, and the Australian Government Style Manual.
How this compares overseas
Australia has no mandatory accessibility statement regime. Two comparable jurisdictions do, and both look a lot like an Alternate Access Plan.
The EU requires it under the Web Accessibility Directive, Directive (EU) 2016/2102, with the wording set by Commission Implementing Decision (EU) 2018/1523 of 11 October 2018. Public sector bodies there must publish a statement listing non-accessible content, any disproportionate burden claim, and the alternatives available. The UK does the same under its 2018 accessibility regulations, which require a statement written to a set model. The Government Digital Service publishes a sample statement to work from, and flags which wording is legally required.
So this is not an exotic idea. It is the standard international practice, and here it is voluntary. Writing one before you are required to is the cheapest credibility a digital team can buy.
Why it is content design work
Naming the WCAG criterion you failed is the easy half. An agency usually knows.
The hard half is writing the fallback in words the affected person can act on, at the moment they hit the barrier. Get that wrong and the barrier is just a dead end with a policy statement attached.
That is content design, not a developer ticket.
How to use this template
List every known barrier. Pull failures from your latest accessibility audit or assessment. One entry per barrier.
Write a real alternative for each one. A phone number nobody answers is not an alternative. Name the channel, the hours, and what the person will get.
Assign an owner and a date to every fix. A barrier without a named owner and a dated commitment is not a plan.
Publish it where the barrier is. Link to the plan from the failing page or component, not only from a buried accessibility statement.
Review it on a set cycle. An out-of-date access plan is worse than none, because it misleads.
What good looks like
A strong plan can be read by the person it affects, not only by a lawyer. Every barrier has a named owner and a dated fix. Every alternative route is a real channel a person can use today, with hours and an outcome. And the plan is linked from the point of failure, so someone who hits the barrier finds the way through in the same moment.
If your plan cannot pass that test, it is a compliance shield rather than an access plan. The difference is whether a person who cannot use your service can still get what they came for.
Get the template
Use it two ways. Download the branded version to publish and adapt, or open the plan in the accordion below and copy it into your own document.
Alternate Access Plan template
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Everything in [square brackets] is a placeholder for you to complete. Everything in italics is guidance you should delete before publishing.
1. Plan summary
Service or product: [name of the website, app, form, or platform]
Agency and business owner: [agency], [name and role of the accountable officer]
Standard applied: WCAG 2.2, Level AA.
Date published: [date]
Next review date: [date]
Contact for accessibility help: [staffed phone, email, and hours]
This summary is what a user, an auditor, or a complaint investigator reads first. Keep it plain and specific. Every line above is a field, not a sentence.
On the standard: the Australian Human Rights Commission recommends WCAG 2.2 Level AA as a minimum, and Criterion 4 of the Digital Inclusion Standard requires it. Keep that reasoning here in the guidance, not in the published plan.
On the review date: we recommend no more than 90 days. Nothing in the Commission's guidance or the Digital Inclusion Standard sets a review period, so that is a Content Co recommendation rather than a requirement. Set a cycle you will actually keep, because an out-of-date plan misleads.
Do not cite the Digital Access Standard here. That standard is about reducing duplicate entry points and myGov integration, not accessibility. Criterion 4 of the Digital Inclusion Standard is the right reference.
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Repeat this block for every known barrier. Do not summarise multiple failures into one vague entry.
Barrier [number]
What is failing: [the component, page, or task, in plain language, for example "the online concession application cannot be completed with a screen reader at the identity step"]
WCAG 2.2 criterion: [for example 4.1.2 Name, Role, Value, Level A]
Who this affects: [for example "people using a screen reader or keyboard-only navigation"]
Impact on the task: [what the person cannot do as a result]
Alternative access route: [how the person completes this task today]
Is the alternative equivalent: [state honestly whether the alternative gives the same outcome, timeframe, and privacy. If it does not, say so.]
Fix owner: [name and role]
Remediation date: [committed date]
Status: [Not started / In progress / Fixed and verified]
Write the alternative access route as one short instruction. Two that work: "Call [number] between [hours] and a service officer will complete the application with you." Or "Ask us for an accessible document and return it by [channel]." Never name a PDF as the accessible option.
The AHRC's own framing is useful here: the alternative "does not require the person to have an identical experience but should offer an experience that can provide a similar service". Equivalent outcome, not identical route.
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This is the content design section. The routes above have to be turned into words the affected person can act on. Write each as a short, action-first instruction, not a policy statement. Avoid "This service is not currently accessible" as an opening.
Do: "Cannot complete this form with a screen reader? Call [number] between [hours] and we will complete it with you."
Do not: "Users experiencing accessibility difficulties may wish to contact the department for assistance."
Model the Australian Government Style Manual here. If the plan itself is hard to read, it fails the people it is meant to serve. Do not contract negatives in formal wording: use "cannot", not "can't".
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Prepared by: [name, role, date]
Accessibility review by: [name or team, date]
Approved by: [accountable executive, role, date]
Where this plan is published: [URL, plus the pages and components it is linked from]
Sign-off matters because this plan commits the agency to dated fixes. Route it through the same clearance as any public statement, and make sure the executive who signs it can see the remediation dates they are agreeing to.
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Review every barrier on the next review date.
When a barrier is fixed and verified, mark it Fixed, record the date, and remove the alternative route once the fix is confirmed with assistive technology.
When the register is empty, retire the plan and note the date the service met WCAG 2.2 Level AA.
Photo by Fiona Murray-deGraaff on Unsplash.
Did this land?
I write these to be used, not just read. Tell me if this wouldn't work in your organisation, and why.