When we talk about supporting students with disabilities in the vocational education and training (VET) sector, the conversation often gravitates toward individual adjustments: extra time on assessments, alternative formats for a particular student, or a support worker in the classroom. These adjustments are important. But they are, by nature, reactive. They respond to a barrier after it has been built into the system. The far more powerful approach, and the one now clearly expected by both national regulators and the Department of Employment and Workplace Relations (DEWR), is to design training and assessment that is inclusive from the outset.
Before exploring how inclusive design applies in practice, it is worth pausing on a term that is gaining renewed attention across the sector: curriculum. In Australian VET, the word has historically sat outside the everyday vocabulary of RTOs. The sector operates through a tiered development framework where national bodies create training packages, independent organisations develop accredited courses to fill niche skill gaps, and instructional designers then unpack these endorsed regulatory documents to write the actual learning resources, session plans, and assessment materials for delivery. The word "curriculum" does not appear in the Standards for RTOs 2025, nor in most training package documentation. What RTOs develop and deliver are training and assessment strategies, learner guides, assessment tools, and supporting resources, all mapped to nationally endorsed competency standards.
Yet the concept of curriculum, understood as the totality of a student’s learning experience, is precisely what inclusive design must address. As TAFE SA’s recent roadmap and a growing body of VET research acknowledge, there is increasing attention across tertiary education to the role of curriculum in connecting what is intended by training packages with what is actually implemented in classrooms, workshops, and workplaces, and what is ultimately attained by learners. The international literature, including work by Chen and colleagues published in the International Journal for Research in Vocational Education and Training, describes this as the relationship between the intended curriculum (the formal competency standards, training package requirements, and regulatory frameworks), the implemented curriculum (the actual teaching, learning, and assessment activities delivered by providers), and the attained curriculum (the knowledge, skills, and capabilities that learners actually acquire). In Australian VET, the intended curriculum is defined comprehensively through training packages and accredited courses. The challenge, and the opportunity for inclusive design, lies in the implemented and attained dimensions: the training and assessment strategies, the learning resources, the delivery methods, and the assessment tools that RTOs develop from those national frameworks.
Throughout this article, when we refer to inclusive design in training and assessment, we are speaking about what happens at the RTO level: how training and assessment strategies are written, how learning resources are developed, how delivery is planned and executed, and how assessment tools are designed and applied. This is where inclusive practice either succeeds or fails, because this is where the student experience is shaped.
The DEWR guidance materials released through the Supporting Students with Disability in VET project include two dedicated practice guides on this subject: one focused on inclusive design and development, and another on inclusive delivery and assessment. Together with ASQA’s practice guides on diversity, inclusion, and training support under the Standards for RTOs 2025, these resources establish a clear expectation that inclusive training and assessment are not an optional enhancement. It is a core regulatory obligation and a hallmark of quality training provision.
This article examines what inclusive design means in practice within the VET framework, how it should be embedded across the full cycle of training and assessment strategy development, learning resource creation, delivery, assessment, and continuous improvement, and why it ultimately benefits every student and every registered training organisation.
What Inclusive Design Means in the VET Context
The DEWR practice guide on inclusive design and development defines accessible, usable, and inclusive training and assessment as approaches that anticipate diverse learner needs, apply the principles of Universal Design for Learning (UDL), and remove barriers in advance rather than relying solely on individual adjustments after enrolment. The guide makes the important observation that inclusive education is not achieved by ticking a checklist. Instead, it is achieved through intentional design and practice.
This definition has three dimensions. Accessibility refers to ensuring that all learners can access, understand, and interact with training and assessment materials, regardless of their abilities. Usability refers to ensuring that materials are not only technically accessible but genuinely practical and effective for learners with diverse needs. And inclusiveness refers to the broader culture and approach of the RTO, ensuring that learners feel welcomed, valued, and supported throughout their training.
The DEWR materials position UDL as the underpinning framework for achieving all three. UDL is built on the premise that there is no typical or average learner. We all learn differently because of our diversity and variability, including disability. Greater flexibility in teaching and learning practice helps engage and support all learners to succeed. In practical terms, UDL means designing training and assessment with multiple means of engagement (the why of learning), multiple means of representation (the what of learning), and multiple means of action and expression (the how of learning).
In the VET context, this translates directly into how RTOs unpack training packages and accredited courses. The ten industry-owned Jobs and Skills Councils define the competency standards and qualifications through training packages, and regulators accredit courses that address emerging skill gaps not covered nationally. But neither training packages nor accredited courses prescribe how an RTO should design its learning resources, structure its delivery sessions, or format its assessment tools. That is the RTO’s responsibility, exercised through its training and assessment strategy and the materials it develops. It is at this level, the level of RTO design and development, that UDL principles must be embedded.
The Regulatory Baseline: Why Inclusive Design Is Not Optional
The regulatory case for inclusive training and assessment design is now unambiguous. The Standards for RTOs 2025 and ASQA’s accompanying practice guides expect RTOs to provide a safe, accessible, and welcoming environment free from discrimination, and to ensure that enrolment practices, training environments, materials, assessment processes, and wellbeing supports are culturally appropriate and inclusive. The Outcome Standards require RTOs to identify and respond to student needs, make reasonable adjustments for students with disabilities, and maintain an inclusive environment with appropriate supports throughout the learning journey.
These expectations operate within the broader legislative framework of the Disability Discrimination Act 1992 (DDA) and the Disability Standards for Education 2005 (DSE). The DSE require, under Part 6, that education providers take reasonable steps to ensure that courses are designed in such a way that students with disabilities can participate in the learning experiences, including assessment and certification, on the same basis as students without disabilities. The DDA makes it unlawful to discriminate on the basis of disability, including through indirect discrimination, which is precisely what poorly designed training and assessment materials do when they create unnecessary barriers for students with particular needs.
For RTOs, this means that inclusive design of learning resources and assessment tools is not a matter of goodwill or best practice aspiration. It is a legal and regulatory requirement that is assessed through audit, self-assurance, and outcomes monitoring. An RTO that develops its training and assessment materials without considering the needs of students with disabilities is not merely falling short of an ideal; it is failing to meet its obligations.
How Training Packages and Accredited Courses Define the Framework
To understand where inclusive design sits within the VET system, it is essential to understand the development framework itself. Training packages are developed and maintained by the ten Jobs and Skills Councils, which collaborate with industry stakeholders to define workplace competencies and adopt a qualification-first approach. Drafted training products are rigorously reviewed by the DEWR Assurance team against the Training Package Organising Framework, and the Skills and Workforce Ministerial Council endorses the packages for publication on the National Register.
When a distinct skills gap cannot be met by an existing training package, stakeholders or RTOs can develop a VET-accredited course by demonstrating an ongoing industry need. The course must be written using the national course document template to meet the Standards for VET Accredited Courses 2021, including the drafting of custom enterprise units alongside technical experts. These documents are then submitted to regulators such as ASQA, the Victorian Registration and Qualifications Authority (VRQA), or the Training Accreditation Council (TAC) in Western Australia for a multi-stage assessment and formal accreditation.
Neither training packages nor accredited courses dictate how an RTO should teach, what learning resources it should use, or how its assessment tools should be formatted. They define what must be achieved (the competency standards, performance criteria, required knowledge, and required skills) but leave the how to the RTO. This distinction is critical for inclusive design. The training package does not create barriers for students with disabilities. The barriers are created, or prevented, at the point where the RTO translates those competency standards into actual learning experiences and assessment instruments. That translation process, centred on the training and assessment strategy and the development of compliant learning resources and assessment tools, is where inclusive design must live.
Designing Inclusively at the Training and Assessment Strategy Level
The training and assessment strategy (TAS) is the foundational document that guides how delivery and assessment will occur for a given qualification or training product. The DEWR practice guide makes clear that the TAS should address the needs of all learners, not just the majority cohort. Many elements influence the development of a TAS, including the size and resources of the RTO, its location, primary method of delivery, assessment approaches, industry partnerships, entry requirements, and the diversity and variability of target student cohorts. Each of these elements must be considered through an inclusive lens.
In practice, this means that UDL principles should be explicitly embedded in the TAS. The strategy should articulate how multiple means of engagement, representation, and action and expression have been built into learning outcomes, content formats, and assessment tasks. It should identify the known access demands for the qualification, whether physical, sensory, cognitive, or digital, and describe how the TAS addresses them through modes of delivery, resources, and support pathways. It should also describe the reasonable adjustment framework that will apply when individual students require support beyond what the universal design provides.
The DEWR materials prompt RTOs to ask searching questions of their training and assessment design: Does the design facilitate learning for all students? Are training and assessment materials, resources, platforms, and technology accessible and inclusive? Is instructional detail provided in ways that are informative and clear? Are there variable aspects built in to suit individual learner needs and preferences? These are not rhetorical questions. They are the practical checkpoints against which an RTO’s training and assessment approach should be evaluated.
It is worth noting that the TAS is the point at which the RTO bridges the gap between the intended and the implemented. As VET researchers have observed, the implementation of intended competency frameworks has always been challenging in Australia. Training packages define competencies comprehensively and, at times, rigidly, leaving limited flexibility for those working in providers to meet the immediate needs of local employers, learners, and communities. The TAS is the instrument through which the RTO exercises whatever flexibility exists, and it is within that flexibility that inclusive design must be deliberately planned rather than left to chance.
Developing Accessible Learning Resources and Assessment Tools
Designing inclusively at the strategy level is essential, but it must be followed through into the development of actual learning resources and assessment tools. Instructional designers translate endorsed training packages or accredited courses into actionable delivery models, unpacking specific units of competency and assessment requirements to create customised learner guides, session plans, and compliant assessment instruments. The DEWR guidance emphasises that, wherever possible, all aspects of training and assessment practices should be accessible by design. This means that the development of learning materials, assessment tools, digital platforms, and student-facing documentation must all be undertaken with accessibility as a non-negotiable requirement.
Concrete development strategies drawn from the DEWR materials and supporting state and national guidance include providing materials in multiple accessible formats such as large print, audio, accessible PDFs, and structured digital content. Online materials should feature high contrast, readable fonts, alternative text for images, and compatibility with screen readers and other assistive technologies. Video content should include captions and transcripts. Written materials should use clear language, chunked content, and consistent navigation to support learners with cognitive, language, or digital access needs.
Equally important is the development of resources that offer practice and scaffolding opportunities. Check-your-understanding interactions, glossaries, visual supports, and formative activities allow learners to approach the same outcomes through different routes, reducing the reliance on a single mode of learning and building confidence for students who may need more time or alternative pathways to engage with content. The goal is not to lower the standard. The competency requirements defined in the training package remain fixed. The goal is to provide multiple on-ramps to the same destination.
This distinction is particularly important in Australian VET because the competency standards are nationally endorsed and cannot be modified at the RTO level. An RTO cannot change what a student must demonstrate to be deemed competent. But it has considerable latitude in how it structures the learning journey toward that demonstration, what resources it provides, and how it scaffolds the development of the required skills and knowledge. That latitude is where inclusive design operates, and it is where the difference between an accessible and an inaccessible learning experience is determined.
Delivering Training Through an Inclusive Lens
Inclusive design of training and assessment strategies and accessible resource development set the stage, but it is in the delivery of training that the principles are either realised or lost. ASQA’s diversity and inclusion practice guide highlights that compliant RTOs invest in creating a learning environment that is safe, accessible, and welcoming of all students. The DEWR materials reinforce this with detailed guidance on what inclusive delivery looks like in practice.
At the delivery stage, trainers should routinely explain the supports available to students, encourage disclosure of learning needs in a safe and non-medicalised way, and normalise the use of assistive technologies and flexible participation. Delivery should use varied methods, including discussion, visual aids, demonstrations, hands-on tasks, and digital activities, and trainers should check in regularly with learners about accessibility and pacing, adjusting where possible without lowering competency standards. The DEWR materials emphasise that even when an RTO has a strong Universal Design approach and upholds inclusive principles, some individual learners will need specific support and adjustments. Inclusive delivery is about minimising how often this is necessary, not eliminating the need for individual responsiveness altogether.
Underpinning all of this is the capability and confidence of the trainers and assessors themselves. The DEWR materials identify whole-staff disability awareness and confidence as one of the ten key principles for inclusive practice. RTOs should ensure that their staff have access to disability-confidence training and UDL capability development, through initiatives such as the ADCET UDL eLearning program, the UDL Leaders Program, and disability awareness training available through organisations like disabilityawareness.com.au. Inclusive delivery cannot be achieved through policy alone; it requires trainers who understand the principles, believe in them, and have the practical skills to apply them in the classroom, workshop, or online learning environment.
This is where the distinction between the implemented and the attained becomes real. A training package may define competency standards with precision. An RTO may develop beautifully designed, accessible learning resources. But if the trainer delivering those resources does not understand how to engage diverse learners, does not feel confident responding to a student who discloses a disability, or does not know how to adapt their delivery in real time without compromising competency requirements, the inclusive design fails at the point of implementation. The attained experience for the student falls short of what was intended.
Assessment and Reasonable Adjustment Without Compromising Integrity
Assessment is perhaps the area where the tension between inclusivity and integrity is most keenly felt. RTOs are rightly concerned about maintaining the validity and reliability of assessment, and about ensuring that qualifications retain their meaning and value to industry. The DEWR guidance addresses this tension directly, making clear that inclusive assessment and rigorous assessment are not in conflict.
The practice guide on inclusive delivery and assessment stresses that training and assessment approaches should provide for, and reflect, diverse perspectives and allow students to demonstrate their learning in more than one way, while still meeting unit requirements. The key principle is that reasonable adjustments are about the format and conditions of assessment, not the standard. A student who demonstrates competency through an oral presentation rather than a written report has still met the performance criteria. A student who completes a practical assessment with additional time or in a quieter environment has still demonstrated the required skills and knowledge.
In practical terms, this means that RTOs should design assessment tools with multiple valid formats, such as oral, written, practical demonstration, and portfolio, mapped explicitly to the same performance criteria. The TAS and assessment tools should clearly distinguish between what aspects of performance are essential and cannot be adjusted (the inherent requirements defined by the training package) and what can be flexibly adapted, such as mode, timing, environment, or support arrangements. Assessors must be trained to negotiate adjustments with students, document them transparently, and verify that the adjustments do not compromise the validity, reliability, or fairness of the assessment process.
The DEWR toolkit includes a dedicated template for exploring inherent requirements and reasonable adjustments at the unit level, which guides assessors through the process of identifying potential barriers in each unit of competency and documenting both suggested and agreed-upon adjustments. This is an invaluable resource for ensuring that assessment adjustment decisions are systematic, evidence-based, and defensible. It also reinforces the fundamental point that the competency standard itself, as defined in the training package, is the fixed point. Everything else in the assessment design is within the RTO’s discretion and therefore within the scope of inclusive adjustment.
Continuous Improvement and Ongoing Development
Inclusive design of training and assessment is not a one-time exercise. The DEWR materials position it as a whole-of-RTO responsibility that must be embedded in ongoing resource development and continuous improvement processes. Policies, procedures, and strategies should explicitly support the development of accessible and inclusive training and assessment materials, and learner feedback on accessibility should inform ongoing improvement.
For RTOs that develop or contextualise training products, this means applying UDL and inclusive design checklists at the concept and development stages of new learning resources and assessment tools, not simply retrofitting accessibility after the materials have been created. It means involving learners with disabilities and diverse backgrounds in co-design or user-testing of materials and platforms, to capture real barriers and drive genuine improvements. And it means embedding inclusive design requirements in internal product approval processes and quality reviews, so that no training and assessment strategy or resource is signed off until basic accessibility, UDL alignment, and adjustment pathways have been evidenced.
This continuous improvement imperative connects directly to the broader quality framework of the Standards for RTOs 2025. Standard 4.4 requires systematic monitoring and evaluation to support quality delivery and continuous improvement. For inclusive design, this means collecting and analysing data on how students with disabilities and other diverse learners are experiencing training and assessment, whether they are completing qualifications at comparable rates, and whether the learning resources and assessment tools are genuinely accessible in practice rather than just in design. The feedback loop must be genuine: real data, honest analysis, and visible changes in response to what the data reveals.
The DEWR self-check tools support this approach. The RTO Self-Check includes specific indicators for training and assessment design, asking whether a range of resources and supports are available for staff to enable accessible, usable, and inclusive delivery, and whether processes are in place to gather feedback from students about the accessibility and inclusiveness of training and assessment. Similarly, the Trainer and Assessor Self-Check prompts individual practitioners to reflect on whether they are using inclusive approaches, considering UDL principles, and ensuring their materials are accessible. Both tools use the Beginning, Developing, and Competent scale, providing a structured pathway for building organisational and individual capability over time.
The Benefits: Why Inclusive Design Matters for Everyone
While the regulatory and legislative case for inclusive training and assessment design is compelling in its own right, the practical benefits extend well beyond compliance. The DEWR materials identify a range of benefits that flow from adopting a UDL approach. For learners, these include training and assessment that aligns with their strengths, needs, and preferences, greater independence and self-efficacy, empowerment, less need to share personal information about disability, and better outcomes through the elimination of barriers. For trainers and assessors, benefits include less need for individualised supports and associated costs, more time to focus on high-value learning, and the confidence that comes from feeling advocated for and supported in taking more inclusive approaches.
For RTOs, inclusive design of training and assessment reduces the administrative burden of managing large numbers of individual adjustment plans, mitigates the risk of discrimination complaints, and generates evidence of quality that is directly aligned with the outcome-focused expectations of the Standards for RTOs 2025. It also supports student retention and completion, which are increasingly important metrics for both funding and regulatory purposes.
There is a broader point here that connects to the VET development framework itself. Training packages define what competence looks like. Accredited courses fill gaps that training packages do not cover. But neither of these national instruments can control the quality of the learning experience at the point of delivery. That quality is determined by the training and assessment strategy the RTO writes, the learning resources it develops, the assessment tools it designs, and the trainers it employs to bring all of this to life. Inclusive design is not a separate activity layered on top of this process. It is a quality dimension that should be embedded within every step of it. When RTOs design their training and assessment with accessibility built in from the start, the result is not just a more inclusive experience for students with disabilities. It is a better experience for every student.
A Note on the Language of Curriculum in VET
It is worth acknowledging that the language used in this article reflects a deliberate choice. The word "curriculum" is not commonly used in Australian VET, and for good reason. The sector’s regulatory framework is built around training packages, accredited courses, units of competency, training and assessment strategies, and learning resources. These terms have specific regulatory meanings and defined relationships to each other. Using the word "curriculum" loosely risks obscuring those relationships and confusing the distinct roles of national bodies (which develop training packages), accrediting authorities (which approve accredited courses), and RTOs (which design and deliver training and assessment).
However, the concept that curriculum represents, the totality of what a student experiences in the educational process, is precisely what inclusive design must address. As TAFE SA and a number of prominent VET researchers are now arguing, there is real value in thinking about the relationship between what is intended by a training package and what is actually experienced by a learner. The intended, implemented, and attained framework provides a useful lens for understanding where barriers arise and where inclusive design can intervene. In most cases, the barriers are not in the training package itself. They are in the implementation: the way RTOs interpret competency standards, the way they develop resources, the way they structure delivery, and the way they design assessment. That implementation space is where inclusive design lives, and it is where every RTO has both the responsibility and the opportunity to make a difference.
Inclusive design of training and assessment is not a specialised add-on for the benefit of a minority of students. It is a foundational approach to how RTOs develop and deliver their programs that improves the experience and outcomes of all learners, while ensuring compliance with the DDA, DSE, and the Standards for RTOs 2025. The DEWR guidance materials provide RTOs with everything they need to begin this work: a clear conceptual framework grounded in UDL, detailed practice guides covering every stage from design through to continuous improvement, templates for documenting adjustments and exploring inherent requirements, and self-check tools for tracking organisational and individual progress. The resources are freely available. The expectation is clear. The time to act is now.
