AFI has made a submission to the National Disability Safeguards Consultation, emphasising that effective safeguarding requires more than regulatory compliance. It requires strong independent advocacy, preventative strategies and properly resourced oversight grounded in human rights.
Our central message is that independent advocacy is itself a core safeguard. Where advocacy is weak, under-resourced or absent, other safeguards routinely fail—particularly for people under guardianship, living in congregate settings or facing significant power imbalances. Advocacy enables early intervention, accountability and the translation of lived experience into reform.
We highlight that many safeguarding failures are systemic and preventable. In the ACT, under-resourcing, segregation and fragmented service coordination continue to create unsafe and dehumanising environments. Examples include large congregate housing models with institutional features, restrictive practices and exclusion in segregated education settings, and long-stay hospital placements without adequate access to primary health care, social engagement and wellbeing supports. Safeguarding must address these structural drivers of harm, not simply respond after abuse occurs.
Our submission also raises concerns about the heightened risks faced by people under guardianship and trustee arrangements. Safeguards must include ongoing scrutiny of how substitute decision-making operates in practice, with a clear focus on dignity, autonomy and lived experience.
AFI strongly supports strengthened implementation of OPCAT (the Optional Protocol to the Convention Against Torture). Preventative oversight must be properly resourced and include community engagement, education and cultural change, not just inspection functions.
Effective safeguarding must be preventative, disability-led and grounded in human rights.
You can read the full submission below.