Digital accessibility

The legislation, the challenge, the opportunity
23 September 2020 is the deadline for compliance with the Public Sector Bodies (Websites and Mobile Applications) (No. 2) Accessibility Regulations 2018. For many senior leaders, this seems like yet another responsibility, another drain on budgets and another box to tick. But seen through a different lens, this is potentially a once-in-a-lifetime opportunity to significantly increase return on existing investments, increase productivity and foster improved student outcomes.

What is digital accessibility?

In the physical world of buildings and classrooms, accessibility is easy to understand. Automatic doors, ramped access to buildings and lifts between floors are all tangible demonstrations of the social model of disability. A wheelchair user is disabled not by the wheelchair, but by a poorly designed building. A well-designed building “un-disables” them.

In the digital world, the same concepts apply. A student is disabled by poor digital practice. For example, a tutor uses formatting instead of Styles to create section and subsection headings in a long document or web page. This is very challenging for a print-impaired student to read. The same content created with heading styles transforms the experience – it can be:

•    instantly navigated by assistive technologies like screen readers
•    turned into a list of nested headings for instant overview of the content
•    instantly transformed to a mind map with compatible mind mapping tools.

And, like ramps in the physical world, digital accessibility benefits users far beyond the target audience.

What is the problem with digital accessibility?

The core problem with digital accessibility is that it appears to ‘belong to somebody else’. The disability support team don’t own it (it’s about technology). The e-learning team or IT services team don’t own it (it’s about disability). Teaching teams don’t own it (it’s about technology or disability!).

They are all wrong. Digital accessibility belongs to anyone who communicates digitally. This includes everything from documents and presentations to systems and tools. If you don’t know what good practice is (the basics can be learned in 30 minutes), you are likely to be creating barriers. It is the educational equivalent of employing chefs with no understanding of allergies or food intolerance.

The core problems and solutions are summarised below:

Problem: The benefits of digital accessibility are usually untaught therefore unappreciated and underexploited.

  • Solution: Digital training of any kind needs to include ‘good digital accessibility practices’ with a focus on the benefits for ALL students.

Problem: Even when resources have high accessibility, students don’t know how to exploit the benefits.

  • Solution: The productivity and personalisation benefits of digitally accessible content and assistive technologies (like text to speech and voice recognition) need to be promoted to all students via study skills guidance and student inductions.

Problem: The basics of digital accessibility are not difficult to master. They make a significant difference to a range of students with and without disabilities, yet most staff remain ignorant of the basics and training is rarely mandatory.

  • Solution 1: Digital accessibility needs to be more discoverable in many policies. Vague terms like ‘valuing diversity and inclusivity’ need to be turned into specific commitments like ‘accessible course materials’ or ‘accessible library platforms’.
  • Solution 2: Digital accessibility needs to appear in quality assurance processes such as self-assessment reviews.

Training is likely to have lasting value once its purpose is embedded in the cultural values of an organisation. Unless digital accessibility is a tangible part of the culture, training will not deliver long term change.

What is the legal position?

The Public Sector Bodies (Websites and Mobile Applications) (No. 2) Accessibility Regulations 2018 is already partly in force. The final provisions for web content become law on 23 September 2020.

There are two implications for colleges and universities. They must:

  • meet the accessibility requirement on their websites/VLEs etc. The accessibility requirement relates to level AA of this suite of objective technical standards.
  • produce an accessibility statement that details
    • the extent to which they have succeeded or failed in meeting the accessibility requirement
    • alternative formats/services available to people who cannot access the content
    • the complaints and escalation process (up to and including the Equality and Human Rights Commission)
    • how they are addressing current failures.

For the first time since the Disability Discrimination Act (1995), the onus is not on a disabled person to request support or alternative formats every time they meet a barrier. The onus is on the institution to get rid of the barriers.

Technically, a ‘website’ is any resource or information accessed through a browser. The legislation therefore applies to your:

  • public-facing website,
  • learning platform,
  • library platforms etc,
  • your internal systems like HR, timetabling etc.

It also applies to content uploaded to your digital systems such as multimedia and ’office files’ – documents, presentations, and spreadsheets etc.

Government Digital Services (GDS) are responsible for auditing and reporting on compliance. They have stated that their approach will be supportive rather than punitive – but the real threat is not from GDS.

What is the threat?

The key threat to colleges is not Government Digital Services auditing your websites and finding them lacking. The bigger threat is from individual students or speculative lawyers.

The key vulnerability is Section 12 of the legislation. It defines Reasonable Adjustment for the first time in 25 years’; “a failure by a public sector body to comply with the accessibility requirement is to be treated as a failure to make a reasonable adjustment.” This maps directly to a failure to sections 20, 21 and 29 of the Equality Act 2010 and sections 19 to 21 and 21B to 21E of the Disability Discrimination Act 1995(13).

The key issue here is the “60-second vulnerability” – in less than a minute, an automated accessibility checker like the the WAVE tool can report on the accessibility issues of your website. It is an objective measure of your “failure to make a reasonable adjustment” and can be used against you – unless your accessibility statement has a convincing and realistic roadmap of planned improvements.



Figure 1 - screenshot of the WAVE tool results for a college website.

What’s the opportunity?

Digital accessibility is less about disabled people and more about being digitally grown up. Accessibility is an emergent property of good practice. When digital technology is properly implemented using best practice techniques, the user experience is significantly enhanced.

Resources can reflow when magnified, change colours, navigate by heading levels, speak content, work without a mouse, interact with assistive technology tools and plug-ins.



Figure 2: Screenshot showing two versions of an accessible PDF in Adobe Reader. Users can navigate to any point in the document using the bookmarks panel. The right-hand version has been magnified and reflowed into a single column to make reading easier. The background colour has been changed. This document also works with text-to-speech.

Most colleges and universities have already invested in tools and infrastructure that can give enormous flexibility and personalisation to end users, but organisations could get considerably more return on investment if those:

  • creating content know the simple author practices that make it so flexible.
  • consuming content are introduced to the options to navigate, reflow, speak out loud or change colours etc.

The differences in Figure 3 have been achieved in seconds using features inbuilt to Adobe Reader. Adaptable content that can be personalised to a user’s needs and preferences helps in focus and makes them more productive. Fewer barriers mean fewer support requirements, allowing support staff to provide better quality interventions for students with more complex issues. Accessible content is also more adaptable for use on mobile phones and tablets.

The combination of the public sector web accessibility legislation and a global pandemic provide a unique opportunity to use the lever of legislation to improve staff digital skills.

Understanding the big picture

Digital accessibility is about more than teaching people to make better use of Office, Google classroom or the VLE. The Accessibility Maturity Model for Education (extract below) helps an organisation view their practice through different cultural lenses. Accessible online teaching and learning is about more than accessible content; it is also about inclusive pedagogy, inclusive course design, accessible assessments etc.


Figure 3: Screenshot from the Accessibility Maturity Model for Education.

The accessibility maturity model can be freely downloaded and used as a tool to generate discussion within the organisation. Alternatively, a guided service is also available that helps you collate staff perceptions, explore evidence and produce recommendations for priorities.

The critical starting point is to ensure responsibility for digital accessibility is properly distributed. It cannot belong to a single team such as disability support, e-learning or IT. Anybody involved in creating digital content or procuring digital products has a responsibility. The planning template in the Appendix provides an outline that may help you.

What support is available?

Since digital accessibility involves the whole organisation, different types of support are required for different types of role. The examples below include both freely available and paid-for services from different providers.

Free support

Technical support – benchmarking and auditing

  • Automated and manual (in-house) testing is a good starting point. Automated tests pick up about 30 – 50% of potential issues. Test websites with WAVE tool or Accessibility Insights.
  • Evaluate the accessibility of Word documents using the in-built Accessibility Checker. Check PDFs in Adobe Reader for Bookmarks. Try to reflow them (View, Zoom, Reflow) and magnify to 300%. Try selecting text across a page break and reading it with text to speech.

Staff training and awareness raising

Strategy and policy

Join the Digital Accessibility Regulations Jiscmail list and attend the monthly Jisc accessibility clinics. Explore the LexDis Accessibility toolkit. Join the Jisc Accessibility Teams site.

Paid-for support

Technical support – benchmarking and auditing

Staff training and awareness raising

Strategy and policy

  • AbilityNet/McNaught’s FE/HE bundle and Accessibility Maturity consultancy are very effective at helping organisations get a realistic sense of their strengths, weaknesses and priorities. This includes an Accessibility Statement Mapper, which uses the process of creating a compliant accessibility statement to identifying organisational digital accessibility priorities.

AllAble provide a wide range of services around strategy, policy, and accessibility statements.

  • Jisc’s consultancy team have a range of support offers. Whilst none are specific to digital accessibility, many relate to the student’s end experience.


Who is involved? A planning template

Digital accessibility involves everybody in one way or another. The table below gives you some prompts for identifying key leaders to take responsibility in different areas.

The role

The issues

Named lead?

Procurement teams

Ensuring accessibility is embedded in the procurement process. Identifying the additional costs inherent in purchasing less accessible products.


Digital system leads

Ensuring the current accessibility strengths/weaknesses are known for each digital system. Accessibility statement and improvement plan in place by September 23.


Marketing and comms

Ensuring branding is compliant with accessible colour contrasts. Ensuring course descriptions, prospectuses, application processes etc are fully accessible.


Teaching staff

Ensuring teaching staff know how to create accessible teaching resources and assessments.


Student support / ALS teams

Ensuring team supporting disabled students know how to help students exploit the benefits of digitally accessible content.


Student induction

Ensuring students understand their rights to accessible digital content and the benefits to their productivity.


Quality assurance

Ensuring accessible practices are part of quality assurance and self-assessment reviews.


Alistair McNaught, Lead Consultant, McNaught Consultancy Limited