WCAG compliance or learner engagement – do we have to choose?

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In recent years, there’s been a notable shift towards accessible e-learning. In 2017, we started to make our e-learning more accessible and worked hard to fully integrate accessibility into our learner-focused and human-centred design approach. At the time, most of our customers did not seem to care much about it. They often did not understand what accessibility meant, or how their organisation could benefit from it.

This attitude has changed significantly in the last few years. More organisations, especially public sector bodies, are now coming to us demanding e-learning solutions which comply with WCAG level AA, and which work with a wide variety of assistive technology.

This change was largely driven by the Public Sector Bodies (Websites and Mobile Applications) Accessibility Regulations 2018, which came into effect in September 2020. It makes a huge difference to many learners with disabilities who previously would have struggled to get past the start page of most e-learning courses. However, even though we have come a long way, it is still too early to relax and be pleased with ourselves. There are many more challenges still to face.

Accessibility versus learning?

Accessible e-learning should be about creating effective and engaging learning solutions for all learners. However, at times it seems that ticking the right WCAG boxes has become much more important than good instructional design and learner engagement.

Indiscriminately trying to meet all WCAG guidelines without stopping to consider which guidelines are relevant or suitable for e-learning and which aren’t, can easily lead to the development of e-learning solutions which no longer function as a learning tool, and which do not provide a good experience for any of our learners.

For example, trying to create an e-learning course which is fully in line with a very narrow interpretation of WCAG will either lead to the boring ‘click and reveal e-learning’ of earlier times, or we will end up with a good experience for the majority of learners and an accessible Word document as the accessible alternative for learners with certain accessibility issues, e.g., screen reader users.

Surely, that’s not good enough? As learning professionals, we want to create exciting and effective learning solutions for all learners.

But before we go on, let’s have a look at WCAG in more detail. Where did these guidelines come from and how are they being used in e-learning?

What is WCAG about?

WCAG stands for Web Content Accessibility Guidelines. These guidelines were developed by the World Wide Web Consortium (W3C). Their purpose is to ensure that digital content can be accessed and used by all users – or at least by as many users as possible.

Originally, the focus was on websites, but nowadays there are many more types of digital content, such as e-learning or apps. WCAG also applies to those, even though their purpose and the way we use them can differ considerably.

On a website it can be important to be able to ‘jump around’ easily to find the news article we want to read or the product we want to buy. E-learning, in comparison, is usually different. As instructional designers we think carefully about the best way to structure and present our content and the activities we want to use to reinforce the learning. Even if navigation isn’t restricted, the learner is not meant to read one page in one section and then do a completely unrelated activity in another section. Even in courses which allow the learner to explore sections in any chosen order, there will still be a certain logical order within each section.

For example, a learner would never really jump from one Submit button to the next without reading any of the text in between. Instead, they would read the question first, then the answer options, then make their choice and then select the Submit button related to this question. So, why would anybody testing an e-learning course just jump from one Submit button to the next and then declare that the course is not accessible because the alt text on the Submit button does not say which question it is linked to?

Instead of desperately trying to tick all WCAG boxes, it is much more helpful to focus on the ‘spirit’ of WCAG, its goal and its principles and try to understand how these apply to e-learning.

WCAG principles

Instead of fixating on meeting every WCAG requirement, let’s delve into the essence of WCAG – its principles and goals as they apply to e-learning.

Perceivable – all learners are aware of all the content and don’t accidentally miss anything. For instance, they don’t miss information provided in a diagram because they cannot see it, or information delivered via a podcast because they cannot hear it.

Operable – all learners must be able to navigate through all the content and do all the activities. Nobody should get stuck anywhere or miss out on part of the learning, for example, because they are unable to use a mouse.

Understandable – all learners must be able to understand the content and how they are supposed to navigate the course. The course must be well structured, the reading level must be appropriate for the audience and navigation must be intuitive so that the learner can fully concentrate on their learning instead of trying to figure out what button to select next.

Robust – the e-learning should work with the most popular browsers and with as wide a range of assistive technology as possible.

These principles are what we are aiming for. However, sometimes we may have to make choices, based upon the goals of our e-learning and our audience and balance everybody’s needs as best as we can.

Take assistive technology as an example. There are so many different assistive technologies on the market, that no matter how much effort we put into the development, we will never be able to make the e-learning work with all of them. Sometimes simplifying the module may be the best solution and sometimes we may have to provide the content in a different format (e.g. as an accessible Word document) to ensure that nobody misses out on any of the information provided. At other times, offering alternatives might be the best solution for all learners.

WCAG guidelines

Each of the four WCAG principles is supported by several specific guidelines. Originally, they were created to support web developers, but now they are also meant to guide app and e-learning developers.

However, these are only guidelines to help achieve a goal. They are not rigid rules everybody has to follow at all times no matter if they make sense or not.

Moving beyond WCAG level AA

International legislation is often, at least to some degree, based on WCAG, level AA, and this is also the legal requirement for public sector bodies in the UK. However, to create e-learning, which is accessible, engaging, and effective, it is worth going further. At Netex we do this by:

  • Voluntarily meeting those level AAA criteria which can further improve the learning experience without adding much extra effort or extra costs.
  • Continuing to apply good instructional design.
  • Ensuring good usability for all learners.
  • Providing alternatives where appropriate. Providing transcripts as alternatives for videos is included in WCAG, but to create the best possible learning experience for all learners, we should also provide alternatives for activities where appropriate. Sometimes the best option can be to provide a text alternative, but often providing a different type of activity as an alternative can be a better option from a learning point of view. Whichever we decide to do, the key is that all learners cover the same learning, even though they may occasionally do this in slightly different ways.

This commitment may require some additional effort and costs, but the end result is an exciting, effective, and inclusive learning solution that caters to diverse learner needs.

What about authoring tools?

Most instructional designers/e-learning developers are dependent on the authoring tools available on the market. Unfortunately, there is no perfect tool available yet, which makes it quick and easy to develop fully accessible e-learning,

At Netex we try to stretch the capabilities of the tools which we are using as much as possible, but there are limits to what we can do. Luckily, we have our own authoring tool, Author, which we are working hard to enhance its accessibility capabilities.

Accessibility audits

To check if e-learning products are accessible, external auditing companies are sometimes employed. However, not all of these companies are experienced in e-learning, so they may test the e-learning just like a regular website.

Their reports are often written in a way that’s not useful for e-learning developers as they provide recommendations as how to change the code to improve accessibility. Unlike web developers, e-learning developers usually cannot do this as they are limited by the capabilities of their authoring tool.

A great way to overcome this dilemma is for e-learning developers and auditors to collaborate closely to figure out how to make e-learning as accessible as possible within the limitations of the tools, ensuring a great learning experience for everyone.

What’s the solution?

Hopefully it’s clear that something must change. In an ideal world, the solution would be to have a framework specifically focusing on e-learning accessibility, maybe similar to the eLa (eLearning accessibility) framework that has been developed by eLaHub.

But whatever it looks like, it would be a framework that would be recognised across the industry, be written in an ‘accessible’ language, and meet all WCAG, level AA criteria as a minimum. A framework which not only starts with the e-learning but also helps us understand how we can make sure that all the different elements which we typically use in e-learning (text, images, videos, audio, etc.) can be accessed by all learners – no matter what their abilities are.


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Sabine de Kamps

Sabine is passionate about learning and teaching in all its forms. Over the past eleven years she has successfully transitioned from delivering face-to-face trainings to developing e-learning experiences. Her goal is to design e-learning that is inclusive and engaging, ensuring that all learners can benefit from education.