My eLearning accessibility training courses generally follow this pattern. I begin by looking at the ‘Why?’ and ‘Who?’ of eLearning accessibility, and find that engagement and commitment are high. I then focus in more detail on the Web Content Accessibility Guidelines (WCAG), which are the standards needed for legal digital accessibility compliance. I mention that there are 50 A and AA standards which need to be applied, and engagement begins to falter. Next I show people the WCAG quick reference guide, and engagement takes another hit. We then look at one of the requirements and its detailed pass or fail criteria, and disbelief begins to set in. I know people leave my training knowing that eLearning can be made accessible, but seeing firsthand this negative reaction to the guidelines, has convinced me they are a major reason why people find it so difficult to engage with eLearning accessibility.
Before September 2018, the main legislation governing accessibility in the UK was the Equality Act, which was passed in 2010. While the act does specify that organisations have an ‘anticipatory duty’ to provide accessible services, it doesn’t stipulate that for online content, this means meeting Web Content Accessibility Guidelines. It was hugely significant then, that the new Public Sector Bodies (Website and Mobile Application) Accessibility Regulations 2018 specified WCAG 2.1 A and AA standards as the legal requirement. There are exemptions, and time limits vary depending on the type of content and where it is held, but in most cases, it is illegal for any new digital content not to be accessible to these standards by September 2020 for web content, and July 2023 for mobile app content. While the legislation only applies to public sector bodies, further and higher education institutions and some charities, and anyone who supplies content to them, it does mean that there are now indisputable accessibility standards for all digital content, including eLearning, in the UK.
What’s good about WCAG?
Before we look at some of the issues with the guidelines, let’s look at all the good things about them.
- They are cooperatively developed international standards.
- They are recognised by both governments and businesses.
- They are adaptable and flexible for different situations.
- They change to include developing technologies and techniques, e.g. the latest version 2.1, incorporates mobile technology.
- They are precisely testable to pass or fail standards, e.g. the contrast ratio which must be achieved between text and background colour is 4.5:1.
Axel Leblois, Executive Director, G3ict summarises the benefits well when he says:
“WCAG creates the foundation for a level of standardisation of web accessibility around the world.”
Few would argue with these benefits of WCAG, yet this isn’t necessarily much consolation when trying to work with them. So just why are they so difficult to implement?
I believe that the complicated and technical language of WCAG is one of the chief reasons people struggle with the regulations. Even the four categories the standards are divided into, Perceivable, Operable, Understandable and Robust are problematic. So yes, although they do spell out the easy to remember acronym POUR, every time I have ever heard them discussed, or seen them written about, they always need to be explained in more detail. This instantly creates the impression that digital accessibility is complicated and difficult to achieve.
When you begin to try and understand each guideline, things can get even more complex. If you’ve never read a WCAG standard, a good example might be 3.1.5 Reading Level:
“When text requires reading ability more advanced than the lower secondary education level after removal of proper names and titles, supplemental content, or a version that does not require reading ability more advanced than the lower secondary education level, is available.”
This is one of my favourites, because it tells us that the language we use should be understandable by someone who has a lower secondary level education (i.e. age 12-14 in the UK and grade level 7-9 in the US), and yet the language the guideline uses scores a grade level of 22 on a readability test tool. (Note this is a AAA standard and so is not a legal requirement in the UK.)
Some of the complexity of the language is undoubtedly because WCAG are technical standards. In notes for a W3C 2010 presentation on WCAG, I found an interesting point:
“WCAG 2 itself is not designed for novice Web developers or content authors,” but rather for “Web developers and designers, authoring tool and evaluation tool developers.”
This would suggest that us content authors are not technical enough to understand the regulations. If you research web accessibility forums and blog sites, however, it seems clear that even those who this quote suggests WCAG are aimed at, find them difficult to understand. As Denis Boudreau in a 24 Accessibility post on Unlocking Accessibility for UX/UI Designers says:
“Some might argue that WCAG 2.1 doesn’t make things any easier! After all, there’s a reason why hundreds of “Understanding” pages are needed to explain what WCAG is really about.”
2. Suitability for eLearning
While everyone may be finding the language of WCAG difficult to understand, an additional challenge for eLearning content authors, is that the guidelines are designed for websites. So even though a lot of them do apply to eLearning, some of them are simply not applicable because they refer to website coding, e.g. 4.1.1 Parsing:
“In content implemented using markup languages, elements have complete start and end tags, elements are nested according to their specifications, elements do not contain duplicate attributes, and any IDs are unique, except where the specifications allow these features.”
Another issue is the fact that the focus of the guidelines is on informational websites. They don’t cater for content authors who need to engage the audience in a learning experience. One standard I always struggle with, for example, is 2.4.5 Multiple Ways:
“More than one way is available to locate a Web page within a set of Web pages except where the Web Page is the result of, or a step in, a process.”
Although I can completely understand why you should give users of websites more than one way to access a page, in an eLearning resource there may be sound pedagogic reasons why you want the learner to interact with your content in a certain order. You could argue that the learning is “a process” and so this requirement doesn’t apply to eLearning, but this brings me to the next issue, which is testing the content.
Although there are a wide range of tools and organisations which provide accessibility testing for websites, I am not aware of any which currently offer WCAG 2.1 compliance testing specifically for eLearning content created using rapid authoring tools. As a result, I haven’t been able to find any information about which regulations might not be applicable to eLearning, due to technical constraints or the different requirements of the audience. This leaves any content authors trying to apply WCAG to eLearning in a position where they are having to make their own judgement calls about which of the regulations are applicable.
4. Industry engagement
There seems to be very little engagement with digital accessibility from the eLearning industry. I found one blog post from Sponge posted in 2015 which recognises that it is something which needs to be addressed:
“As the eLearning industry matures, perhaps it is time for a collective agreement and a specific set of standards for best practice when it comes to accessibility.”
As far as I’m aware, this excellent suggestion has never come about. Although I believe the Public Sector Bodies Accessibility Regulations has now superseded the need for a “specific set of standards and best practice,” what would still be hugely helpful is a collective agreement on how to apply these standards to eLearning. If you know of any work which is taking place around this, it would be fantastic to hear about it. As it stands, I guess that many people who are grappling with interpreting and applying WCAG to eLearning are feeling isolated and unsupported.