Accessibility can and should also be ensured in the area of e-learning. The focus is on well-considered and empathetic implementation — but what challenges stand in the way?
“An inclusive society in which all people lead a self-determined life is our goal — in Germany and Europe. ”
— Federal Ministry of Labour and Social Affairs, Germany
To promote an inclusive society, the Accessibility Strengthening Act (known as the BFSG) was enacted in 2021. This legislation governs equal and non-discriminatory access to products and services — particularly for people with disabilities, impairments, or older individuals. The aim of the BFSG is to implement the European Accessibility Act (EAA). The EU-level recommendation calls on Member States to harmonise their legislation. Small and medium-sized enterprises should also be able to rely on clear, consistent EU directives, enabling them to remain competitive in the European single market while promoting inclusion.
How do BSFG and EAA influence the e-learning industry?
The European Accessibility Act defines the technical requirements for accessibility in relation to products and services. However, the specific accessibility requirements among EU Member States are as diverse as their populations and, at present, often create confusion rather than clarity.
The goal should therefore be to establish clear and uniform standards that strengthen the single market and increase the availability of affordable, accessible products and services. At the same time, this would also enhance the competitiveness of German products.
Just as important as the creation of standards is their enforcement and effective monitoring. This is ensured by the federal states through what is known as market surveillance. The Federal Institute for Occupational Safety and Health (BAuA) supports this process by coordinating efforts among the federal states and facilitating communication with the European Commission and other EU Member States. Consumers who feel their rights have been violated are not alone — they can seek support in asserting their rights either through the BAuA or with the help of a relevant association.
Challenges for e-learning in conception, graphics/design and technology
The various accessibility criteria at EU level also lead to different solutions at the federal level — and this is precisely where one of the main stumbling blocks becomes apparent: there is (as yet) no universal solution for all types of training. Depending on the target audience, it is therefore advisable to assess the needs and requirements of each training course individually.
One of the most “most accessible” solutions, requiring the least effort, might be to offer a PDF document containing the subject matter, which can be read aloud using a screen reader. However, this approach is neither interactive nor particularly engaging.
To still ensure a basic level of accessibility in engaging web-based trainings (WBTs), we have defined a set of baseline criteria that all low-barrier training courses we offer must fulfil. We view these criteria as a foundational framework, on which more comprehensive accessibility features can be built where necessary.
Implementation is focused on three core dimensions: concept, graphic/design, and technology.
In terms of conceptual design, this involves complying with gender-inclusive language, considering diversity, and maintaining product neutrality.
More specifically, all forms of interaction must be formulated in a way that is easily understandable for people with disabilities or impairments. For instance, instead of saying “Click on...”, a more neutral phrase such as “Select...” is used. Similarly, feedback should be clearly worded — not “Take a look at the solution”, but “The correct answer is...”.
Drag-and-drop tasks and mouse-over functions are entirely omitted, as they significantly hinder mouse-free operation. Other visual changes on the so-called “stage” must not be purely time-dependent, as users must be able to process content at their own pace. Screen content must not automatically disappear and should only progress through manual interaction.
Screen readers can be used to read text content aloud in a logical order, but for this to work effectively, the reading sequence must be clearly defined during the planning stage. Adding alternative texts (alt-texts) to images, links, and functional elements is another key conceptual responsibility. Visual content, especially when essential to understanding, must be described clearly and meaningfully.
For video and audio content, a transcript of the audio track, an accessible PDF, subtitles, and where applicable, an audio description must be provided, especially if the media content is crucial to the overall message.
Conceptually, it is also vital to ensure a simple, well-structured page layout, clear and concise language (especially for non-native speakers), and meaningful labelling and organisation of sections.
On the visual design level, all functional elements — such as buttons and links — must be clearly labelled. For keyboard navigation, the “focus” state must be visually evident. In terms of colour usage and contrast, both visual impairments — such as red/green colour blindness — and general legibility must be considered. This includes using strong contrasts and avoiding reliance on colour alone to convey meaning. Whenever possible, text embedded within graphics should be avoided, and layouts should allow for adjustable font sizes.
Finally, at the technical level, pages must be designed to be responsive and allow for adjustable text spacing. Audio and visual elements should not auto-play or auto-display, but rather be user-activated. Furthermore, accessible PDF documents must be created for all course materials, and glossary access must be designed to be barrier-free.
There is no doubt that producing accessible e-learning is significantly more complex — and therefore more costly. However, we must primarily consider those who stand to benefit from these efforts. These include highly skilled individuals who, despite physical or cognitive limitations, possess valuable talents and expertise — people whose abilities might otherwise go underutilised in conventional learning environments. With fully accessible e-learning, we can unlock and support their development more effectively. In the end, though, it is the world of work that stands to gain the most — especially in light of the current shortage of skilled professionals.