Accessibility usually turns up late in a training project. The course is storyboarded, the films are shot, and someone in the procurement asks whether the material meets WCAG. What remains is to add subtitles, write alt texts after the fact and hope that the interactions can be reached with a keyboard. It gets expensive, it often ends up half-done, and the course rarely gets better from it.
At the same time there is a misconception that pulls in the opposite direction: that accessibility means offering everything. Film, audio, text, transcript and a downloadable PDF for every segment, so that the participant can choose for themselves. It sounds generous. In practice it is often a way to avoid making a pedagogical decision, and it makes the course neither more accessible nor better.
This blog post covers what is actually required, of whom, how accessibility relates to usability, where the line against overambition runs, and how we build it into production instead of bolting it on afterwards.
What the law requires, and of whom
For public-sector organisations the Act on accessibility of digital public services applies – often called the DOS Act. It refers to the European standard EN 301 549, which in turn builds on WCAG 2.1 Level AA. That is therefore the level that is the starting point for a government agency, region or municipality that commissions digital training.
A detail that is often missed: intranets and extranets are covered too. They count as websites for closed groups, and the requirement applies to those published from 23 September 2019 onwards. An intranet published before that date is covered only when it undergoes a substantial overhaul. That means an internal learning portal on an older intranet may sit outside the requirement today, but fall inside the next time it is rebuilt. Building accessibly only then is more expensive than doing it straight away.
Private employers are not covered by the DOS Act. They are, however, covered by the Discrimination Act, where inadequate accessibility is a form of discrimination. An employer must take reasonable accessibility measures so that a person with a disability can be put in a comparable situation to others. That applies to employees, job applicants and interns. What is reasonable is weighed against economic and practical conditions and against how lasting and extensive the relationship is.
The difference between the two frameworks is therefore not that one requires accessibility and the other does not. The difference is that the DOS Act states a measurable level, while the Discrimination Act makes a reasonableness assessment in the individual case. A mandatory internal training that every employee must complete in order to carry out their work is hard to argue away as unreasonable to make accessible.
On top of that comes a practical driver that often weighs heavier than both: procurement. A private company that delivers training to the public sector meets the WCAG requirements anyway, because the buyer must pass them on. The same applies to anyone who sells a learning platform to a government agency.
The boundaries are rarely obvious
What makes the area difficult is not finding the rules. It is deciding which ones hit your particular training. A course can sit in a platform that is covered while the content was produced by someone else. A company can be private but carry out publicly funded activities. A training programme can start as internal and then be sold on. An intranet can have been built before September 2019 and still have modules added long afterwards. In every case the boundary moves depending on details that are rarely documented anywhere.
Beyond the DOS Act and the Discrimination Act there are also other frameworks that may become relevant depending on the organisation, industry and who the training is aimed at, not least through EU directives that are gradually implemented in Swedish law. We do not list them here, because a catalogue risks becoming both incomplete and quickly out of date. The point is that the assessment must be made carefully case by case, and that it should be made together with someone who knows your organisation and the law, not from a general rule of thumb.
Our practical recommendation: when the boundary is unclear it is almost always cheaper to build to WCAG 2.1 AA from the start than to investigate whether you are exempt. The investigation often costs more than the measure, and the answer can change the next time the system is rebuilt.
High usability and high accessibility are not the same thing
The terms are often used as synonyms. They overlap heavily, but they are not interchangeable, and the difference matters when you have to prioritise.
Accessibility is a floor with a defined level. Can the course be used with a keyboard? Does the video have subtitles? Is the contrast sufficient? Does a screen reader read the headings in the right order? It can be tested, it can be approved, and it can be required in a contract.
Usability is a slope without a pass mark. Is the course comprehensible? Does the participant know where they are and what is expected? Does the next step feel obvious? It can be measured, but not ticked off.
That is why a course can fully meet WCAG and still be painful to go through. Every contrast value can be correct while the structure is incomprehensible and the language is bureaucratic. Conversely, a course can be elegant and well written and still shut out everyone who does not use a mouse.
What matters in practice is that the work overlaps more than the concepts do. Clear headings, consistent navigation, plain language, subtitles and comprehensible link texts help everyone, not only someone with a disability. Subtitles are used by more people sitting in an open-plan office without headphones than by people with hearing loss. That is why accessibility work is rarely a sacrifice for the other participants. It is usually the same work that makes the course better for everyone.
Choice is not the same as accessibility
Here lies the trade-off few talk about. The reasoning sounds reasonable: everyone learns differently, so offer film, audio, text and transcript and let the participant choose. But it rests on two assumptions that do not hold.
The first is that every participant has a learning style that the teaching should match. That idea has not been supported by research, even though it is persistent. Letting someone choose format does not affect how well they learn the content. What matters is how the content is structured, how it is worked with and how it is tied to something the participant already knows.
The second is that more formats automatically mean higher accessibility. WCAG requires equivalent alternatives for specific things: text alternatives to images, captions to speech, audio description where the image carries information that is not spoken. A transcript is an alternative to the audio in a film. It is not an alternative to the course, and it is not a second pedagogical track.
The difference is decisive. An equivalent alternative gives the same content in another form. Four parallel formats give four different experiences that must be kept in sync, updated at the same time and quality-assured separately. In practice they drift apart. The text version is updated, the film is not, and after a year they say different things. Then you do not have four accessible paths; you have one current and three misleading.
There is also a cost for the participant. Choosing a format before you know anything about the content is a decision most people cannot make on good grounds, and it takes attention away from what is actually meant to be learned. A course that says this is how we go through this is usually more respectful of the participant’s time than one that offloads the choice.
The conclusion is not that alternatives are wrong. The conclusion is that you must dare to decide on a pedagogical path, make that path really good and make it accessible, and then add the equivalent alternatives that are actually needed. Not every format for every piece of content, as a matter of principle.
How we build accessibility into the process
What makes accessibility expensive is almost always that it comes last. Built in from the start, the extra cost is small. This is what it looks like in our production.
1. Needs and analysis
Ask early which level applies and why. If the buyer is a public-sector organisation, WCAG 2.1 AA is the starting point. If it is a private employer with a mandatory training, the reasonableness assessment is different from that for an optional deep dive. Also find out which assistive technologies are actually used in the organisation and which learning platform the course will sit in. The platform sets a boundary you cannot build past in the course.
2. Pedagogical design and storyboard
This is the cheapest place to solve it. Decide on the pedagogical path. Write the text alternatives in the storyboard, not afterwards, so that the person writing the script also formulates what the image should convey. Drop interactions that cannot be performed with a keyboard before they have been designed. A drag-and-drop exercise that has to be rebuilt afterwards costs ten times as much as choosing a different interaction at the storyboard stage.
3. Production
Contrast, focus order, heading levels, alt texts and subtitles are production steps with a named owner, not a final check. Subtitles should be reviewed, not only generated. Automatic transcription of Swedish specialist terminology rarely comes out right without a human pass, and a subtitle with the wrong term is worse than none at all.
4. Testing
Automated tools find some things, above all contrast, missing alt attributes and incorrect markup. They do not find whether the alt text is meaningful, whether the focus order is logical or whether the content can be understood. Complement with a pass entirely without a mouse, a check with a screen reader and, when possible, a real user. Test in the platform the course will sit in, not only in the authoring tool.
5. Maintenance
Accessibility decays. Every update can break it: a new image without alt text, a pasted heading at the wrong level, a film replaced by one without subtitles. Appoint an owner, build the check into the routine for content updates and rerun the test when the course changes fundamentally. It is the same thing that applies to any other content that is meant to live on.
In summary
Find out which framework applies and which level the buyer requires. Treat accessibility as a floor you should get above, not as an ambition. Put the work into the analysis and the storyboard where it is cheap. And dare to decide on a pedagogical path instead of offloading the choice onto the participant in the name of accessibility. A course that is thought through, clearly structured and built for keyboard and screen reader is more accessible than one that offers four formats and does none of them well.
We build training with accessibility baked into the process, in our own platform, in WordPress or in the environment you already have. If you have existing material that needs to be reviewed against WCAG, we help with that too.