Accessibility in e-learning

The BFSG sets new standards for digital accessibility in Germany. It is based on the European Accessibility Act (EAA) and obliges numerous digital offerings to be accessible from the end of June 2025. This applies in particular to products and services aimed at consumers, i.e. B2C offerings - including many e-learning offerings. Important: The law does not explicitly refer to "e-learning", but to services such as e-commerce, e-books, software, websites or digital services. In practice, however, this applies to digital training content if it is publicly accessible or intended for end users.

The BFSG is the first legal framework that makes digital accessibility mandatory for private sector providers and thus establishes cross-industry standards for the first time.

The main aim of the law is to:

• To give people with disabilities equal access to the world of digital education and products,
• To create harmonized, binding requirements throughout the EU

These requirements may therefore also affect your digital learning offer or your platform ("service") - especially if you are aimed at end users. Internal offerings purely for your own employees are generally exempt (see exceptions below).

The BFSG covers various digital services - the accessibility obligation therefore also applies to many digitally supported educational offers. The following deadlines apply to e-learning offers, which are therefore to be classified as digital services within the meaning of the law:

• From June 28, 2025: the accessibility obligation applies to new offers and content (offered from this date) that fall under the BFSG.
• Existing offers: Services that were already legally provided before June 28, 2025 can continue to be used within the framework of transitional provisions until June 27, 2030 with the previous (i.e. possibly not fully accessible) means. After this date at the latest, 100% accessibility is mandatory.

Digital formats that are frequently affected can be, for example

• Video tutorials and webinars
• Interactive learning modules and quizzes
• E-books and digital scripts
• Learning apps and software training
• Exams and assessments

Important: The law does not provide an exhaustive list. The actual obligation depends on whether your digital offers are considered "services for consumers" within the meaning of the law and how they are structured.

Exceptions (simplified):

• For micro-enterprises (less than 10 employees and less than EUR 2 million annual turnover), the exception only applies to services, not products.
• Purely internal learning offers (e.g. company-internal intranet e-learning) are not affected by the BFSG. In public institutions, separate requirements continue to apply, such as BITV 2.0.

From June 28, 2025, violations of the accessibility requirements will result in serious fines:

• Up to € 25,000 can be imposed for the provision of non-accessible services.
• In the case of particularly serious or repeated violations, fines of up to € 100,000 are possible.
• In addition, fines can be imposed for continued non-compliance. The legislator takes into account the severity and duration of the infringement and the willingness of the company concerned to cooperate.

The principle of perceptibility ensures that information is presented in such a way that it can be grasped by all learners - regardless of their sensory abilities.

Concrete requirements for e-learning content:

• Images and graphics must have meaningful alternative texts. Example: A diagram on the product life cycle does not just have the alt text "Graphic", but "Pie chart: 4-phase product life cycle with sales distribution"
• Infographics must have structured text equivalents. Example: Complex process illustrations are supplemented by additional structured descriptions
• Video content requires subtitles and audio descriptions Example: Video tutorials receive subtitles for spoken content as well as descriptions of important visual information
• Audio content needs transcriptions. Example: Podcast-style learning content provides full text transcripts
• Non-color differentiators^** must also be provided. Example: Errors in quiz answers are not only highlighted in red, but also marked with icons and text

The best results are achieved if you develop a multimodal concept from the outset, i.e. design learning content in such a way that it appeals to different channels of perception or senses. Do not regard alternative representations as an afterthought, but as an integral part of your didactic design.

Usability means that all interactive elements can be activated and controlled by all users - even without a mouse and with different input devices.

Practical implementation in e-learning:

• Full keyboard operability: All interactive elements such as menus, forms, drag-and-drop exercises and quizzes must be operable without a mouse
• Sufficient time measurement: For timed tests, individual adjustments to the available time must be possible
• Navigation aids: Jump labels, logical tab order and consistent structures facilitate orientation
• Avoidance of motion activation: Functions must not be activated exclusively by swipe gestures or shaking
• Input aids: Alternative input methods such as voice recognition must be supported

A practical example: In addition to the usual drag-and-drop control, an interactive simulation for operating a machine also offers step-by-step keyboard control with clear instructions and increased error tolerance. The individual control elements are generously dimensioned and have sufficient spacing.

Comprehensibility goes far beyond plain language and includes the logical organization of content, consistent operating concepts and helpful orientation.

Core aspects for learning content:

• Linguistic clarity: Avoidance of complex sentence constructions and technical terminology without explanation
• Structured content: Consistent heading hierarchies, logical structure, meaningful organization
• Predictable interactions and navigation: Similar functions behave identically in all learning modules
• Error prevention: Inputs are validated, helpful hints are given for correction
• Context help: Glossary for technical terms, context-sensitive help for complex tasks

A concrete example: An e-learning course on programming offers code snippets not only as images, but also as structured text with syntax highlighting. Technical terms are explained the first time they are used and remain accessible at all times through hover or click interactions. Incorrect entries in programming exercises provide specific instructions for correction.

The principle of robustness ensures that content is compatible with current and future technologies, including assistive tools.

Technical requirements:

• Valid code: HTML documents conform to published standard without errors
• Name, role, value: UI components are correctly labeled
• Compatibility with assistive technologies: Screen readers, screen magnifiers, alternative input devices
• Responsive design: Adaptability to different screen sizes and orientations
• Format alternatives: Critical content in different technical formats

A concrete example: Imagine an online course in which complicated graphics or diagrams are explained. In an accessible version, these images are designed in such a way that they are not only clearly visible, but also have a descriptive text (alternative text) that blind people can hear with a read-aloud program. In addition, everything can be operated using the keyboard - and the content works smoothly on any device, whether computer, tablet or smartphone. You don't need to install any special additional programs for everything to work. This means that anyone can use the course without any restrictions.

These are descriptive texts for images and graphics on websites. They are read aloud by screen readers so that people who cannot see also know what is shown on an image.

ARIA stands for "Accessible Rich Internet Applications". ARIA attributes are special additional information in the code of websites or apps. They help people with disabilities, especially blind and visually impaired users, to better understand and operate digital content. For example, a screen reader can use them to recognize which element is a button, whether a navigation is open or closed or which area is particularly important. ARIA attributes are therefore an important tool for enabling accessibility on modern, interactive websites - they make invisible information "visible" for assistive technologies.

Accessibility means that digital offerings, content and services are designed in such a way that they can be used as easily and fully as possible by all people - including those with disabilities or restrictions. This includes visible, audible and comprehensible information as well as ease of use.

The BFSG is a German law that prescribes accessibility for many digital products and services from June 28, 2025. It affects companies and organizations that offer online stores, learning platforms, e-books or other digital services for consumers, for example.

• Products: These are, for example, software programs or devices that are purchased and used - such as an e-book reader, downloaded educational software or an installable app.
• Services: These are digital offerings that you use without owning them, i.e. services that are provided on an ongoing basis such as online courses, learning platforms, cloud software or e-book portals.

Consumers are people who use digital services or products from companies for private purposes - not as part of their own business or profession. They are often also referred to as "end users".

Internal services are offers only for a company's or organization's own employees (e.g. an internal training portal). Public services are accessible to everyone, i.e. the general public or external customers.

WCAG stands for "Web Content Accessibility Guidelines". These are international rules and tips on how to design websites, apps and digital content so that they are as accessible as possible. The BFSG refers to these guidelines (via the EU standard) - they are considered the benchmark for accessibility.

The WCAG distinguishes between different levels of severity (A, AA, AAA). Level AA is the recommended standard for most websites and apps because it removes most barriers and is still easy to implement.

A screen reader is special software that reads out screen content as speech or in Braille to blind and visually impaired people on a computer or smartphone.

This means that a website or app can be controlled entirely with the keyboard, even without a computer mouse. This is particularly important for people with motor impairments or visual impairments.

These are very small companies with fewer than 10 employees and an annual turnover of less than 2 million euros. Special exceptions apply to them under the BFSG - especially for services.

Accessibility is a firmly defined technical and legal standard that takes particular account of the needs of people with disabilities. Usability generally refers to how easy and pleasant software or websites are to use for everyone. Accessibility is therefore a "plus point" for user-friendliness, but is specifically aimed at additional requirements.