Why digital accessibility is now a leadership issue for universities

Digital accessibility is becoming a defining benchmark for global higher education. In Europe, the European Accessibility Act (EAA), which came into effect on 28 June 2025, requires organisations that provide products and services to people in the European Union to meet strict physical and digital accessibility standards. Digital accessibility is the practice of ensuring that digital content and technologies are usable by all, inclusive of disabled people, who face barriers and exclusion when digital environments fail to accommodate diverse ways of perceiving, navigating and interacting with information.  

For universities and other public bodies in the UK, the accessibility regulations for public sector bodies (PSBAR) already contain the legal obligation to meet digital accessibility standards. And the EAA added an important dimension; its commercial scope and tougher enforcement create sharper risks, and bigger opportunities. For museums, cultural institutions and charities, the act underscores accessibility as a condition of market access and consumer trust, not just compliance. It is a leadership challenge and opportunity: whether to settle for the minimum or to embed accessibility as a marker of institutional excellence across teaching, research and civic mission.

A new level of risk

The UK’s regulations already demand compliance, but penalties are limited to civil sanctions. The EAA raises the stakes with criminal liability in some member states. Ireland allows fines of up to €60,000 (about £52,000) and imprisonment, while France levies annual fines per non-compliant website. The German Barrierefreiheitsstärkungsgesetz (BFSG), or Accessibility Strengthening Act, allows for fines of up to €100,000.

For senior executives, accessibility is now a matter of strategic governance and personal accountability.

Like PSBAR, EAA covers far more than digital front doors. It includes:

• documents (PDFs, lecture notes, email attachments)
• platforms (e-learning, CPD systems, publishing platforms)
• media and culture (audiovisual services, digital collections).

Critically, the EAA also extends to hardware, such as e-readers, lab equipment, ATMs and ticketing machines. Universities with a campus or in-person learning in Europe will also need to consider the EAA’s requirements around the built environment and physical accessibility. 

Accessibility, therefore, applies to procurement, IT, estates, digital experience, marketing and academic delivery – where challenges are well documented by disabled students and staff. Digital and IT legacy systems make compliance harder, but they also highlight the need for investment in infrastructure that is designed with disability in mind.

Why Brexit is no shield

The EAA applies to any organisation serving EU consumers. For UK universities, that means students in Europe, online courses, commercial enterprise and publishing. For universities, cultural institutions and charities, it includes visitors, users or clients based in the EU.

Students may be treated as consumers for certain paid, cross-border services. This depends on contractual and national law. Every part of the student experience – from admission portals to lecture recordings – must meet accessibility standards. 

Closing governance gaps

One of the higher education sector’s risk points is governance. Too often, no single department “owns” accessibility, leaving responsibility fragmented and progress on improvements uneven. Sector leaders identified these governance challenges as a key concern at the Accessible Digital Futures workshop in November 2024. 

Change is needed, as the EAA requires an accessible experience across all points of contact that a customer has with a brand or business through online channels, including websites, email, apps and online advertising. Governance is a necessity, and the EAA brings this into sharper focus. It means developing strategies that clearly assign ownership and responsibility across departments, and provide a visible road map for improvements, so that progress is transparent, deliberate and sustained over time. 

• Digital accessibility is real and tangible
• Is collaboration the key to digital accessibility?
• Taking digital accessibility from mandate for change to business as usual

Great work is already taking place across the grass roots of university delivery teams, where accessibility expertise is thriving, but it often lacks opportunities to scale. Resourcing and sustained backing is needed from the top, to ensure this effort is prioritised and aligned with institutional goals. Digital user experience (UX) and accessibility specialists need a place in procurement, governance boards and project sign-off, so this work has lasting impact. 

Sector bodies have a role in issuing guidance and supporting structured knowledge exchange between institutions, work that UK digital service provider Jisc has begun and the country’s Government Digital Service fulfils for the public sector with PSBAR.

Embracing a strategic opportunity

Universities face a choice between meeting basic compliance and striving for inclusive excellence. The former means doing the minimum to avoid penalties, while the latter means embedding accessibility as a core part of strategy and student experience.

To succeed, accessibility needs to be treated as a strategic lever and shared endeavour, not an operational or tactical task. 

Inclusive excellence delivers dividends with longer-term benefits in many aspects:

Market advantage

Inclusivity strengthens international recruitment and distance-learning experience. It also strategically positions institutions to ensure access to markets with changing legislation.

Operational efficiency

Accessible systems are simple and cheaper to run, especially if they are built on good foundations of fully tested components and service patterns.

Staff development

Apprenticeships, internships and continuous professional development build institutional capability.

Reputation

Leadership in accessibility supports teaching, community impact and civic goals by helping all members of society to engage in a democratic knowledge economy. It also meets research funding frameworks, including Horizon and UK Research Council requirements for equality, diversity, inclusion and accessibility.

Student experience

Accessible systems meet disabled students’ requirements, and are also easier for all students to use, which increases equity and student satisfaction.   

The global direction of travel

To get a sense of the global trajectory, look east and west. In the US, the Americans with Disabilities Act (ADA) and Section 508 have long set the benchmark for digital accessibility in public life and education. The EAA builds on the same principles, seeking to create a harmonised framework across the EU. India’s activity is instructive. In 2024, its Supreme Court reaffirmed accessibility as a constitutional right. The new standards, IS 17802, became legally binding in 2023, and in early 2025 more than 150 organisations were fined for non-compliance. For universities operating in India, these rules now apply directly.

This convergence shows that accessibility and EAA alignment is not just about Europe. Together, these frameworks help unite global accessibility expectations; they reference the same technical standards (WCAG 2.2 and EN 301 549), and foster a consistent and shared understanding. They help enforce the conditions that can support progress and improvements in accessibility.

For universities, this means that accessibility should be treated as a global requirement. It is about being ready for multiple markets, reducing compliance complexity through harmonisation, and enhancing global prestige. This is particularly important as universities continue to internationalise and expand operations. 

Procurement and commercial agreements need to take these accessibility dynamics into account. They should require that suppliers evidence how they meet standards, as it is the institution that remains accountable for compliance, not its suppliers. In Europe, supporting standards for the EAA, including those on procurement, are in train to aid organisations in their compliance. As commercial product suppliers must meet accessibility standards for EU customers, UK university procurement policies should ensure that equivalent compliant products are delivered for UK users.

Accessibility can no longer be thought of as a technical challenge, it is a central test of institutional quality. The EAA crystallises the choice for universities and other complex organisations: treat accessibility as a compliance risk or seize it as a catalyst for international inclusive leadership.

Ayala Gordon is a digital transformation, UX and accessibility leader in the public sector. Sarah Lewthwaite is a principal research fellow and co-director of the Centre for Research in Inclusion in the Southampton Education School at the University of Southampton. 

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