More and more organisations are selling online training courses, and more and more public sector bodies and universities are managing their own courses using Moodle. On all these platforms, there are people who navigate using a keyboard, who use a screen reader, or who cannot distinguish between certain colours.
Digital accessibility has moved beyond being simply a best practice to become a legal requirement for a large part of the business sector. There is one aspect that Moodle already addresses, and another that depends entirely on how you structure your training.
If your organisation uses Moodle or is considering implementing a platform, it is worth having a clear understanding of both.
Who is bound by the Accessibility Act?
Law 11/2023 transposes the European Accessibility Act into Spanish law and applies from June 2025. Among the services it covers is e-commerce, and this is where many training platforms come into play.
In practice, there are three different situations:
- You sell training courses to individuals via your website. Registration, the purchase process, payment and access to the course must be accessible.
- You work in the public sector. Accessibility was already a requirement before this law came into force and forms part of the tender specifications, alongside the National Security Framework (ENS) and data protection.
- Is your training programme internal, or do you sell it to other companies? The law does not apply to you directly, but you are still obliged to make reasonable adjustments for the people on your staff.
This year, moreover, the regulatory framework has been strengthened: in February, a unit was set up to coordinate the supervisory authorities and handle consumer complaints.
What Moodle offers as standard
Here’s the good news. Moodle LMS, Moodle Workplace and the Moodle App have been certified as compliant with WCAG 2.2 Level AA, the leading international standard for web accessibility.
This means that the platform already has this sorted, without you having to configure anything:
- Full keyboard navigation.
- Compatibility with screen readers.
- Sufficient colour contrast in the interface.
- Correct semantic structure of headings and forms.
- Focus indicator visible when scrolling down the page.
- Accessible labelling of input fields.
The relevant European technical standard, EN 301 549, is still based on WCAG 2.1, so Moodle currently exceeds the requirements of the standard.
The conversation usually ends here. And that is exactly where it should begin.
Where accessibility falls short in practice
An accessible platform with inaccessible content remains, for its users, an inaccessible platform. You are the one who provides the content, and that is where almost all the real problems lie:
- Scanned PDFs, which are images of text that no screen reader can interpret.
- Videos without subtitles or transcripts, which exclude those who cannot hear and also those who are studying without headphones.
- Images without alternative text, or with alternative text such as ‘image1’, which is disruptive without providing any information.
- Links that say ‘click here’, they make no sense to anyone who browses by hopping from link to link.
- Information conveyed solely through colour, which is not visible to those who cannot distinguish between red and green.
- Poorly designed interactive activities, such as an H5P that only allows users to respond by dragging elements with the mouse.
In addition to this, there are two factors that depend on technical decisions:
- The visual theme. Careless customisation can undermine the platform’s compliance in a single afternoon – simply by lowering the contrast of a button or removing the focus indicator. That’s why we at Fresk take care to get this right too.
- Third-party plugins and SCORM packages, which come with their own interface and their own rules. Moodle delivers them, but does not mark them.
There is also an organisational factor worth bearing in mind: the person who creates the content is almost never the same as the person who manages the platform. That is why a well-structured course template works better than a general recommendation.
Where to start
There’s no need to overhaul the entire campus. An environment with two hundred courses cannot be adapted all at once, but the critical path can. A realistic approach would be:
- Prioritise what is used most: access and enrolment, and the three or four courses that the whole organisation goes through.
- Combine automated testing with manual testing. Going through the entire registration process without using the mouse, and repeating it with a screen reader, provides more information than any report.
- Create a course template that includes pre-defined headings, colour contrast and structure, so that the problem does not recur with each new piece of content.
- Ask for subtitles and a transcript when you order the videos; it works out much cheaper than adding them later.
- Document the ‘disproportionate burden’ exception if full adaptation is not feasible in the short term. The law provides for this, but requires it to be justified and reviewed.
The 3ipunt approach
At 3ipunt, we have been working for many years with universities, public authorities and businesses that require training platforms which meet stringent regulatory requirements.
As Spain’s first Moodle Premium Partner, accessibility is an integral part of how we approach projects: from the development of our own themes and plugins to the review of customisations and content on each platform. It is another key criterion, on a par with security and performance.
This is a requirement that is also appearing with increasing frequency in public tender documents and in the procurement processes of large organisations.
Is your training platform accessible?
If your organisation sells online training or works with public authorities, it is important to check how your platform is performing before someone else asks.
At 3ipunt, we help to implement, maintain and develop Moodle environments, ensuring the compliance requirements that each project demands.
