How does it affect Learning Management Systems?
Since June 2025, the European Accessibility Act (EAA) (Directive (EU) 2019/882), is now part of Irish law under Statutory Instrument No. 636 of 2023. This directive is reshaping how digital platforms in Europe, including Learning Management Systems (LMSs), now need to be accessible to everyone.
This marks a major shift towards digital inclusion, and for LMS providers, it means accessibility can no longer be optional; it is a legal and ethical obligation.
Key deadlines
- June 2025: All new digital content must meet EAA accessibility requirements.
- June 2030: All existing content must be updated to comply.
Who must comply
If your organisation provides digital learning services to consumers, you must comply with the EAA unless you qualify as a microenterprise:
- Fewer than 10 employees, and
- Annual turnover below €2 million.
Enforcement in Ireland
The EAA will be enforced by market surveillance authorities and compliance authorities, who can issue directions to businesses to comply with the directives. They also outline a procedure for individual consumers to take action against businesses in Irish courts.
National Disability Authority (NDA) – Acts as the National Monitoring Body under the EU Web Accessibility Directive; conducts reviews of public sector websites and mobile apps. The NDA issues notices, publishes reports, and provides guidance to public bodies.
Centre for Excellence in Universal Design – Oversees monitoring & compliance, including web accessibility under the EU Directive and disability legislation.
Why does it matter?
According to the World Health Organization, over one billion people, about 15% of the global population, live with a disability. In Ireland alone, that’s 640,000 people, or one in seven citizens. The EAA recognises that accessibility benefits everyone, not just those with permanent disabilities. Temporary impairments, ageing, and environmental factors all affect how people interact with technology.
“Diversity is being invited to the party; inclusion is being asked to dance.” — Verna Myers
When it comes to digital inclusion for LMS users, what does it look like if you can’t dance? What are the issues encountered by users when an LMS is not meeting accessibility guidelines?
- Fixed text sizes or poor contrast make reading challenging or impossible for low vision users
- Instructions like “click the green button” exclude those who are colour blind and can’t distinguish colours
- Drag-and-drop quizzes or mouse-only navigation prevent learners with motor impairments from completing tasks
- Screen readers can’t interpret unlabeled buttons, menus, or quiz controls making the LMS impossible for blind users to navigate
- Videos or audio modules without captions/transcripts block understanding for deaf or hard-of-hearing users
- Un-structured content without headings or logical order creates confusion for neurodiverse learners and possibly all learners
What Standards Apply
Although the EAA doesn’t name a specific standard, WCAG 2.1 Level AA is the accepted baseline. Key requirements that apply to Learning Management Systems including content and ebooks will include:
- Perceivable information: Content must be presentable to users in ways they can perceive (e.g., text alternatives for non-text content, captions for multimedia)
- Operable interface: All functionality can be used via keyboard or assistive technology.
- Understandable information: Information and operation must be understandable (e.g., readable text, predictable functionality)
- Robust content: Content must be robust enough to be interpreted by a wide variety of user agents, including assistive technologies
Next in This Series
In our next post, we will share practical steps LMS providers can take to achieve EAA compliance, including accessibility audits, technical updates, and content best practices for Moodle and Totara.
