How to get your LMS ready to meet the European Accessibility Act requirements

Practical Steps for Moodle and Totara Site Owners

Both Moodle and Totara are designed to meet WCAG 2.1 Level AA standards out of the box. However, themes, third-party plugins, and inconsistent content practices can undermine compliance with the new EAA Accessibility legislation (Directive (EU) 2019/882).

Here’s how to make sure your Moodle or Totara platform meets EAA requirements and delivers a better learning experience for everyone.

1. Start with an Accessibility Audit

Assess your LMS against WCAG 2.1 AA using both automated and manual testing:

Automated tools:

Use an automated tool like BrowserStack, Axe or Wave to identify:

• Low colour contrast
• Missing alt text
• Non-keyboard-accessible navigation
• Focus traps or missing focus indicators
• Incorrect heading structures
• Non-Descriptive Links
• Missing Video Captions

Manual testing:

• Use screen readers like ReadSpeaker, NVDA, JAWS, or VoiceOver
• Test keyboard-only navigation  (Tab, Shift+Tab, Enter, Esc)
• Check colour contrast – example: WebAIM Contrast Checker

Audit content:

• Test images for alt text
• Check that headings used semantically (not just bold text)?
• Check that videos are captioned or transcribed
• Note – eBooks are included in the legislation so ideally should be included for testing under the content umbrella.Compliance isn’t measured as a score, it is about meeting required success criteria.

2. Review theme and plugin compliance

Theming

Themes in Moodle and Totara define the visual design, layout, and navigation of your LMS platform. While the core LMS frameworks (Moodle’s Boost / Totara’s base theme) are designed to meet WCAG 2.1 AA, custom or third-party themes, as well as branding, often introduce accessibility problems that can compromise overall compliance.

Plugins

Plugins (add-ons, blocks, activities, and integrations) extend functionality but they can also introduce design, coding, and usability inconsistencies for learners using assistive technologies. Similar to other accessibility issues it is recommended that  you audit all installed plugins and identify accessibility blockers early. 

3. Develop a Compliance Plan

After your audit:

• Prioritise critical fixes (navigation, login, course pages)
• Assign responsibilities and create a timeline/project plan
• Decide on cadence and schedule re-audits to track progress

4. Publish an Accessibility Statement

Businesses must display an accessibility statement outlining their commitment and efforts towards accessibility. Developing an Accessibility Statement, by W3C outlines what should be included in an accessibility statement. It is advisable to include any known limitations, to avoid frustration of your users.

5. Maintain Continuous Updates and Training

Accessibility is a shared responsibility. Train your administrators, designers, and course creators to:

• Understand accessibility issues and adopt best practices
• Recognise and fix common accessibility issues
• Use assistive tools during testing
• Keep up with evolving WCAG standards

Accessibility is an ongoing process:

• Re-test after theme or plugin updates
• Monitor new releases for accessibility changes
• Update your accessibility statement and training materials regularly

Moodle Theme –  Boost Union 

For Moodle one solution is to explore the Boost Union theme. Boost Union is a child theme of the base Moodle Boost theme, known for being WCAG certified.  Boost Union follows a design principle of being configurable and disabled by default. This allows administrators and users to choose and enable only the accessibility features they need. This approach ensures that the theme doesn’t hinder accessibility for everyone by imposing unnecessary or conflicting features. Boost Union provides a facility for users to report accessibility issues and a facility to devise and display an accessibility statement. 

You can also add an Accessibility plugin – Moodle-local_accessibilitytool. This provides configuration options for the user to change colour scheme, font style, readability and text size across the whole site. This benefits all users, including those with disabilities.