This extended abstract is a contribution to the Accessible E-Learning Online Symposium of 16 December 2013. The contents of this paper was not developed by the W3C Web Accessibility Initiative (WAI) and does not necessarily represent the consensus view of its membership.

Implementing Accessibility into Australian Federal Government eLearning

1. Problem Description

Developing and implementing eLearning products in the Australian Federal Government that conform with the Web Content Accessibility Guidelines 2.0 (WCAG 2.0) and the Australian Human Rights Commission Web Disability Discrimination Advisory Notes (Advisory Notes), whilst not compromising the level of interactivity or learner experience.

2. Background

Accessibility in the Australian Government was introduced in June 2010, when the government launched its Web Accessibility National Transition Strategy (NTS). Prior to the NTS, government agencies and their contractors who produced online training materials paid little attention to providing accessible materials.

As of January 2013, the NTS requires all Federal Government web content to be compliant with WCAG 2.0 at Level A. Agencies have taken a step further and have agreed to aim for Level AA conformance and in addition, meet the requirements of the Advisory Notes.

The Human Rights Commission states that developers of online content should assume users with a disability will not have access to current versions of software or know how to use it, meaning developers should not rely solely on one technology.

Developers have a clear responsibility to ensure all technologies are accessible and take into account the realistic situation of users. For a technology to be regarded as accessibility supported, it must be reasonably available to the user, taking into account financial or other considerations.

In other words, it is wrong to assume that an improvement in the accessibility of a technology means that it can be used indiscriminately, without regard for the principles of accessible web design. The WCAG 2.0 principle of being robust, meaning a wide range of technologies can access the content, re-enforces the points made under the Advisory Notes.

The commission also states that non-conforming content can be included in a program assuming the same information or functionality is also available in another way, providing scope for alternative accessible versions.

3. Strategy

It is heavily debated amongst industry professionals on the best approach to accessibility while maintaining the learner experience. While some professionals strive to develop one fully accessible and interactive program, our approach involves developing multiple versions of the one program.

eLearning is generally created as interactive, rich media content which aims to create a heightened learning experience, however this content does not conform with WCAG 2.0 Level AA. We produce a non-conforming interactive version which allows us to retain the user learning experience. The interactive version however is optimised as much as possible for accessibility and conformance with the guidelines. This includes implementing elements such as tab order, colour contrast and alternate text to ensure that learners are provided the greatest return on their learning experience.

In addition to the interactive version, we also produce alternative versions of the content which are more likely to conform. It is not enough to just provide one alternative, as a minimum we would include a Word and PDF version, and ideally an accessible, less interactive HTML version which are optimised for screen readers.

4. Major Difficulties

Creating equal access is important. While there is the temptation to produce a single toned down HTML version to provide the conforming access, we are in turn sacrificing the learning experience for all learners, thus creating ineffective learning. Fletcher, J.D. (1990) documented evidence of the direct relationship between eLearning interactivity and the effectiveness of the learning experience.

Most eLearning in Australian Government is created using authoring tools to create HTML programs. While many authoring tools have improved their accessibility features (mostly in line with the less stringent Section 508 compliance) they still fall short on conforming with WCAG 2.0. This has created extra work in attempting to either modify the HTML/CSS/Javascript or rethink and create a different interaction.

Incorporating accessibility has added up to 20 per cent extra work to a typical project. It has required significant allocation of resources to produce the materials required. Although this has become a required part of any project, it has come at significant cost to the department.

5. Outcomes

A lot of work has been done to convert Federal Government eLearning to meet the accessibility requirement in Australia. Many federal departments have adopted the above strategy to achieve this. However, the strategy is evolving as new developments are made and tools available become more supportive.

Compliance with WCAG 2.0 is strongly recommended, but will not, of itself, always guarantee equal access to the web and the fulfillment of obligations under the Disability Discrimination Act and the Convention on the Rights of Persons with Disabilities (excerpt from the Advisory Notes).

A key lesson learnt, is that organisations cannot rely on one technology. After countless testing using assistive technologies, we have discovered that relying on one technology does not work for all users and fails to conform with the Advisory Notes. At the very least, organisations should be producing an accessible Word and PDF version.

It is important to note that the learner experience should remain the most important component of online training. From an instructional design perspective, it does not make sense to sacrifice learner experience as it can lead to poor learning, and ultimately poor productivity. Accessibility needs to become an extension of projects, enhancing them where possible and offering accessible alternatives that provide the greatest learner experience possible, but still adhering to the guidelines.

Incorporating conformant accessibility has become a required part of every project. A key learning has been to include accessibility at the start of the project and factored into any project management process. This is to ensure that both the timeline and cost are taken into account.

Finally, another key lesson is not to rely on the accessibility features of authoring tools to conform with WCAG 2.0, most authoring tools are developed to the less stringent Section 508 requirement and no eLearning authoring tools currently exist to create fully interactive accessible eLearning.

In 2013, the work of some Australian federal government departments to implement accessibility in eLearning was recognised by the LearnX Foundation. The Department of Education, Employment and Workplace Relations and the Department of Immigration and Citizenship were both conferred awards for Best eLearning design – Accessibility at the LearnX Impact Awards.

6. Open Research Avenues

With the growing demand for HTML5, there is topical debate as to whether we can produce one fully accessible, rich media version for all users. There has been some development in the area, but no one has yet produced such a concept.

While WCAG 2.0 and the Advisory Notes have been reasonably clear on information and guidance for typical web content, for eLearning, they remain quite grey. This has meant the guidelines have needed to be interpreted and implemented by professionals, which leads to issues. There is scope to produce more guidance on eLearning content as it introduces many elements not considered when creating other web content. Clear guidance will hopefully lead to a uniform standard across the industry in Australia.

We need to remember currently, and for future research, that we do not at any stage compromise the learning experience. In some ways the current guidelines in Australia limit the potential of eLearning out of fear for not conforming to the guidelines. That is not to say we do not implement accessibility, there is great potential in producing accessible eLearning as we are opening access to as many users as possible. Currently in Australia, 20 per cent or 1 in 5 people identify as having a disability (Australian Bureau of Statistics, 2011) and of 165,906 government employees, approximately 7 per cent identify as having a disability, a significant portion of the learner population (The Australian Public Service Commission State of the Service Series 2010-11).


  1. Journal: Fletcher, J.D. (1990), Effectiveness and Cost of Interactive Videodisc Instruction In Defence Training and Education and Instructional Effectiveness Study, Skills Sydamics (1992), both referenced in e-Learning Developers’ Journal, July 16 2002.
  2. Website: Australian Bureau of Statistics (2011), One in 5 Australians with a disability, viewed 12 November 2013, <>.
  3. Website: Australian Human Rights Commission (2010), World Wide Web Access: Disability Discrimination Act Advisory Notes ver 4.0, viewed 13 November 2013, <>.
  4. Website: Australian Public Service Commission (2010-11), Employee Survey Results State of the Service Series, viewed 12 November 2013, <>.
  5. Website: Ben Caldwell et al. (2008), Web Content Accessibility Guidelines (WCAG) 2.0, W3C, viewed 13 November 2013, <>.