Does a private online learning platform have to be accessible since 2025?

As a rule, yes. Since 28 June 2025 the BFSG has applied, among other things, to e-commerce services: services offered via websites or apps and provided electronically at a consumer's individual request with a view to concluding a consumer contract. Anyone selling online courses or e-learning offerings to consumers in this way is generally covered. Micro-enterprises providing services are exempt: fewer than 10 employees and an annual turnover or balance sheet total of no more than 2 million euros. The BFSG requirements cover the details.

Does BITV 2.0 also apply to state universities?

For federal universities, yes: BITV 2.0 applies to federal public bodies. Universities run by the federal states are subject to the respective state law, which also implements EU Directive 2016/2102. In both cases an accessibility statement must be published, a feedback mechanism provided and the enforcement procedure named. The technical requirements are based on EN 301 549 and WCAG 2.1 AA. We assess the status against Table A.1 of EN 301 549 in the BITV assessment.

How are video lectures made accessible?

Video lectures require at minimum corrected captions (WCAG 1.2.2) and, where essential visual content is not described by the spoken text, an audio description (WCAG 1.2.5); a transcript is also recommended. Automatically generated captions are a useful starting point but must be manually checked for technical term accuracy. The media player itself must be fully operable by keyboard.

Can Moodle be configured to be accessible?

Moodle has made considerable improvements in accessibility since version 4.x. Many WCAG 2.1 AA criteria are met in the core. Some plugins and activities remain problematic, particularly older H5P content and database activities. With targeted theme adjustments, plugin selection and configuration, a high level of conformance can be achieved. We carry out Moodle-specific WCAG audits and recommend concrete measures.

How are mathematical formulae made accessible for screen readers?

Formulae as images are inaccessible to screen readers. The W3C standard MathML enables a semantic representation of mathematical expressions that can be read by modern screen readers. Via MathJax, LaTeX input can be automatically converted into accessible MathML and visual rendering. We configure MathJax in Moodle, ILIAS and other LMS and train teaching staff in accessible mathematical typesetting.

Does implementing accessibility mean abolishing reasonable accommodations for students?

No. Accessibility and reasonable accommodations are not mutually exclusive. Accessibility ensures that digital systems are fundamentally accessible. Reasonable accommodations address individual needs that go beyond general accessibility, such as extended exam time or special technical tools. Both instruments are complementary and should be used in parallel.

Accessible Education: WCAG 2.2 and BFSG for Universities and Learning Platforms

Learning management systems, video lectures, exam portals and PDF handouts must be accessible to every student — depending on the provider and the service, this is required by the BFSG or by the rules for public bodies. We audit against WCAG 2.2 AA, prioritise and technically implement accessible learning environments, with a WCAG audit from €2,480 fixed price.

Request a Free Consultation View WCAG Audit

WCAG 2.2 audit from €2,480 fixed price Audit against WCAG 2.2 AA and EN 301 549 Own accessibility statement published

In short and in plain language

This page is for universities and providers of online courses. It is about learning platforms, videos, scripts and exams.

All students should be able to use these services. This includes people with disabilities. Private providers often fall under the BFSG. This is a German law. Public universities have their own rules.

We test your systems against the WCAG. These are rules for accessible websites. For example, we check if videos have captions. We also check if people can take tests with a keyboard.

You get a plan that shows what to fix first. We help you put it in place and train your teaching staff.

Do you have questions? Write to us or give us a call.

Key figures

EN 301 549

audit basis

WCAG 2.2 AA

audit benchmark

Fixed price

audit quote after reviewing your systems

28 June 2025

BFSG effective date

Accessibility for educational institutions

from €2,480 fixed price net

WCAG 2.2 AA audit of LMS, exam portal, video lectures and PDF scripts
Prioritised action plan by severity and legal risk
Accessibility statement under BITV and BFSG for €390 fixed price

Request a Free Consultation All services and prices

WCAG 2.2 audit (SMEs up to 30 pages). Start with the BFSG quick check for €490; accessible remediation for LMS, videos and portals from €4,900 net. A concrete fixed quote follows a review of your systems.

Prices as of October 2026.

Accessibility in education is not a voluntary service but a legal and ethical obligation. For private providers selling online courses to consumers, the Accessibility Strengthening Act (BFSG) applies; public universities are subject to the rules for public bodies. In both cases, EN 301 549 serves as the technical benchmark. Students with visual, hearing or motor impairments must not be disadvantaged through poorly accessible learning platforms, uncaptioned video lectures or non-navigable exam portals. We guide educational institutions from a systematic audit through to accessible implementation.

WCAG 2.2 AA · BFSG · Education

Building blocks of an accessible learning platform

Six accessibility building blocks that matter in digital learning environments

Accessible learning platform · WCAG 2.2 AA

LMS course navigation · keyboardVideo lectures · captionsPDF scripts · PDF/UAExam portal · extendable time limitMathematics · MathML not imagesStudent portal · form labels

Findings total56prioritised

GoalWCAG 2.2 AAafter work

Findings listSeveritysorted descending

WCAG 2.2 auditfrom €2,480 fixed price

Audit reportprioritised and verifiable

Accessibility audit of a learning platform: six audit areas, findings by severity and the implementation goal. Example view — values are illustrative.

Our audit benchmark: WCAG 2.2 AA

WCAG 2.2 AA covers the requirements of WCAG 2.1 AA on which EN 301 549 has been based so far; the new version V4.1.1 adopts WCAG 2.2. We assess our own website against WCAG 2.2 AA ourselves; status and known limitations are set out in our accessibility statement. For private education providers selling to consumers online, the BFSG has applied since 28 June 2025; violations can incur fines of up to €100,000 (BFSG §37). A systematic audit documents the status of your systems and the measures required.

Specific Challenges in the Education Sector

Educational institutions operate multiple digital systems simultaneously: learning management systems such as Moodle, ILIAS or Canvas, video conference platforms for lectures, exam portals, library catalogues, student portals and the main website. These systems are often grown IT landscapes in which accessibility was historically not a priority. At the same time, the user group is particularly heterogeneous: students with learning difficulties, motor impairments, visual disabilities or chronic conditions must be considered alongside international students who benefit from well-structured language quality.

The significance of exam situations adds another dimension: an inaccessible exam portal can prevent a student with impairments from sitting an exam under standard conditions. This is not merely a WCAG violation but can have legal consequences for the institution. Under section 2(4) of the Framework Act for Higher Education (HRG), universities must ensure that students with disabilities are not disadvantaged in their studies and can use the university's services as far as possible without outside help. The BFSG requirements for private education providers add to this obligation from 28 June 2025 onwards. We help institutions understand and address these legal requirements systematically.

Learning Management Systems

Moodle, ILIAS, Canvas and comparable LMS must be accessible to keyboards, screen readers and assistive technologies. Course navigation, assignment submission, forums and grade views are typical problem areas that we audit and optimise specifically.

Video Lectures and Webcasts

Recorded lectures and live streams need correct captions; transcripts additionally make access easier. We check caption quality, media player accessibility and integration into learning platforms against WCAG 1.2 (time-based media).

Learning Materials and Scripts

Lecture PDFs, presentations and scripts must be structured according to PDF/UA: correct tag structure for headings and tables, alt texts for graphics and formulae, logical reading order. Mathematical formulae in particular have specific requirements.

Exam Portals and E-Assessments

Online exams must be equally accessible to all candidates. Time limits must generally be possible to turn off, adjust or extend (WCAG 2.2.1), multiple choice questions must be implemented as proper radio groups, and result feedback must be programmatically linked.

Student Portals and Administration

Enrolment, re-registration and exam registration portals must be accessible to all students. Form fields with labels, understandable error messages and clear process guidance are essential for administrative portals.

University Websites and Public Presence

The institutional website with programme information, application portals and event calendars is the first point of contact. Poor accessibility here deters potential students even before enrolment.

Making Video Lectures and Time-Based Media Accessible

Time-based media — recorded lectures, explainer videos, webinars and live streams — are especially critical in education because they carry the core content of learning. WCAG 1.2 is dedicated entirely to this category and sets clear requirements: captions for all pre-recorded videos (1.2.2), audio description for visual content that is essential to understanding (1.2.3 and 1.2.5), and transcripts for audio-only content (1.2.1). Level AA additionally requires synchronised audio descriptions.

Automatically generated captions frequently mistranscribe technical jargon, proper names and mathematical expressions. Left uncorrected, they are of little use to deaf or hard-of-hearing students and must be manually corrected. We audit the caption quality of existing materials, advise on suitable captioning workflows and train your teaching staff in the creation of accessible video content. For the media player itself, we check keyboard accessibility, screen reader output and volume control by keyboard.

Accessible video lectures: what is concretely audited

Captions, transcript and audio description

An accessible video lecture goes beyond automatically generated captions. We check the quality, accuracy and synchronicity of captions as well as the accessibility of the media player itself and train teaching staff in creating WCAG-compliant video materials.

Caption quality and technical term accuracy checked
Transcripts for all recordings in an accessible format
Media player fully operable by keyboard (play, pause, volume)
Audio description for visual teaching content (formulae, graphics, demonstrations)

WCAG 1.2 · time-based mediaCC on

1.2.1 Audio-only and transcript

1.2.2 Captions (recorded)

1.2.3 Audio description open

1.2.4 Live captions

1.2.5 Audio description AA open

Technical term accuracy78 %

Media player fully keyboard operableverified

Learning Management Systems: Accessibility at the LMS Core

The LMS is the heart of digital teaching. Moodle, ILIAS and Canvas have different starting positions with regard to accessibility. Moodle and ILIAS have removed many barriers in recent versions. Gaps can nonetheless remain, for example in complex activities such as glossaries, databases, tests and H5P content or in embedded external tools. How accessible a platform actually is depends heavily on version, theme, plugins and configuration.

We carry out LMS audits that look beyond the surface to examine the complete learning path: course enrolment, navigation between lessons, assignment submission with file upload, forum interaction, quiz completion and grade viewing. Special attention is paid to dynamic content: when an assignment is submitted and a confirmation message appears, it must be programmatically announced (ARIA live region). When a quiz has a time limit, users must generally be able to turn it off, adjust it or extend it (WCAG 2.2.1). These requirements are frequently overlooked in standard LMS configurations.

Course Navigation and Structure

Course menus, lesson paths and page hierarchies must be keyboard-navigable and structurally understandable to screen readers. Breadcrumbs, skip links and a consistent heading hierarchy are essential.

Quizzes and Tests

Multiple choice questions as radio groups, time limits with extension options (WCAG 2.2.1), error feedback programmatically linked. Result views must be readable by screen readers and have sufficient contrast.

Assignment Submission and Feedback

File upload fields with correct labels and ARIA descriptions. Confirmation messages as ARIA live announcements. Instructor feedback in an accessible format, fully readable with assistive technologies.

Forums and Discussions

Discussion forums as a frequently used learning component must have correctly hierarchically structured reply threads and accessible notifications. New posts must be recognisable and readable without a mouse.

Grades and Learning Progress

Grade books and progress indicators in LMS must be implemented as tables with correct header markup or labelled lists. Bar charts and percentages need text alternatives.

Materials Library

Download areas for scripts, slides and materials must be accessible. Filenames must be meaningful, file types programmatically named and downloads triggerable without a mouse.

Exam Equality and Legal Risk

Inaccessible exam portals can be treated as a violation of anti-discrimination law. Under section 2(4) HRG, universities must ensure that students with disabilities are not disadvantaged in their studies. Students can demand reasonable accommodations and, in cases of persistent disadvantage, take legal action. A systematic audit and documentation records where barriers exist and how the institution is removing them.

Making Mathematical Formulae and STEM Content Accessible

Mathematical and scientific content places specific demands on accessibility. Formulae embedded as images are completely inaccessible to screen readers. MathML is the W3C standard for accessible mathematics on the web and is supported by modern screen readers such as NVDA with MathPlayer. LaTeX-based systems can be switched to accessible MathML output via MathJax, which is configurable in Moodle and ILIAS.

We support STEM-focused departments in converting their digital materials: migrating formula images to MathML, configuring MathJax in LMS environments, training teaching staff in accessible mathematical typesetting, and auditing interactive simulations and graphics for accessibility. Chemical structural formulae and physical diagrams need qualitative text descriptions that make the content understandable for blind students. These descriptions require subject knowledge, which we pass on to teaching staff through training sessions.

Where does your digital learning environment stand today?

We audit your LMS, video lectures, exam portal and scripts against WCAG 2.2 AA and deliver a prioritised action plan — WCAG audit from €2,480 fixed price.

Request a Free Consultation Call +49 5123 9579000

Legal Framework for Educational Institutions

Educational institutions are subject to a tiered system of legal bases. Public universities in Germany are subject to the rules for public bodies: federal universities to BITV 2.0, state universities to the respective state law. Private education providers, online course operators and continuing education platforms that sell to consumers online have been required to comply with the BFSG since 28 June 2025, unless they are micro-enterprises. This covers not only websites but also mobile apps through which such services are offered and provided.

BFSG has applied since 28 June 2025 to online course providers selling to consumers (micro-enterprises excepted)
BITV 2.0 applies to federal public bodies; universities run by the federal states are subject to the respective state law
BGG §12a obliges federal public bodies to make their websites and mobile applications accessible
Accessibility statement mandatory for public bodies (BITV 2.0 or state law)
The technical reference standard is EN 301 549, which builds on WCAG; our audit benchmark is WCAG 2.2 AA
Reasonable accommodations for students do not absolve institutions of accessibility obligations

Our Audit Approach for Educational Institutions

Step 1

Inventory and Scope Definition

Together we record all digital touchpoints of your institution: LMS, website, exam portal, library system, apps and e-learning materials. We prioritise by frequency of use and legal risk, so that exam-relevant systems are analysed first. We test web interfaces in the browser; for native apps we support the development, and tests on real devices are not part of our assessment.

Criterion	Without a systematic audit	With BFSG Expert
Legal risk	Barriers undetected, warning-notice risk	Barriers documented and prioritised against WCAG 2.2 AA
Exam portals	Accommodations purely reactive	Accessibility audit before the exam period
Video lectures	Automatic captions, error-prone	Captions and transcript checked
LMS (Moodle, ILIAS, Canvas)	Default configuration with gaps	Theme and configuration fixes at the core
Accessibility statement	Text template without a testing basis	Based on a real audit, for €390
Cost framework	Unclear, project-dependent	WCAG audit from €2,480 fixed price

Accessibility as a Quality Standard in Teaching

Accessible learning environments benefit not only students with disabilities. Clear video structure with chapter markers helps everyone who cannot watch an entire lecture in one sitting. Transcripts enable more efficient learning and simplify exam preparation. Correct heading hierarchies in scripts improve navigation for everyone. Accessible exam portals reduce technical stress during examinations. These side effects argue for treating accessibility not as a special case but as a standard in didactic quality assurance.

Universities and educational institutions that invest early in accessibility also reach a group that has grown: the proportion of students with a health impairment that makes studying more difficult rose from 8 per cent in 2011 to around 16 per cent in 2021 (DZHW, best3, 2023). Institutions that offer an accessible learning environment can increase their attractiveness to these students while fulfilling the legal framework. Implementation usually takes less effort when accessibility is considered early in the development process; we describe our project approach under references.

For institutions wishing to develop a comprehensive accessibility strategy, we offer, in addition to technical implementation, strategic consulting: defining quality standards for new materials, establishing review processes in course development, building internal competencies for sustainable accessibility management and continuous monitoring of all digital access points. The goal is an educational institution that views accessibility not as an external obligation but as part of its pedagogical ethos.

Teaching material, video and e-books

Recorded lectures need more than automatic captions — what belongs to a complete solution is described in the article on captions and transcripts. For scripts and handouts the article on accessible PDFs is the right entry point, complemented by the PDF accessibility service page. Where publishers and universities distribute digital textbooks, the rules from the article on e-books and EPUB obligations under the BFSG apply as well.

Key takeaways

Accessible education under WCAG 2.2 AA covers the LMS, video lectures, exam portals, PDF scripts and the university website alike
The BFSG has applied to private education providers selling to consumers online since 28 June 2025; fines up to €100,000 (BFSG §37)
WCAG 2.2 audit from €2,480 fixed price (SMEs up to 30 pages), entry via the BFSG quick check for €490
Accessible remediation for learning environments from €4,900, accessibility statement at a fixed price of €390
Time-based media (captions, transcript, audio description) and time limits in exam portals are among the critical audit points

Frequently Asked Questions on Accessibility in Education

How the website of a rehabilitation clinic could look

The draft shows structure and handling: departments to switch through, the path from medical report to arrival, a weekly plan and stated details on step-free access. The clinic in it is invented.

Draft

Rehabilitation clinic

Rehab clinic with application path and verifiable details

A draft for a rehabilitation clinic: three departments can be switched through, and the path from the medical report through the application to the funding body up to the arrival day is set out in four steps. A week in the house is shown as a daily plan, alongside rooms, visiting hours and support for relatives. The accessibility section states door widths, lift dimensions and call systems instead of a blanket assurance.

DepartmentsApplication pathWeekly planVerifiable measurements

Illustrative layout drafts. The businesses shown are fictitious; these are not client projects.