by Kevin Andrews
Digital accessibility in higher education is often discussed as a compliance requirement. Universities are expected to meet legal duties, publish accessibility statements, and make reasonable adjustments when barriers arise. Over the last decade the policy environment has strengthened considerably. In the UK the Equality Act 2010 established obligations to remove barriers for disabled students and staff, while the Public Sector Bodies (Websites and Mobile Applications) Accessibility Regulations introduced additional scrutiny of institutional digital services. More recently the Jisc Accessible Digital Futures project has highlighted the opportunities created by emerging digital and AI technologies when accessibility is considered early in design and procurement.
These developments signal an important shift. Accessibility is no longer treated solely as a matter of compliance or accommodation. Instead it is increasingly recognised as part of the digital infrastructure that supports teaching, research, and student experience. Yet despite this growing awareness, accessibility failures remain common across higher education systems. Students still encounter inaccessible learning platforms, course materials that cannot be used with assistive technologies, and institutional processes that place the burden of adaptation on disabled individuals.
This persistence of barriers suggests that the problem is not simply one of awareness or policy guidance. Rather, accessibility failures often arise from the way institutions adopt and govern digital technologies. To understand why the problem continues even where intentions are good, it is useful to think in terms of accessibility debt.
Accessibility debt in higher education systems
Accessibility debt accumulates when digital systems are adopted without accessibility being fully considered from the outset. Like technical debt in software development, the consequences may not be immediately visible. Platforms may appear to function adequately until disabled students begin to rely on them at scale. At that point the cost of remediation becomes significant, requiring workarounds, retrofitting, or labour-intensive accommodations.
Universities are particularly susceptible to this problem because their digital environments are complex and layered. Institutional technology ecosystems typically include learning management systems, student portals, library platforms, assessment tools, lecture capture technologies, and a growing number of AI enabled services. Many of these systems are supplied by external vendors and integrated with one another over time.
Even when individual platforms claim compliance with standards such as WCAG 2.2 AA, accessibility problems can emerge through the interaction between systems. A student may navigate successfully through one platform only to encounter barriers when moving to another tool that forms part of the same learning environment. Over time these problems accumulate as institutions add new tools without addressing existing accessibility limitations.
How institutions create accessibility debt
Procurement and governance decisions are central to the accumulation of accessibility debt. In principle, accessibility requirements can be evaluated during vendor selection. In practice this process is often difficult. Suppliers may provide incomplete or ambiguous accessibility documentation, and institutional buyers may lack the expertise needed to interpret those claims.
The Accessible Digital Futures project identified procurement as a major challenge for the UK higher education sector. Universities frequently struggle to obtain reliable information about whether digital and AI powered products meet accessibility standards. Even when accessibility statements are available, they may not reflect how the system performs in real institutional contexts.
Institutional governance structures add another layer of complexity. Universities are typically decentralised organisations where digital decisions are made in multiple places. Academic departments adopt specialised teaching tools. Administrative units introduce new platforms to manage services. Individual instructors experiment with emerging technologies. Each decision may appear limited in scope, but collectively they shape the accessibility of the institutional digital environment.
Under these conditions accessibility responsibility can become fragmented. Policies may exist at the institutional level, yet practical decisions about technology adoption occur across many different teams. Without clear governance and accountability, accessibility considerations are often introduced late in the process rather than guiding decisions from the beginning.
Why retrofitting accessibility rarely works
When accessibility barriers become visible, institutions often respond by attempting to retrofit accessibility into existing systems. This approach is understandable but rarely efficient. By the time problems are identified, platforms may already be embedded in teaching and administrative processes.
The scale of institutional digital infrastructure makes remediation difficult. Learning management systems may contain thousands of courses with legacy materials. Institutional websites can consist of hundreds of thousands of pages. Third party platforms may require vendor cooperation to address technical barriers. Even well-resourced remediation efforts can take years to complete.
In the meantime new technologies continue to be introduced. Emerging tools such as generative AI, immersive learning environments, and advanced analytics systems offer significant potential benefits. The Jisc project highlights how these technologies could support more inclusive forms of digital learning if accessibility is considered early. However the same technologies may create new barriers if institutions repeat existing patterns of procurement and governance.
The result is a cycle in which accessibility problems are repeatedly addressed after the fact rather than prevented through earlier decision making.
What structural change would look like
Reducing accessibility debt requires institutions to treat accessibility as a governance issue rather than a purely technical one. Responsibility cannot sit solely with disability services or specialist accessibility teams. Decisions about procurement, platform adoption, and digital strategy shape the accessibility of the entire institutional environment.
Procurement practices are one important lever. Universities need clearer processes for evaluating vendor accessibility claims and stronger expectations that suppliers provide reliable documentation. The European Accessibility Act having recently gone into force may increase pressure on technology providers to meet accessibility standards, but institutional buyers will still need the expertise and governance structures necessary to interpret those requirements.
Accessibility expertise must also be integrated earlier in institutional decision making. Too often accessibility specialists are consulted only after technology has already been selected. Involving accessibility expertise during planning and procurement can significantly reduce the need for costly remediation later.
Finally, institutions must recognise the cumulative nature of accessibility debt. Addressing individual barriers is necessary but not sufficient. Progress depends on examining the institutional systems that produce those barriers in the first place.
The higher education sector is currently undergoing rapid technological transformation. Digital platforms and AI driven tools are reshaping how universities teach, assess, and support students. Initiatives such as Accessible Digital Futures rightly emphasise the opportunity to ensure these changes produce more inclusive educational environments.
Whether that opportunity is realised will depend less on technological capability than on institutional governance. Accessibility failures rarely arise from a single decision. They emerge gradually as accessibility debt accumulates across procurement choices, platform ecosystems, and fragmented responsibility. Recognising and addressing that structural dynamic may be one of the most important steps universities can take toward genuinely accessible digital futures.
Kevin Andrews is a Certified Web Accessibility Specialist working at the intersection of digital accessibility, technology governance, and higher education systems. His work focuses on how institutional technology decisions shape accessibility outcomes for disabled students and staff. He brings both professional expertise and lived experience of disability to his work on accessible digital infrastructure.

















