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Digital accessibility debt in higher education: how institutional decisions create structural exclusion

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.  


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Higher Education, High Hopes, and Heavy Bureaucracy

by Phil Power-Mason and Helen Charlton

UK higher education is pulled between its lofty ambitions for transformative learning and the managerialism that sometimes constrains their realisation. This tension defines the contemporary Higher Education workplace, where the mantras of “more with less” and “highly regulated freedom” collide with the desire for rich, personalised student experiences amidst fiscal belt-tightening, quantification, and standardisation. Bubbling through the cracks in any long-term political or economic vision for the sector is a professional identity steeped in ambivalence of purpose and position, one whose contradictions are nowhere rendered more vividly than in England’s higher and degree apprenticeships (HDAs). Conceived to braid university learning with workplace productivity, HDAs promise the best of both worlds yet must be delivered within one of the most prescriptive funding and inspection regimes in UK higher education. This provision also sits amidst a precarious and volatile political landscape, with continuous changes to funding rules, age limits and eligibility of different levels of study, and ‘fit’ within a still poorly defined skills and lifelong learning landscape.  

At the heart of this ongoing policy experiment stands an until-recently invisible workforce:  Higher Education Tripartite Practitioners (HETP). These quiet actors emerged as a series of pragmatic institution level responses to the Education and Skills Funding Agency (ESFA, now subsumed into the Department of Education) related to progress reviews involving the provider, apprentice, and employer. Yet, as we argued in our paper at the SRHE International Conference in December last year, they have evolved into nuanced, often misunderstood boundary-spanners who simultaneously inhabit academia, industry, and compliance. Part coach, part conduit, part compliance specialist, they facilitate developmental conversations, broker cultural differences, and ensure every clause of the ESFA rulebook is honoured. The quality of this brokerage is decisive; without it even the most carefully designed apprenticeship fractures under audit pressure.

Consider the core activities of HETPs. Much of their time is spent in close personal engagement with apprentices – fostering professional growth, guiding reflective practice, and offering pastoral support traditionally associated with mentoring. They encourage apprentices to think holistically, integrate theory with workplace reality, and map long-term career aspirations. Almost simultaneously, they must document progress reviews, monitor the evidence of every single hour of learning, and tick every regulatory box along a journey from initial skills analysis through to end point assessment.

This duality produces a daily oscillation between inspiring conversations and tedious paperwork. The tension is palpable and exhausting, revealing a deeper struggle between two visions of education: one expansive, transformative, and relational; the other restrictive, measurable, and dominated by compliance. Fuller and Unwin’s expansive–restrictive continuum maps neatly onto this predicament, underscoring how universities are urged by policymakers to deliver high-skilled graduates for economic growth while simultaneously squeezed by intensifying regulation and managerial oversight.

Little wonder, then, that HETPs describe their roles with the language of complexity, ambiguity, and invisibility. They are neither purely academic nor purely administrative. Instead, they occupy a liminal institutional space, mediating competing demands from employers, regulators, apprentices, and colleagues. Esmond captures the resulting “subaltern” status of these practitioners, whose contributions remain undervalued even as they shoulder the brunt of institutional attempts to innovate without overhauling legacy systems.

Their experiences lay bare the contradictions of contemporary university innovation. Institutions routinely trumpet responsiveness to labour-market need yet bolt new programmes onto structures optimised for conventional classroom delivery, leaving HETPs to reconcile expansive educational ideals with restrictive managerial realities. The role becomes a flashpoint: universities ask boundary-spanners to maintain quality, build relationships, and inspire learners within systems designed for something else entirely.

Yet amidst these tensions lies opportunity. The very ambiguity of the HETP role highlights the limits of existing support systems and points towards new professional identities and career pathways. Formal recognition of boundary-spanning expertise – relationship-building, negotiation, adaptability – would allow practitioners to progress without abandoning what makes their contribution distinctive. Communities of practice could break the apprenticeship echo-chamber and enrich the wider HE ecosystem, while institutional investment in bespoke professional development would equip practitioners to navigate the inherent tensions of their work.

Senior leadership must also acknowledge the strategic value of these hidden roles, reframing them not as incidental administrative burdens but as essential catalysts for integrated educational practice. Making such roles visible and valued would help universities reconcile expansive aspirations with regulatory realities and signal genuine commitment to reshaping education for contemporary challenges.

Policymakers and regulators, too, have lessons to learn. While accountability has its place, overly rigid compliance frameworks risk stifling innovation. Trust-based, proportionate regulation – emphasising quality, transparency, and developmental outcomes – would free practitioners to focus on learning rather than bureaucratic survival. The current neo-liberal distrust that imagines only regulation can safeguard public value inflates compliance costs and undermines the very economic ambitions it seeks to serve.

Ultimately, the emergence of HETPs challenges HE institutions to decide how serious they are about bridging academic learning and workplace practice. Recognising and empowering these quiet brokers would signal a genuine commitment to integrated, expansive education – an education capable of meeting economic demands without losing sight of deeper human and intellectual aspirations. HETPs are far more than practitioners managing checklists; they are a critical juncture at which universities must choose either to treat boundary-spanning labour as a stop-gap or to embrace the complexity and potential it represents.

Dr Phil Power-Mason is Head of Department for Strategic Management at Hertfordshire Business School, University of Hertfordshire, where he leads a diverse portfolio spanning executive education, apprenticeships and professional doctorates. A practice-focussed academic with a passion for innovative workforce development, Phil has overseen significant growth in the school’s business apprenticeships, MBA, and generalist provision, while nurturing cross-sector partnerships and embedding work-aligned learning at every level. With a research background in educational governance and strategy, he is a Senior Fellow of Advance HE and co-convenor of national apprenticeship knowledge networks. Phil’s research and sector leadership focus on emerging pedagogic and HE workforce practices, driving collaborative solutions that meet employer, learner and university needs. An invited speaker at national forums and a frequent contributor to sector conferences and publications, he remains committed to transforming vocational and work-ready learning practice for the future. (herts.ac.uk)

Dr Helen Charlton is Associate Professor of Work Aligned Learning and Head of Executive Education at Newcastle Business School, Northumbria University, where she leads the school’s business apprenticeships, executive CPD and distance-learning programmes. After almost a decade steering apprenticeship design and compliance, she stays keenly attuned to each fresh regulatory tweak – and the learning opportunities it provides. A former senior HR manager in the arts and not-for-profit sectors, Helen holds a Doctorate in Education and an MSc in Human Resource Management, is a Senior Fellow of Advance HE, a Chartered MCIPD, and a Chartered Manager and Fellow of the CMI. Her research examines how learners, employers and universities negotiate the tripartite realities of degree apprenticeships. (northumbria.ac.uk)


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Risk-based quality regulation – drivers and dynamics in Australian higher education

by Joseph David Blacklock, Jeanette Baird and Bjørn Stensaker

Risk-based’ models for higher education quality regulation have been increasingly popular in higher education globally. At the same time there is limited knowledge of how risk-based regulation can be implemented effectively.

Australia’s Tertiary Education Quality and Standards Agency (TEQSA) started to implement risk-based regulation in 2011, aiming at an approach balancing regulatory necessity, risk and proportionate regulation. Our recent published study analyses TEQSA’s evolution between 2011 and 2024 to contribute to an emerging body of research on the practice of risk-based regulation in higher education.

The challenges of risk-based regulation

Risk-based approaches are seen as a way to create more effective and efficient regulation, targeting resources to the areas or institutions of greatest risk. However, it is widely acknowledged that sector-specificities, political economy and social context exert a significant influence on the practice of risk-based regulation (Black and Baldwin, 2010). Choices made by the regulator also affect its stakeholders and its perceived effectiveness – consider, for example, whose ideas about risk are privileged. Balancing the expectations of these stakeholders, along with their federal mandate, has required much in the way of compromise.

The evolution of TEQSA’s approaches

Our study uses a conceptual framework suggested by Hood et al (2001) for comparative analyses of regimes of risk regulation that charts aspects respectively of context and content. With this as a starting point we end up with two theoretical constructs of ‘hyper-regulation’ and ‘dynamic regulation’ as a way to analyse the development of TEQSA over time. These opposing concepts of regulatory approach represent both theoretical and empirical executions of the risk-based model within higher education.

From extensive document analysis, independent third-party analysis, and Delphi interviews, we identify three phases to TEQSA’s approach:

  • 2011-2013, marked by practices similar to ‘hyper-regulation’, including suspicion of institutions, burdensome requests for information and a perception that there was little ‘risk-based’ discrimination in use
  • 2014-2018, marked by the use of more indicators of ‘dynamic regulation’, including reduced evidence requirements for low-risk providers, sensitivity to the motivational postures of providers (Braithwaite et al. 1994), and more provider self-assurance
  • 2019-2024, marked by a broader approach to the identification of risks, greater attention to systemic risks, and more visible engagement with Federal Government policy, as well as the disruption of the pandemic.

Across these three periods, we map a series of contextual and content factors to chart those that have remained more constant and those that have varied more widely over time.

Of course, we do not suggest that TEQSA’s actions fit precisely into these timeframes, nor do we suggest that its actions have been guided by a wholly consistent regulatory philosophy in each phase. After the early and very visible adjustment of TEQSA’s approach, there has been an ongoing series of smaller changes, influenced also by the available resources, the views of successive TEQSA commissioners and the wider higher education landscape as a whole.

Lessons learned

Our analysis, building on ideas and perspectives from Hood, Rothstein and Baldwin offers a comparatively simple yet informative taxonomy for future empirical research.

TEQSA’s start-up phase, in which a hyper-regulatory approach was used, can be linked to a contextual need of the Federal Government at the time to support Australia’s international education industry, leading to the rather dominant judicial framing of its role. However, TEQSA’s initial regulatory stance failed to take account of the largely compliant regulatory posture of the universities that enrol around 90% of higher education students in Australia, and of the strength of this interest group. The new agency was understandably nervous about Government perceptions of its performance, however, a broader initial charting of stakeholder risk perspectives could have provided better guardrails. Similarly, a wider questioning of the sources of risk in TEQSA’s first and second phases could have highlighted more systemic risks.

A further lesson for new risk-based regulators is to ensure that the regulator itself has a strong understanding of risks in the sector, to guide its analyses, and can readily obtain the data to generate robust risk assessments.

Our study illustrates that risk-based regulation in practice is as negotiable as any other regulatory instrument. The ebb and flow of TEQSA’s engagement with the Federal Government and other stakeholders provides the context. As predicted by various authors, constant vigilance and regular recalibration are needed by the regulator as the external risk landscape changes and the wider interests of government and stakeholders dictate. The extent to which there is political tolerance for any ‘failure’ of a risk-based regulator is often unstated and always variable.

Joseph David Blacklock is a graduate of the University of Oslo’s Master’s of Higher Education degree, with a special interest in risk-based regulation and government instruments for managing quality within higher education.

Jeanette Baird consults on tertiary education quality assurance and strategy in Australia and internationally. She is Adjunct Professor of Higher Education at Divine Word University in Papua New Guinea and an Honorary Senior Fellow of the Centre for the Study of Higher Education at the University of Melbourne.

Bjørn Stensaker is a professor of higher education at University of Oslo, specializing in studies of policy, reform and change in higher education. He has published widely on these issues in a range of academic journals and other outlets.

This blog is based on our article in Policy Reviews in Higher Education (online 29 April 2025):

Blacklock, JD, Baird, J & Stensaker, B (2025) ‘Evolutionary stages in risk-based quality regulation in Australian higher education 2011–2024’ Policy Reviews in Higher Education, 1–23.

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Embracing plurality and difference in higher education – necessary but not sufficient

By Rob Cuthbert – Editor, SRHE News

The SRHE Annual Research Conference in December 2014 invites us to reflect on Inspiring future generations: embracing plurality and difference in higher education: ‘Within the HE research community we have the capacity, the history, the knowledge and the expertise to inform and shape the transformation of the higher education sector globally into an innovative, multi-faceted system; one with new and different sources of funding, with diverse modes of participation and one more responsive to the changing needs and expectations of people, institutions and societies.’ Quite right: inspiration is a benefit we expect of Conference every year. We have it in ourselves to be the best, but there are always temptations to be otherwise, with the lure of funds and reputation sometimes suggesting unethical short cuts. SRHE Vice-President Roger Brown, who in his latest book bemoaned the kind of marketisation where it appears that everything is for sale, has recently warned that ‘The pursuit of status will be the death of the university as we know it.’

Reports of ethical lapses are usually tales of individual transgression and recent European research on unethical behaviour suggests that too many academics admit to some of the behaviours of which they disapprove. But even this pales by comparison to an academic scandal at one of the US’s leading universities, the University of North Carolina at Chapel Hill. Continue reading →