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Legal Risks of Inaccessible Online Learning: What Teams Should Know
Oct 19, 2025
Posted by Damon Falk

Imagine this: your company spent months building a new online training platform. It looks sleek, runs fast, and has all the right features. But when a new employee with low vision tries to log in, they can’t navigate the menus. The videos have no captions. The quizzes don’t work with screen readers. They give up. And then, two weeks later, your legal team gets a letter.

This isn’t hypothetical. In 2024, the U.S. Department of Justice settled three major cases against corporations for inaccessible e-learning platforms. One company paid $1.2 million in damages and was ordered to overhaul its entire training system. Another was forced to hire a full-time accessibility officer. These aren’t outliers-they’re warnings.

Why Accessibility Isn’t Just a ‘Nice-to-Have’

Online learning isn’t optional anymore. It’s how companies onboard new hires, train remote teams, and keep certifications current. But if your platform doesn’t work for people with disabilities, you’re not just excluding users-you’re breaking the law.

The Americans with Disabilities Act (ADA) doesn’t just cover physical spaces. Courts have consistently ruled that websites and digital platforms are public accommodations. That includes learning portals, LMS systems, and training modules. The same goes for the Equality Act 2010 in the UK and the European Accessibility Act, which came into full force in June 2025.

It’s not about being politically correct. It’s about legal exposure. If someone can’t access your training because of a design flaw, you’re liable. And liability doesn’t stop at fines. It includes mandatory remediation, ongoing audits, and reputational damage that can affect hiring, customer trust, and investor confidence.

Who’s at Risk? Teams That Don’t Realize They’re in Danger

Most teams think accessibility is the job of the IT department or the HR compliance officer. That’s a dangerous assumption.

Marketing teams pick color schemes that fail contrast checks. Instructional designers build interactive modules that require mouse gestures. Procurement teams buy off-the-shelf LMS platforms without asking about WCAG compliance. Project managers set deadlines without factoring in accessibility testing.

Here’s the truth: accessibility is a team sport. And if your team hasn’t been trained on it, you’re already at risk.

A 2023 study by the World Institute on Disability found that 78% of organizations had no formal accessibility policy for digital learning. Of those, 62% had received complaints from employees with disabilities. Only 9% had taken corrective action before being contacted by a lawyer.

The Most Common Legal Triggers in Online Learning

Here’s what actually gets organizations sued:

  • No captions or transcripts for videos-this violates Title III of the ADA and the European Accessibility Act.
  • Keyboard-inaccessible interfaces-if you can’t tab through a quiz or skip to the next module without a mouse, you’re blocking users with motor disabilities.
  • Non-descriptive links like “click here” or “learn more”-screen reader users hear dozens of these in a row and can’t tell where they lead.
  • PDFs without tags-many training materials are still distributed as untagged PDFs. These are unreadable by screen readers.
  • Time-limited assessments-if your quiz expires in 10 minutes and a learner with a cognitive disability needs extra time, you’re discriminating.

These aren’t edge cases. They’re the top five reasons for accessibility complaints in 2024, according to the UK Equality and Human Rights Commission.

Comic book style courtroom scene with a blind plaintiff and corporate team overwhelmed by accessibility failures.

What the Law Actually Requires

There’s no single rulebook, but there’s a clear standard: WCAG 2.1 Level AA. That’s the benchmark courts and regulators use worldwide.

WCAG stands for Web Content Accessibility Guidelines. It’s maintained by the World Wide Web Consortium (W3C). Level AA means:

  • All text has enough contrast against its background (minimum 4.5:1).
  • Every image has alternative text that describes its purpose.
  • Forms have clear labels and error messages.
  • Navigation works without a mouse.
  • Media has captions and audio descriptions.

Complying with WCAG 2.1 AA isn’t optional if you serve the public-or your own employees. In the UK, failing to meet this standard can lead to claims under the Equality Act 2010. In the U.S., it’s the ADA. In the EU, it’s the European Accessibility Act.

And here’s the kicker: courts don’t care if you didn’t know. Ignorance isn’t a defense. If your platform is inaccessible, and someone with a disability was harmed by it, you’re on the hook.

Real Cases, Real Consequences

In 2023, a major UK bank was sued after its mandatory compliance training was inaccessible to a blind employee. The employee had to rely on colleagues to read the material-something they weren’t supposed to do. The case settled for £210,000. The bank had to rewrite all 47 training modules and hire an external accessibility auditor for three years.

Another case involved a U.S. healthcare provider whose online certification portal didn’t support screen readers. A nurse with low vision failed her recertification because she couldn’t complete the exam. She filed a complaint with the Department of Justice. The provider paid $350,000 in damages and was forced to adopt an accessibility policy that included mandatory staff training.

These aren’t rare. They’re becoming routine.

A crumbling training tower under legal threats, with a golden WCAG key restoring accessibility.

How to Protect Your Team Before It’s Too Late

You don’t need to be an expert to reduce risk. Here’s what to do now:

  1. Test your platform with free tools like WAVE or axe DevTools. Run a scan on your main training pages. If you see more than five high-priority errors, you’re already in danger.
  2. Ask your LMS vendor for a Voluntary Product Accessibility Template (VPAT). If they can’t or won’t provide one, find another vendor. This isn’t negotiable.
  3. Train your team-not just IT. Marketing, design, content writers, and HR need to know what accessibility means in their daily work.
  4. Include people with disabilities in testing. Hire a consultant or partner with a local disability organization. Real users will find problems no automated tool can catch.
  5. Document everything. Keep records of your accessibility assessments, fixes, and training. If you’re ever sued, this is your best defense.

Fixing accessibility doesn’t have to cost a fortune. Many fixes are simple: adding alt text, using proper heading structure, enabling keyboard navigation. The cost isn’t in the fixes-it’s in the lawsuits you avoid.

What Happens If You Do Nothing?

Let’s say you ignore this. Here’s what could happen:

  • An employee files a complaint with your national equality body. You’ll be forced into mediation or a tribunal.
  • A student or customer sues you for discrimination. Legal fees alone can hit £50,000 before a settlement.
  • Your brand gets flagged in accessibility watchdog reports. Customers notice. Investors notice.
  • You lose talent. People with disabilities won’t work for you if your training is unusable.

And here’s the worst part: you won’t get a second chance. Once a lawsuit is filed, the court doesn’t care about your budget, your timeline, or your excuses. You fix it-or you pay.

It’s Not About Perfection. It’s About Progress.

You don’t need to make your platform perfect overnight. But you do need to start. And you need to show you’re trying.

Start with one course. Fix the captions. Add alt text to images. Make sure the navigation works with a keyboard. Test it with someone who uses a screen reader. Then do it again with the next module.

Every step you take reduces your risk. Every fix makes your training more inclusive. And every action you take today protects your team from tomorrow’s lawsuit.

Accessibility isn’t a technical checkbox. It’s a legal obligation. And the people who ignore it are the ones who end up in court.

Is accessibility required by law for internal company training?

Yes. If your company employs people with disabilities-or if training is mandatory for all employees-then your online learning platform must be accessible under the Equality Act 2010 (UK), the ADA (U.S.), and the European Accessibility Act (EU). Internal training isn’t exempt. Courts have ruled that workplace training is a condition of employment, and denying access based on disability is discrimination.

Can we be sued even if we didn’t know our platform was inaccessible?

Absolutely. Ignorance is not a legal defense. Courts don’t accept "we didn’t know" as an excuse. What matters is whether the platform was accessible to people with disabilities. If it wasn’t, and someone was harmed by that, you’re liable. The key is showing you took reasonable steps to fix it once you became aware-or should have become aware.

What’s the difference between WCAG 2.1 and WCAG 2.2?

WCAG 2.2 adds new guidelines for users with cognitive disabilities and mobile accessibility, but courts and regulators still primarily use WCAG 2.1 Level AA as the standard. While WCAG 2.2 is the latest version, compliance with 2.1 AA is still legally sufficient in most jurisdictions. However, adopting 2.2 is recommended for future-proofing your platform.

Do we need to hire a specialist to fix accessibility?

Not always. Many fixes-like adding alt text, using proper headings, or enabling keyboard navigation-can be done by your existing team with basic training. But for complex platforms or legal protection, hiring an accessibility consultant for an audit is wise. It’s cheaper than a lawsuit. Look for certified professionals with experience in e-learning platforms.

What if our LMS provider says they’re "accessible"?

Ask for a VPAT (Voluntary Product Accessibility Template). A vendor saying "we’re accessible" without documentation is a red flag. A VPAT is a formal report that shows how their product meets WCAG standards. If they can’t provide one, assume they’re not compliant. You’re responsible for what you use-even if the vendor says otherwise.

Can we be fined for inaccessible online learning?

Yes. In the U.S., the Department of Justice can impose civil penalties up to $75,000 for a first violation and $150,000 for subsequent ones. In the UK, courts can order compensation for distress and loss of opportunity. In the EU, national authorities can issue fines under the European Accessibility Act. Fines are only part of the cost-reputational damage and mandatory system overhauls often cost far more.

Damon Falk

Author :Damon Falk

I am a seasoned expert in international business, leveraging my extensive knowledge to navigate complex global markets. My passion for understanding diverse cultures and economies drives me to develop innovative strategies for business growth. In my free time, I write thought-provoking pieces on various business-related topics, aiming to share my insights and inspire others in the industry.
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