Accessible Compliance Training: What the Law Actually Requires (and What the EAA Does Not)

Search for accessibility and e-learning and you will find a great deal of content telling you that the European Accessibility Act now requires your staff compliance training to be accessible. Read the Directive and that is not what it says. The obligation on a UK or Irish employer is real, but it comes from somewhere else entirely, and it bites differently.

This guide works through the actual provisions: what the European Accessibility Act covers, what the Equality Act 2010 requires of every employer, what the public sector accessibility regulations require of NHS trusts, councils and other public bodies, and a procurement change from February 2025 that has gone almost unremarked. It is written from the primary texts and is general information, not legal advice.

The European Accessibility Act does not cover your staff training

Directive (EU) 2019/882 applies to a closed list. Article 2(1) covers products placed on the market after 28 June 2025: consumer general purpose computer hardware and its operating systems, certain self-service terminals including payment terminals, ATMs, ticketing and check-in machines, consumer terminal equipment for electronic communications and for accessing audiovisual media services, and e-readers.

Article 2(2) then covers a list of services "provided to consumers" after 28 June 2025: electronic communications services, services providing access to audiovisual media services, specified elements of air, bus, rail and waterborne passenger transport, consumer banking services, e-books and dedicated software, and e-commerce services.

Two definitions settle the question. Article 3(22) defines a consumer as "any natural person who purchases the relevant product or is a recipient of the relevant service for purposes which are outside his trade, business, craft or profession". An employee completing mandatory anti-money-laundering or safeguarding training is receiving it squarely within their trade, business or profession. And Article 3 defines e-commerce services as services provided at a distance by electronic means "at the individual request of a consumer with a view to concluding a consumer contract" — which a business-to-business licence sold to an employer is not.

So a compliance LMS bought by a firm to train its own staff falls outside the Directive's scope on its own terms. That matters in both directions: if a supplier is telling you their platform is "EAA compliant" as a reason to buy, they are selling you compliance with a law that does not apply to the transaction.

Where the Directive can catch a training provider is on the consumer side. Selling a course to an individual learner through a website, for their own purposes rather than their employer's, looks like an e-commerce service. A provider doing both needs to know which side of the line each sale falls on.

What actually binds a UK employer: the Equality Act 2010

The chain is short and it is specific to training.

Section 39(2)(b) prohibits an employer from discriminating against an employee "in the way A affords B access, or by not affording B access, to opportunities for promotion, transfer or training or for receiving any other benefit, facility or service". Access to training is named in the statute. Section 39(5) then states plainly that "A duty to make reasonable adjustments applies to an employer".

Section 20 sets out what that duty comprises. Two of its three requirements are the relevant ones here:

• Section 20(3) — where a provision, criterion or practice puts a disabled person at a substantial disadvantage, the employer must take such steps as it is reasonable to have to take to avoid the disadvantage. A mandatory e-learning module that cannot be completed with a screen reader is a practice that does exactly that
• Section 20(5) — where a disabled person would be at a substantial disadvantage but for the provision of an auxiliary aid, the employer must take reasonable steps to provide it

Then the provision that does the work for digital training content. Section 20(6): where the first or third requirement relates to the provision of information, "the steps which it is reasonable for A to have to take include steps for ensuring that in the circumstances concerned the information is provided in an accessible format".

Compliance training is the provision of information. Section 20(6) makes accessible format an expressly reasonable step. And section 20(7) prevents the employer from passing the cost on: a person subject to the duty is not entitled to require the disabled person to pay for it.

Note what this regime is not. It is not a technical standard. It names no WCAG level and sets no conformance target. It is an individual, contextual duty that is triggered by substantial disadvantage and assessed on reasonableness — which means a firm cannot discharge it by buying a platform with a conformance badge, and equally cannot be told it has failed simply because a module falls short of a success criterion. The question is always whether a particular disabled employee was put at a substantial disadvantage and whether reasonable steps were taken.

Public bodies: a hard standard, and it covers intranets

For NHS trusts, councils, central government and other bodies governed by public law, the Public Sector Bodies (Websites and Mobile Applications) (No. 2) Accessibility Regulations 2018 add a real conformance obligation.

Regulation 6 requires compliance with the "accessibility requirement", defined in regulation 3 as making a website or mobile application "perceivable, operable, understandable and robust". Regulation 9, as substituted in October 2022, gives a presumption of conformity where the site meets the Web Content Accessibility Guidelines "as amended from time to time" at Level A and AA success criteria. Note the drafting: no WCAG version number is named, so the target moves with W3C rather than being pinned by the statute.

The point most relevant to training is the treatment of closed systems. Regulation 4(3)(b) defines extranets and intranets as a website "only available for a closed group of people and not to the general public" — which is what a staff learning platform is. Regulation 4(2)(g) excludes only their content published before 23 September 2019, and then only "until such websites undergo a substantial revision". A public body's current staff training platform is therefore in scope.

The rest of the machinery:

• Regulation 7 — no obligation where compliance would impose a disproportionate burden, but regulation 7(2) requires an assessment and 7(4) requires the statement to explain the non-compliant parts. The exemption is evidenced, not asserted
• Regulation 8 — an accessibility statement following the model statement published by the Secretary of State, kept under regular review, explaining the inaccessible parts and why, any accessible alternatives, a contact route for reporting failures, and a link to the enforcement procedure
• Regulation 5 — the deadlines have long passed: September 2019, September 2020 and June 2021 depending on the asset
• Regulations 11 and 12 — enforcement sits with the Equality and Human Rights Commission (or the Equality Commission for Northern Ireland), and a failure to comply "is to be treated as a failure to make a reasonable adjustment". The two regimes connect directly
• Regulation 14 — the Secretary of State may assess compliance with the statement requirement, issue information notices with 28 days to respond, determine non-compliance and publish names

Schools and nurseries are largely out of scope under regulation 4(1)(c) except content relating to essential online administrative functions, and non-governmental organisations are excluded unless they provide services essential to the public or aimed at disabled people.

The procurement change almost nobody has noticed

Until February 2025, regulation 42(8) of the Public Contracts Regulations 2015 required that "for all procurement which is intended for use by natural persons, whether the general public or staff of the contracting authority, the technical specifications shall, except in duly justified cases, be drawn up so as to take into account accessibility criteria for disabled persons or design for all users".

That provision expressly covered staff-facing systems — a learning platform among them — and made accessibility a mandatory specification consideration in public tenders.

The Public Contracts Regulations 2015 were revoked on 24 February 2025 by the Procurement Act 2023. Section 56 of that Act, the successor technical-specifications provision, contains no accessibility wording at all.

Read that carefully rather than as a conclusion: the public sector equality duty and the 2018 Regulations are untouched, and I have read section 56 rather than the whole Act and its subordinate regulations, so accessibility obligations may well sit elsewhere in the new regime. But the specific, explicit instruction to build accessibility into technical specifications for staff-facing procurement no longer appears where it used to. If your tender templates inherited that language from a 2015-era framework, the legal citation under it is now wrong even if the requirement is still good practice.

What to ask a training supplier

Four questions that follow from the above rather than from a vendor checklist.

First, which WCAG version and level the content conforms to, and when it was last tested — the 2018 Regulations float with W3C, so "WCAG compliant" without a version is not an answer.

Second, whether conformance covers the platform and the course content. These are often built by different parties, and a conformant player delivering inaccessible modules fails the duty just as completely.

Third, what the supplier can provide as an accessible alternative where a module falls short, since that is what both regulation 8(4)(b) and a reasonable-adjustments defence actually turn on.

Fourth, whether the completion record survives the alternative route. An employee who completes training by an accessible alternative must still appear as trained in the record, or the adjustment creates a compliance gap of its own — the point where this meets the evidence obligations set out in our guide to training records systems under CQC Regulations 17 and 18.

On the wider selection question, our buyer's guide to choosing a CPD and compliance training platform covers the commercial criteria, and structured CPD programmes have to be deliverable to every member of staff to be worth buying at all.

Sources and limits: Directive (EU) 2019/882 Articles 2 and 3 and the Equality Act 2010 sections 20 and 39 were read on EUR-Lex and legislation.gov.uk in October 2026, as was SI 2018/952 regulations 1 to 14 and section 56 of the Procurement Act 2023. Schedule 1 of SI 2018/952, the remainder of the Procurement Act and the Procurement Regulations 2024 were not read. Irish transposition of the Directive and the Irish public-sector accessibility rules are not covered here. This is general information about published law, not legal advice; take your own advice on any specific obligation.