In Brief
Delivering digital training in the United States requires navigating complex accessibility expectations. Organizations must understand the distinction between the Americans with Disabilities Act (ADA), Section 508 of the Rehabilitation Act, and how the Web Content Accessibility Guidelines (WCAG) serve as the technical standard for compliance.
US eLearning and Accessibility
When organizations build digital courses or customer academies for audiences in the United States, accessibility is the primary legal and operational consideration.
The US legal framework for digital accessibility can be confusing because it involves multiple laws that apply to different types of organizations, all of which generally point toward a shared technical standard.
The Technical Standard: WCAG
Before discussing specific US laws, it is essential to understand the Web Content Accessibility Guidelines (WCAG).
WCAG is an international technical standard developed by the World Wide Web Consortium (W3C). It defines exactly how to make digital content accessible (e.g., contrast ratios, keyboard navigation, screen reader compatibility).
In the United States, WCAG (specifically versions 2.0 or 2.1 at the AA level) is widely adopted by courts, government agencies, and corporations as the benchmark for whether a website or eLearning course is legally accessible.
Section 508 of the Rehabilitation Act
Who it applies to: US Federal agencies, departments, and any organization receiving federal funding or working as a federal contractor.
What it means for eLearning: If you are building a custom eLearning course to sell to a US federal agency, that course must comply with Section 508.
In 2017, Section 508 was “refreshed” to explicitly adopt WCAG 2.0 AA as its technical standard for websites and electronic documents (which includes digital courses). Therefore, a course that fails WCAG 2.0 AA generally fails Section 508.
Vendors are often required to provide a Voluntary Product Accessibility Template (VPAT) to prove their platform or course meets these standards before procurement.
The Americans with Disabilities Act (ADA)
Who it applies to: State/local governments (Title II) and private businesses/places of public accommodation (Title III).
What it means for eLearning: The ADA is a broad civil rights law that prohibits discrimination based on disability. While the law was written before the internet existed, US courts and the Department of Justice (DOJ) have consistently interpreted the ADA to apply to websites and digital services.
If a US corporation provides an online customer academy or a mandated employee training program, those digital environments must be accessible.
While Title III of the ADA does not explicitly mandate a specific technical standard in its legal text, the DOJ and the courts look to WCAG (often 2.1 AA) as the standard for measuring ADA compliance.
Practical Implications for Digital Courses
To meet US accessibility expectations, eLearning developers must implement specific technical features within their authoring tools (like Storyline or Rise) and their Learning Management Systems (LMS):
- Keyboard Operability: The entire course must be navigable using only the Tab, Enter, and Arrow keys.
- Screen Reader Compatibility: All slide text must be readable by assistive technologies, and a logical reading order must be established.
- Closed Captions: All training videos and audio narrations must have synchronized captions.
- Alternative Text: Meaningful graphics and charts must have descriptive alt text.
- Color Contrast: Text and interactive buttons must meet the 4.5:1 contrast ratio requirement.
Readiness Questions for US Deployment
Before launching a training program in the US, organizations should ask:
- Are we selling this course to a federal agency? (If yes, strict Section 508 compliance and a VPAT are likely required).
- Is our LMS vendor capable of producing a VPAT demonstrating their platform’s accessibility?
- Has our course undergone manual QA testing with a screen reader and keyboard, or are we only relying on automated scans?
- Have we provided transcripts and captions for all multimedia?
Disclaimer: This resource provides general educational information about digital learning considerations and does not constitute legal advice. Requirements can vary according to the organization, service, learner group and implementation. Organizations should confirm applicable obligations with qualified legal, privacy or accessibility professionals.
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