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UDL Is Not Accessibility: The Problem with UDL Inflation

Written by CEN-PICKETAL on . Posted in blog, reflection, teaching online.

Why one useful pedagogical framework should not become shorthand for accessibility, inclusive teaching, and everything we value in quality online course design

Lately, I have been hearing Universal Design for Learning (UDL) invoked more and more often in conversations about accessibility. Sometimes the terms are used almost interchangeably. An online course is described as “accessible because it uses UDL.” UDL is presented as the standard for inclusive course design. And accessibility practices are folded into UDL as though accessibility were simply one application of the larger framework.

That has been bothering me.

I don’t oppose UDL. UDL offers educators a useful way to think proactively about learner variability, barriers, flexibility, and choice.

What bothers me is something I have come to think of as UDL inflation: the tendency to expand UDL until it becomes shorthand for accessibility, inclusion, equity, learner-centered teaching, good instructional design, and sometimes almost anything we consider good educational practice.

But when a framework comes to mean everything, we risk losing the distinctions among the things it now claims to encompass.

That distinction is particularly important in online teaching and course design. In an online course, much of the learning experience is mediated through digital content, technologies, documents, media, navigation, interaction, and assessment. Accessibility therefore cannot remain only a pedagogical aspiration; it has to be built into the actual materials and technologies through which students encounter the course. A thoughtfully designed learning activity can reflect UDL principles and still be inaccessible. Conversely, an online course can meet rigorous accessibility requirements without necessarily representing a comprehensive application of UDL.

UDL is not synonymous with accessibility.

UDL is a Pedagogical Framework

CAST, the organization that developed UDL, describes it as an educational framework intended to guide the design of learning environments and experiences around learner variability. Its current goal is the development of learner agency, and its familiar architecture addresses multiple means of engagement, representation, and action and expression (CAST, 2024).

Federal education law similarly defines UDL as a “framework for guiding educational practice” that provides flexibility in how information is presented, how learners respond and demonstrate knowledge, and how learners engage. Importantly, that same definition says UDL reduces instructional barriers while providing appropriate accommodations and supports. In other words, even the statutory definition does not assume that UDL eliminates the need for disability-specific accommodations (20 U.S.C. § 1003(24)).

That is very different from an accessibility standard.

In fact, CAST itself makes this distinction clearer than some applications of UDL do. CAST says that its Guidelines are not intended to be a prescription or checklist, that educators do not need to use every guideline, and that guidelines can be selected and combined according to the learning goal and barriers present (CAST, 2024).

That flexibility is part of UDL’s value as a pedagogical framework. It is also precisely why it should not be treated as an accessibility conformance standard.

Accessibility Asks a Different Question

Accessibility asks whether people with disabilities can actually perceive, navigate, understand, interact with, and use a resource, technology, environment, or experience. In an online course, that includes the LMS, course navigation, documents, multimedia, learning activities, communication tools, assessments, and third-party technologies through which teaching and learning occur.

In digital environments, that question can be assessed against defined technical criteria.

For example, the U.S. Department of Justice’s Title II web and mobile accessibility rule adopts WCAG 2.1 Level AA as the technical standard for covered state and local government web content and mobile applications. In April 2026, the Department extended the compliance date for public entities with populations of 50,000 or more to April 26, 2027, but the accessibility standard itself did not change: it remains WCAG 2.1 Level AA, not UDL (U.S. Department of Justice, 2026).

WCAG does something fundamentally different from UDL. It includes testable success criteria concerning such things as keyboard access, captions, text alternatives, contrast, structure, navigation, labels, and compatibility with assistive technologies.

That does not mean WCAG represents the entirety of accessibility or every disability-rights obligation. It does mean that accessibility has functional, technical, and legal dimensions against which actual access can be evaluated.

UDL does not work that way.

There is no analogous determination that a course “conforms to UDL 3.0 Level AA.” There is no required subset of UDL Guidelines that establishes accessibility. CAST explicitly says the Guidelines are suggestions rather than a checklist and need not all be applied in a particular learning experience (CAST, 2024).

That difference matters.

Five inaccessible alternatives do not equal accessibility

Consider a common online course-design example. Suppose I provide students with a video, a transcript, an infographic, an interactive activity, and a narrated slide presentation. From a UDL perspective, I might reasonably describe that as offering multiple means of representation.

But now imagine that:

  • The video is not captioned.
  • The transcript is an inaccessible PDF.
  • The infographic has no meaningful text alternative.
  • The interactive activity cannot be operated with a keyboard.
  • The narrated presentation is inaccessible to a screen reader.

I have provided plenty of options. I have not necessarily provided access. Five inaccessible alternatives do not equal accessibility.

The reverse can also be true. I might provide a single carefully designed HTML reading with meaningful heading structure, accessible images, excellent contrast, keyboard functionality, descriptive links, accessible tables, and strong compatibility with assistive technology. That resource may be highly accessible even though it represents a relatively modest application of UDL’s emphasis on multiple means.

The concepts overlap. They are not the same concept.

Accessibility is foundational to UDL. It is not replaced by UDL.

None of this means that accessibility sits outside UDL. Quite the opposite.

CAST’s current Guidelines explicitly address accessible materials and assistive technologies and stress the importance of curricula and technologies working with assistive technologies rather than creating barriers to their use (CAST, 2024). CAST also describes access as a critical entry point into UDL while encouraging educators to extend UDL beyond access (CAST, 2024).

That seems to me exactly the right relationship. Accessibility can be foundational to good learning design. UDL can help educators go beyond minimum access by thinking more broadly about learner variability, flexibility, engagement, representation, interaction, expression, and agency.

But a framework that goes beyond accessibility should not therefore be allowed to replace accessibility.

The Problem of UDL Inflation

This distinction has become harder to maintain because UDL itself has expanded significantly.

UDL Guidelines 3.0 goes well beyond the earlier emphasis on disability and learner variability. CAST explains that the current version intentionally addresses identity, belonging, systemic bias, exclusion, interdependence, joy and play, restorative practices, diverse perspectives, multiple ways of knowing, and other dimensions of inclusive educational environments (CAST, 2024).

Many of these are worthwhile concerns. But the expansion creates a conceptual challenge. When accessibility, inclusive pedagogy, culturally responsive teaching, belonging, identity, learner agency, equity, motivation, self-regulation, assessment flexibility, and instructional design can all be described through UDL, it becomes increasingly difficult to know exactly what someone means when they say, “We use UDL.”

That is what I mean by UDL inflation.

The problem is not that UDL intersects with these ideas. Of course it does. The problem comes when intersection becomes absorption, when a useful framework begins to function as a master label for a collection of distinct constructs, practices, traditions, and obligations that have their own histories, evidence bases, purposes, and standards.

  • Accessibility does not become UDL merely because UDL values access.
  • Inclusive teaching does not become UDL merely because UDL values inclusion.
  • Culturally responsive pedagogy does not become UDL merely because UDL now incorporates attention to identity and culture.
  • Good instructional design does not automatically become UDL because it anticipates learner needs.
  • Sometimes the more intellectually responsible thing to do is to preserve distinctions.

And what about the evidence?

This is another area where I think greater precision would benefit UDL.

UDL is frequently described as “research-based,” and there is empirical evidence supporting UDL-based instruction. A meta-analysis by King-Sears et al. (2023), for example, examined 20 studies comprising 50 effects and found a moderate positive combined effect on learner achievement (g = .43) for UDL-based interventions compared with comparison conditions.

That is meaningful evidence and should not be dismissed. But it is not the end of the story.

A systematic review by Zhang et al. (2024) examined 32 studies of UDL implementation in preK–12 settings and identified persistent problems in the research literature: inconsistent alignment between interventions and UDL checkpoints, uneven implementation across the framework, overlap among guidelines and checkpoints, and insufficient theoretical guidance about what constitutes UDL implementation.

A separate critical analysis by Boysen (2024a) examined empirical studies that CAST itself cited as support for three selected UDL guidelines related to choice, learning, and brain function. Boysen concluded that much of the cited evidence supported particular instructional techniques rather than directly validating the broader claims associated with those UDL guidelines and called for stronger basic and implementation research on the framework.

And a 2026 scoping review of 113 empirical studies of UDL in higher education identified continuing gaps involving methodological rigor, measurement of learning outcomes, and the contexts represented in the research literature (Ren et al., 2026).

Taken together, this evidence supports a more nuanced conclusion than either “UDL is evidence-based” or “UDL has no evidence.”

There is empirical evidence supporting UDL-based interventions, including evidence of positive effects on learning. At the same time, significant questions remain about how UDL is defined and operationalized, how consistently research labeled as UDL actually represents the framework, and whether evidence for individual practices incorporated within UDL should be treated as evidence validating UDL as an integrated framework (Boysen, 2024a; King-Sears et al., 2023; Ren et al., 2026; Zhang et al., 2024).

Those are related questions, but they are not identical questions.

  • Evidence that captions benefit learners does not, by itself, validate UDL as a theoretical framework.
  • Evidence that retrieval practice improves learning does not become evidence for UDL simply because retrieval practice can be incorporated into a UDL-designed course.
  • Evidence that learner choice sometimes supports motivation does not necessarily validate a broader claim about multiple means of engagement.

Likewise, a study describing an intervention as “UDL” tells us relatively little unless we know what was actually implemented and how faithfully the intervention represented the framework.

This distinction is especially important for a framework as broad as UDL. The more practices a framework incorporates, the easier it becomes to point to evidence supporting something contained within the framework. That is not necessarily the same thing as demonstrating the validity or effectiveness of the framework as an integrated whole.

So I would not argue that UDL lacks an evidence base. I would argue that claims about that evidence should be appropriately bounded. UDL deserves the same intellectual scrutiny we would expect of any influential educational framework.

A Cautionary Parallel: Learning Styles

There is another reason I think the evidence question matters. Some aspects of the way UDL is discussed and promoted bear an uncomfortable resemblance to the history of learning styles. Boysen (2024b) makes this comparison directly, arguing that UDL and learning styles share important problems in theory, operationalization, and research, including appeals to learner variability, instructional matching, neuroscience-based rationales, and difficulty specifying exactly what counts as implementation.

The comparison is cautionary, not equivalence: UDL is not simply learning styles by another name.

Learner variability is real. That does not, by itself, validate every theoretical claim made by UDL or establish UDL as the singular framework through which learner variability, accessibility, and inclusive teaching should be understood.

The history of learning styles should make us cautious about allowing intuitive appeal, neuroscience language, evidence for individual practices, and widespread adoption to substitute for evidence validating an educational framework itself (Boysen, 2024b).

This is particularly important because the values now associated with UDL are so compelling. Who wants to argue against access, inclusion, flexibility, equity, learner agency, or recognizing learner variability? As UDL becomes increasingly associated with all of those values, questioning a claim about UDL can begin to sound like questioning the values themselves.

It is not. Scrutinizing the evidence for a framework is not the same as rejecting the goals the framework is intended to serve.

Seen this way, UDL inflation is not only inflation of scope; it can also become inflation of evidentiary claims.

Accessibility Should Remain Accessibility

This is why I am increasingly convinced that Accessibility and Inclusive Online Teaching Practices should remain distinct conceptual lenses rather than being folded together under UDL.

Accessibility asks us to identify and eliminate barriers to access, particularly for people with disabilities, and to meet established functional, technical, and legal requirements.

Inclusive teaching asks broader questions about belonging, participation, representation, identity, equity, relationships, and whose experiences and ways of knowing are recognized in the learning environment.

UDL can inform both. It can help educators anticipate variability and think proactively rather than waiting for individual students to encounter barriers. It can provide useful strategies for representation, engagement, interaction, and expression. But UDL does not need to own either concept in order to contribute to them.

In fact, I would argue that a stronger conceptual model treats UDL as one informing pedagogical framework that can operate across multiple dimensions of quality online course design, rather than as the master framework under which accessibility and inclusive teaching must sit.

That preserves something important. It allows us to say that accessibility is a non-negotiable condition of equitable educational participation, grounded in disability rights and functional access. It allows us to recognize inclusive teaching as a broader pedagogical and relational commitment. And it allows us to use UDL as one valuable framework for proactively designing around learner variability without asking it to carry conceptual weight it was never meant to bear.

Precision Matters

Perhaps the easiest response to all of this is: Does the terminology really matter if everyone is trying to make learning better?

I think it does.

If I tell faculty that using UDL makes their courses accessible, I may inadvertently give them confidence that they have satisfied accessibility requirements when their documents, videos, technologies, or learning activities remain inaccessible.

If I describe every inclusive teaching practice as UDL, I risk obscuring the scholarship and traditions from which those practices actually emerged.

And if I call UDL a “standard,” I blur an important distinction between a flexible pedagogical framework and requirements against which accessibility can actually be evaluated.

We do not need to diminish UDL to make these distinctions. We need to put it in the right place.

UDL can help us design more accessible and inclusive learning experiences, but it should not be used as a proxy for accessibility. Accessibility has specific functional, technical, and legal requirements. UDL is a broader pedagogical framework for reducing barriers and supporting learner variability.

Accessibility is not merely a checkpoint inside UDL. Inclusive teaching is not merely another application of UDL. And UDL does not have to become the name for everything we value in teaching in order to be valuable.

Perhaps the best way to protect the usefulness of UDL is to stop asking it to be everything.

References

Boysen, G. A. (2024a). A critical analysis of the research evidence behind CAST’s universal design for learning guidelines. Policy Futures in Education, 22(7), 1219–1238. https://doi.org/10.1177/14782103241255428

Boysen, G. A. (2024b). Lessons (not) learned: The troubling similarities between learning styles and universal design for learning. Scholarship of Teaching and Learning in Psychology, 10(2), 207–221. https://doi.org/10.1037/stl0000280

CAST. (2024). CAST Universal Design for Learning Guidelines version 3.0. https://udlguidelines.cast.org/

Higher Education Opportunity Act, 20 U.S.C. § 1003(24) (2008). https://www.law.cornell.edu/uscode/text/20/1003

King-Sears, M. E., Stefanidis, A., Evmenova, A. S., Rao, K., Mergen, R. L., Owen, L. S., & Strimel, M. M. (2023). Achievement of learners receiving UDL instruction: A meta-analysis. Teaching and Teacher Education, 122, 103956. https://doi.org/10.1016/j.tate.2022.103956

Ren, N., Lam, G. Y. H., Wang, Y., King, R. B., & Lee, V. W. Y. (2026). Integrating Universal Design for Learning in higher education: A scoping review of empirical studies. Higher Education Research & Development, 45(6), 1866–1883. https://doi.org/10.1080/07294360.2026.2627873

U.S. Department of Justice, Civil Rights Division. (2026). Extension of compliance dates for nondiscrimination on the basis of disability; Accessibility of web information and services of state and local government entities. https://www.ada.gov/assets/pdfs/2026-ifr.pdf

Zhang, L., Carter, R. A., Jr., Greene, J. A., & Bernacki, M. L. (2024). Unraveling challenges with the implementation of Universal Design for Learning: A systematic literature review. Educational Psychology Review, 36, Article 35. https://doi.org/10.1007/s10648-024-09860-7

 

accessibility, udl