The regulations say that intranets are exempt until September 2020, however this exemption for intranets only applies to the content of the web pages not the website itself.
The text of the regulation is “content of extranets and intranets published before 23rd September 2019, or until such time as the website undergoes a substantial revision, whichever is sooner;”.
Therefore any updates to content after September 2019 would require it to meet accessibility standards including the publishing of an accessibility statement. Below are example statements for a Moodle-based VLE:
A large amount of the VLE online content is produced and controlled by teaching staff, and ensuring this content is all updated to comply with the legislation is an enormous challenge. IT and e-learning staff need help to manage a major staff training challenge to improve the accessibility of content staff produce. There is a need to balance a call-to-action with the risk of panic and push-back.
Intranet/extranets are not required to comply with the regulations if they do not undergo substantial revision. However, if they are newly published or substantially revised on or after 23 September 2019 then they are in scope and will need to be compliant from the date published or substantially revised.
On the topic of substantial revision there is not yet a clear consensus on exactly what the definition of substantial revision is. Is it moving to an updated version of a platform? Is it the addition of new features or changes to the look and feel? Is it after a certain percentage of content has undergone changes? Government guidance on the question includes the following in the deadline section (however as yet there is still no definitive legal definition of substantial revision):
“If you make substantial changes to the code, for example to create new features, or if you create a subdomain with its own distinct codebase, it’s likely that these will need to be fully accessible from 23 September 2019 (the same deadline as for new websites).”
Blackboard Ally for VLEs
Blackboard Ally plays a crucial role in enabling the University to prepare to meet these regulations by helping to quantify the current accessibility maturity of all key learning and teaching materials held within Moodle. In addition, Blackboard Ally will help to maintain awareness of accessible content creation and identify opportunities for targeted training to support academic schools and administrative departments to improve the accessibility of all of their content in line with the aims of the regulations.
Blackboard Ally works like Sensus Access in that it supports accessible document conversion; taking otherwise inaccessible electronic documents and adding key functionality in order to make them available to people with print disabilities.
The integration of alternative formats document functionality into learning and teaching processes delivers a number of collateral benefits for inclusive education. Fluid, retrospective optical character recognition (OCR) enables inaccessible documents to be converted very speedily to audio format that will read aloud documents on a range of portable devices, simultaneously addressing accessibility and learning style preferences. Document conversion capability can also support self-sufficiency as users are able to manipulate documents styles to suit their preferences (magnification, font, colour changes, annotation) and support better compatibility of assistive technologies.
In addition to ensuring basic Optical Character Recognition (OCR), Ally offers automatic semantic markup of documents (e.g. headings for navigation) to provide a solid basic level of accessibility. The use of Ally in improving the native accessibility of Word and PowerPoint documents is closely aligned to the following Kent Inclusive Practices:
Ally is able to report on all content across Moodle in order to assess the overall accessibility of documents across the VLE. This could help to take the temperature of accessibility awareness in content creation and identify opportunities for targeted training to support academic schools and administrative departments to improve the accessibility of all of their content.