# Inclusive Credential Programmes *Universal Design for Learning, accessibility and fair outcomes.* ## About this course This course belongs to the ICoBC Credentialing Skills Framework (ICSF). It develops the skill INCL "Inclusion and accessibility" (VRITE pillar: Experience) at level L3 "Enable", stage A "Ability". At this level you design inclusive credential programmes and plan recognition routes for non-formal learning and for under-represented groups. At stage A you practise this on realistic tasks, in a controlled setting, using the knowledge you gain. **Who it is for** - Programme and micro-credential leads (E1) - Learning designers and teaching staff (E2) - Professional bodies and sector associations (P1) - Policy makers and public agencies (P2) - L&D and corporate academy leads (C1) **Prerequisite:** ICB-F08 Accessible and Inclusive Credentials: the Basics. **Learning outcomes.** After this course you can: 1. Apply Universal Design for Learning to credential design and assessment. 2. Plan accessible platforms and materials against WCAG 2.2. 3. Design recognition routes for under-represented groups. 4. Monitor equity of outcomes. **Workload.** The course is a workshop with 6 hours of notional learning. This file covers the self-paced part. Live or workshop elements appear as facilitator notes. **How it is assessed.** You complete a knowledge check with single-choice questions, and you submit an inclusion plan for one programme, with metrics. A person assesses the plan using the rubric in "Assessment and badge". The file does not grade the plan. **Badge.** "Inclusive Credential Programmes (Ability, L3)", alignment code ICSF-INCL-L3-A. The badge evidence is your inclusion plan. Completing the course does not prove competency in a job. The badge records that you practised the capability on a realistic task and that an assessor reviewed your evidence. | Outcome | Module | How it is assessed | |---|---|---| | 1. Apply Universal Design for Learning to credential design and assessment | Universal Design for Learning | Module quiz, practice activity, knowledge check, inclusion plan (rubric criteria 1 and 2) | | 2. Plan accessible platforms and materials against WCAG 2.2 | Accessible delivery | Module quiz, practice activity, knowledge check, inclusion plan (rubric criterion 3) | | 3. Design recognition routes for under-represented groups | Language and culture | Module quiz, practice activity, knowledge check, inclusion plan (rubric criterion 4) | | 4. Monitor equity of outcomes | Equity data | Module quiz, practice activity, knowledge check, inclusion plan (rubric criteria 5 and 6) |
Facilitator notes **Workshop outline (6 hours notional learning).** Suggested split: about 3 hours self-paced work in this file, about 2 hours live session, about 1 hour to draft the inclusion plan. 1. Opening (15 minutes): confirm the prerequisite ICB-F08 and ask participants to name one programme they will use for the inclusion plan. They should choose a programme they know well and can describe with real or illustrative data. 2. Pair work: participants work in pairs for each practice activity and swap drafts for peer feedback. 3. Closing (20 minutes): each participant presents one barrier and one fix from their plan in two minutes. Participants from different settings (a university or training provider, a professional body, a public agency, a corporate academy) can learn from each other's contexts. Mix them in pairs where possible.
## Universal Design for Learning Universal Design for Learning (UDL) is a framework for designing learning so that more people can take part without a separate adjustment. In this module you apply UDL to a credential: the programme, its assessment and its evidence. ### The three UDL principles UDL is organised around three principles, which the framework owner CAST describes in its guidelines: - **Engagement:** offer ways to interest people, sustain effort and support self-regulation. This is the "why" of learning. - **Representation:** offer information in more than one format, so people can perceive and understand it. This is the "what" of learning. - **Action and expression:** offer more than one way to act, to show what you know and to plan your work. This is the "how" of learning. A credential programme has many places where these principles apply: the way outcomes are written, the learning materials, the activities, the assessment and the form of the final badge. UDL asks you to build in options early, so that fewer people need a special request later. Two points matter for credential design: 1. **Separate the outcome from the method.** The outcome states what a person can do. The method of showing it can vary. If an outcome says "present a case to a panel", ask whether presenting is the skill, or whether communicating a case is the skill. If communicating is the skill, a written case or a recorded explanation may serve equally well. 2. **Keep standards constant.** UDL does not lower the standard. It widens the routes to the same standard. The criteria and the level of performance stay the same for every route. {{1}} UDL principles applied to one credential A navy circle in the centre labelled "One credential outcome" is connected to three boxes. The first box, Engagement, lists choice of topic for the case and flexible deadlines. The second box, Representation, lists text, audio and captioned video briefs. The third box, Action and expression, lists written report, recorded walk-through or live presentation. All three routes lead to the same assessment criteria. One credential outcome Engagement (the why) Choice of case topic, flexible pacing Representation (the what) Text brief, audio brief, captioned video brief Action and expression (the how) Written report, recorded walk-through, or live presentation Same criteria and same standard for every route ### Applying UDL to assessment Assessment is where barriers often hide. A written exam can test reading speed when the outcome is about analysis. A live demonstration can test confidence under observation when the outcome is about technique. Use this sequence when you review an assessment: 1. **Write the outcome in one sentence.** Use a verb that describes performance. 2. **List what the task also demands.** Examples: fast reading, handwriting, speaking aloud, travelling to a site, a stable internet connection, a quiet room. 3. **Mark which demands are part of the outcome.** Keep those. Treat the rest as barriers. 4. **Offer options that remove the barriers.** For example, allow typed or dictated answers when handwriting is not the skill. 5. **Check that every option measures the same criteria.** Use one rubric for all routes. Not every barrier can be removed. Some professions require a physical or sensory capability for a licensed task. Those requirements should be stated openly, justified by the role and kept to what is essential. Where a requirement is set by law or a regulator, follow the regulator's rules. ### Credential design choices UDL also applies beyond assessment: - **Entry:** offer clear information on what the programme demands, in plain language and more than one format. - **Pacing:** allow reasonable flexibility in deadlines and sequence where the outcomes allow it. - **Feedback:** give feedback in a form people can use, such as written comments, audio comments or a short conversation. - **Badge metadata:** describe criteria in plain language, so earners and verifiers can understand what the badge records. **Worked example: Redesigning a capstone task in a training provider** *Context: a college or training provider.* A programme lead at a training provider runs a micro-credential in project coordination. The capstone task is a 20-minute live presentation to a panel. The outcome reads: "Present a project plan and justify the main decisions." The lead applies the five-step review: 1. Outcome in one sentence: the learner explains and justifies a project plan. 2. Other demands: speaking in front of strangers, travelling to the panel venue, a fixed time slot, no notes. 3. Part of the outcome: explaining and justifying decisions. Not part of it: a fixed venue, speaking live to strangers, a single time slot. 4. Options added: a live presentation, a recorded presentation submitted by the deadline, or a written justification with an oral follow-up of ten minutes by video call. 5. One rubric: criteria cover clarity of plan, quality of justification and response to questions. All three routes use it. The lead also publishes the options in the programme guide before enrolment. The standard stays the same. The routes differ. **Practice activity: UDL review of an assessment** Choose one assessment from a programme you know. If you do not have one, use this illustrative case from a professional body: a continuing professional development credential for safety officers, with a 60-minute timed written exam of 40 short-answer questions. 1. Write the outcome in one sentence. 2. List at least four demands of the task beyond the outcome. 3. Mark which demands belong to the outcome. 4. Propose at least two alternative routes and say how one rubric covers all routes. 5. Note one requirement you would keep fixed and justify it. Keep your notes. You will reuse them in the inclusion plan.
Facilitator notes Run the practice activity in pairs for 25 minutes. Ask each pair to swap their list of demands and challenge one item: "Is this really part of the outcome?" Collect two examples of fixed requirements and discuss whether a regulator or the role justifies them. Remind participants that offering options must not create a different standard for different groups.
**Quiz: Universal Design for Learning** **Question 1.** Which statement describes the three UDL principles? [( )] Speed, accuracy and cost. [(X)] Engagement, representation, and action and expression. [( )] Access, adjustment and appeal. [( )] Planning, delivery and review. [[?]] Think of the "why", the "what" and the "how" of learning. **** UDL is organised around multiple means of engagement, representation, and action and expression. These cover the why, the what and the how of learning. **** **Question 2.** A credential outcome says "Explain a safety procedure." Which assessment change keeps the standard and widens the routes? [( )] Remove the explanation criterion for some learners. [( )] Give a shorter exam with easier questions to some learners. [(X)] Allow a written, recorded or live explanation, all marked with the same rubric. [( )] Require everyone to give a live explanation for consistency. [[?]] Look for the option that changes the method and keeps the criteria. **** UDL widens the routes to the same standard. One rubric for all routes keeps the criteria constant. Lowering the criteria or forcing one method does not meet the principle. **** **Question 3.** What is the first step in reviewing an assessment for barriers? [( )] Choose accessible software. [( )] Ask learners to disclose their disabilities. [(X)] Write the outcome in one sentence and list what the task also demands. [( )] Shorten the task by half. [[?]] You need to know what is being measured before you judge the task. **** The review starts with the outcome. Once you know what must be shown, you can see which task demands are part of it and which are barriers. **** **Question 4.** A credential for a licensed role requires a physical capability that the regulator names. What is the best practice? [( )] Hide the requirement to avoid discouraging applicants. [( )] Remove it, because UDL removes all requirements. [(X)] State it openly, keep it to what is essential and follow the regulator's rules. [( )] Apply it to all credentials in the same sector. [[?]] UDL widens routes but does not override legal requirements for a role. **** Some requirements are essential to the role and set by a regulator. State them openly and keep them limited to what the role needs. **** ## Accessible delivery A programme can be well designed and still fail if the platform, the documents or the videos cannot be used. This module covers how to plan accessible delivery against WCAG 2.2. ### What the rules say Three sources shape accessibility planning for credential programmes in Europe: - **The European Accessibility Act (EAA)** applies since 28 June 2025. It sets accessibility requirements for a range of products and services in the EU. Whether and how it applies to your programme depends on what you offer and on national law. - **WCAG 2.2** is the current W3C Recommendation for web content accessibility. It is organised under four principles: perceivable, operable, understandable and robust. Success criteria are tested at levels A, AA and AAA. - **EN 301 549** is the European standard on accessibility requirements for ICT products and services. It is widely used in public procurement and refers to WCAG for web content. Status as of November 2026; check before publishing. This course does not give legal advice. If you are unsure whether a law applies to your organisation, ask your legal or compliance contact. As a planning target, many organisations aim for WCAG 2.2 level AA for the platform and the materials. Check which target your organisation, funder or national rules require. ### Planning against WCAG 2.2 Planning means turning the standard into a list of checks for each part of the programme. Work through the four principles: - **Perceivable:** text alternatives for images, captions for video, transcripts for audio, enough colour contrast, text that can be resized. - **Operable:** everything works with a keyboard, no time limits without options, clear focus indicators, no content that flashes dangerously. - **Understandable:** plain language, consistent navigation, clear error messages and instructions in forms. - **Robust:** correct structure in the code and documents, so assistive technology can read them. WCAG 2.2 added success criteria to WCAG 2.1. Examples include requirements about focus not being hidden, the size of pointer targets, and accessible authentication. Check the exact criteria in the W3C text when you write your checklist. {{1}} Accessibility plan across the learner journey Four steps in a row show the learner journey: find and enrol, learn, be assessed, receive and share the badge. Under each step is one accessibility check. Find and enrol: accessible forms and plain-language information. Learn: captions, transcripts and keyboard use. Be assessed: alternative formats and time options. Receive and share the badge: readable badge page and text description of criteria. 1. Find and enrol 2. Learn 3. Be assessed 4. Receive and share the badge Accessible forms, plain-language programme guide Captions, transcripts, keyboard use Alternative formats, time options, one rubric Readable badge page, text description of criteria Plan one check per step, then test with real users ### Materials and platforms Most barriers in credential programmes come from ordinary materials. Plan these basics: - **Documents:** use real headings, lists and table headers. Add alternative text to images that carry meaning. Avoid scanned pages without a text layer. - **Video and audio:** provide captions and a transcript. Describe important visual information in the audio or in the transcript. - **Slides:** use a clear reading order, sufficient contrast and large text. - **Colour:** never use colour alone to carry meaning. Label with text or pattern as well. - **Platform:** test keyboard use, screen reader use, zoom to 200 per cent and mobile use. Check login steps for memory or puzzle tasks that could block people. - **Assessment tools:** check that timers can be extended and that answer formats work with assistive technology. ### Testing and responsibilities Automated checkers find some problems, not all. Combine methods: 1. **Automated checks** for quick coverage of common issues. 2. **Manual checks** by a trained person against your checklist. 3. **User testing** with people who use assistive technology. Assign each task to a named role: for example the programme lead owns the accessibility target, the learning designer owns the materials, the platform administrator owns configuration, and a named contact handles accessibility feedback. Publish a way to report barriers and a response time you can meet. An accessibility statement or equivalent page can set out the target, known limits and the contact route. If your procurement involves a supplier, ask for the supplier's accessibility conformance information and check it, without relying on it alone. **Worked example: Accessible delivery plan at a professional body** *Context: a professional body.* A professional body in the logistics sector offers an online credential for warehouse supervisors. Learners use a web platform, watch video lessons and sit an online multiple-choice test. The education manager prepares a WCAG 2.2 plan, with an illustrative target of level AA. Her plan: | Area | Check | Owner | Evidence | |---|---|---|---| | Video lessons | Captions and transcripts for all 12 videos (illustrative number) | Learning designer | Caption files and transcripts | | Documents | Headings and alternative text in all PDFs | Learning designer | Checklist per document | | Platform | Keyboard and screen reader test of enrolment, lessons and test | Platform administrator | Test report | | Online test | Option to extend time and clear instructions | Education manager | Test settings record | | Badge page | Text description of criteria, readable on mobile | Education manager | Page review | | Feedback | Barrier report form and named contact | Education manager | Published page | She schedules user testing with two members who use assistive technology and records the fixes made. She also notes which items depend on the platform supplier and asks the supplier for conformance information. **Practice activity: Build an accessibility plan** Take the programme you chose in the first module, or use this illustrative case from a public agency: a national agency runs a free online credential on digital skills for adults, with a web platform, PDF guides, 8 videos and an online assessment. 1. Map the learner journey in four steps: find and enrol, learn, be assessed, receive and share the badge. 2. For each step, name at least two accessibility checks drawn from the four WCAG principles. 3. Assign an owner and the evidence you would keep for each check. 4. State your target (for example WCAG 2.2 level AA) and what you would check with your legal or compliance contact. 5. Describe how you would collect feedback on barriers and how fast you would respond. Keep the plan for your inclusion plan.
Facilitator notes If a participant has access to a demonstration platform or sandbox, ask them to test one page with a keyboard only for five minutes and report where focus gets lost. Do not name or recommend commercial tools. Remind participants that the session is not legal advice and that national rules vary. For mixed groups, ask the public agency participants to explain how procurement rules affect their choices.
**Quiz: Accessible delivery** **Question 1.** Which is the current W3C Recommendation for web content accessibility referred to in this course? [( )] WCAG 1.0 [( )] EN 301 549 only [(X)] WCAG 2.2 [( )] The Accessibility Statement [[?]] It has four principles: perceivable, operable, understandable, robust. **** WCAG 2.2 is the current W3C Recommendation for web content accessibility. EN 301 549 is a European ICT standard that refers to WCAG for web content. **** **Question 2.** When does the European Accessibility Act apply, according to the course notes? [( )] Since 1 January 2020 [( )] From 2030 [(X)] Since 28 June 2025 [( )] It has never applied [[?]] The date is in mid-2025. **** The European Accessibility Act applies since 28 June 2025. Whether it covers your programme depends on what you offer and on national law, so check with your legal or compliance contact. **** **Question 3.** Which action best follows the principle "perceivable" for a training video? [( )] Use a faster speaking pace. [( )] Add background music. [(X)] Provide captions and a transcript. [( )] Remove the video and use a poster. [[?]] Think about people who cannot hear the audio. **** Captions and transcripts make audio content perceivable to people who cannot hear it, and they also help many other learners. **** **Question 4.** Why combine automated checks with manual checks and user testing? [( )] Automated checks are illegal. [( )] Manual checks are cheaper. [(X)] Automated tools find only some problems, so other methods are needed for coverage. [( )] User testing replaces the need for a target. [[?]] Consider what a tool can and cannot judge, such as whether alternative text is meaningful. **** Automated tools detect some issues, such as missing attributes, but cannot judge everything, such as whether a text alternative is meaningful. Manual checks and user testing add coverage. **** ## Language and culture Inclusion also depends on language, culture and the routes by which people reach a credential. This module covers plain language, translation, and recognition routes for non-formal learning and under-represented groups. ### Language that people can use Many barriers are linguistic. Learners may study in a second language, use assistive technology that reads text aloud, or come from a setting where terms differ. Practical steps: - **Plain language:** short sentences, common words, one idea per paragraph, terms explained at first use. - **Consistent terms:** use the same word for the same thing across the programme. - **Criteria in plain language:** badge criteria and rubrics should be understandable to earners, not only to specialists. - **Examples with variety:** use names, places and situations from different backgrounds, and avoid idioms and jokes that need local knowledge. - **Instructions:** state clearly what is expected, how long it takes and where to get help. ### Translation and AI translation Translating programme guides, criteria and materials can open a credential to more people. Translation also creates risks, because a translated criterion may change meaning. AI translation tools can produce a fast draft. They have limits, which you should plan for: - **Meaning can shift.** A tool may translate a technical term with a common word that has a different meaning in the field. - **Terms of art and standards vary.** Professional and legal terms may not have a direct equivalent. - **Tone and register can change.** Instructions may sound too formal or too casual. - **Errors can be hard to spot.** A fluent text may still be wrong. - **Data protection.** Learner data and unpublished assessment content should not be entered into a tool unless your organisation has checked how the data is handled. A sound approach is to treat AI translation as a draft. Then: 1. Keep a glossary of key terms with approved translations. 2. Ask a qualified human reviewer who knows the field to check criteria, rubrics and badge descriptions. 3. State which language version is authoritative if versions differ. 4. Record who reviewed the translation and when. 5. Collect feedback from users and correct errors. Do not publish machine-translated criteria as the official text without human review. A credential's criteria define what the badge means, so errors can affect fairness. {{1}} Translating credential criteria with human review A five-step flow from left to right. Step 1: source criteria in plain language. Step 2: AI translation draft. Step 3: human review by a subject expert, using a glossary. Step 4: authoritative language statement and publication. Step 5: user feedback and correction, which loops back to step 3. The AI draft box is marked as draft only. 1. Source criteria in plain language 2. AI translation draft (draft only) 3. Human review by subject expert with glossary 4. Publish with authoritative language stated 5. User feedback and corrections Corrections return to human review AI gives a draft, people decide the meaning ### Recognition routes for non-formal learning and under-represented groups Many people have skills from work, volunteering, community roles or informal study, but no formal certificate. Others come from groups that are under-represented in a field, and may face barriers in entry, cost, networks or trust. A recognition route is a defined way to have prior or non-formal learning assessed against the same criteria as the standard route. Key design points: - **Same standard.** The criteria and level are the same as for the standard route. Only the route to the evidence differs. - **Clear information.** Explain who the route is for, what evidence is accepted, how long it takes and what it costs. - **Flexible evidence.** Accept work samples, references, observation by a supervisor, a portfolio or a short assessment, as long as each links to the criteria. - **Fair process.** Train assessors, use the rubric, and offer an appeal route. - **Reduce structural barriers.** Consider fees, language, location, time and access to technology. Consider whether outreach is needed so the right people know the route exists. - **Support.** Offer guidance on preparing evidence, for example a template or an advice session. - **Define the group carefully.** Which groups are under-represented depends on the field and the country. Use your own context and data, and avoid assumptions. Be careful with data on groups. Collect only what you need, explain why, and follow your data protection rules. **Worked example: A recognition route at a public agency** *Context: a public agency.* A regional public agency runs a credential for community health support workers. Many experienced people have worked in community roles for years without formal training. Early data show few applicants from rural areas (illustrative finding). The programme lead designs a recognition route: - **Criteria:** identical to the standard route: five competence areas with the same rubric. - **Evidence:** a portfolio with three work examples, a reference from a supervisor or community leader, and a 30-minute conversation with an assessor by video call or in a local office. - **Language:** the guide is in plain language and in two additional regional languages, translated with AI as a draft and checked by two bilingual reviewers who work in the field. The agency states which version is authoritative. - **Barriers:** no fee for the portfolio review for the first year (illustrative), local advice sessions, and a template for evidence. - **Quality:** assessors are trained, use the same rubric, and a second assessor reviews any borderline case. An appeal route is published. - **Monitoring:** the agency will compare applications, completions and outcomes by route. The route is the same standard, reached by a different path. **Practice activity: Design a recognition route** Use your own programme or this illustrative case from a university: a short micro-credential in data literacy, where the standard route is a 6-week course with weekly online sessions. The university wants to recognise adults with workplace data experience and no degree. 1. Name the target group and the barriers you think they face. Say how you could check these assumptions. 2. Define the evidence you would accept, and link each type to a criterion. 3. Describe how you would keep the standard the same as for the course route. 4. Design the information and support: language, cost, location, guidance. 5. Plan the assessor process: training, second review and appeal. 6. Note how AI translation, if used, would be checked by humans. Keep your route for the inclusion plan.
Facilitator notes Invite participants to bring a translated document from their organisation if available, with permission. In pairs, ask them to pick three key terms in the criteria and discuss whether a translation could shift the meaning. Stress that recognition routes must keep the same standard, and that fairness comes from clear criteria, trained assessors and an appeal route. Do not discuss specific named tools or vendors.
**Quiz: Language and culture** **Question 1.** What is the best way to use AI translation for official credential criteria? [( )] Publish the output directly to save time. [( )] Avoid translation altogether. [(X)] Use it as a draft and have a qualified human reviewer check it against a glossary. [( )] Translate only the title of the badge. [[?]] Criteria define what the badge means, so errors matter. **** AI translation can give a quick draft, but it can shift meaning, especially for technical terms. A subject-expert reviewer and a glossary help keep the criteria accurate. **** **Question 2.** In a recognition route for non-formal learning, what stays the same as in the standard route? [( )] The fee and the duration. [( )] The type of evidence. [(X)] The criteria and the level. [( )] The assessor. [[?]] The route differs, the standard does not. **** A recognition route changes the path to the evidence. The criteria and level of the credential stay the same, so the badge means the same for all earners. **** **Question 3.** Which is an example of plain-language practice in a programme guide? [( )] Using long sentences with technical terms and no explanation. [( )] Using idioms to sound friendly. [(X)] Using short sentences and explaining terms at first use. [( )] Using different words for the same concept in each module. [[?]] Think about a reader who studies in a second language. **** Short sentences, common words and explained terms help all readers, including those who use a second language or assistive technology. **** **Question 4.** Why should a translated programme state which language version is authoritative? [( )] To reduce the number of translations. [( )] To avoid human review. [(X)] To make clear which text applies if versions differ. [( )] To remove the need for a glossary. [[?]] Think about what happens when two versions say different things. **** If translations differ, people need to know which text counts. An authoritative version avoids disputes and supports fair decisions. **** ## Equity data An inclusive programme needs evidence that it works for different people. This module covers how to choose metrics, collect data responsibly and act on what you find. ### What equity of outcomes means Equity of outcomes asks whether people from different groups have a fair chance to enter, progress, complete and benefit from a credential. It looks at results, not only at intentions. A programme may offer a recognition route and still find that few people from some groups complete it. Data helps you see where barriers remain. Equity is not the same as treating everyone identically. Fair outcomes may need different support for different people, while the standard stays the same. ### Choosing metrics Follow the learner journey and ask where people may drop out or be held back: - **Reach:** who applies, compared with the intended audience. - **Entry:** who is accepted or enrolled, and through which route. - **Progress:** who reaches key points in the programme. - **Completion:** who completes and earns the badge. - **Assessment results:** pass rates and rubric scores, by route and group where numbers allow. - **Experience:** satisfaction and reported barriers. - **Use of the badge:** whether earners share it and how it is received, where you can learn this. - **Access:** requests for adjustments, response time and outcome. For each metric, define a clear formula, a data source, an owner, a reporting frequency and a trigger for action. For example: "Completion rate by route = learners who earn the badge divided by learners who enrol, for each route, reported each term." Do not set targets without context. A target should reflect what is realistic and what your organisation can influence. Compare groups with care, and look at trends, not single figures. {{1}} Sketch of an equity dashboard A simple dashboard sketch with four panels and a table. Panel 1: reach, applicants by group. Panel 2: completion rate by route, standard route against recognition route. Panel 3: assessment results by route. Panel 4: barrier reports and response time. A strip at the bottom reads: review each term, act when a gap appears. All figures are placeholders for illustration. Equity dashboard (illustrative sketch) 1. Reach: applicants by group Group A Group B Group C 2. Completion rate by route Standard Recognition Gap to investigate 3. Assessment results by route Pass rate and rubric scores Shown only if group size is large enough Placeholder values 4. Barrier reports Number received, themes Response time against target Placeholder values Review each term, and act when a gap appears ### Collecting data responsibly Equity data can include sensitive information. Handle it with care: - **Purpose:** collect only what you need for a stated purpose. - **Consent and notice:** explain what you collect, why and who sees it. Make disclosure voluntary where the law and your context allow. - **Legal basis and rules:** follow data protection law and your organisation's policy. If you work in the EU, ask your data protection contact how the GDPR applies. This course gives no legal advice. - **Minimise and protect:** store data securely, limit access and keep it only as long as needed. - **Small groups:** where a group has very few people, results can identify individuals. Combine categories or hide small numbers when you report. - **Separate data from decisions about individuals:** use equity data to review the programme, not to decide on a person's result. - **Define categories carefully:** categories differ across countries and fields. Use ones that are meaningful and lawful in your context. ### Acting on the data Data matters only when it leads to action. Build a simple cycle: 1. **Review** the dashboard on a set schedule. 2. **Ask why** when a gap appears. Check the process before drawing conclusions: entry rules, language, platform access, assessor practice, cost, timing. 3. **Involve people** from the groups concerned, through interviews or a small advisory group. 4. **Change** one thing at a time where you can, so you can learn what worked. 5. **Record** the decision, owner and date. 6. **Report** results to leaders and, where appropriate, publicly. Be honest about limits. A gap in numbers does not always show its cause. Small samples, changes in who applies and other factors can distort comparisons. Treat data as a prompt for enquiry. **Worked example: An equity review at a university** *Context: a university.* A university runs a micro-credential in sustainability reporting for working adults. The programme lead sets up an equity review. All figures are illustrative. She defines four metrics: applicants by route, completion rate by route, rubric score by route, and barrier reports with response time. After the first term she finds that 80 per cent of learners on the standard route complete, against 55 per cent on the recognition route (illustrative). She does not conclude that the recognition route is weaker. She asks why. She reviews the process and interviews six learners from the recognition route. She hears that evening sessions clash with shift work and that the portfolio template is confusing. She changes two things: the sessions are recorded with a short live Q&A at two different times, and the template is rewritten in plain language with an example. In the second term she records the same metrics again and compares them. She records the decisions, owners and dates, and reports the findings to the programme board. She also hides group figures below a minimum number of learners to protect privacy. **Practice activity: Design an equity metrics set** Use your own programme or this illustrative case from a professional body: a certification route for early-career engineers, with a standard exam route and a recognition route for experienced practitioners without a formal qualification. 1. List at least five metrics across the learner journey. 2. For each, write a formula, data source, owner and reporting frequency. 3. Set a trigger for action for at least two metrics (for example, "if the completion gap between routes exceeds a level agreed by the board, start a review"). 4. Describe what data you would collect on groups, why, and how you would protect it. 5. Name a rule for small groups. 6. Describe a review cycle: who meets, how often, and how decisions are recorded. Keep your metrics set for the inclusion plan.
Facilitator notes Provide a blank dashboard template on paper or a shared document (without commercial tools). Ask pairs to fill in invented numbers and then to write two possible explanations for one gap and one way to test each explanation. Stress that gaps prompt enquiry and do not prove cause. Ask a participant who works with data protection to share how their organisation handles sensitive categories, without disclosing personal data.
**Quiz: Equity data** **Question 1.** What does "equity of outcomes" ask? [( )] Whether every learner receives exactly the same support. [( )] Whether the programme has an inclusion policy. [(X)] Whether people from different groups have a fair chance to enter, progress, complete and benefit. [( )] Whether the number of badges issued is high. [[?]] It looks at results as well as intentions. **** Equity of outcomes looks at results across groups. Fair outcomes may need different support, while the standard stays the same. **** **Question 2.** A dashboard shows a lower completion rate on the recognition route. What is the best first step? [( )] Close the recognition route. [( )] Lower the standard for that route. [(X)] Investigate possible causes, for example by reviewing the process and speaking with learners. [( )] Remove the data to avoid criticism. [[?]] A gap shows where to look, and does not explain the cause. **** A gap in numbers prompts enquiry. Reviewing process steps and speaking with learners can reveal practical barriers to fix. **** **Question 3.** Why should you hide or combine very small group figures in reports? [( )] Small groups are not important. [( )] Dashboards cannot show small numbers. [(X)] Small numbers can identify individuals and harm privacy. [( )] It makes the charts easier to colour. [[?]] Think about what a reader could work out from a group of two people. **** When a group is very small, results may reveal who the people are. Combining categories or suppressing small numbers protects privacy. **** **Question 4.** Which item belongs in a complete metric definition? [( )] A slogan for the programme. [(X)] A formula, data source, owner, reporting frequency and trigger for action. [( )] A list of competitors. [( )] The name of the platform vendor. [[?]] Someone must be able to calculate it the same way each term. **** A clear metric definition lets different people calculate and read it in the same way and says what happens when it shows a problem. **** ## Assessment and badge You earn the badge "Inclusive Credential Programmes (Ability, L3)" (alignment code ICSF-INCL-L3-A) by passing two parts: a knowledge check and the inclusion plan. Completing the course does not prove competency in a job. The badge records that you practised the capability on a realistic task and that an assessor reviewed your evidence. ### Part 1: Knowledge check The knowledge check has 10 single-choice questions. They cover all four learning outcomes. **Question 1.** Which three principles organise Universal Design for Learning? [( )] Plan, do and review. [( )] Reach, entry and completion. [(X)] Engagement, representation, and action and expression. [( )] Perceivable, operable and understandable. [[?]] They describe the why, the what and the how of learning. **** UDL is built on multiple means of engagement, representation, and action and expression. Perceivable, operable and understandable belong to WCAG. **** **Question 2.** A task outcome is "Analyse a case study." The exam is a handwritten paper under time pressure. What is the best UDL response? [( )] Keep the exam, because it has always been used. [(X)] Check which demands (handwriting, speed) are not part of the outcome and offer options such as typed answers, with one rubric. [( )] Lower the marking criteria for some learners. [( )] Replace the analysis with a multiple-choice quiz for all. [[?]] Remove barriers that are not part of what you want to measure. **** Handwriting and speed may not be part of analysis. Offering options and keeping one rubric widens routes while keeping the standard. **** **Question 3.** Which statement about UDL and standards is correct? [( )] UDL lowers the standard for some learners. [( )] UDL removes all essential requirements of a role. [(X)] UDL widens the routes to the same standard. [( )] UDL replaces assessment with self-reporting. [[?]] Criteria stay constant across routes. **** UDL offers options in how people engage, receive information and show learning, without changing the criteria. **** **Question 4.** Which pairing of WCAG 2.2 principle and example is correct? [( )] Operable: provide captions for video. [(X)] Perceivable: provide captions and transcripts for video. [( )] Robust: use plain language in instructions. [( )] Understandable: increase the video resolution. [[?]] Captions make audio available to people who cannot hear it. **** Captions and transcripts make audio content perceivable. Plain language supports understandable content, and keyboard use supports operable content. **** **Question 5.** According to the course notes, what is the status of the European Accessibility Act? [( )] It is a draft proposal. [( )] It was repealed. [(X)] It applies since 28 June 2025. [( )] It applies only to physical products. [[?]] Check the date in the Accessibility rules topic. Status as of November 2026; check before publishing. **** The European Accessibility Act applies since 28 June 2025. Whether it covers a specific programme depends on what is offered and on national law. **** **Question 6.** Why combine automated checks, manual checks and user testing when planning accessible delivery? [( )] Because laws require all three in every case. [(X)] Because each method finds different problems, and automated tools alone miss some. [( )] Because user testing replaces the need for a checklist. [( )] Because automated checks are always wrong. [[?]] Think about what a tool can and cannot judge. **** Automated tools find some issues. Manual checks and tests with people who use assistive technology find others, so combining them gives better coverage. **** **Question 7.** What is a recognition route for non-formal learning? [( )] A shorter qualification with lower criteria. [( )] A route that grants the badge without assessment. [(X)] A defined way to assess prior or non-formal learning against the same criteria as the standard route. [( )] A separate badge with a different meaning. [[?]] The standard is the same, the route to evidence differs. **** A recognition route keeps the same criteria and level. It accepts different forms of evidence so more people can show what they can already do. **** **Question 8.** How should AI translation be used for official credential criteria? [( )] Publish the output directly, because it is fast. [( )] Use it only for marketing text. [(X)] Treat it as a draft, and have a qualified reviewer check it against a glossary before publication. [( )] Enter all learner records to improve accuracy. [[?]] Meaning can shift, and data protection matters. **** AI translation can produce fluent text with wrong meaning. Human review by someone who knows the field, and a glossary, reduce the risk. Learner data should not be entered unless handling has been checked. **** **Question 9.** The completion rate on a recognition route is lower than on the standard route. What is the most appropriate response? [( )] Conclude that the route is inferior and close it. [( )] Remove the data from the dashboard. [(X)] Investigate causes in the process, involve learners, change one thing and track the effect. [( )] Lower the criteria on that route. [[?]] A gap is a prompt for enquiry. **** A numerical gap does not show its cause. Investigation, involvement of affected learners and tracked changes lead to better decisions. **** **Question 10.** Which is a sound practice when reporting equity data for small groups? [( )] Publish names to be transparent. [( )] Report every group, however small, with exact figures. [(X)] Combine categories or suppress small numbers to protect privacy. [( )] Use the data to decide individual results. [[?]] Think about whether individuals could be identified. **** Small numbers can identify people. Combining categories or suppressing small figures protects privacy, and equity data should be used to review the programme, not to decide on individuals. **** **Pass rule for the knowledge check:** the pass mark is set by the programme owner. A suggested mark is 8 of 10 correct answers. ### Part 2: Inclusion plan with metrics **Task.** Prepare an inclusion plan for one credential programme. Use a real programme you know, or a realistic one that you describe. If you use real data, protect personal data. If you use illustrative data, label it as illustrative. **Contents of the plan** (suggested length: 3 to 6 pages, or equivalent): 1. **Programme profile:** purpose, audience, outcomes, route(s), delivery mode, and the setting (for example university, college, training provider, professional body, sector association, public agency or corporate academy). 2. **UDL review:** one assessment or learning task reviewed with the five-step method, with the options you propose and how one rubric covers all routes. 3. **Accessible delivery plan:** your target (for example WCAG 2.2 level AA, or the target your organisation requires), checks across the learner journey, owners, evidence, and a way to report and fix barriers. Note what you will confirm with legal or compliance contacts. 4. **Language and recognition routes:** plain-language measures, translation approach including human review and an authoritative version, and at least one recognition route for non-formal learning or an under-represented group, with evidence types, support and fairness safeguards. 5. **Equity metrics:** at least five metrics with formula, data source, owner, frequency and trigger for action; data protection approach; small-group rule; review cycle. 6. **Risks and next steps:** main risks, an action list with owners and dates. **Submission.** Submit the plan as a document in an accessible format (with headings and alternative text for any images). A trained assessor reviews it using the rubric below. Peer feedback during the workshop is formative and does not replace assessor review. ### Rubric Each criterion is rated on three levels. This file does not grade the plan. A person assesses it. | Criterion | Outcome | Not yet | Meets | Exceeds | |---|---|---|---|---| | 1. UDL applied to design | 1 | UDL is named but not applied, or options change the standard | At least one task is reviewed with the method; options are specific; one rubric covers all routes | Several tasks or the whole journey are reviewed; essential requirements are justified and stated openly | | 2. UDL applied to assessment | 1 | Assessment demands that are not part of the outcome are left unchanged | Barriers separated from the outcome; at least two alternative routes with the same criteria | Routes tested or piloted with learners; evidence of how consistency between routes is checked | | 3. Accessible platforms and materials against WCAG 2.2 | 2 | Generic statements; no target, owners or evidence | Target stated; checks for each step of the learner journey; owners, evidence and a barrier-reporting route; legal points referred to the right contact | Includes user testing with assistive technology, supplier conformance checks and a schedule for retesting | | 4. Recognition routes for under-represented groups | 3 | Route is vague, lowers the standard or ignores structural barriers | Same criteria as standard route; defined evidence; support; fair process and appeal; language and cost barriers addressed; translation reviewed by humans | Route informed by consultation with the group; outreach plan; risks of tokenism and bias addressed | | 5. Equity metrics | 4 | Fewer than five metrics or unclear definitions | At least five metrics with formula, source, owner, frequency and trigger; data protection and small-group rule stated | Metrics linked to decisions and targets agreed with leadership; plan to compare routes over time | | 6. Use of data and improvement cycle | 4 | No review cycle or data used to judge individuals | Review cycle with roles and dates; gaps lead to enquiry; decisions are recorded | Involves affected groups in review; explains limits of data and how causes will be tested | | 7. Clarity and professionalism | All | Hard to follow; many unsupported claims | Clear, organised, plain language; assumptions and illustrative data labelled | Concise and usable by a team without further explanation | **Pass rule for the inclusion plan:** a pass requires "Meets" or higher on criteria 1 to 6 and at least "Meets" on criterion 7. Plans with one or more "Not yet" ratings may be revised and resubmitted once. **Badge award.** The badge "Inclusive Credential Programmes (Ability, L3)" (ICSF-INCL-L3-A) is awarded when the knowledge check and the inclusion plan are both passed. The badge evidence is your inclusion plan.
Facilitator notes **Before the task.** Share the rubric at the start of the workshop. Offer a short template with the six headings. Remind participants to protect personal data and to label illustrative figures. **Assessor guidance.** Use the rubric as written. Look for evidence that the same standard applies to all routes. Do not reward the length of the plan. Where the participant uses AI tools in drafting, ask them to be transparent about it and to confirm that they have checked the content. Offer reasonable adjustments for the submission format, such as an audio or video walk-through with a transcript, as long as the contents match the six headings. **Moderation.** Where several assessors are involved, review at least two plans together to align judgements, and keep a record.
## Sources and further reading Status as of November 2026; check before publishing. The sources below are official texts, standards bodies and framework owners. Check titles, versions and current availability before you use them. URLs are not listed here so that no link is given that has not been verified. - **ICoBC, Credentialing Skills Framework (ICSF):** the framework owner for the skill INCL "Inclusion and accessibility" and the VRITE pillars. Obtain the current version from ICoBC (info@icobc.net). - **W3C, Web Content Accessibility Guidelines (WCAG) 2.2:** W3C Recommendation. Check the W3C website for the current text and understanding documents. - **W3C Web Accessibility Initiative (WAI):** guidance and educational resources on accessibility. - **CAST, Universal Design for Learning Guidelines:** the framework owner of UDL guidelines. Check the CAST website for the current version. - **European Union, Directive (EU) 2019/882 (European Accessibility Act):** official text in EUR-Lex. Applies since 28 June 2025. Check national transposition and scope for your organisation. - **ETSI, CEN and CENELEC, EN 301 549:** European standard on accessibility requirements for ICT products and services. Check the current version and its relation to WCAG 2.2. - **European Union, General Data Protection Regulation (Regulation (EU) 2016/679):** official text in EUR-Lex, relevant to collecting equity data. - **ICB-F08 Accessible and Inclusive Credentials: the Basics:** the prerequisite course in the ICoBC Kursbibliothek.