08 / accessibility
Accessibility: strong content, one evidence gap
We tested the courseware directly rather than relying on documentation. The
headline is favourable: on every criterion tested so far, the authored content passes.
The issues that did surface sit in the integration layer, and they are small, specific, and cheap to
fix. The table below separates what has been reviewed from what has not — the second half is
genuinely untested, not quietly passing.
| Criterion | Result | Evidence |
|---|
| 1.1.1 Non-text Content | Passes |
67 images sampled across one module — zero missing alt text. |
| 1.2.2 Captions (Prerecorded) | Passes |
Captions provided and verbatim accurate, correctly punctuated and
capitalised — consistent with human authoring rather than raw speech recognition. |
| 2.1.1 Keyboard | Passes |
Checkbox questions operate with Space. The drag-and-drop activity is keyboard
operable — Space grabs an item and the drop zones become live targets. |
| 2.4.7 Focus Visible | Passes |
Clear high-contrast focus ring throughout; the page scrolls to bring the focused
element into view. |
| 2.5.7 Dragging Movements | Passes |
Click-to-select then click-to-place works with a single pointer, no dragging.
A “No dropzone” target returns a placed item. Tested and reverted. |
| 4.1.2 Name, Role, Value | Needs a fix |
Content inside the frames is correctly named; the embedding
<iframe>s carry no title. A one-line embed fix. |
| Screen reader (simulated) | Passes |
68 focusable elements, none unnamed. H5P announces
“Grabbable 1 of 6” and “Dropzone 1 of 3” with a live region.
role="application" still needs a real AT session. |
| Not yet reviewed — no conclusion
should be drawn from the absence of a finding below this line. |
| 3.3.1 / 3.3.3 Error handling | Pending |
Capstone submission form: field labels, error identification and suggestion. |
| 2.2.1 Timing Adjustable | Pending |
Whether the capstone or final assessment imposes a time limit. |
| 1.4.1 Use of Colour | Pending |
How auto-scored results are conveyed — text, or colour alone. |
| 1.4.10 Reflow · 1.4.12 Text Spacing | Pending |
400% zoom / 320 px reflow and text-spacing passes. |
| 1.4.3 / 1.4.11 Contrast | Pending |
Text and non-text contrast measurement. |
| IBM watsonx Prompt Lab | Pending |
A separate platform required by the final capstone. IBM publishes 152 watsonx ACRs
— those get checked first. |
| Credly claim flow | Pending |
Credential claiming. Credly’s published VPAT is v2.4 (May 2022), WCAG 2.0 only,
with 19 self-reported “Does Not Support” findings. |
// the drag-and-drop works by keyboard
This is the finding worth highlighting, because a drag-and-drop activity is the most common
hard blocker in authored courseware. In the Categorize tasks by suitability for AI activity,
Tab reaches each item, Space picks it up, and the category zones become live drop
targets. The instruction wording — “Match each task… then select
Submit” — avoids both “drag” and “click”, which is deliberate
good practice.
It also satisfies WCAG 2.5.7 Dragging Movements: a single click selects an item and a second click places it, with a “No dropzone” target to undo. A keyboard path and a single-pointer path — belt and braces, and the credit belongs to H5P.
Two refinements would still help: Escape does not cancel a grab, and the keyboard interaction is never explained on screen, so a keyboard user has to discover it.
// simulated screen-reader pass — the content is well named
Inspecting the accessibility tree — the names, roles and relationships assistive
technology consumes — found 68 focusable elements in the course layer with not one
missing an accessible name, five landmarks, six headings with no level skips, a
“Skip to lesson” link, and four live regions.
The H5P activity is the standout. Draggable items announce as
“Grabbable 1 of 6. Automatically tagging photos…” and the
categories as “Dropzone 1 of 3. Suitable for AI”, with a polite live
region to announce placements. Those positional counts are exactly what a non-visual learner needs
to know where they are in a set. This is deliberate, well-executed assistive-technology support.
Which sharpens the one defect. H5P named everything correctly and gives its
activity a meaningful document title — but the <iframe> placing it in the
lesson carries no title. A screen reader user arrives at an unnamed region containing
a well-built activity they were told nothing about. That is a one-line fix in the embed
configuration, in the layer IBM controls, requiring nothing from H5P or the instructional
designers.
What this method cannot settle
One thing genuinely needs a real screen reader
The H5P wrapper uses role="application", which tells screen readers to pass
keystrokes to the widget rather than use their own browse mode. It is a defensible choice for
drag-and-drop and it is what makes Space-to-grab work — but application mode is a known sharp
edge, and behaviour differs across NVDA, JAWS, and VoiceOver.
Inspection cannot assess that. It is the clearest example of why the simulated pass is a
starting point and a real assistive-technology session remains the authoritative check.
The one gap is published evidence. IBM operates a public accessibility
conformance report portal covering roughly 4,100 offerings. Filtered by hand on 27 July 2026:
152ACRs for watsonx
0ACRs for SkillsBuild
0ACRs for Prompt Lab
The watsonx result confirms the filter works, so the zeroes are a genuine
searched-and-not-found. This is emphatically not evidence that the platform is
inaccessible — our own testing above found the opposite. IBM commits its teams to
WCAG 2.2 Level AA under the IBM Accessibility Requirements v7.3, a higher bar than the DOJ
rule’s 2.1 AA. The product appears to meet that standard; what is missing is the published
report saying so.
That matters only because California procurement asks for the document. The college’s own
signoff requires a VPAT, an internal review, or an approved alternative before a platform becomes
mandatory. An ACR for the SkillsBuild delivery stack would remove that step entirely
— and given watsonx already has 152 published reports, the capability plainly exists inside
IBM.
On timing: DOJ’s ADA Title II web rule adopts WCAG 2.1 Level AA, and an Interim Final Rule
of 20 April 2026 extended both compliance tiers by a year, to 26 April 2027 and 26 April 2028.
Neither has passed, so there is room to do this properly rather than in a rush.
Which tier applies to a community college district turns on whether it counts as a special district
government — a question for district counsel, not for this analysis.