The Cognitive and Learning Disabilities Accessibility Task Force (COGA)

19 March 2025 - Snigdha Ramkumar

Brain surrounded by equations and colourful lights, indicating the amazing complexity of the neurodiverse brain

It’s Neurodiversity Celebration Week, so what better time to, well, celebrate the research being conducted in this space? Let’s talk about the Cognitive and Learning Disabilities Accessibility Task Force – a mouthful that luckily comes with a much nicer acronym: COGA. As the name suggests, it focuses on accessibility for cognitive and learning disabilities, which are an important part of the broader spectrum of neurodiversity.

As much as I admire the Web Content Accessibility Guidelines (and, as an accessibility consultant, I’m practically obliged to), the documentation does have some shortcomings. One gap we’ve discussed before in our accessibility masterclass series(this will open in a new window) is the lack of neuroinclusivity. While WCAG provides comprehensive guidance for users with visual, motor, and auditory disabilities, its coverage for those with cognitive and learning disabilities is sparse, especially at Level AA.

To clarify, it’s not as though WCAG completely ignores individuals with cognitive and learning needs. There are success criteria that address issues like reading level, session timeouts, and improved error handling, and more. However, these criteria typically fall under Level AAA… which means they tend to be largely glossed over. Accessibility legislation only requires Level AA compliance, and indeed, complete Level AAA compliance is often seen as unattainable, even by accessibility professionals. This often leads to criteria that could benefit users with cognitive disabilities being overlooked entirely.

This gap is where the Cognitive and Learning Disabilities Accessibility Task Force (COGA) steps in.

What is COGA?

COGA is a specialised task force within the W3C that aims to advance accessibility for individuals with cognitive and learning disabilities. Its contributions address areas that have long been underrepresented in accessibility standards. Key resources developed by COGA include:

  • Cognitive Accessibility User Research: This document explores cognitive challenges related to attention, memory, perception, and reasoning. Organised by specific disabilities, it offers insights into the unique needs and experiences of different user groups.
  • Cognitive Accessibility Roadmap and Gap Analysis: This outlines gaps in current accessibility standards and provides a roadmap to bridge them. For example, it includes best practice recommendations, such as how to make personalisation practical and testable.

One of my favourite aspects of COGA’s research is its use of personas and user journeys to illustrate barriers. Take, for instance, the example of booking a ticket online. COGA’s analysis sheds light on challenges like:

  • confusing layouts,
  • unclear instructions, and
  • insufficient time to complete tasks.

These personas make the data actionable for designers and developers, bridging the gap between theory and real-world application.

Some of the techniques documented by COGA include:

  • Helping users understand the site and its functionality.
  • Avoiding the use of new symbols, terms, or design patterns[KA3] .
  • Supporting error prevention and enabling easy correction.
  • Providing rapid and direct feedback for user actions.
  • Using clear, structured layouts with short paragraphs and simple language.
  • Helping users maintain focus and restoring context when attention is lost (e.g., using breadcrumbs).

Factors to consider for neuroinclusive design, see https://www.w3.org/TR/coga-usable/ for full textFigure 1:Screenshot of factors to consider for neuroinclusive design (source: https://www.w3.org/TR/coga-usable/)

Why Do We Need COGA?

You might wonder why a separate task force within W3C is necessary. Why not simply incorporate cognitive accessibility into existing guidelines?

The answer lies in the complexity of neurodivergence. It goes beyond medical diagnoses to include a wide spectrum of experiences and needs, many of which can go unnoticed in broader accessibility efforts. The nuances of designing for cognitive accessibility require focused research, guidance, and advocacy, and COGA ensures that these voices are heard, and their needs addressed.

The task force’s work includes:

  • Adding new WCAG criteria, editing existing ones, and revising conformance levels where necessary.
  • Defining testing criteria to help authors determine when their work is complete.
  • Supporting an extension to WCAG with new rule sets, test suites, or specifications.

In addition to pushing for better standards, COGA’s work is also a reminder that inclusion must extend beyond the legally required minimum. Even if Level AAA seems out of reach, the principles behind it are not; incorporating them can create a better web for everyone.

COGA and Regulatory Frameworks

COGA’s work aligns with key regulatory frameworks designed to protect vulnerable users, including the Equality Act 2010, the Consumer Duty, and the European Accessibility Act (EAA).

The Equality Act 2010 requires organisations to make reasonable adjustments for disabled users, which includes those with cognitive and learning disabilities. The Consumer Duty reinforces this by mandating that businesses – particularly in financial services – consider the needs of vulnerable customers. COGA’s research provides actionable guidance that aligns with this duty, particularly in areas like clear communication, reducing cognitive load, and providing multiple ways to complete tasks.

Meanwhile, the European Accessibility Act sets legal requirements for digital accessibility across the EU, primarily based on WCAG Level AA. However, as noted earlier, WCAG does not yet fully address the needs of neurodivergent individuals. Research from task forces like COGA can help bridge these gaps, shaping future legislation and best practices for a more inclusive digital landscape.

Closing Thoughts

It’s important to remember that neurodivergence is not a singular experience . What works for one user might not work for another. While COGA’s work lays a strong foundation, it is crucial to supplement it with lived experiences and user testing.

COGA’s phased approach, which currently analyses eight disabilities, provides a basis for identifying and addressing gaps. However, it is not yet a standalone solution. Therefore, combining COGA’s research with direct input from neurodivergent users during testing will be instrumental in creating a truly inclusive web.

The task force is a valuable resource and a step in the right direction. But as professionals, we must strive to go further – to listen, learn, and design with empathy for the diverse needs of all users.

If you would like to learn more about accessibility and neuroinclusivity, check out our wide range of courses at User Vision Training.

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