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The digital school - can everyone participate on equal terms?

In 2023, the Norwegian Authority for Universal Design of ICT conducted a comprehensive sector audit of digital solutions used in primary schools. The report identifies a systemic issue in the digital school, where the responsibility for dealing with inadequate universal design and accommodations often falls solely on students and their parents.

page-created: 20. juni 2025

    The Norwegian Authority for Universal Design of ICT conducted a comprehensive sector audit of digital solutions used in primary schools in 2023. Through surveys, inspections, and a review of research, we gained insight and a thorough overview of the challenges in the sector.

    The report identifies a systemic issue in the digital school, where the responsibility for dealing with inadequate universal design and accommodations often falls solely on students and their parents.

    Preface

    Almost 640,000 students are currently attending primary school in Norway. Everyone has the same right to quality education, including in digital contexts. The consequence is significant for the student who falls behind due to digital solutions not working.

    Universal design ensures that more people are included in digital social arenas, but there is still a long way to go to ensure that everyone has equal opportunities and to prevent digital exclusion. In 2023, The Norwegian Authority for Universal Design of ICT used its resources in the education sector to investigate how digitalisation affects students' opportunities to participate on equal terms in school.

    Digitalisation has sparked debate and creates divisions between those who welcome it and those who want it to slow down. Questions are raised about learning outcomes and time usage. The benefit of technology versus distraction and concentration. But there is no longer any question that screens are here to stay – schools use screens as part of teaching every day. For students, it is obvious that screens are here to stay:

    «That individual PCs are the way to go, they do not see it as a choice; for them, it appears obvious, but they believe that teachers must receive better training in using the new technology and the opportunities it provides.»

    The main question is whether and how technology can be everyone's helper and whether it creates new divides between students?

    Used correctly, technology provides new opportunities for participation, especially for students with disabilities. But when students who need ICT solutions to be universally designed experience that minimum requirements and core functionality are not met, it constitutes a serious barrier to ensuring that children with disabilities receive the education they are entitled to. Digital solutions must be universally designed to realize the benefits of digitalisation for everyone. It is among innovative suppliers and a forward-thinking industry that we can find good solutions on how technology can benefit everyone.

    At the same time, there are challenges related to competence, both among municipalities and school owners who are to purchase solutions, and among teachers who are to find the right balance in how digital solutions can best be combined with pedagogical and individual needs. From several quarters, more support for teachers is being called for.

    Portrettfoto Malin Rygg

    A student in eighth grade who sits day after day, week after week among their classmates and does not get to participate with them, is an end-user who is running out of time. They need us to have a system that ensures they quickly get the tools, support, and help they need. We see that it takes too long when students complain about what does not work, until it is fixed so that the school day can continue.

    With this report, we want to contribute to more knowledge and nuance the debate about challenges and opportunities in the digital school. We highlight the perspective of those who need digital solutions to be able to participate. This way, we can use technology in a good way for everyone.

    Malin Rygg
    Head of the Authority for Universal Design of ICT

    Signatur Malin Rygg

    Introduction

    Screens in schools, digital learning materials, and digital solutions for students engage many.

    Education is a key asset. All children in Norway must have the same opportunities to develop their skills and benefit from the education provided in schools. The right to education is not only a right, but it is also a prerequisite for participating in society and achieving their rights in other areas such as the right to work, freedom of expression, and inclusion and participation in society. Therefore, the school is an arena where a high degree of inclusion is particularly important.

    The pandemic and homeschooling accelerated the digitalisation of schools with digital teaching, digital interaction, and digital feedback on schoolwork performed using technology. This places great demands on students, parents, and schools. It highlighted the need for inclusive technology and inclusive teaching practices.

    User organisations reported early on that digital learning materials were a barrier to equal participation in school. The media had several cases of individual students being excluded. At the same time, studies showed that many digital learning materials were not accessible. The number of complaints about discrimination in the ICT area increased sharply. Therefore, we dedicated 2023 to examining the extent to which all children and students have equal opportunities to participate in the digital school. We did this in the form of a sector-based inspection.

    A sector-based inspection consists of monitoring compliance with regulations, guidance, dialogue with user organisations and suppliers, municipalities, and other authorities. We have systematised inputs, conducted surveys, analysed data from inspections, and reviewed research. Together, this has given us a good overview of the challenges in the sector.

    The aim is to ensure that the digitalisation of schools benefits all students.

    Initially, we summarise the overall knowledge base we have established through the sector-based inspection with the most important conclusions and recommendations to the ministry and other educational authorities, to the supplier industry, and to schools. We point out the need to support schools and teachers' work in realizing the potential of using technology and including all students in school, especially the most vulnerable.

    Political goals and guidelines through strategies and action plans form the basis. Then we look at the extent of the use of digital learning materials and other digital solutions in primary schools. We present the results of a survey of parents' assessments and experiences with their children's and the school's use of technology, with a particular focus on children with learning difficulties or disabilities.

    Knowledge about what schools emphasize when purchasing digital learning materials and the market for the sale of digital learning materials is reviewed.

    We have explained the regulations on the right to education and training, anti-discrimination protection, and the obligations municipalities and school owners must ensure universally designed digital solutions in schools. Data from the inspections of learning materials included in the sector-based inspection are analysed, with particular emphasis on the extent of various types of regulatory violations and which disabilities the requirements are particularly intended to address. The enforcement of the regulations is assessed, and inputs from user organisations, suppliers, and municipalities are systematised and used as the basis for recommendations on measures.

    Finally, we present findings and assessments in selected research articles and notes. The knowledge base points in different directions, and there is a need for more knowledge on how to ensure that digitalisation benefits all students. This way, we can realize the potential of the technology used in schools.

    1. Conclusions and Recommendations

    All children and young people have the right to equitable education, adapted to their own conditions. The right to education for children and young people is anchored in international conventions and through the Constitution. The right to education is a right, but also a prerequisite for realizing other human rights.

    It is an explicit political goal to have basic education where the use of technology and the development of digital skills are strong.

    Overall, we conclude that the digitalisation of schools offers great opportunities for learning and mastery for students with different conditions. However, much needs to be in place to ensure that all children and young people can participate on equal terms.

    Currently, the challenge is that there is a lack of a holistic and systematic approach to ensure that individual students do not end up with the responsibility for their learning situation when digital solutions do not work. This threatens the right to equitable education.

    There is a chain of causal factors contributing to the challenge. Municipalities and school owners report that they lack the competence to ensure universal design in the procurement process and that they need support for this. They face the same challenges regarding privacy and information security. Suppliers find it difficult to ensure that learning materials take into account pedagogy while also ensuring universal design in a good way. Teachers need competence to assess how learning materials should be used in an inclusive manner and how to ensure sufficient training for students.

    The result is that individual students and parents feel that they are left with the responsibility for their own learning situation and must figure out how solutions and assistive technology work themselves.

    When the student tries to complain to have their rights upheld, it takes too long to get a decision that comes quickly enough to make a difference in the school day.

    There is a need for more research-based knowledge to ensure good inclusive use of technology in schools.

    Conclusions

    Summarised, our conclusions after the sector-based inspection are:

    1: Lack of universal design of digital solutions threatens the right to equal education

    None of the digital learning materials and other digital solutions that were controlled in inspections and complaints cases met the minimum requirements in the regulations for universal design of ICT.

    Suppliers are aware of the requirements and see universal design as an important part of product development, but many still fail to meet the requirements for universal design in practice. Several see the benefit of standardisation as a means to raise competence in the sector.

    Some suppliers have expressed concern that universal design of ICT may be a hindrance to innovation. The regulations for universal design of ICT do not contradict pedagogical purposes. Inspections show that suppliers do not use the flexibility in the regulations to meet different user needs with alternative loops, parallel tracks, and the possibility for user customisation within one solution.

    The Norwegian Authority for Universal Design of ICT works risk based. Inspections have proven to be effective, both through correcting errors in solutions and through learning in municipalities. However, the authority has limited ability to control the use of over 300 digital solutions used in schools by 356 municipalities, and the number of inspections is too low to provide effective follow-up of solutions that violate the regulations.

    Imposition and other reactions such as daily fines after inspections are directed at the municipality as the school owner. Suppliers are not a party to the inspection case. Both school owners and suppliers find this challenging.

    2: It is challenging for municipalities to ensure universal design of ICT when purchasing digital solutions.

    School owners are responsible for setting requirements for universal design through the purchase of digital solutions from publishers and other suppliers. Only twelve percent of primary schools consider that they have sufficient competence in universal design of ICT. Requirements for information security, privacy, and universal design have increased the need for competence. Time and economy are the most important framework factors for the choice of learning materials. Four out of ten school owners have content quality as the most important criterion, while privacy, information security, and universal design are emphasized by fewer than 20 percent.

    It is challenging for schools to both ensure that learning materials comply with regulations and have the capacity to assess different alternatives and have the opportunity to take advantage of offers from different suppliers. School owners want the responsibility for ensuring that learning materials meet requirements for privacy, information security, and universal design to be lifted to a national level.

    The Directorate of Education's guide for assessing learning materials in connection with procurement is intended to ensure that students receive learning materials that support effective learning and are engaging and relevant. The guide is rarely used. Less than half of school owners have used the guide.

    3: Schools lack systems and competence to use technology in an inclusive manner.

    A survey conducted by Proba Social Analysis for The Norwegian Authority for Universal Design of ICT shows a wide variation among parents of primary school students regarding the assessment of the use of digital learning materials. A majority believe that children experience mastery, that digital learning materials are user-friendly and provide good learning outcomes, while somewhat fewer believe that individual adaptation is adequately taken care of.

    Parents are more critical than school owners and school leaders, especially regarding basic skills and problems with distraction. The use of digital solutions can weaken the parents' role in schoolwork, especially for the most vulnerable children. Students with disabilities seem to use more digital learning materials than physical ones, and more than students without disabilities. Students with disabilities appear to benefit more from digital solutions than analogue/physical learning materials, but universal design is a challenge.

    Digital skills are one of the basic skills in the new curriculum. Three out of four schools want to increase the use of digital learning materials.

    Most teachers are positive about the pedagogical benefits of technology, but there are few concrete plans for developing digital competence among teachers and students.

    Lack of inclusion can create unnecessary divides between students. Assistive technology often depends on digital solutions being universally designed to function optimally. Some students have a greater need to use adapted digital assistive technology than others and depend on inclusive technology to participate in regular teaching. Weak competence among teachers contributes to this being difficult, and many parents and students feel they are alone in the challenges created.

    4. Inefficient process for handling complaints weakens students' protection against discrimination.

    The process for complaints from students about discrimination is unclear, fragmented, and inefficient. User organisations find that their members find it difficult and cumbersome to complain. There are many steps in a case involving both the Norwegian Discrimination Tribunal, The Norwegian Authority for Universal Design of ICT, the complained municipality, the supplier, and the complainant. Correcting errors goes through several rounds and requires retesting and new case processing in each round. The processing time becomes long, and students risk missing out on teaching and learning while the cases are being processed.

    5: We lack knowledge to ensure that the full potential of technology is realised in teaching

    The use of digital learning materials and other digital solutions in schools has both advantages and disadvantages. The government-appointed Screen Use Committee concludes that there is a need for more knowledge about good digital teaching practices and the consequences of screen use on reading and writing skills, at all grade levels and over time.

    A research-based knowledge summary on digitalisation in basic education, prepared by the Knowledge Center for Education (KSU) at the University of Stavanger and others, states that the potential of digitalisation is not being realised. The knowledge summary shows that there is a need for more research-based knowledge, including on artificial intelligence and education, pedagogical practices and didactic facilitation with extensive use of digital devices, digital ecosystems, and inclusion-exclusion in schools.

    Recommendations from The Norwegian Authority for Universal Design of ICT

    The Norwegian Authority for Universal Design of ICT's recommendations to the sector are:

    1. Efforts to ensure that digital solutions in schools are universally designed must be prioritised.
      1. Enforcement of solutions used in the education sector that violate regulations must be strengthened.
        The authority works risk-based and needs data to make good risk assessments. Further work on the knowledge base must therefore be prioritised so that the authority can effectively target measures such as control, inspection, and guidance where the risk of failure is greatest. The number of inspections should be increased. Strengthening the enforcement task is also one of the measures in the Action Plan for Increased Inclusion in a Digital Society.
      2. Standardisation should be prioritised as a means to combine pedagogical considerations with universal design. Standardisation will be a good tool that should be used more to provide clear direction for solving unique challenges in the sector, especially to coordinate requirements for universal design and pedagogical considerations. Work is already underway that should be strengthened and prioritised.
        • The Standardisation Committee for Universal Design of Digital Learning Materials (SN/K 607 (standard.no)).
        • It should also be considered whether there is a need for more standardisation initiatives.
      3. Development and adaptation of digital assistive technology should be prioritised higher.
        Financial support for the development of necessary learning materials that do not have great commercial potential must be strengthened. There is a great need for support for learning materials and assistive technology for the blind, severely visually impaired, deaf and sign language users, students with cognitive disabilities, and students with needs for Augmentative and Alternative Communication (AAC).
      4. Develop specific guidance for the education sector on how the requirements for universal design should be interpreted for digital learning materials.
        Uutilsynet.no is the authority's main channel for guidance, but much of the guidance applies generally across sectors and is not specifically developed for the education sector. Guidance should be developed that addresses interpretation questions and doubts that arise particularly in connection with digital learning materials and can help make it easier for businesses and suppliers to comply with the requirements.

    2. Better coordination of the procurement of digital solutions in municipalities should be ensured.
      Municipalities should receive support to ensure that basic requirements for universal design, privacy, and information security are well taken care of when purchasing digital solutions for use in schools.
      This has already been proposed as measures in the Strategy for Digital Competence and Infrastructure in Kindergarten and School, and the authority recommends that these measures be followed up:
      1. Investigate a common support service to take care of, among other things, universal design, including how common public procurement can be organised for a more demand-driven market, and how a support service can be linked to the customer portal in Feide, the national service catalogue for digital learning materials, and other common solutions such as the authority's solution for accessibility declaration.
      2. Establish a publicly managed national service catalogue for digital learning materials. In connection with a publicly managed national service catalogue, the Ministry of Education should consider the need for a national approval body for digital learning materials and possibly other digital solutions used in schools.

    3. Teachers should have the opportunity to strengthen their competence both in education and digital competence development. Teachers should receive support and help to increase their competence both in universal design of ICT and inclusive use of technology in teaching situations.
      1. Competence in universal design and inclusive use of technology should be considered in teachers competence development programs.
      2. Educational authorities should follow up that the competence boost has an effect for teaching staff, students, and parents through cross-sector collaboration to increase competence in the education sector on universal design of ICT and inclusive digital learning.
      3. Guidance on inclusive digital learning should be a highly prioritised task.
      4. Suppliers must contribute to the competence boost on inclusive use of technology.

    4. Students' protection against discrimination in digital education must be better safeguarded. Compliance with the regulations for universal design of ICT is a prerequisite for successful digitalisation in schools, and there is a need for clarifications on violations of the regulations to come quickly enough to make a difference in the school day for the student.
      1. Responsible ministries should take the initiative to investigate the need to adapt the handling of complaints about discrimination in the ICT area so that the protection against discrimination for students who depend on universal design is safeguarded more quickly.
      2. Education cases should be prioritised in the queue, and a faster processing path for these cases should be considered.
      3. It should be considered whether there is a need to establish a role as a coordinator to ensure quick help for students where learning materials do not work. Students should be able to turn to a coordinated unit either at school or municipality, which has a coordinated responsibility to help the student find their rights, solve challenges in learning materials in dialogue with the supplier, and ensure sufficient training for the student and teacher.

    5. Digitalisation in the education sector should be better anchored in knowledge-based research.
      1. There is a need for a national research program as referred to in the knowledge summary from the University of Stavanger and others. Such a program should also address the need for research-based knowledge as the Screen Use Committee also suggests.
      2. The potential for systematic use of learning analytics should be considered, also aimed at students with disabilities and their need for inclusive use of digital solutions.

    2. Summary

    2.1 Overall goals and guidelines

    The Knowledge Promotion Reform aims for all students to acquire basic skills and necessary competence to manage in life. In the Directorate of Education's framework for basic skills, digital skills are considered one of the basic skills.

    The government's strategy for digital competence and infrastructure in kindergarten and school sets the direction for the digitalisation of schools towards 2030. Goals have been set for increased digital competence, inclusive learning, and equal access to education, inclusive technology, and adapted digital assistive technology. To ensure equal access to education, all digital solutions must be universally designed and used so that everyone has access. This requires competence among school leaders and teaching staff.

    2.2 Extent of digitalisation and user experiences

    Figures from the Directorate of Education show that 93 percent of students in primary school have access to their own digital device, such as a tablet, PC, or Mac.

    Almost all schools that participated in a survey among school leaders and school owners in the spring of 2023, conducted by NIFU, use both digital and printed learning materials. 98 percent of primary schools use digital learning materials. Time and economy are essential for the choice of learning materials. Privacy, information security, and universal design are less emphasized.

    Oslo Economics has prepared the survey "Use of Digital Solutions in Primary Schools and Universal Design of ICT," commissioned by The Norwegian Authority for Universal Design of ICT. There is a wide variation in the use of digital learning materials and extensive use of digital learning resources not primarily developed for use in schools. More than 70 percent of schools use NRK School and YouTube in teaching. The learning materials Book Creator, Salaby, and Geogebra are used by between 50 and 70 percent of schools. Microsoft appears to be a dominant player in terms of learning platforms and collaboration and file-sharing solutions.

    Proba Social Analysis's survey "Experiences with Digital Solutions in Schools - Survey and Analysis of Advantages and Disadvantages of Digital Solutions," commissioned by The Norwegian Authority for Universal Design of ICT, is based, among other things, on a survey among 2750 parents of children in primary school, including 533 interviews with parents who have children with various types of disabilities. Among those who participated in the survey, 19 percent have children with disabilities, reading and writing difficulties, or learning difficulties.

    Parents are divided in their assessments of whether the use of digital learning materials is appropriate. The majority believe the digital solutions are user-friendly and understandable, but they are somewhat more divided in their assessments of learning outcomes and the extent to which teaching is adapted to the individual student.

    Children with reading and writing difficulties, learning difficulties, or other disabilities use digital learning materials more than they use physical ones. They benefit more from digital solutions and use digital learning materials to a greater extent than students without disabilities. Parents of children with disabilities also assess that digital solutions provide better learning outcomes and generally function better, compared to the assessments of parents of children without disabilities.

    In some areas, digital solutions work worse for students with disabilities. They have more technical challenges and challenges with understanding and navigation. This may indicate that digital solutions are not well enough designed, which supports existing knowledge about digital solutions in general. Many of the students who experience problems with digital solutions depend on their parents' efforts. For the most vulnerable students, where parents cannot or do not manage to help them, digital solutions contribute to reinforcing differences in learning outcomes.

    2.3 The market for digital learning materials

    Statistics from the Norwegian Publishers Association show a sharp increase in the sales of digital learning materials. In 2021, the sales of digital learning materials accounted for 41 percent of the total sales of learning materials. The corresponding figure in 2017 was twelve percent.

    Oslo Economics has prepared an analysis of "The Market for Digital Learning Materials and Learning Resources in Primary and Secondary Education." The major publishers have a strong position. High entry barriers reduce the threat from potential new competitors, which can weaken incentives to invest in innovation and development.

    Oslo Economics’ report "Use of Digital Solutions in Primary Schools and Universal Design of ICT" also contains information from suppliers of digital learning materials showing that suppliers seem to be well aware of the requirements for universal design of ICT. Universal design is an important part of product development, but some experience challenges in meeting the requirements, especially in science subjects. Many highlight Standard Norway's committee for universal design of digital learning materials, SN/K 607, as a useful forum for raising competence.

    2.4 Regulations and status of universal design of ICT

    The regulations on universal design of ICT solutions were extended in 2018 to also apply to digital learning materials and other digital solutions used in the education sector. School owners are responsible for ensuring that digital solutions used in schools are universally designed.

    The regulations for universal design of ICT are operationalized through standards and technical requirements. The Standardisation Committee (SN/K 607 (standard.no)) has a mandate to create Norwegian standards for universal design of digital learning materials, summarise best practices, provide guidance, and contribute to innovative development for inclusive digital learning. The Norwegian Authority for Universal Design of ICT participates in this work.

    Inspections of digital solutions in the education sector in 2023 covered eleven digital learning materials in the form of websites and apps. The learning materials are used in many primary schools. The most basic requirements were selected for control. These are requirements where potential conflicts between universal design and pedagogical considerations, in our assessment, do not come to a head. Nevertheless, violations of the regulations for universal design of ICT were uncovered in all learning materials. The violations are extensive and have consequences for students with different user conditions and disabilities.

    Lack of universal design can make it impossible or difficult for children with reading and writing difficulties, visual impairments, hearing impairments, or motor disabilities to participate in schoolwork on equal terms. Students who use assistive technology are generally dependent on digital learning materials being universally designed for the assistive technology to function.

    It is a misunderstanding that all content in a digital learning material or other types of ICT solutions should be usable in the same way by all students. The regulations do not prevent different tracks in the same ICT solution, provided that the parallel tracks consider different user conditions. The purpose is, in any case, that the different tracks ensure equal learning joy and mastery and contribute to the student achieving the learning goal.

    In cases where individual requirements for universal design do not harmonize well with, for example, pedagogy and learning goals, exceptions from the requirements can be made. This applies in cases where compliance with the requirements imposes an unreasonably large burden.

    2.5 Challenges with regulations and enforcement procedures

    Inspections yield results and must continue. School owners are responsible for setting requirements for universal design through the procurement of digital solutions from publishers and other suppliers. Orders and other reactions such as daily fines after inspections are directed at the municipality as the school owner. Suppliers are not a party to the inspection case. This is challenging for school owners and suppliers.

    Individuals can file complaints about discrimination. The Discrimination Tribunal has decision-making authority in such cases, including in the ICT area. The Norwegian Authority for Universal Design of ICT provides ICT-related statements after testing the complained ICT solutions against relevant requirements for universal design of ICT. It takes too long from when a case is filed until it is resolved. The design of the complaint process makes the processing time long, and students risk missing out on teaching and learning while the cases are being processed. This is very serious.

    2.6 More knowledge is needed to ensure that digitalisation of schools benefits students

    "Student Perspectives on the Digital School Day" is a research article based, among other things, on interviews with students. Students are positive about the opportunities in the digitalisation of the school day but are also aware of challenges and negative aspects of technology. For students, technology is a given, but they believe that teachers need better training in using new technology and the opportunities it provides.

    The Screen Use Committee was established by the government to establish knowledge and provide advice on the use of screens in kindergarten, school, and leisure time. The committee has presented an interim report in the form of two thematic notes, where "Consequences of Screen Use in Schools – A Knowledge Base from the Screen Use Committee, 2023," refers to a large international meta-analysis of research showing a positive correlation between screen use and various learning outcomes, provided that the purpose of use is pedagogical. UNESCO also finds that the use of digital devices and technology in teaching can positively affect students' learning, but it depends on pedagogical use. However, the use of digital devices can also be disruptive to learning, concentration, and attention. There is a need for more knowledge about the consequences of screen use. Digital technology changes the learning situation and places new demands on schools. Several studies show that there is a need to develop teaching practices that are geared towards the opportunities offered by digital devices.

    The Knowledge Center for Education (KSU) at the University of Stavanger, together with the University of Oslo and Volda University College, has prepared a research-based knowledge summary on digitalisation in basic education. The allocation of a digital device to each student has been a decisive shift, and the integration of digital tools, resources, and learning materials has potential for students. Most teachers are positive about the pedagogical benefits of digital technology. The teacher's role is very important in the use of digital technology, but there are few concrete plans for developing digital competence among teachers and students. Challenges with digital technology in teaching are also highlighted, and realizing the potential does not happen by itself. The knowledge base is insufficient, and there is a need for a national research program that more effectively ensures knowledge-based digitalisation. Systematic use of learning analytics is one of several measures that can ensure a more knowledge-based approach. This is recommended in the report "Learning, Where Did You Go in All the Confusion? – Use of Student Data to Promote Learning.

    The full report will soon be available as a PDF. The Norwegian version is available on our report pages.