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While Universal Design for Learning (UDL) represents a significant improvement on the traditional accommodations approach in higher education, it can become alarming that literature and research are currently framing it as an ‘end goal’; there is – this session will argue – an urgent need to remain critical in our approach to its implementation. There are, in particular, three lenses that this session will propose as axes of reflection to encourage practitioners to consider accessibility and inclusive design as work in progress, rather than finite processes. First, it will be argued that UDL remains in essence a Western model which can be perceived as still hermetic to Indigenous and Global South voices; it must eventually become decolonized. Second, even in cases of fully fledged implementation, UDL runs the risk of remaining an instructor-centric design process and this session will question what might be ways to optimize the relevance of student voice and student agency. Third, it will be argued that there is a degree of contradiction and tension in the way UDL – which seeks to promote social justice goals of inclusion – is increasingly marketed, branded, and developed along neoliberal logics.