The multilayered implementation gaps: a comparative systematic review of legislative frameworks for students with learning differences and disabilities in global STEM higher Education

Abstract

This systematic comparative policy review investigates how legislative frameworks translate into institutional practice and student outcomes for students with learning differences and disabilities in STEM higher education. Drawing on 43 peer-reviewed journal articles published from 1990–2025, a qualitative narrative synthesis and thematic analysis through an analytical lens linking law, policy, institutional practice, and student outcomes was used across a regional framework of North America, Europe, Asia, Oceania, and Africa. Findings reveal regionally distinct implementation challenges. Regions with mature rights-based legislative systems tend to experience administrative and pedagogical gaps, limited faculty preparation and continued reliance on student disclosure. Other regions demonstrate more fragmented law-policy environments and institutional discretion, while resource-constrained contexts face structural and infrastructural barriers that limit the practical impact of legislative mandates. Across regions, gaps persist between policy intentions and the lived experiences of these students. The cross-regional synthesis highlights uneven implementation of inclusive pedagogies including universal design for learning, blended learning, and assistive technologies, often applied as supplementary rather than integrated practices. Although inclusive initiatives are increasingly present across regions, STEM-specific research on learning differences and disabilities remains limited. Inclusion depends less on geographic context than on alignment between policy frameworks, institutional capacity, pedagogical practices, and student outcomes.