Universal Design for Learning (UDL) is an instructional framework to improve learning outcomes in the general education curriculum. A critical analysis of its theoretical foundation and underlying assumptions is essential to understand its potential usefulness and limitations. Our analysis identifies seven issues that challenge key assumptions of the UDL framework. Although UDL developers assert the universal applicability of their framework to all learners, including those with disabilities, several concerns call into question the possibility of true universality with UDL. The UDL instructional framework emphasizes multiplicity in how information is presented, yet this UDL principle may conflict with cognitive load theory. UDL’s conceptual problems lead to challenges in testing its effectiveness. Finally, while proponents of UDL advocate using digital technology for its flexibility, it is imperative to distinguish between effective and ineffective ways to integrate technology within instruction.