The Universal Design for Learning (UDL) framework emphasizes multiplicity of representation, expression and engagement to cater for the widest possible set of learning styles and abilities. Digital Game Based Learning (DGBL) can slot into a universally designed approach to education as one of several alternative ways of learning that will suit some learning preferences, such as those who prefer to learn in an active way. However, DGBL can itself encapsulate the principles of UDL if the game designer embraces UDL as a fundamental set of game design principles. This paper discusses, with examples, the ways in which a game designer can universally design a DGBL solution with respect to game mechanics, representation and personalization, with an emphasis on the use of gameplay data for formative and summative evaluation during the design, build and retrospective phases, as well as for adaptive learning and formative feedback during the delivery phase.