New ADA regulations require public higher education institutions to update their digital content accessibility by 2026. This guide outlines what to do next.
1. 🎓 Introduction: Why This Guide Matters
In April 2024, the U.S. Department of Justice (DOJ) finalized a major update to the Title II regulation of the Americans with Disabilities Act (ADA), making digital accessibility a legal requirement for public colleges and universities.
Under this rule, all public-facing digital content—websites, portals, mobile apps, online forms, and educational services—must meet WCAG 2.1 Level AA accessibility standards.
This guide is designed to help higher education institutions:
- Understand the new legal landscape
- Conduct audits and remediations with confidence
- Assign responsibility across departments
- Work with vendors and track compliance
Whether you’re a part of IT, accessibility services, communications, or leadership, this guide will help you move from awareness to execution.
📖 Key Sources:
2. ⚖️ What the New DOJ Title II Rule Requires
2.1 What Changed
The April 2024 rule mandates that all web-based and mobile content from public higher education institutions be accessible to people with disabilities, under the technical standard of WCAG 2.1 Level AA.
This rule applies to:
- Public university websites and subdomains
- Course catalogs and class registration portals
- Financial aid and admissions forms
- Mobile apps
- Learning management systems (LMS) with public-facing pages
- Emergency alert systems
- Content from third-party providers under institutional branding
This closes a legal gray area that existed for years. Now, digital inaccessibility is not just a barrier. It is a federal violation.
2.2 Compliance Deadlines
Institutions have two years or less to achieve compliance, depending on size:
| Institution Size | Deadline |
| ≥50,000 students, staff, and service population | April 24, 2026 |
| All other public higher education institutions | April 26, 2027 |
These deadlines are non-negotiable. Institutions that fail to comply may face legal action from students, advocacy groups, or the DOJ itself.
2.3 Who Is Responsible for Compliance?
Legal responsibility falls on the institution, not vendors or contractors. Even if a mobile app or platform is built by a third party, if your school uses it to serve the public, you are accountable.
Typical stakeholders:
- IT and Web Teams (implementation)
- Communications/Marketing (content)
- Legal and Risk Offices (policy)
- Disability Services (testing and feedback)
- Procurement (vendor vetting)
3. 🧪 Technical Audit — Where to Begin
A good audit program is the cornerstone of ADA Title II compliance. It reveals what’s broken, where to focus, and how to measure progress.
3.1 Creating a Digital Content Inventory
Before fixing anything, you must map what you have.
Create a living document that includes:
- URLs of all public-facing domains and subdomains
- Mobile apps owned or branded by the institution
- PDFs and forms embedded or linked publicly
- Third-party services (e.g., chatbots, payment gateways)
- Media (videos, audio players, image-heavy pages)
🛠 Tools to help:
- Screaming Frog SEO Spider (site crawls)
- Sitebulb (visual crawl reports)
- Manual review for forms, videos, documents
📋 Pro Tip: Flag each asset by content type, department owner, and last update date.
3.2 Running a WCAG 2.1 AA Audit
Once you know your digital landscape, begin testing pages for WCAG conformance.
A strong audit includes:
- Automated scans using tools like:
- axe DevTools, WAVE, or Accessibility Insights
- Manual checks for:
- Keyboard navigation
- Focus order and skip links
- ARIA roles and alt text
- Color contrast and resize behavior
- Assistive tech testing with:
- Screen readers (NVDA, VoiceOver)
- Screen magnifiers or browser zoom
- Speech-to-text interfaces
🔍 Prioritize pages with:
- High traffic (homepage, admissions)
- Legal exposure (financial aid, student services)
- Frequent updates
3.3 Conducting Inclusive User Testing
No audit is complete without real-world feedback from disabled users. Engage students or faculty with lived experience to test high-risk content.
Suggested format:
- Assign tasks (e.g., apply to a program, pay a bill)
- Observe with permission
- Collect qualitative feedback on pain points
✅ Benefits:
- Reveals issues missed by checkers
- Builds trust with your disabled community
- Demonstrates proactive compliance efforts
4. 🏗️ Remediation and Planning
Audits identify what’s broken. Now comes the harder part: fixing it.
Remediation is not just about code. In higher education, it’s a multi-departmental, multi-phase effort that requires both technical repair and process change. This section offers a framework for building an achievable remediation plan that aligns with your institution’s resources and compliance timeline.
4.1 Prioritizing Fixes by Risk and Visibility
You won’t be able to fix everything at once. The DOJ doesn’t expect you to. What they do expect is that you are strategic, measurable, and proactive.
📊 Use a Risk Matrix
Create a 2×2 matrix to triage accessibility issues based on:
- Visibility: Is this a high-traffic or public-facing asset?
- Severity: Does this block access entirely or cause confusion?
| High Visibility | Low Visibility | |
| High Severity | 🔴 Fix Immediately | 🟠 Schedule Fix |
| Low Severity | 🟡 Add to Backlog | ⚪ Optional / Monitor |
✅ Fix First:
- Admissions and financial aid pages
- Forms for enrollment, payment, or contact
- Course catalogs and registration portals
- Video and PDF content required for public outreach
- Public-facing elements of your LMS (e.g., open course listings)
🛑 Common Pitfalls:
- Fixing “easy” things first just because they’re easy
- Ignoring mobile or PDF experiences
- Assuming internal-only tools don’t matter (if any part is public, it’s in scope)
4.2 Establishing Roles Across Campus
Accessibility cannot live with a single office or staffer. You’ll need a distributed ownership model with clear roles and timelines.
🧭 Recommended Roles
| Role/Team | Responsibility |
| Web/IT | Implements code fixes, remediates structure, ensures responsive behavior |
| Communications | Ensures all new content (images, announcements, emails) meets accessibility |
| Disability Services | Offers user testing, feedback, and connects with disabled users/students |
| Procurement | Reviews digital vendor compliance (VPATs, demos, contracts) |
| Faculty/Instructional Design | Ensures LMS content (syllabi, media, assignments) is accessible |
| Legal/Risk | Oversees policy compliance, tracks enforcement risk |
🛠 Tools to Coordinate:
- Shared accessibility issue tracker (Google Sheet, Airtable, Jira)
- Monthly or quarterly accessibility working group meetings
- Named liaison per department to monitor progress and surface blockers
📌 Institutional Policy Note:
Consider creating an Accessibility Policy that:
- Affirms commitment to WCAG 2.1 AA
- Outlines remediation responsibilities
- Defines timelines, training, and reporting structures
📄 University of Minnesota Accessibility Policy Example
🔁 Build Accessibility Into Your Workflow
Don’t just fix. Evolve.
- Embed accessibility checks into content publishing (CMS workflows)
- Add accessibility gates in code review (linting, automated tests)
- Require accessibility statements from vendors and software providers
- Provide annual or onboarding training to staff and faculty
🎓 For example:
“Before publishing a new academic program page, ensure that all media has alt text, color contrast passes WCAG AA, and forms have accessible labels.”
5. 🧾 Procurement and Vendor Management
Accessibility compliance doesn’t end with what your internal teams build. If your institution uses or endorses digital platforms created by third parties, you are still legally responsible for ensuring those services meet ADA Title II and WCAG 2.1 Level AA standards.
This includes Learning Management Systems (LMS), payment portals, virtual advising systems, admissions software, mobile apps, and more.
5.1 Why Procurement Matters for Compliance
Under the new DOJ rule, it’s not enough to say, “That product is built by a vendor.” If the platform is used to deliver services to the public, your institution is on the hook for its accessibility.
📌 Legal responsibility remains with your institution, even if you didn’t design the tool.
Examples of tools under scrutiny:
- Canvas, Blackboard, Moodle (LMS)
- Salesforce-based student portals
- Chatbots and AI-powered help desks
- Online tutoring platforms
- Virtual tour platforms
- Campus apps used for scheduling or events
5.2 What to Ask Vendors
During RFPs, renewals, or new product evaluations, ask vendors to provide:
| Requirement | Why It Matters |
| VPAT (Voluntary Product Accessibility Template) | Explains the vendor’s current WCAG/Section 508 conformance |
| Accessibility Conformance Report (ACR) | Summarizes actual test results (best if WCAG 2.1 AA aligned) |
| Demo with Assistive Tech | Lets your team evaluate real-world usability |
| Remediation Roadmap | Shows how the vendor handles known accessibility gaps |
| Support Contacts | Establishes accountability if users report issues |
🟨 Note: Many VPATs are outdated, vague, or overly optimistic. Always request updated versions and supplement with testing when possible.
5.3 Recommended Contract Language
Consider working with legal counsel to add accessibility clauses to vendor contracts. These should:
- Reference WCAG 2.1 Level AA as the required standard
- State that the institution may audit or test digital accessibility
- Require vendors to remediate accessibility issues at no additional cost
- Allow termination or penalty clauses for failure to comply
📝 Sample clause:
“Vendor agrees to ensure that all digital products and services provided under this contract conform to WCAG 2.1 Level AA. Vendor further agrees to remediate any identified accessibility barriers at their own expense and within a mutually agreed-upon timeframe.”
📄 Helpful Resource:
5.4 Accessibility in RFPs and Renewals
Add accessibility criteria as a non-optional requirement in your procurement and RFP documentation.
Include:
- A clear accessibility statement in the scope of work
- A requirement to submit a VPAT and roadmap
- A scoring rubric that includes accessibility testing or conformance claims
✅ Bonus: Use a standardized evaluation sheet for comparing vendor claims against actual accessibility issues during trials or demos.
5.5 Collaborate with Procurement and Legal Teams
In many institutions, accessibility professionals are not consulted until after a contract is signed—when it’s too late.
Proactively train and partner with:
- Procurement officers
- General counsel or risk officers
- Department buyers making tech decisions
This collaboration ensures accessibility is baked in, not patched on later.
6. 📊 Monitoring, Reporting, and Training
Accessibility is not a one-time project. Sustained compliance and meaningful inclusion requires institutions to monitor performance, educate stakeholders, and build accessibility into long-term operations.
This section outlines how to track progress, respond to issues, and embed accessibility into your institutional culture.
6.1 Monitoring and Maintenance
After remediation begins, you’ll need a system to monitor content changes, new content uploads, and emerging risks.
🛠 Recommended Practices
| Task | Frequency |
| Automated WCAG scan of top pages | Monthly |
| Manual spot-check of high-traffic pages | Quarterly |
| Review of newly uploaded PDFs/media | Weekly or real-time |
| Update content inventory + audit log | Quarterly |
| Update public accessibility statement | Annually |
🧰 Tools:
- Deque Axe Monitor
- Pope Tech (for Higher Ed)
- SiteImprove
- Custom scripts or workflows with WAVE API + internal checklists
📎 Tip: Use a shared document or dashboard (Google Sheet, Airtable, or LMS-integrated tool) to track issues and assign fixes.
6.2 Handling Accessibility Issues and User Reports
Make it easy for users, especially students and faculty, to report accessibility issues.
Include in your digital properties:
- A public accessibility statement
- A contact form or email address monitored by trained staff
- Clear instructions on how to request alternative formats
Sample text:
“If you experience difficulty accessing this page or require content in an alternate format, please contact accessibility@university.edu.”
🟢 Best practices:
- Acknowledge issues within 24–48 hours
- Provide an interim accommodation, if needed
- Document the issue and remediation timeline
6.3 Training Staff and Faculty
Compliance requires participation across departments. Regular training ensures that content creators and technical teams understand their role in maintaining accessibility.
👨🏫 Who Should Be Trained:
- Web developers and IT staff
- Faculty (especially uploading LMS content)
- Communications/Marketing staff
- Event coordinators (for digital events or forms)
- Procurement staff
🧑🏫 What Training Should Cover:
- WCAG 2.1 basics and real examples
- Creating accessible PDFs, Word docs, and presentations
- Captioning videos and describing images
- Accessibility checklists for course shells and syllabi
- Vendor review workflows (VPATs and demos)
🎓 Delivery Formats:
- Recorded webinars for onboarding
- Required training modules in LMS (e.g., Canvas, Blackboard)
- Quarterly live refreshers or “office hours”
- Microlearning reminders (email, intranet prompts)
6.4 Building a Culture of Accountability
True accessibility success happens when everyone takes shared ownership, not just the accessibility coordinator or IT lead.
Strategies to build this culture:
- Celebrate accessibility wins (e.g., remediated sections, team shout-outs)
- Add accessibility checkpoints to project kickoff checklists
- Include accessibility goals in department KPIs or annual plans
- Encourage feedback from disabled students and staff
📢 Message to reinforce:
“Accessibility is everyone’s job — not because it’s required, but because it’s right.”
7. 🧭 Conclusion: Compliance as Culture
Accessibility in higher education is no longer optional. It is now a federal legal obligation, a strategic priority, and, most importantly, a moral imperative.
The DOJ’s 2024 update to ADA Title II reflects what many accessibility advocates have argued for years: digital access is a civil right. For public colleges and universities, this means that digital experiences must be designed, developed, and maintained with the understanding that not all students use the web the same way — and that every student deserves equitable access.
✅ A Recap of What Institutions Should Do Now:
- Understand the Rule
WCAG 2.1 Level AA is the new legal standard. Compliance deadlines are April 2026 or April 2027, depending on the size of your institution. - Conduct a Thorough Audit
Inventory your digital content. Use both automated and manual tools. Involve users with disabilities. - Remediate with Strategy
Prioritize by visibility and impact. Assign fixes by team. Track progress transparently. - Embed Accessibility in Procurement
Require VPATs, audits, and conformance reports from all digital vendors. Update contract language accordingly. - Train Your Campus
Offer training to faculty, IT, communications, and procurement. Make accessibility part of digital onboarding and content creation. - Monitor and Sustain
Set up recurring checks, feedback loops, and reporting workflows. Make accessibility a living practice, not a one-time fix.
💬 A Final Note
“Accessibility is not about checking a box. It’s about removing barriers. It’s about empowering every student to learn, engage, and succeed — regardless of ability, device, or circumstance.”
When institutions prioritize accessibility, they don’t just mitigate legal risk. They improve user experience, demonstrate leadership, and fulfill their mission of equitable education for all.
If your institution has not started this work, now is the time. If you’re already underway, this guide is here to support your next steps. And if you need help translating accessibility from a legal requirement into a campus-wide movement, you’re not alone.
Brady Gerber is a writer, journalist, and creative strategist specializing in music, tech, and accessibility. This blog post is part of a series exploring the ideas and tools every writer should know. Learn more about Brady on his home page, find his writing and content samples, and subscribe to his newsletter.
Also, download Brady’s latest “Blue Paper”: a one-page summary of this blog’s technical guide to higher education accessibility compliance.