ADA title II for public universities

Public universities must comply with the DOJ's 2024 ADA Title II rule on digital accessibility. WCAG 2.1 Level AA is the required technical standard for the university’s web content and mobile apps that it provides or makes available (including through contractual, licensing, or other arrangements), which can include web-posted documents and multimedia used to deliver programs and services.

Given the approaching 2026/2027 deadlines, public universities must prioritize digital accessibility enhancements that significantly affect student and public engagement. Don’t just treat these improvements as legal requirements. Making accessibility part of the university’s commitment to inclusion and academic excellence will also strengthen the school’s reputation.

For example, by ensuring the admissions website is accessible to applicants with visual impairments — such as implementing proper alternative text for critical navigation buttons and maintaining logical tab sequences — universities not only meet legal requirements, but also visibly demonstrate a dedication to equity. Showing these values in action helps get leadership on board faster and makes the university more attractive to students and the public.

Key takeaways for public universities

• Prioritize accessibility as part of your academic mission and compliance efforts. Emphasize actions that support recruitment, retention, equity, and risk mitigation.
• Use shared templates and clear guidance for learning management system (LMS) content and departmental sites to support consistency and compliance.
• Require current ACR/VPAT documentation for all EdTech tools contractually require remediation timelines for accessibility issues (with escalation steps if timelines slip).
• Establish a scalable program for remediating PDFs and providing media captioning across all campus assets.
• Select and monitor a focused set of KPIs that align with accreditation and risk reporting requirements.

What the 2024 ADA Title II rule requires (WCAG 2.1 AA)

Title II requires the university’s web content and mobile apps to meet WCAG 2.1 AA. This includes institutional websites (main and departmental) and mobile apps—and it can also include web content delivered through LMS platforms, library/repository sites, and other online program sites when the university provides or makes that content available (including via vendors).

Note: the rule also includes specific exceptions for certain categories of content (for example, archived web content, some preexisting conventional electronic documents unless they’re needed to access programs/services, certain third-party posted content absent a contractual arrangement, certain individualized password-protected documents, and preexisting social media posts). These exceptions don’t eliminate Title II’s broader obligations to provide access when needed.

Admissions, financial aid, athletics, research centers, labs, and public documents/videos are all in scope. For example, imagine a blind applicant navigating your admissions pages. They rely on screen readers to apply, which means alt text for images and a logical tab sequence are vital to avoid barriers.

Consider a scenario in which a prospective student who is blind attempts to navigate an online admissions application. When an image, such as a button labeled Submit Application, lacks alternative text, the screen reader provides no information, resulting in a critical gap in understanding and interrupting the submission process.

Similarly, if the interactive elements on the application page are presented in a disordered or illogical tab sequence, the user may struggle to follow the intended workflow, leading to confusion and potential failure to complete essential steps. These experiences illustrate that digital accessibility requirements are critical mechanisms for ensuring equitable access to university opportunities.

Be sure to support faculty-generated content with clear pathways, templates, and training. Prioritize required courses and high-enrollment sections. Exceptions should follow a structured, documented process. If the university asserts undue financial and administrative burdens or fundamental alteration, the determination must be made by the head of the public entity (or designee) with a written statement of reasons—and the university must still provide an equally effective alternative where needed.

This creates a consistent approach, reducing ad-hoc interpretations. An equally effective alternative must be provided when exceptions are approved.

Adopt a state-level approach for tone and structure. Publish a single policy referencing WCAG 2.1 AA. Make exceptions time-bound, verify vendors with ACR/VPATs, and release only tools that meet accessibility requirements or have a documented remediation plan, risk acceptance, and an equally effective alternative where needed.

Timeline and 90-day plan to meet the 2026/2027 deadlines

Communicate the compliance deadlines clearly: April 24, 2026 for public entities with a total population of 50,000 or more (other than special district governments), and April 26, 2027 for public entities with a total population under 50,000 and for special district governments.

Inform the provost, CIO, and ADA office first, then publish an institution-wide plan. Set quarterly milestones aligned with budget cycles and consider aligning the first university-wide update with a high-visibility event, such as new student orientation. Connecting these updates with moments of campus pride can foster shared anticipation and help momentum stick.

Your 90-day plan (campus playbook)

Inventory (weeks 1–2)
Map key public journeys such as applying, visiting, financial aid, enrollment, and payment. Identify the top 300 pages per college, register official mobile apps, list all LMS tools and LTI integrations, and catalog public PDFs and media libraries.

Triage (weeks 2–3)
Prioritize admissions, financial aid, student services, registrar, bursar, and high-traffic departmental pages. Flag PDFs and videos required for enrollment, compliance, or student services.

Remediate (weeks 3–8)
Update global templates and components in your design system. Launch a PDF remediation queue. Implement a captioning and audio description policy and vendor process. Address key mobile issues such as focus order, labels, and hit targets.

Govern (weeks 6–10)
Update policies to reference WCAG 2.1 AA. Require ACR/VPATs for all EdTech, including LTIs. Publish an accessibility statement and a request process and document the exception workflow: request → review → decision → alternative provided. This concise sequence can make policy action-oriented, reducing confusion and delays when exceptions arise.

Evidence (weeks 8–12)
Set up dashboards, assign owners, and schedule updates for the cabinet or board. Prepare auditor-ready packets for counsel, DOJ, or OCR inquiries.

Top high-risk digital assets for universities

Prioritize assets with high student impact and legal risk, such as high-traffic pages and tools with complex workflows and public visibility. Third-party dependencies often create accessibility barriers that can block applications, enrollment, payments, or required services.

Address these areas first to reduce risk quickly. To help overwhelmed teams, the following assets are ranked in “first, next, later” tiers:

• The initial priority should be assigned to digital assets that present the highest potential impact on student access and legal compliance. Specifically, admissions and financial aid pages and forms warrant immediate attention due to their central role in facilitating prospective and current student engagement with essential institutional processes.
• Similarly, core workflows within the LMS (such as syllabi, assignments, and quizzes) must take priority, as they underpin the educational experience and academic progression.
• Finally, departmental microsites, including those for research centers and laboratories, should be addressed early in the remediation process, given their significant visibility and potential to serve a wide range of users. Consider event calendars and registration systems, campus maps and virtual tours, student health/mental health portals, and mobile app (campus app) features.

What to require in RFPs and renewals (VPAT/ACR)

Before remediating every page, check that vendors meet accessibility standards. You can do this by requesting current ACR/VPAT reports, setting clear go-live pass/fail criteria based on WCAG 2.1 AA, and requiring fixes by contract renewal deadlines (PDF).

Additionally, establish a threshold for commissioning independent third-party audits, such as when critical gaps affecting keyboard access are identified. This detailed approach prevents accessibility issues from third-party tools, including LMS LTI add-ons.

Here are some requirements to consider:

• Current, accurate ACR/VPAT (or equivalent accessibility report) for all modules, including LTI tools
• Target standard: WCAG 2.1 Level AA for priority user journeys
• Pre-go-live accessibility testing of critical flows (e.g., apply, register, pay)
• Time-bound remediation plan for any known gaps and a named vendor contact
• Ongoing reporting and cooperation on audits and remediation SLAs tied to renewals

Clarify EdTech governance by maintaining a central list of approved tools with current ACRs. Tools without remediation paths should be deprecated with a requirement for progress before renewal. This approach aligns with proven state-level controls adapted for campuses.

This guidance is informational and not legal advice. Please work with your counsel and procurement team to finalize the terms.

Governance: Roles, policy, and measurement

Governance sustains accessibility efforts. Assign owners such as the ADA coordinator, CIO or CTO, instructional design, and procurement. Publish a single policy referencing WCAG 2.1 AA and an exception process and provide a definition of the release acceptance criteria. To maintain audit-ready evidence for leadership reviews, track a small set of KPIs with owners and dates.

KPIs (report to cabinet/board)

Leaders should have a concise summary of deadline readiness with five to seven measures. Link each KPI to the student impact and legal or accreditation risk. For each KPI, display the current value, target, 90-day trend, and owner with the next milestone. Use green, yellow, or red status indicators. Link each KPI to supporting evidence, such as issue lists, PDF queues, or captioning logs, to guide clear follow-up:

• Average A/AA issues per page on top 300 pages
• Percentage of priority PDFs remediated
• Percentage of videos captioned (auto + human quality assurance)
• Percentage of LMS templates/components that are compliant
• Percentage of approved tools with current ACR/VPAT

How Siteimprove helps universities

Siteimprove is not just another platform. It is a catalyst that frees up valuable hours for teaching and research staff. By efficiently identifying, prioritizing, and guiding remediation of WCAG 2.1 AA issues—and supporting monitoring of PDFs and media—Siteimprove enables faculty and staff to focus on their primary responsibilities: education and innovation.

This time savings translates into enhanced teaching and research opportunities, demonstrates progress with defensible evidence, and provides leaders with a clear understanding of risk and deadlines.

If you are standardizing templates, strengthening governance, or improving vendor accessibility, these capabilities integrate seamlessly without changing your teams’ workflows.

• Monitoring and evidence: Regular WCAG 2.1 AA scanning, trend reporting, issue ownership, and exportable audit trails (turns dispersed fixes into measurable progress tied to deadlines). Note: automated scans are not a substitute for manual and assistive-technology testing; some WCAG checks require human judgment.
• Policy and governance: Centralized policies, exception logging, and approval workflows (enforces standards and creates defendable evidence)
• Document remediation: Batch discovery of PDFs/Office docs, prioritization, and remediation services (tackles the largest volume risk with proof of fix)
• Mobile app accessibility: iOS/Android guidance mapped to WCAG 2.1 AA criteria (closes the common “apps gap”)
• Executive reporting: Deadline readiness dashboard for chancellors and counsel (keeps leadership aligned with milestones)

FAQs

Do faculty have to retroactively fix every file?
Not necessarily, but prioritize current/active courses, as well as required student materials. Archive or replace outdated files and provide assistance through a remediation queue.

What if an EdTech vendor’s ACR shows gaps?
To fix gaps, require a time-bound remediation plan, monitor via renewal gates, and provide an equivalent alternative where needed. Consider independent testing before going live.

Which WCAG version should we implement?
Title II sets WCAG 2.1 Level AA as the compliance standard. You can optionally future-proof templates/components toward WCAG 2.2 where practical, but policy and acceptance testing for Title II compliance should be anchored to WCAG 2.1 AA.