A Guide to the ADA Title II Accessibility Rule

What Is the ADA Title II Web Accessibility Rule?

The U.S. Department of Justice has indicated for many years that it interprets the Americans with Disabilities Act as covering technology accessibility. But the ADA Title II regulations are the first time that it has set specific accessibility standards via regulation, in this case for online content, services and systems as well as for mobile applications.

Title II is the part of the ADA that addresses the accessibility requirements for state and local government entities, which means that the regulations apply to all public colleges and universities. Compliance requires that all web content and mobile apps meet the technical standards in the Web Content Accessibility Guidelines (WCAG) 2.1, Level AA guidelines, which have been developed by the World Wide Web Consortium. However, these guidelines do not prevent institutions from updating to a higher standard, as long as they can meet the same or higher standards of  accessibility and usability.

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How the ADA Title II Web Accessibility Rule Will Impact Public Universities

So far, the regulations are set to take effect for most public higher education institutions on April 24, 2026. However, institutions located in towns with census-defined populations of under 50,000 (the population of the area the institution is designed to serve) currently have until April 26 of the following year to achieve compliance.

The rule applies to an institution’s web content and the systems through which it is accessed, including all of the institution’s online courses and program content.

“All relevant content, services and systems need to fully meet the WCAG 2.1 AA standards in order for the institution to be in compliance. There are limited exceptions, however, such as archived content and pre-existing electronic documents that are not actively in use for the delivery of the institution’s services, programs or activities,” explains Jarret Cummings, senior adviser for policy and government relations at EDUCAUSE.

While every department will have its own challenges, Jamie Axelrod, director of disability resources at Northern Arizona University, says that content for STEM fields can be particularly difficult to get to this technical standard.

“Lots of STEM faculty will create their own content, but a lot of the tools they currently have available to them don’t offer great options for creating and rendering that content accessibly. As new tools come online or get adopted to address those things, faculty in those areas are likely going to need some assistance in building those skills. I’m sure every institution has a math faculty member who likes to handwrite and scan all the homework that they give to students. That’s going to be a big change and cultural shift,” Axelrod says.

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What Steps Can Universities Take to Ensure Compliance With ADA Title II?

According to Axelrod, there is variability in terms of where schools are at now in the compliance process. “But I think what many schools are doing is trying to bring together all the stakeholders on their campuses who have responsibility for digital spaces and put into place or enhance the infrastructure they have. Schools need to take an overall assessment of their web space and digital environments and what they contain, and get a sense of the current accessibility in those environments. Where do we have gaps? Where do we have issues? And based on that, take the steps necessary to address and remediate those issues for spaces and content that they create,” Axelrod says.

While it may be easier for campuses that already have centralized control of their web spaces, other schools have a more decentralized approach, with many individuals holding the authority to publish online content.

“That makes it even more challenging to get to all of those folks. Schools need to be designing some governance around web space to be able to assess and audit what you’ve got, then prioritize the environment and what you’re going to address first, how you’re going to address that, and designate the resources necessary to those spaces so that they can handle those issues,” says Axelrod.

But those resources, he adds, need to come with some authority. Whoever is overseeing the work will need to have the authority to ensure that there’s accountability and compliance.