For most of the last fifteen years, “what exactly are we required to do about digital accessibility, and by when” had an unsatisfying answer: general non-discrimination law, a body of Office for Civil Rights settlements, no single standard, no fixed date attached to any of it. There is now a standard and a date. That is genuinely useful, because it turns an open-ended intention into a plan with real milestones.
What the rule sets
In April 2024, the Department of Justice issued a final rule under Title II of the Americans with Disabilities Act, setting a technical standard for the web content and mobile apps of state and local government entities, which includes public colleges and universities. The standard is WCAG 2.1 Level AA (U.S. Department of Justice, 2024).
In April 2026, the compliance dates got extended by a year. Public entities serving a population of 50,000 or more now have until April 26, 2027. Public entities serving fewer than 50,000, along with special district governments, have until April 26, 2028 (Accessible.org, 2026).
The standard itself is unchanged, and the general non-discrimination obligation applies the entire time regardless. Private institutions fall under Title III rather than Title II, but still carry Section 504 obligations where they take federal funds, and are largely adopting WCAG 2.1 AA as the working standard anyway.
What it covers
The rule reaches the public website, the portal, web applications, mobile apps, and course content delivered through the LMS to enrolled students. It includes narrow exceptions. Genuinely archived content, certain pre-existing documents not used to apply for or take part in a service, third-party content outside the institution’s contract. A useful default: if a document is how a student registers, learns, or completes a course, treat it as in scope, full stop. A separate accessible version of an otherwise inaccessible page is allowed only in limited cases, and tends to drift out of sync fast. Fixing the primary content directly is usually the better path.
A sequence that builds a practice
Running one large audit and producing one large defect list gets you to the date with a shorter list that starts refilling immediately, because inaccessible content is the default output of most authoring workflows until the workflow itself changes (WebAIM Million). A sequence that builds a lasting practice looks different.
Set the procurement gate now. An accessibility requirement in procurement is the least expensive step available, and it keeps the volume from growing while you work the existing backlog. Every product bought without an Accessibility Conformance Report review between now and the deadline becomes a longer-term remediation item you are creating for yourself.
Over the next year or so, fix at the template level and build the pipelines. Remediate the web presence through accessible templates and a shared component library rather than page by page. Bring the LMS course template up to standard. Stand up the captioning pipeline, the document workflow, and the authoring-time checks. Start faculty support with the highest-volume content first.
In the run-up to the deadline, work the backlog while the pipelines keep running. Prioritize by exposure and traffic: public-facing and high-traffic content first, then the highest-enrollment courses, then the long tail after that. Because the pipelines already exist, the backlog shrinks instead of refilling behind you.
At the deadline itself, this is a standing function. A named owner, a monitoring cadence that samples real content, and accessibility built into every new content and procurement decision going forward.
The part that carries it: faculty support
Faculty are being asked to bring years of course material up to a standard most of them were never taught in the first place. What works is giving them the tools to do it as part of normal authoring. A checker that flags issues as they write, a captioning service with a fast turnaround, templates that start accessible, and support aimed at their highest-volume material. Along with a clear explanation of why the standard exists and whom it serves. A bare requirement with a date attached produces minimum compliance, understandably enough. A walkable path and a reason that makes sense produce real engagement, and the capability the institution builds along the way is one it keeps for good.
Emily Connelly is an instructional multimedia technologist at Wrightmann Education Technologists. Part of the Accessibility and Compliance series.
References
- Accessible.org. (2026). DOJ Extends ADA Title II Web Compliance Deadline by One Year. https://accessible.org/news/doj-extends-ada-title-ii-web-compliance-deadline/
- U.S. Department of Justice, Civil Rights Division. (2024). Fact Sheet: New Rule on the Accessibility of Web Content and Mobile Apps Provided by State and Local Governments. https://www.ada.gov/resources/2024-03-08-web-rule/
- U.S. Department of Justice. (2024). Nondiscrimination on the Basis of Disability; Accessibility of Web Information and Services of State and Local Government Entities. Final rule amending 28 CFR Part 35, published in the Federal Register April 24, 2024.
- W3C. (2018). Web Content Accessibility Guidelines (WCAG) 2.1. https://www.w3.org/TR/WCAG21/
- WebAIM. The WebAIM Million. https://webaim.org/projects/million/