This groundbreaking regulation will reshape how public organizations, including educational institutions, approach their digital presence. The law requires all web content and mobile applications to be accessible for those with disabilities.
“Just as steps can exclude people who use wheelchairs, inaccessible web content can exclude people with a range of disabilities from accessing government services.”
The Justice Department adopted WCAG 2.1 Level AA as the technical standard. This middle-tier compliance level is considered “reasonably accessible for most users” and addresses visual, auditory, physical, cognitive, and neurological accessibility needs.
“Just as steps can exclude people who use wheelchairs, inaccessible web content can exclude people with a range of disabilities from accessing government services,” said United States Attorney General Merrick B. Garland. “With accessible web content and mobile apps, people with disabilities can access government services independently and in some cases with more privacy.
What’s Covered Under the New Rule?
The website and app accessibility regulation applies to all web content, from basic text and images to interactive elements and password-protected content. This includes educational materials, administrative resources, and public-facing information that institutions provide through their digital platforms. Some exceptions to the rule exist, primarily for archived and preexisting content that meets certain requirements.
The rule provides a staggered compliance approach based on population size. Large entities with 50,000 or more users must comply by April 24, 2026, while smaller entities and special district governments have until April 26, 2027.
What Educational Institutions Should Do to Prepare
If they haven’t already, institutional leaders should begin preparing for these changes immediately. The scope of work required to achieve compliance may be substantial, particularly for those with extensive online resources and learning materials. Starting early can help ensure a thorough and well-planned compliance journey.
Start with a Digital Audit: Catalog all your digital assets, not just on your main website, but your learning management system, student portals, administrative systems, and mobile apps. Document which platforms currently meet WCAG 2.1 Level AA standards and which need updates. Pay special attention to commonly overlooked elements like PDF forms, video content, and interactive tools.
Develop Your Compliance Strategy: Create a realistic timeline working backward from your compliance deadline. Your strategy should include budget allocation, resource planning, and clear milestones. Remember that accessibility improvements often benefit all users, not just those with disabilities.
Build Internal Expertise: Invest in training and software for instructors and content creators, IT staff, and faculty. Everyone who produces digital content needs to understand accessibility requirements. This includes training on creating accessible documents, adding alt text to images, and ensuring proper color contrast in designs.
Review and Update Procurement Processes: Examine your relationships with technology vendors. Update purchasing policies to require WCAG 2.1 Level AA compliance in new contracts. Review existing contracts to ensure vendors can meet the new standards. This includes textbook publishers, LMSs, and any third-party tools integrated into your learning environment.
Create Sustainable Processes: Accessibility isn’t a one-time fix. Establish an ongoing review process to maintain compliance as you add new content to your learning environment. Create clear guidelines for content creation, regular accessibility audits, and a system for addressing accessibility complaints or issues quickly.
Learn more about the regulation in our whitepaper, Web and App Accessibility: Understanding the U.S. Justice Department’s New Rule, and about accessibility in this Digital Accessibility in Higher Education resource.
