The countdown has officially begun. As of early February 2026, we are fewer than 80 days away from one of the most consequential shifts in digital accessibility that higher education has ever faced. On April 24, 2026, the Department of Justice’s (DOJ) Final Rule on ADA Title II takes full effect for most public higher education institutions.
For marketing teams, IT departments, instructional designers, and campus leaders, this moment isn’t about checking a box or adding accessibility to a long list of competing priorities. It’s a clear signal that digital accessibility in higher education is no longer reactive or optional. It is now a baseline expectation for how public institutions serve their communities.
So what does this rule actually require? And what should institutions be doing right now to be ready?
What Does the ADA Title II Final Rule Require for Public Colleges and Universities?
For years, higher education has operated in a gray area when it came to web accessibility. While courts consistently affirmed that the ADA applies to digital spaces, there was no single, universally adopted technical standard.
That ambiguity is now gone.
The DOJ’s Final Rule establishes, for the first time, a clear and enforceable accessibility standard for state and local government entities—including public colleges, universities, and community colleges.
The Technical Standard: WCAG 2.1 Level AA
The DOJ has officially adopted the Web Content Accessibility Guidelines (WCAG) 2.1 Level AA as the compliance benchmark. At a practical level, this means your websites, apps, and digital materials must be:
- Perceivable: Information and interface elements can be perceived by all users (for example, meaningful alternative text for images).
- Operable: Users can navigate and interact using a keyboard or other assistive technologies.
- Understandable: Content and navigation behave in predictable, consistent ways.
- Robust: Content works reliably across browsers, devices, and assistive technologies.
Who Must Comply—and When
These timelines define how ADA Title II higher education requirements apply across different types of public institutions:
- Large public entities (serving populations of 50,000 or more): Compliance is required by April 24, 2026.
- Small public entities (serving populations under 50,000): Compliance is required by April 26, 2027.
A note for private institutions: While this specific rule applies to public entities, private colleges and universities are not insulated. Institutions receiving federal funding under Section 504 or those targeted by Title III lawsuits are increasingly being held to these same WCAG 2.1 AA standards.
What Types of Digital Content Must Be ADA Title II Compliant?
A helpful rule of thumb: if the content is digital and supports your institution’s programs, services, or activities, it is likely covered under ADA Title II. This includes:
- Websites: Your main .edu site, departmental pages, campaign microsites, athletics sites, and admissions experiences.
- Mobile applications: Any university-branded app for registration, campus maps, or student life.
- Course-related content: Syllabi, lecture slides, and materials hosted on learning management systems like Canvas or Blackboard.
- Documents: All PDFs, Word docs, spreadsheets, and forms intended for student, employee, or public use.
- Social media: Posts made on official university channels (including the use of alt text and captions).
- Third-party tools: If you pay for a service (like a virtual tour or a scholarship portal), accessibility responsibility does not transfer to the vendor—you still own the risk.
How Can Higher Education Institutions Prepare for ADA Title II Compliance by 2026?
If you haven’t completed your remediation plan, the time to act is now. Follow these five critical steps to ensure ADA compliance for your college or university:
Step 1: Build a Digital Inventory
You cannot fix what you don’t know exists. Catalog every digital touchpoint, prioritizing:
- High-traffic pages: Admissions, Financial Aid, and Student Portals.
- Learning management system environments: Student- and faculty-facing content within your learning management system.
- Vendor contracts: Review VPATs (Voluntary Product Accessibility Templates) for all third-party software.
Step 2: Audit and Remediate
Effective audits combine automated testing and human evaluation. Automated tools help surface common issues like missing alternative text or color contrast failures. Manual testing, especially keyboard navigation and screen reader checks, is essential for identifying more complex barriers.
Step 3: Tackle the “PDF Problem”
Higher ed is notorious for “PDF bloat,” and many institutions are carrying years of inaccessible PDFs.
A sustainable strategy is simple in concept, if not in execution:
- Create new content in accessible HTML whenever possible
- Fix essential, current documents
- Remove or archive outdated files that no longer serve an active purpose
Step 4: Faculty & Staff Training
Accessibility is a distributed responsibility. Your marketing team can have a perfect homepage, but if a professor uploads an untagged PDF to a course, the institution is out of compliance.
Mandatory, role-based training for anyone with publishing authority—faculty, staff, and student employees—is critical.
Step 5: Establish a Digital Accessibility Policy
Policies turn intention into accountability. A strong digital accessibility policy should clearly define:
- Technical standards (WCAG 2.1 Level AA)
- Procurement expectations for vendors and software
- A transparent process for reporting and resolving accessibility barriers
Are There Exceptions to ADA Title II Digital Accessibility Requirements?
The DOJ final rule does allow for limited exceptions, but these are narrower than what you might expect. Examples include:
- Archived content: Content created before the deadline that is held only for reference/record-keeping and not currently used.
- Third-party user-generated content: Content posted by a third party (like a student comment on a forum) that is not under the university’s control.
- Pre-existing electronic documents: Certain documents available on your site before the compliance date, unless they are actively used for current programs or services.
Relying on exceptions as a strategy is risky. In practice, most high-impact content will still need remediation.
Why Digital Accessibility Must Be Treated as Infrastructure, Not Compliance
April 24, 2026, is a compliance deadline, but it’s also a cultural marker for digital accessibility in higher education. This moment challenges institutions to move beyond accommodation-as-afterthought and toward accessibility-as-infrastructure. When digital experiences are designed to work for everyone from the start, the benefits extend well beyond legal compliance.
Accessible campuses are more usable, more equitable, and ultimately more human. And that is a standard worth meeting—well before the clock runs out.
Carnegie’s award-winning website development team can help you create (and maintain) a site that is as stunning as it is accessible and user-friendly. Ready to take your website to the next level? Reach out and start a conversation.
Frequently Asked Questions (FAQ)s
Who does the ADA Title II Final Rule apply to?
The ADA Title II Final Rule applies to state and local government entities, including public colleges, universities, and community colleges. Private institutions are not directly covered but may still be required to meet WCAG standards under Section 504 or ADA Title III.
When does ADA Title II compliance take effect?
Public higher education institutions serving populations of 50,000 or more must comply by April 24, 2026. Smaller public entities have until April 26, 2027.
What accessibility standard is required under ADA Title II?
The Department of Justice requires compliance with WCAG 2.1 Level AA, which covers web content, mobile applications, digital documents, and other electronic information.
Does ADA Title II apply to PDFs and course materials?
Yes. PDFs, Word documents, spreadsheets, and course materials hosted in learning management systems are all considered in scope if they support institutional programs, services, or activities.
Are third-party tools exempt from ADA Title II requirements?
No. If an institution uses or pays for third-party tools such as virtual tours, registration platforms, or scholarship portals, the institution remains responsible for accessibility compliance—even if the vendor created the content.
Are there any exceptions to the ADA Title II Final Rule?
Limited exceptions exist for archived content, certain pre-existing documents, and third-party user-generated content. However, these exceptions are narrow, and most active or high-impact content must still be accessible.
What happens if a college or university is not compliant with the ADA Title II Final Rule?
Institutions that fail to comply may face DOJ enforcement actions, civil rights complaints, legal risk, and reputational damage. More importantly, noncompliance can limit equal access for students, staff, and community members with disabilities.