Accessibility Home/Policy

ADA Title II Web & Mobile Accessibility Rule

Understanding the Department of Justice's 2024 rule requiring state and local governments to make web content and mobile apps accessible.

Final Rule Published:April 24, 2024

Effective Date:June 24, 2024

Compliance Deadline:April 24, 2026 (large entities) or April 24, 2027 (small entities)

Overview

The ADA Title II rule establishes specific technical standards for web content and mobile applications of state and local government entities, including public universities.

Why This Matters

  • Clear standards:For the first time, there's a defined technical standard (WCAG 2.1 Level AA)
  • Enforceable deadlines:Specific dates for compliance
  • Legal clarity:Ends ambiguity about what "accessible" means under the ADA
  • Consistent expectations:Same standards apply to all covered entities

Key Takeaway

Public universities must ensure their websites and mobile apps conform toWCAG 2.1 Level AAby the applicable deadline.

Who It Applies To

The rule applies to all "public entities" under Title II of the ADA:

  • State and local governments
  • Public school districts
  • Public colleges and universities
  • Public libraries
  • Public transit agencies
  • Courts and law enforcement
  • Public hospitals and health departments

Size Categories

Category Definition Deadline
Large entity Population 50,000 or special district April 24, 2026
Small entity Population < 50,000 April 24, 2027

Note:Most public universities are classified as large entities due to enrollment, service area, or affiliation with state systems.

What It Requires

The rule requires conformance toWCAG 2.1 Level AA, which includes:

WCAG 2.1 Level AA Requirements

  • Perceivable:Users can perceive content
    • Text alternatives for images
    • Captions for videos
    • Sufficient color contrast
    • Resizable text
  • Operable:Users can navigate and interact
    • Keyboard accessible
    • No seizure-inducing content
    • Navigable structure
    • Pointer gestures alternatives
  • Understandable:Users can understand content
    • Readable text
    • Predictable operation
    • Input assistance
  • Robust:Content works with assistive technology
    • Compatible with screen readers
    • Valid, well-formed code
    • Status messages announced

View WCAG 2.1 Quick Reference

Compliance Timeline

Date Milestone
April 24, 2024 Final rule published
June 24, 2024 Rule effective date
April 24, 2026 Large entities must comply
April 24, 2027 Small entities must comply

Important:Even before the compliance deadline, entities have existing obligations under the ADA to provide accessible services. The rule simply codifies specific technical standards.

What's Covered

Web Content

  • Websites (all pages, not just homepage)
  • Web applications
  • Documents posted online (PDFs, Word docs, etc.)
  • Multimedia content (videos, audio)
  • Online forms and services
  • Learning management systems (LMS) content
  • Third-party content posted by the entity

Mobile Applications

  • Native mobile apps
  • Mobile web applications
  • Apps for smartphones and tablets

Specific to Higher Education

  • Admissions and registration systems
  • Course catalogs and schedules
  • Financial aid information and applications
  • Student portals
  • Library resources
  • Campus maps and wayfinding
  • Event registration
  • Research publications

Exceptions

The rule includes limited exceptions:

Archived Content

  • Content created before the compliance date
  • Must be maintained exclusively for reference, research, or recordkeeping
  • Cannot be updated after the compliance date
  • Must be clearly identified as archived
  • Note:Upon request, entities must provide an accessible version

Pre-existing Conventional Documents

  • Paper documents that were scanned before the compliance date
  • Not updated or used to provide current information
  • Must provide accessible version upon request

Third-Party Content

  • Content posted by third parties (not the entity)
  • Doesnotapply to content the entity posts or controls
  • Entity must still ensure its own content is accessible

Individualized Accommodations

  • Documents prepared specifically for one individual
  • Medical records, individualized education programs
  • Must be provided in an accessible format to that individual

What's NOT Excepted

  • Content currently in use for programs and services
  • Frequently referenced materials
  • Forms that are still active
  • Course materials for current courses
  • Content on third-party platforms contracted by the entity

Steps to Compliance

1. Assess Current State

  • Inventory all web content and mobile apps
  • Conduct accessibility audits (automated + manual)
  • Identify high-priority content
  • Document current accessibility levels

2. Establish Governance

  • Assign accessibility leadership
  • Create accessibility policy
  • Define roles and responsibilities
  • Set up feedback mechanisms

3. Remediate Existing Content

  • Prioritize high-traffic and critical services
  • Fix web page accessibility issues
  • Remediate or recreate documents
  • Add captions to videos

4. Build Accessible Going Forward

  • Train content creators
  • Update development standards
  • Include accessibility in procurement
  • Establish QA processes

5. Maintain Compliance

  • Regular monitoring and testing
  • Respond to accessibility feedback
  • Track and report metrics
  • Update as WCAG evolves