How Title II Shapes Digital Accessibility

Posted on

Issue 3: Unlocking Equal Access in Higher Education through Digital Accessibility (July 2025). Title II of the Americans with Disabilities Act (ADA) requires state and local government entities, including public universities, to provide equal access to their services, programs, and activities, which now includes a specific standard for digital content as the result of a 2024 rule issued by the U.S. Department of Justice. This means that websites, electronic documents, and mobile apps offered by public institutions must be accessible to individuals with disabilities. Specifically, Title II requires that digital platforms be designed and maintained in ways that allow individuals with visual, auditory, motor, or cognitive disabilities to fully engage with online content and services. To achieve this, organizations must comply with the Web Content Accessibility Guidelines (WCAG) standards at Level 2.1 AA by April 24, 2026.

How does this impact our universities?

In higher education, the Title II digital accessibility rule impacts universities and colleges that are considered public entities. These institutions must ensure that their websites, online learning platforms, admissions portals, and other digital tools are accessible to all users, including those with disabilities. Failure to comply with Title II can lead to legal challenges, financial costs or penalties, reputational damage, and the potential loss of federal funding. As educational institutions increasingly rely on digital platforms for instruction, communication, and administration, compliance with digital accessibility standards becomes crucial not only for legal reasons but also to create an inclusive and equitable environment. Ensuring that all individuals can access and benefit from educational resources is a vital aspect of providing equal opportunities in higher education.

What is expected of our UW faculty and staff to meet this standard?

The rule requires that digital tools and electronic resources used in programs, services, and activities must be accessible so individuals with disabilities have seamless access without needing to request a reasonable accommodation. We can start by creating new content using best practices and remediating inaccessible content that will continue to be used in courses and programs after April 24, 2026. The UW offers training and resources for making accessible content. To learn how to make websites, documents, and videos accessible, please visit the UWSA Digital Accessibility website.

Test your knowledge on these digital accessibility questions:

False
  • Title II of the ADA requires state and local government entities, including public universities, to ensure equal access to their services, including digital services. This means that websites, online learning platforms, mobile apps, and other digital tools must be accessible to individuals with disabilities. This legal requirement emphasizes that digital accessibility is not optional—it’s a fundamental right protected under federal law.



False

Although Title II of the ADA originally focused on physical spaces, the 2024 rule clearly extends Title II obligations to the digital realm. State and local governments, including public universities, are now explicitly required to ensure that digital content, including that which is created and available to students in a learning management system, must be accessible. The shift toward digital enforcement reflects the increasing reliance on technology in education and public service delivery.


B, C and D
  • Noncompliance with Title II digital accessibility standards can have serious consequences for public universities. Institutions that fail to make their digital environments accessible may be subject to federal investigations, lawsuits, and public criticism. In severe cases, they risk losing federal funding, which supports critical operations such as research, financial aid, and infrastructure. More importantly, noncompliance undermines the university’s mission to provide equitable education and services to all students, including those with disabilities.

True
  • The Web Content Accessibility Guidelines (WCAG) are internationally recognized standards for making web content more accessible to people with disabilities. Under Title II, institutions are required to align their digital content with WCAG standards to ensure compliance. This includes practices like ensuring text can be read by screen readers, providing captions and audio descriptions for multimedia, and designing interfaces that can be navigated without a mouse. WCAG serves as a practical benchmark for Title II enforcement in the digital space.

C) Ensuring all students, including those with disabilities, can access and engage with digital content equally
  • The central goal of Title II digital accessibility is to create equal opportunities for participation in public services, including education. In higher education, this means making sure that digital learning environments, admissions platforms, and communication tools are usable by all students, including those with disabilities. Digital accessibility is not just about legal compliance—it’s about inclusion, equity, and equal opportunity to succeed, enabling success for every learner. By removing digital barriers, universities uphold their ethical and legal responsibility to provide inclusive education for all.

True
  • This new rule recognizes that public universities have a lot of digital content and focus on making the content used in programs, services, and activities, including classes, accessible if that item will be used after April 24, 2026. Old electronic documents, for example, that will no longer be used in spring 2026 do not need to be made accessible. Universities may, however, still need to take proactive steps to archive some legacy digital content and may consider removing unused digital content from websites and learning management systems to facilitate compliance.

True
  • Your university does have a contact (or team) assigned to oversee digital accessibility efforts on your campus. Check out the UW Digital Accessibility directory. These university contacts/teams are committed to creating an inclusive digital environment where all students can access and interact with our online content regardless of disability. Whether you need assistance with accessible document creation, website navigation, or accommodations for online coursework, your campus accessibility contact/team is here to help.

 

Check out these additional UW resources:

Sources: