Original Issuance Date: May 9, 2025 Last Revision Date: May 9, 2025 Effective Date: April 1, 2026

1. Purpose of Guidance

This document provides plain language guidance to comply with UW System Administrative Policy SYS 655, Accessibility of Web Content and Mobile Applications, and provides information for common digital accessibility applications. Not all standards are reviewed in this guidance document. If a reviewer seeks a specific standard or success criterion not readily evident in this document, consult WCAG 2.1. In limited circumstances, complying with the WCAG 2.1 Level AA standards may result in a fundamental alteration or undue financial and administrative burdens to a university service, program or activity. For guidance, users must consult their designee as noted in the policy.

2. Publishing Office(s)

Office of Compliance and Risk Management.

3. Affected Stakeholders on Campus

Primary individuals and offices responsible for ensuring adherence to these guidelines:

• Division leaders including Provosts, CBOs, SSAOs, and SSEOs
• Compliance officers
• IT leadership
• Teaching & learning centers
• Campus communications
• Procurement

Distribution list:

• Senior Leadership including Chancellors, Provosts, CBOs, SSAOs, SSEOs
• Chief Information Officers
• Communications and Marketing Directors
• ADA Coordinators & Compliance Officers
• Centers for Teaching and Learning Directors
• Learning Technology Development Council
• Disability/Accessibility Services Directors
• Procurement Directors
• Council of Universities of Wisconsin Libraries
• Digital Learning Environment Institutional Liaisons

4. Primary Responsibility

As outlined in SYS 655, each university must provide web content and mobile applications (mobile apps) that are accessible.

1. All web content and mobile apps, including electronic information technology, digital content, electronic resources, and software used to apply to, participate in, or benefit from a service, program, or activity must comply with WCAG 2.1 Level AA.
   1. Examples of web content and mobile apps include: webpages, learning management systems, videos, podcasts, electronic documents such as Word, PowerPoint and PDFs, enterprise tools such as email and multifactor authentication apps, and third-party tools such as ParkMobile.
   2. Examples of services, programs, and activities are any offerings or events delivered or sponsored by a university.
2. Digital content limited to and only used by university employees in their capacity as employees (e.g., not as a student-employee, student, program participant, or visitor), do not need to comply. In the event an employee with a documented disability cannot access, use, or gain the full benefits of a tool, the university must provide a reasonable accommodation as required under federal and state laws.
3. Limited exceptions and exemptions apply to the digital accessibility requirement (see Section 5.F below) and universities should document any determination that digital content meets an applicable exception or exemption.

5. Policy Guidance

A. Technical Standards

1. The WCAG standards are developed by the Word Wide Web Consortium (W3C) and are applicable to all types of technology.
2. There are various versions and levels of achievement within each WCAG version. Each achievement level is known as a “Success Criterion” and there are three levels: A, AA, and AAA.
3. The policy requires adhering to version 2.1 at Level AA.
4. Technology is considered accessible per the policy when the content meets WCAG 2.1 Level AA.
5. Accessible technology is not achieved only through remediating barriers, but through ensuring accessibility through all the life stages of a digital tool from procurement, design, development, implementation, and maintenance. More information is available on W3C’s Accessibility Maturity Model.
6. A quick reference guide for meeting WCAG 2.1 Level AA is available.

B. Remediation, Archiving, Retrieval, and Barrier Reporting

A university’s web content and mobile apps must meet the WCAG 2.1 Level AA standards, regardless of whether it is viewed on desktop computers, laptops, kiosks, smartphones, tablets, or other mobile devices.

1. As outlined in the Policy (Section 6.A.), existing digital resources that are not accessible shall be remediated to comply with WCAG 2.1 level AA by April 24, 2026, unless:
   1. Adhering to WCAG 2.1 level AA results in a fundamental alteration or undue administrative burden (see further guidance in Section 5.F.III);
   2. A university determines that a digital asset or resource can be archived because it is no longer used in connection with a university program, service, or activity (see criteria in Section 5.F.I); or
   3. A digital asset or resource meets another defined exception under the April 24, 2024, Rule on Digital Accessibility (see further guidance in Section F).
2. Archiving: Programs often maintain digital content that is not currently used because it is outdated, not needed, repeated elsewhere, or only retained for research, reference, or recordkeeping.
   1. UW universities may archive web content not needed to participate in, apply to, or benefit from a university service, program, or activity in accordance with the criteria in Section 5.F.I.1.
      1. Archived content must be clearly identified as such.
      2. Archived content must contain an accessibility tagline statement indicating how an individual can request a reasonable accommodation for an accessible version as necessary to interact with the content.
   2. Retrieval of archived web content
      1. Archived content that is updated or reused in connection with a service, program, or activity must comply with WCAG 2.1 Level AA.
3. Barrier reporting
   1. A mechanism must be provided for users to report an accessibility barrier.
      1. The barrier reporting tool should be located across user platforms and interfaces.
   2. An overview of an accessibility barrier reporting form and process is located on the Universities of Wisconsin website.

C. Guidance for Specific Types of Web Content and Mobile Apps

The following is some high-level guidance based on select types of digital content and electronic resources. Consult WCAG 2.1 AA for more information.

I.  Electronic documents

1. 1. Definition: Any file formats, such as spreadsheets, word processing, portable document formats (PDFs), and presentations, that contain information meant to be read by a human.
   2. Electronic documents must comply with WCAG 2.1 Level AA.
   3. Best practices for making documents accessible include:
      1. Using plain language (employ university’s style guide),
      2. Using appropriate font sizes and types,
      3. Adding alternative text (alt text) to images,
      4. Using heading structure to organize content,
      5. Ensuring sufficient color contrast,
      6. Using tables with proper column and row headers,
      7. Using informative/descriptive link text rather than “click here” or “more information,”
      8. Using built-in accessibility checkers, and
      9. Setting document language and using document properties to enter the title, subject, and author.
   4. A list of best practices in accessibility by document type is available from the Center for User Experience at UW-Madison.

II.  Audio and visual media

1. 1. Definition: Any live or pre-recorded multimedia, such as videos, podcasts, audio recordings, recordings of lectures, narrated presentations, video quizzes, screencasts, and third party-provided media content.
   2. Multimedia must comply with WCAG 2.1 Level AA (visit 1.2: Time-based Media)
   3. Multimedia accessibility requirements by format include:
      1. Pre-recorded video with synchronized audio:
         1. If equivalent information that meets the success criteria is not already available on the screen, captions are required.
         2. If audio does not describe visual elements, synchronized audio description is required.
      2. Pre-recorded video with no audio:
         1. Synchronized audio description or a text alternative is required.
      3. Live video with synchronized audio:
         1. Captions are required.
      4. Audio-only with no video:
         1. If equivalent information that meets the success criteria is not already available on the screen, a transcript is required.

D. Training

To support policy implementation, training should be made available to ensure the development of documents, applications, and other electronic tools that comply with WCAG 2.1 Level AA. The following trainings are recommended based on stakeholders or technology:

1. Learning or Content Management Systems (LMS) Course Instructors or Users,
2. Employees with permission to write or publish internal or external websites,
3. Employees who purchase, create, or manage third-party websites, applications, and mobile apps, and
4. Other responsible employees who are:
   1. Designated under the Policy to serve as a primary contact for technical consultation and policy compliance issues,
   2. Designated under the Policy to provide guidance on regulatory exceptions to the Rule or make decisions with respect to the applicability of the Rule or Policy to certain digital content, and
   3. Responsible for reporting, tracking, and resolving reported accessibility barriers.

E. Review and Procurement of Third-Party Products or Services

1. Digital content and electronic resources created, maintained, hosted, or delivered by third parties for use in UW universities’ services, programs, or activities must be accessible pursuant to the Policy.
2. Current or existing third-party contracts:
   1. UW universities should evaluate and remediate barriers. To prioritize evaluation and remediation, UW universities may use a risk-informed approach to identify digital content:
      1. In high usage,
      2. In student-facing, high-revenue, or publicly attended activities, or
      3. In close connection to a university’s mission.
3. Future third-party contracts:
   1. UW universities should incorporate processes to ensure that web content and mobile apps will be accessible in compliance with the Policy.
   2. In procurement processes, such as requests for proposals (RFPs) or requests for bids (RFBs), and in contracts, UW universities may incorporate language requiring that:
      1.  Digital content procured, created, or maintained under the contract must comply with the WCAG 2.1 Level AA accessibility standards;
      2. Vendors provide a completed Voluntary Product Accessibility Template (VPAT), either as an addendum to a bid/proposal, prior to executing a contract, or upon the university’s request; and
      3. Vendors have a system for reporting accessibility barriers and commit to resolving these issues in a timely manner at the vendor’s cost.
         1. If timely resolution cannot be achieved, vendors should be required to provide a conforming alternate version of affected digital content.
   3. UW universities should consider allocating resources to review a vendor’s VPAT or conduct a manual accessibility review of digital content procured, created, or maintained by a third-party contract in accordance with the priorities in Section 5.E.II.
4. The following sample contract language or any of its parts may be incorporated into third-party contracts for digital content procurement, creation, or maintenance:

“For all products or services provided pursuant to this Agreement, the Vendor shall comply with the Americans with Disabilities Act (ADA) in a manner consistent with the W3C Web Content Accessibility Guidelines (WCAG), version 2.1 (“WCAG 2.1”), at conformance level AA. If the Product does not fully conform to WCAG 2.1 Level AA, the Vendor shall inform the University of non-conformance prior to the execution of this Agreement and shall provide a plan and timeline to achieve conformance and develop a conforming alternate version that complies with WCAG 2.1 Level AA. If, during the Term of this Agreement, the Vendor fails to maintain compliance with WCAG 2.1 Level AA, or the University identifies an accessibility barrier in a product or service that renders the product or service inaccessible or unusable to people with disabilities, the University shall notify the Vendor of non-compliance. If the Vendor does not achieve product or service accessibility in conformance with WCAG 2.1 Level AA within 7 days of the Vendor receiving the notification of non-compliance (“Notice”), the Vendor and the University shall meet and mutually agree upon an appropriate resolution of the accessibility barrier(s), including a timeline for resolution and any damages for which the Vendor may be responsible. Should Vendor: (i) fail to acknowledge receipt of the Notice within 7 days of receipt of the Notice or (ii) fail to materially resolve the accessibility barrier(s) within the agreed-upon timeline, Vendor agrees to indemnify and hold harmless University from any claims arising out of its failure to comply with the aforesaid requirements. Failure to comply with these requirements shall constitute a material breach and may be grounds for termination of this Agreement by the University.”

F. Exceptions and Exemptions

Under federal regulation and the Policy, there are certain limited situations for which digital content is not required to comply with WCAG 2.1 Level AA.

1. The following digital content are exceptions to the Rule and do not need to comply with WCAG 2.1 Level AA:
   1. Archived web content: digital content not used in a current service, program, or activity such as a course. The following must be met for content to be considered archived:
      1. The content was created before April 24, 2026, or reproduces paper documents or the contents of other physical media (audiotapes, film negatives, and CD-ROMs for example) created before April 24, 2026;
      2. The content is kept only for reference, research, or recordkeeping;
      3. The content is kept in a dedicated area accessibly labeled as “archived content”;
      4. The content has not been changed to add information or alter meaning since it was archived.
   2. Preexisting conventional electronic documents: spreadsheet, word processing, portable document formats (PDFs), and presentation files created before April 24, 2026, and not used to apply to, participate in, or benefit from a University service, program, or activity.
   3. Content posted by a third party: Content where the third party is not posting due to contractual, licensing, or other arrangements with the university.
      1. Examples of excepted content include user posts on University forums or social media pages.
      2. Content posted or linked to by the university or its contractor does not fall under this exception.
   4. Individualized, password-protected documents: Conventional electronic documents that are about a specific individual, their property, or their account and password-protected or otherwise secured. Examples include student transcripts and employee pay statements.
   5. Preexisting social media posts: A university’s social media posts created before April 24, 2026.
2. Digital content that is otherwise covered by the Rule and Policy may be exempt from the requirement to comply with WCAG 2.1 in the following limited circumstances:
   1. Conforming alternate versions: Where it is not technically or legally possible to make web content accessible, a university may use conforming alternate versions as defined by WCAG 2.1. A link to the conforming alternate version must be provided from the inaccessible version.
   2. Equivalent facilitation: A university may use alternative designs, methods, or techniques that result in substantially equivalent or greater accessibility and usability of digital content.
   3. Minimal impact on access: In especially limited circumstances, a university may be able to demonstrate that noncompliance has a minimal impact on access such that it does not affect the ability of individuals with disabilities to do any of the following in a manner that provides substantially equivalent timeliness, privacy, independence, and ease of use:
      1. Access the same information,
      2. Engage in the same interactions,
      3. Conduct the same transactions, and
      4. Otherwise participate in, apply to, or benefit from the same services, programs, and activities.
3. In limited circumstances, a university may demonstrate that compliance with the Rule or Policy with respect to certain digital content would fundamentally alter the nature of a university service, program or activity or result in undue financial and administrative burdens. In that event, compliance is required to the fullest extent possible while avoiding the fundamental alteration or undue financial and administrative burdens.
   1. Any decision that compliance would result in such alteration or burdens must be made by a Chancellor or designee after considering all resources available for use in the funding and operation of the service, program, or activity, and must be accompanied by a written statement of the reasons for reaching that conclusion.
   2. Any decision that compliance would result in such alteration or burdens should not be reached without first consulting subject matter experts, legal counsel, or other employees with knowledge to advise on the burden of proving this decision.

6. Contact

Chief Compliance and Risk Officer

7. Guideline History

Original Issuance: May 9, 2025

8. Scheduled Review

May 2027