Why the DOJ Updated Title II of the ADA’s Digital Accessibility Rules
The DOJ’s 2024 update was driven by a simple reality: people rely on digital services for nearly everything. Registering for classes, accessing course materials, paying bills, applying for jobs, and getting public information all require digital accessibility. When those digital services don't meet WCAG 2.1 AA standards, people with disabilities are effectively shut out.
The DOJ explains several key reasons for the update:
- Digital access is now essential for participation. Government services, including higher education, are increasingly delivered online.
- Inconsistent accessibility practices create inequity. Without clear standards, institutions interpret accessibility differently, leaving many users behind.
- People with disabilities face real barriers. The DOJ cites examples like unreadable PDFs, videos without captions, and forms that can’t be completed with assistive technology.
- Clear, enforceable standards are needed. The update formally adopts WCAG 2.1 AA as the required technical standard.
➡️ Why the DOJ Set Specific Requirements for Web and Mobile App Accessibility
ADA Title II Overview & Compliance Timelines
The updated Title II rule requires state and local governments, including public colleges like RIC, to ensure that all web content and mobile apps meet WCAG 2.1 AA standards by April 24, 2026. This includes websites, course materials, documents, videos, forms, and any digital tools/content that are public-facing or used to deliver services.
➡️ How Long State & Local Governments Have to Comply
What This Means for RIC
For RIC, this means that we must ensure that new and updated content meets WCAG 2.1 AA standards now, and we must remediate existing content according to federal timelines and institutional priorities.
Exceptions
The updated rule includes a few narrow exceptions, but they are fairly limited:
- certain archived web content
- some pre-existing documents that are not needed for active administrative tasks
- third-party content not under the institution’s control
- individualized documents that are password-protected
- preexisting social media posts
The DOJ emphasizes that exceptions are not loopholes; they are specific, documented and reviewed cases where full compliance is not feasible. Even when an exception applies, the institution must still provide equally effective alternative access that is timely and meets the individual’s needs. Exceptions do not remove the obligation to provide access.
➡️ Summary of Title II Exceptions
WCAG 2.1 AA as the Required Standard
The updated rule formally adopts WCAG 2.1 AA as the technical standard for digital accessibility. Level AA encompasses both level A and level AA standards. We need to meet both. This means:
- clear structure and headings
- text alternatives for images
- keyboard accessibility
- captions and transcripts for video and audio
- readable text and sufficient color contrast
- consistent navigation and predictable interactions
- other POUR-based access practices
WCAG is built around four principles: content must be Perceivable, Operable, Understandable, and Robust (POUR). These principles guide all accessibility work at RIC.
"You don't need to memorize WCAG. Most accessibility improvements come from a few consistent practices, as mentioned on Creating Accessible Digital Content."
Roles & Responsibilities Across Departments
Meeting Title II requirements is a shared responsibility across campus. Each group plays a role in ensuring accessible digital content:
- Faculty – create accessible course materials and share accessible external resources with students
- Staff – ensure documents, forms, and public-facing content meet accessibility standards
- Web Editors – maintain accessible web pages and follow CMS best practices
- IT and Procurement – evaluate digital tools for accessibility and review VPATs/ACRs
- Accessibility Liaisons – support departments and help coordinate remediation
Please Note: Role definitions, workload expectations, and resourcing will be aligned through normal institutional processes.
"Accessibility is a campus-wide effort. When each group fulfills its role, we create a more inclusive environment for everyone."