What ADA Title II Actually Means for Public Institutions

Your institution may rely on vendors to deliver digital learning. It cannot hand those vendors its responsibility for accessibility. Here’s what that means for the teams building, buying, and overseeing the experience.

First, a deadline update

On April 20, 2026, the Department of Justice extended the compliance dates for its Title II web and mobile accessibility rule.

Public entities with a total population of 50,000 or more now have until April 26, 2027. Public entities with fewer than 50,000 people, along with special district governments, have until April 26, 2028.

That extra year matters. But it should not be mistaken for a change in direction.

The extension moved the dates. It did not change the rule’s WCAG 2.1 Level AA technical standard or its general scope. Public institutions also remain responsible for their existing obligations under the ADA while preparing for the new technical compliance date.

Most public institutions know the deadline is approaching. Fewer have figured out who is supposed to act on it and what that work looks like once it reaches campus.

The hard part is not writing an accessibility policy. It is making sure the next PDF, video, quiz, discussion board, and course page meets the standard without turning every new piece of content into a separate remediation project.

And that work does not belong to just one department.

The rule applies to web content and mobile apps a public institution provides directly, as well as those made available through contractual, licensing, or other arrangements. In plain English, an institution cannot outsource its Title II responsibility to a vendor. If a vendor provides an inaccessible digital experience on the institution’s behalf, the institution still owns the outcome.

The answer looks different depending on your role.

For instructional design teams

Designers already know how to build an accessible course. The strain shows up at volume: every course, every term, with the same size team and a submission deadline that doesn’t move

How do we build accessible courses without adding another layer of work to every project?

The answer cannot be to remediate everything after the course has already been built.

By then, designers may be repairing heading structures, rewriting link text, tracking down missing image descriptions, reviewing tables, captioning videos, and rebuilding interactions that were never accessible in the first place.

A better authoring workflow addresses those requirements while the content is being created. Templates provide a sound structure. The tool prompts authors for information such as image descriptions and captions. Accessible interactions are available from the beginning.

That does not eliminate the need for human review. It does reduce the number of preventable problems that reach the end of the process.

For IT and procurement

Procurement teams face a different question:

How do we know whether a platform actually supports our accessibility obligations?

WCAG 2.1 Level AA is the technical standard required by the Title II rule. A vendor should be able to explain how its product performs against that standard and provide a current Accessibility Conformance Report.

But documentation is only the beginning.

Institutions also need to look at the workflows people will actually use. Can faculty create inaccessible content inside an otherwise accessible platform? Which features have known limitations? What happens when an issue is reported? How quickly does the vendor respond? What accessibility expectations are written into the contract?

Buying a platform with an accessibility statement is not the same as understanding how that platform will perform across a real course-development process.

For administration and legal teams

Where does our responsibility begin and end?

It follows the services, programs, and activities the institution provides. That can include public websites, enrollment systems, learning management systems, course-authoring tools, mobile apps, and the digital materials students use to complete their coursework.

The rule includes limited exceptions for certain content, including qualifying archived materials, some preexisting documents, certain individualized password-protected documents, preexisting social media posts, and content posted independently by third parties. Those exceptions are specific. They are not a blanket exemption for course content, vendor platforms, or material stored inside an LMS.

Institutional ownership does not mean administrators or legal teams must personally repair every document. It means the institution needs a clear system for deciding who is responsible, how platforms are evaluated, how content is reviewed, how barriers are reported, and how problems are corrected.

What the rule requires in practice

WCAG 2.1 Level AA is the required technical standard.

  • Institutions can choose to follow a newer standard, such as WCAG 2.2, but the Title II rule specifically identifies WCAG 2.1 Level AA.

Most active digital course content will need to conform.

  • Web pages, documents, images, videos, quizzes, and other digital experiences can all fall within the rule’s definition of web content. The fact that content is password-protected or located inside a course does not automatically place it outside the rule.

Accessibility has to continue after the deadline.

  • An institution can remediate thousands of existing files and still fall behind when the next semester begins. New courses will be developed. New PDFs will be uploaded. Videos will be recorded. Platforms will change.
  • The Department of Justice makes clear that, after the applicable compliance date, public entities must continue ensuring that their covered web content and mobile apps meet WCAG 2.1 Level AA.

Faculty-created content is part of the institutional picture.

  • The rule does include exceptions: qualifying archived materials, certain preexisting documents, individualized password-protected documents, social media posts published before the compliance date, and content third parties post on their own
  • Read together, they describe material an institution has largely stopped touching. Active course content, the platforms you license, and the files sitting in your LMS don’t fall under any of them.
  • Faculty training matters. But training alone will not solve the problem if the tools they are expected to use make accessible course creation difficult.

April 26, 2027
That is the compliance deadline for public entities with a total population of 50,000 or more.

The question now is not whether an institution can audit enough content before that date. It is whether the institution can build a process that still works the day after the deadline, the following semester, and every time someone creates something new.

Why CourseArc started with accessibility

 

CourseArc came to market in 2015 after founders Katie Egan and Bethany Meyer struggled to find a course-authoring solution that was easy to use, collaborative, consistent, and capable of meeting the accessibility needs of the sector.

Accessibility was not added after the platform was built. It helped define what CourseArc needed to be from the beginning.

As accessibility standards have advanced, CourseArc has continued to evolve. Its current Accessibility Conformance Report documents the platform’s evaluation against WCAG 2.0, 2.1, and 2.2 at Levels A and AA.

That does not transfer an institution’s Title II responsibility to CourseArc. It gives faculty, instructional designers, and course-development teams an authoring environment designed to help them carry that responsibility more consistently.

About CourseArc

CourseArc is a content authoring and management platform that helps teams create, update, and scale accessible, engaging online learning without coding or specialized technical skills.

See what accessibility built in looks like across the course-authoring process.

This article provides general information about the ADA Title II web and mobile accessibility rule. It is not legal advice.

Want to learn more about CourseArc?