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Title II ADA Digital Accessibility Requirements

What the 2024 DOJ rule means for the University of Arizona.

⚠️ Compliance deadline: April 24, 2026

Executive summary

Key points for UA leadership:

  • The Department of Justice published final Title II rules on April 24, 2024
  • Public universities must make web content and mobile apps accessible by April 24, 2026
  • Standard is WCAG 2.1 Level AA
  • Covers all web content, mobile applications, and electronic documents
  • Limited exceptions exist but require documentation
  • Enforcement includes complaints, investigations, and potential loss of federal funding

Background

Title II of the Americans with Disabilities Act (ADA) prohibits discrimination by state and local government entities, including public universities. While digital accessibility has been required under Title II since 1990, the DOJ had not published specific technical standards until April 2024.

Timeline

DateEvent
July 1990ADA signed into law
August 2023DOJ Notice of Proposed Rulemaking
April 24, 2024Final rule published
April 24, 2026Compliance deadline (entities serving 50,000+ population)
April 24, 2027Compliance deadline (entities serving under 50,000)

As a large public research university, UA falls under the April 24, 2026 deadline.

What's covered

Web content

All content made available through a web browser, including:

  • University websites (arizona.edu and all subdomains)
  • Web applications (student portals, registration systems, course management)
  • Online forms and documents
  • Videos and multimedia
  • Social media content created by the university
  • Third-party content embedded in university pages

Mobile applications

Native mobile applications developed by or for the university, including:

  • Campus apps (UA mobile, parking, transit)
  • Student services apps
  • Library and research apps
  • Athletic and event apps

Electronic documents

Documents made publicly available, including:

  • PDFs, Word documents, spreadsheets
  • Course materials in learning management systems
  • Forms and applications
  • Reports and publications

Limited exceptions

The rule includes narrow exceptions, but they require documentation and often alternative access:

Archived content

Exception: Content created before the compliance date that is maintained exclusively for research, reference, or archival purposes.

Requirements:

  • Must not be updated or used for current programs
  • Must be clearly identified as archived
  • Alternative access must be provided upon request

Preexisting conventional electronic documents

Exception: Word processing, presentation, PDF, and spreadsheet files created before compliance date.

Requirements:

  • Must provide accessible version upon request
  • Does NOT apply to documents currently used in programs
  • Does NOT apply to forms used to apply for services

Third-party content

Exception: Content posted by third parties (like public comments on social media).

Requirements:

  • Only applies to content not posted by or on behalf of the university
  • Does NOT apply to contracted third-party services

Individualized password-protected documents

Exception: Documents created for a specific individual that are secured for that person.

Requirements:

  • Must provide accessible version to that individual upon request
  • Does NOT apply to documents shared with multiple people

Enforcement

Complaint process

Individuals can file complaints with:

  • Department of Justice Civil Rights Division
  • Office for Civil Rights (Department of Education)
  • Federal courts (private right of action)

Potential consequences

  • DOJ investigation and compliance agreement
  • Mandatory remediation with monitoring
  • Compensatory damages to complainants
  • Civil penalties (up to $75,000 first violation, $150,000 subsequent)
  • Loss of federal funding (via Section 504)
  • Reputational damage and negative publicity

Recent enforcement actions at universities

The DOJ and OCR have investigated and reached settlements with numerous universities in recent years, including:

  • Large public research universities required to remediate thousands of web pages
  • Mandatory accessibility training for web developers and content creators
  • Establishment of accessibility offices and ongoing monitoring
  • Multi-year compliance agreements with regular reporting

UA compliance approach

Immediate priorities (2024-2025)

  • Inventory all public-facing web properties
  • Automated and manual accessibility audits
  • Remediation of high-traffic, high-priority pages
  • Procurement requirements for new technology purchases
  • Training programs for content creators

Compliance infrastructure

  • Centralized accessibility program office
  • Accessibility liaisons in colleges and units
  • Testing and consultation services
  • Ongoing monitoring and reporting

Resources

Questions

For questions about Title II compliance at UA: