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ADA Title II Compliance for Higher Education

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April 17, 2025
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Accessibility is at the heart of inclusive education, and with the newly updated ADA Title II regulations, higher education institutions in the US have more accountability than ever. This shift strengthens the commitment to equitable access for students with disabilities, leaving no room for outdated systems or practices that create barriers to learning.

Key takeaways:

  • Updated ADA Title II rules require public higher education institutions to meet WCAG 2.1 Level AA standards for digital accessibility.
  • Compliance deadlines are April 24, 2026 for large institutions and April 24, 2027 for all others.
  • Non-compliance risks include lawsuits, fines, reputational damage, and lost opportunities to attract diverse talent.
  • Institutions remain responsible for accessibility even when using third-party platforms or content.
  • Mid-tier schools, those with non-compliant tools, and faculty lacking training face the highest risk.
  • Key steps include auditing systems, creating action plans, training staff, and maintaining ongoing compliance.

Whether you're a compliance officer, an IT specialist, or an instructional designer, this guide will help you understand the new DOJ ADA 2024 rule, its requirements, and actionable steps to get started.

Most importantly, we’ll explain what you need to do before the deadlines of April 24, 2026, and April 24, 2027 (depending on your institution’s population size) to avoid costly non-compliance.

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What does the new ADA Title II rule require?

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The latest Department of Justice (DOJ) update to ADA Title II guidelines is a big leap forward in ensuring digital accessibility across all public US institutions, including colleges and universities.

Here's what you need to know about the rule and its implications:

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Compliance standards

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To comply with ADA Title II, institutions must meet the standards outlined in WCAG 2.1 Level AA (Web Content Accessibility Guidelines). These standards ensure that websites, learning management systems, and other digital resources are accessible to all users, including those using assistive technologies such as screen readers or voice recognition software.
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Risks of non-compliance

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Failing to adhere to ADA Title II and meet WCAG 2.1 Level AA standards can have significant consequences for institutions. Non-compliance risks include legal actions, such as lawsuits and fines, which can damage an institution's reputation and financial stability.

Additionally, inaccessible digital resources can exclude individuals with disabilities. This lack of accessibility can result in lost opportunities to attract and retain a diverse and talented community of students, faculty, and staff.

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Institutions impacted

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The updated rule primarily targets public colleges and universities. Even if you're using third-party platforms or content providers, you are responsible for ensuring that everything your students and faculty use meets WCAG for higher education standards.
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Deadlines you need to know

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Compliance deadlines are based on the size of your institution’s population:

  • April 24, 2026 for institutions serving 50,000+ individuals
  • April 24, 2027 for all other institutions

By these dates, affected entities must ensure their digital content and platforms are fully compliant, or risk legal and reputational repercussions.

A clear roadmap and action plan are essential to meeting these requirements on time.

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Who’s most at risk?

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While the rule is enforceable across all US institutions, certain groups are more likely to face obstacles:
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1. Mid-tier institutions with limited internal support

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Colleges and universities lacking a dedicated team for accessibility may struggle to meet the WCAG 2.1 Level AA requirements. Limited resources can make it harder to implement comprehensive audits or build internal expertise.
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2. Schools using non-compliant tools

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Outdated open educational resources (OERs) or tools that don’t meet accessibility standards can jeopardize compliance. Tracking all third-party tools in use is especially challenging without a proper framework in place.
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3. Faculty with minimal accessibility training

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Many faculty members simply aren’t trained to create or review accessible course content. Without proper education, even well-intentioned staff can unknowingly contribute to noncompliance.
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7 steps to achieve accessibility compliance

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Creating an accessible digital environment is a chance to drive meaningful inclusion. What steps are you taking to ensure your online platforms are welcoming and usable for everyone? By acting now and prioritizing accessibility, you can empower all students to succeed. Here are key actions to guide you toward compliance and true inclusion.

1) Conduct an accessibility audit
Evaluate your website and digital content for accessibility gaps. Use tools like JAWS screen readers and contrast checkers to identify barriers.

2) Create an action plan
Focus on the highest-impact areas first — like login pages, course material portals, and video content. Prioritize compliance with WCAG’s POUR principles; digital content must be perceivable, operable, understandable, and robust.

3) Train faculty and staff
Ensure that instructors, course designers, and administrative staff understand web accessibility best practices. Offer training sessions on using accessibility tools and platforms.

4) Leverage assistive technology
Adopt tools to provide captions, transcripts, and other assistive features across video content and course materials.

5) Engage experts
Partner with organizations experienced in accessibility compliance, like Boundless Learning. We can help assess your current systems, make recommendations, and guide you through implementation.

6) Test with real users
Include individuals with disabilities in your testing phase. Their feedback is invaluable in identifying gaps that automated tools might overlook.

7) Maintain compliance
Treat accessibility as an ongoing commitment. Regular audits will ensure you meet evolving standards.

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FAQs

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What is WCAG 2.1 Level AA?

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WCAG 2.1 is the Web Content Accessibility Guidelines, a set of standards ensuring websites and digital tools are accessible to all. Level AA includes practical standards like sufficient color contrast, text resizing, and keyboard navigation.
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Are third-party tools included in compliance?

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Yes. If a third-party tool or content is part of your institution’s digital ecosystem, it must meet ADA compliance standards. The responsibility ultimately falls on your institution.
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What happens if we miss the deadline?

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Non-compliance can lead to financial penalties, costly lawsuits, and reputational damage. Starting early ensures you have ample time to tackle challenges.
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Stay compliant

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Digital accessibility is no longer optional — with the updated DOJ ADA 2024 rule, it’s a legal and ethical responsibility. But beyond compliance, prioritizing accessibility makes education better for everyone.

At Boundless Learning, we can help you meet and exceed accessibility requirements with confidence. Our learning design solutions and education services provide tailored support, from instructional design guidance to third-party tool recommendations. We’ll ensure any content or resources we provide or develop meet accessibility requirements.

Contact our expert team to discover how we can support your compliance goals.