Don’t Wait Until the Time for Digital Accessibility is Up
Public universities with over 50,000 students are facing an imminent deadline: by April 24, 2026, they must comply with the new Title II standards of the Americans with Disabilities Act (ADA). This urgency is not unwarranted. The timeline is tight, and the scope of compliance is extensive.
Smaller institutions have until April 2027 to meet these standards, yet this extended deadline should not be misconstrued as a comfortable buffer. Instead, it is a brief window of opportunity, especially for IT teams operating with limited resources and budgets. Without prompt action, this one-year lead could quickly diminish, leaving little room to navigate the complexities of compliance.
The U.S. Department of Justice has introduced a final rule that mandates adherence to the WCAG 2.1 Level AA standards across digital platforms. This rule encompasses student portals, mobile applications, online forms, learning management systems, and departmental websites. Essentially, any digital system used for course registration, financial management, or accessing institutional services falls under this requirement.
Understanding the Responsibility for Third-Party Platforms
A critical yet often overlooked aspect of this rule is the treatment of third-party platforms. The responsibility for ensuring accessibility does not transfer to the service providers. Institutions remain accountable for the accessibility of technologies they procure and utilize. If a licensed system fails to meet accessibility standards, the liability rests with the institution itself, making ADA Title II compliance both a governance and procurement issue. This necessitates thorough reviews of internal systems and provider oversight, which require time and cannot be executed in isolation.
For smaller institutions, the message is clear: the months leading up to April 2027 present a crucial opportunity to take action before staffing, funding, and flexibility constraints become significant obstacles.
Prioritize High-Risk Platforms
While Learning Management Systems (LMS) are frequently discussed in accessibility conversations, it is the student portals and mobile apps that pose the greatest legal risks. These platforms manage critical functions such as registration, financial aid, and core administrative tasks, and are often managed by student affairs or remote IT teams that may lack the resources for comprehensive accessibility testing.
Mobile applications, in particular, require special attention. The rule explicitly highlights this, and industry estimates suggest that reactive remediation costs for mobile interfaces in higher education are approximately $68.9 million. Identifying and addressing problems now is considerably more cost-effective than implementing emergency solutions later.
Implement Cross-Departmental Testing
Viewing accessibility as solely an IT issue creates a dangerous compliance gap for smaller institutions. Platforms managed by various departments, including Human Resources, the Registrar’s Office, and Student Affairs, are all subject to the same accessibility mandates. It is essential to create or collaborate with an expert to develop a cross-functional inventory of all systems students interact with, identifying ownership and contract renewal timelines. This inventory serves as the foundation for any credible remediation plan, necessitating coordinated efforts from procurement, legal, and academic technology stakeholders. Addressing these requirements methodically now is far less challenging than doing so under time constraints.
Engage Providers with Specific Requirements
Institutions should not accept providers’ general assurances of accessibility. Instead, request a current Voluntary Product Accessibility Template (VPAT) from each vendor and compare it against WCAG 2.1 Level AA requirements. A VPAT outlines where a product meets the standard and where it does not. Gaps do not necessarily disqualify a product but must be accounted for. When evaluating new platforms, prioritize those with built-in accessibility features rather than add-on overlays, and ensure core functionalities like screen reader compatibility, keyboard navigation, consistent page structure, and compliant contrast ratios are default features, not future promises. Incorporate these expectations into future contract renewals.
The Existing Access Gap
While legal risks and compliance deadlines dominate discussions on accessibility, the issue extends beyond litigation. Inaccessible systems actively deny students with disabilities the services their peers readily access. Currently, these students face challenges with registration, financial aid, and basic campus navigation as they await institutional action.
Smaller institutions often cite limited resources as a reason to delay this work. However, limited resources are the strongest argument for early action. Lean teams cannot manage crisis-mode remediation across multiple platforms while maintaining daily operations.
Many institutions will benefit from engaging experienced accessibility partners to assess risks, prioritize mitigations, and guide procurement decisions. External expertise provides the clarity and dynamism needed, especially for teams balancing compliance with ongoing operational needs. Success in 2027 will belong to institutions that prioritize accessibility today.
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About the author
Shana Holman is Director of Strategic Engagement and Alliances at Pathify.
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