How does my organization comply with Updated Title II ADA Requirements?

The DOJ published an Interim Final Rule to extend by one year the compliance deadlines for the ADA Title II web content and mobile app rule. Large entities must now comply by April 26, 2027 (the previous implementation deadline was April 24, 2026). Small entities must comply by April 26, 2028.

In April 2024, the United States Department of Justice (DOJ) issued a final rule requiring state and local governmental entities — including early childhood, elementary, secondary, and postsecondary institutions — to ensure web- or mobile app-based digital learning resources are appropriate for and usable by students with disabilities. This final rule details the technical requirements (WCAG 2.1 Level AA) these materials must conform to, and set an implementation period based on population size. In April 2026, the DOJ delayed the compliance requirements to 2027 and 2028 per above. 

What does accessibility compliance mean for schools?  

The addition of this technical specification to Title II of the Americans with Disabilities Act (ADA) builds on long-standing accessibility assumptions embedded within civil rights, special education, and copyright law. These statutes are designed to guarantee students with disabilities can acquire the same information, participate in the same activities, and enjoy the same opportunities as other students. It also requires schools to ensure students with disabilities can access web-based and mobile app-delivered information with substantially equivalent ease of use as students without disabilities. Hence, POUR: perceivable, operable, understandable and robust, the four principles of WCAG that define accessible experiences. 

What materials are covered in the Title II Guidance? 

These regulations cover any web or app-based resources that could impact student opportunity. For curriculum materials, this includes all web-based content management (CMS) or delivery systems, all commercial and open educational or teacher-developed resources that may be delivered online or via an app; and all online assessments.  Also included are: any school/parent communication systems and resources, course registration and online grading utilities, as well as any mobile apps that offer access to the same instructional or informational resources. 

Are there exceptions for Title II Compliance? 

Yes. There are five specific categories of web- or app-based materials that, under certain circumstances, need not conform to WCAG 2.1 Level AA accessibility. These include: 

• Archived web content (Example: school board meeting minutes from a meeting that took place in 2020 and that are kept only for historical purposes).
• Older electronic documents (Example: A flyer for a Veteran’s Day ceremony that took place in 2021).
• Preexisting social media posts (Example: a school district’s posts to what was then known as Twitter made in 2024).
• Content posted by third parties that is not covered by a contractual, licensing or other arrangement with the public entity (Example: an individual’s posts to a discussion board would be covered by the exception, but not the discussion board platform procured by the covered entity under a contract).
• Individualized password-protected documents (Example: a transcript intended for an individual student who needs to log in with their credentials to download it).

However, despite these exceptions, material in any of these categories is required to be provided in an accessible format if updated after the rule goes into effect or upon request if it is required to meet “effective communication” under the ADA. 

Where to begin with Title II Compliance? 

Nearly every preK-postsecondary school in this country has significant investments in both informational and instructional technologies that fall within the new accessibility regulations. In some of these settings, protocols and procedures for ensuring accessible materials and practices are already in place. In others, the legal mandates present new challenges. In either situation, a proactive strategy that addresses both the remediation of existing resources and securing new ones that are certified accessible is far more economical and accurate than attempting to retrofit digital materials on an ad hoc basis.  

A common misconception is that accessibility is a “tech problem” for the IT department to solve, but true conformance requires a cross-functional team. While a leadership-level point person (such as a CIO or ADA Coordinator) must steer the ship, the responsibility needs to be shared across:

• Curriculum and Instruction: Ensuring digital lesson plans are readable by screen readers and meet other accessibility requirements.
• Procurement: Vetting third-party software and tools for accessibility before purchase.
• Special and General Education: Aligning classroom tools with student needs.
• Families and Community: Providing feedback on the user experience.

The Five-Step Plan for Conformance

Achieving WCAG 2.1 Level AA compliance might seem overwhelming, but it doesn’t have to be with a five-step approach to make the process manageable:

1. The Audit: Conduct a comprehensive review of all technology properties to understand the current “state of the union” and the scope of work required.
2. The Roadmap: Create a clear timeline to bridge identified gaps. Focus on “high-leverage” items—mission-critical systems like enrollment portals and high-traffic pages identified through web analytics.
3. Procurement Reform: Update Request for Proposals (RFPs) to include strict accessibility requirements. This shares the burden of compliance with vendors.
4. Staff Training: Build internal capacity. When teachers and staff know how to create accessible content from the start, you stop the “leaky bucket” of inaccessible materials.
5. Documentation and Public Statement: Document every action taken. A public accessibility statement on the district website communicates transparency and progress to the community.

How can CAST and its partners help ?

CAST has extensive and publicly available resources for both EdTech creators and consumers. CAST’s expertise represents more than 30 years of innovation in accessible curriculum design. From the 1995 creation of Bobby, the first WCAG-aligned web accessibility checker, accessibility has served as the foundation of CAST’s UDL framework.

To build capacity for meeting the updated rule’s requirements, CAST provides a range of online courses and webinars , and it created CAST Figuration (a free technical framework for building interactive websites that are accessible across devices). In addition to its array of openly available resources, CAST personnel are available to consult, support and help develop inclusive educational policies, practices, and materials that conform to the legal mandates.