Webmasters should start now to comply with new federal Title II accessibility requirements

Barb Iannucci is on a mission: Inform the University of Utah community, particularly website owners and editors, about updates to Title II of the Americans with Disabilities Act (ADA) that will significantly affect those who create, maintain, and use university websites and apps.

In April 2024, the Federal Register published the final rule that updates Title II, which now requires public institutions (entities funded by state or local governments) to “ensure that web content and mobile applications (apps) are accessible to people with disabilities.”

“The Department of Justice (DOJ) recognized that a lot of public entities have websites that present barriers for people with disabilities, and so the updates to the rule are designed to close those gaps — to clarify and strengthen digital accessibility standards — and ensure equal access for all users,” said Iannucci, director for the Web Support & Usability (WSU) team in UIT’s University Support Services (USS).

The University of Utah has until April 24, 2026, to comply with the rule.

“I don’t want anyone to think that they have until the deadline to start looking at this or to resolve these issues, because even before the deadline, we could deal with lawsuits, complaints, fines, etc.,” Iannucci said during the September 19, 2024, presented the updates to the U’s IT governance groups and Modern Campus CMS web editors during her team’s annual fall summit.

Some key requirements:

• Alternative text for images and graphics
• Captions or descriptions for audio and video content
• A minimum color contrast between text and background/images
• Complete operability from a keyboard

All public-facing websites and many internal systems — including the university’s learning management systems, various student and staff portals, and enterprise software products that require login — must comply with the new accessibility standards, Iannucci said.

“The scope is rather large, especially for a university as big as ours, where we have a ton of content. It seems rather daunting, but we’re all in this together and we will get through it,” she said.

Some exceptions:

• Archived web content (not for active use)
• Preexisting documents
• Third-party content/user-generated content provided without university involvement (e.g., message boards, comment sections)
• Password-protected or highly individualized documents not meant for public use that (e.g., )
• Preexisting social media posts

Although preexisting documents and social media posts will be excluded, Iannucci recommended that web editors comply with the rule now. Just be mindful when using accessibility tools, such as Adobe and Microsoft’s Accessibility Checkers, WAVE browser extensions, and other mechanisms. Although they’re a helpful step in building accessible documents, sites, and systems, they are not a substitute for careful, professional accessibility assurance conducted by university staff.

While complex content is not exempt, the DOJ will accept alternate versions when it’s technically not feasible to make the content fully accessible.

“Some examples include complex diagrams, or maps that rely on visuals to communicate the content,” she said. “For example, our Campus Map is difficult to make fully accessible because it’s a visual-based application.”

She said accessibility is critical for higher education because colleges and universities serve a diverse population, many of whom have disabilities. She noted that disabilities come in many forms, including short-term and situational limitations (e.g., a broken arm or hearing issues due to a noisy crowd).

“When you design websites and mobile applications for people with disabilities it benefits everyone. So, focusing on accessibility truly improves the usability of your sites,” she said. “... We also want to provide equity in education so that students can access everything they need to be successful in their pursuit of a degree.”

 

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