Colleges and universities in the United States are facing major shifts in accessibility requirements as new federal rules make WCAG 2.1 Level AA the enforceable standard for public institutions’ digital content. In April 2024, the Department of Justice finalized the ADA Title II Web and Mobile Accessibility Rule, which requires public colleges and universities to ensure that all digital experiences—including websites, LMS course materials, PDFs, videos, mobile apps, administrative portals, and even third-party tools—meet WCAG 2.1 AA by April 2026 (or 2027 for some smaller entities). This marks a significant move from reactive, accommodation-based practices toward a proactive mandate for universal design across teaching, learning, and administrative systems.
Although private colleges fall under ADA Title III, which does not currently mandate a technical standard, courts and settlements continue to treat WCAG AA as the de facto benchmark—meaning compliance pressure is increasing across the sector. State-level laws in places like Colorado and California add additional obligations, especially around procurement and ongoing monitoring of accessible technology. Beyond formal compliance, institutions should anticipate wider operational implications: increased financial investment for captioning and remediation workflows, new contract language and procurement review processes for digital tools, large-scale remediation of legacy content, and a greater need for faculty development and change management. The new rule also increases legal exposure, as federal agencies and advocacy groups are expected to scrutinize accessibility practices more closely than ever. At the same time, accessibility-aligned design has the potential to improve course quality, streamline digital ecosystems, and support all learners—not just those with documented disabilities. Collectively, these changes signal a new era of accountability in which accessibility must be embedded at the point of design, procurement, and delivery—not only addressed when a student requests an accommodation.
To better understand how prepared institutions feel heading into this shifting regulatory landscape, our November Snap Survey asked the OLC community about the status of digital accessibility efforts at their organizations (n=13). While the sample is exploratory, the responses offer insight into the sector’s current readiness and emerging pain points.
Does your institution or organization have a formal policy or framework for digital accessibility compliance (e.g., WCAG 2.1 or Section 508)?
The overwhelming majority of respondents (54%) indicated their institution had a fully implemented, formal policy or framework for digital accessibility compliance. Those whose institutions had an informal or partial policy, had no policy, or were unsure were all tied at 15%. This suggests that many institutions have taken important structural steps toward compliance; however, it may also indicate that some of this work is happening behind the scenes in IT or MarComm units and has not yet been broadly communicated across campus. Institutions without formal policies may be smaller or resource-constrained, or may be waiting for clearer internal guidance before moving forward.
Who holds primary responsibility for ensuring accessibility compliance within your organization?
For the majority (54%), accessibility compliance is a shared responsibility across units—reflecting the growing understanding that accessibility cannot sit within a single office and requires distributed ownership. For others, primary responsibility lies with Central IT/web services (15%) or instructional design/eLearning teams (15%). A small number of respondents (8%) reported that no team or unit has taken on this responsibility or that it falls directly to content creators. These patterns suggest that institutional structure and policy maturity significantly shape how responsibility is allocated. As the ADA Title II deadlines approach, institutions without clear ownership models may face challenges coordinating policy, training, procurement, and quality assurance.
How often are employees, faculty, or staff offered training or resources on accessible course design or digital content creation?
Responses varied widely: 38% reported regular, at least annual training; 31% reported rare opportunities; and 15% indicated occasional, ad hoc sessions. A small percentage reported no training or were unsure (8% each). This variation implies that many institutions are still building internal capacity for accessibility training, which may depend on the availability of expertise, the maturity of accessibility initiatives, or the visibility of communication channels. Inconsistent training presents a risk as the new federal rule will require scalable, repeatable professional development models—not only one-off workshops.
Which types of accessibility support does your institution currently provide?
The most prevalent forms of support included accessibility checkers integrated into campus tools (77%); captioning and transcript services (69%); assistive technology support (69%); consultation or help desk assistance (69%); and case-by-case accommodation support (69%). Document remediation (46%) and systematic accessibility audits (23%) were less common. Given the rise of tools like YuJa, Ally, and built-in caption editors, these results reflect the sector’s reliance on technology to reduce technical barriers for content creators. However, the lower prevalence of remediation services and comprehensive audits signals potential vulnerabilities—especially for legacy content, multimedia-heavy programs, and compliance verification under the new Title II rule.
How confident are you that your institution meets accessibility standards across its online learning environments?
Most respondents (62%) reported being “somewhat confident,” with smaller percentages indicating extreme or high confidence (8% each). Nearly one-quarter (23%) were “not very confident.” This distribution aligns with earlier findings: many institutions have foundational elements in place but recognize gaps in training, legacy content, procurement processes, and quality assurance. As federal enforcement intensifies, this lack of strong institutional confidence may signal a need for more coordinated, transparent, and well-resourced campus strategies.
Taken together, these findings suggest that while many institutions have established policies, tools, and shared responsibility models, readiness for the 2026/2027 ADA Title II requirements remains uneven. The new federal rule will require institutions to go beyond policy creation toward comprehensive, campus-wide implementation—strengthening procurement practices, expanding training and remediation capacity, clarifying ownership structures, and addressing extensive archives of legacy content. Although compliance will require investment and cultural change, it also presents an opportunity to elevate the quality, usability, and inclusiveness of digital learning environments. Institutions that begin aligning people, processes, technology, and pedagogy now will be best positioned not only to meet the legal expectations ahead but to create more equitable educational experiences for all learners.
For more information on the topic, you can review OLC Insights article titled New Federal Digital Accessibility Requirements: What Higher Ed Needs to Know and Do Now.
As senior researcher at OLC, Carrie designs, conducts and manages the portfolio of research projects that align with the mission, vision, and goals of the Online Learning Consortium. She brings with her over 15 years of experience as an online educator and instructional designer with a passion for research. She has peer-reviewed publications covering a variety of topics such as open educational resources, online course best practices, and game-based learning. In addition to a strong background in higher education teaching and instructional design, Carrie brings with her extensive experience in customer service and small business management. She holds a PhD in Educational Technology from Arizona State University, an MS in French from Minnesota State University, and BA in French from Arizona State University.
