Public colleges nationwide will enter 2025 with a pressing mandate to make their web and mobile-app content accessible for all students.
The U.S. Department of Justice earlier this year formally added new language to Title II of the Americans With Disabilities Act that — for the first time — lays out specific technical standards for web content that public colleges and other government entities need to meet. That means colleges must remediate existing digital content, which includes course materials, to meet those standards, and will also need to apply the standards to any new content they create or use.
And many have just under a year and a half to do it.
Private colleges that receive funding from the U.S. Department of Health and Human Services should also pay attention, accessibility advocates said, because of separate regulatory changes that recently imposed the same standards under a similar deadline.
This update is long overdue, advocates and web-accessibility experts say. Some 21 percent of higher-ed students report having a disability, including visual, hearing, cognitive, and manual-dexterity impairments. Every day, many come across images and videos they can’t see, documents that their screen readers can’t interpret, audio they can’t hear, and sites that they can’t navigate effectively without a computer mouse.
These students “have never really had an equitable experience in the digital space,” said Jamie Axelrod, former president of the Association on Higher Education and Disability. “This is crucial.”
Still, the coming months will test colleges — especially those that haven’t historically made web accessibility a priority. Many have a digital footprint made up of hundreds, even thousands, of websites, and potentially millions of web pages. Their learning-management systems are chock full of PDFs and other frequently inaccessible file formats. They’ve also increasingly relied on content and software from third-party providers that must also meet the new standards.
And while institutions have been required to accommodate students with disabilities for decades, having defined standards will force a substantial culture shift: a move from being reactive to being proactive. Instead of primarily responding to individual students’ accommodation requests, colleges will need to make content accessible from the outset.
Judith Risch, the Title IX and equity-access-services special adviser at Grand River Solutions, a higher-ed consulting firm, didn’t mince words about the work ahead.
The sector as a whole is “not in good shape,” she said. “This is going to be painful.”
The deadline to comply is April 2026 or April 2027, depending on the population of the state or local jurisdiction where a college resides. A community college, for example, would base its deadline on the population of the local community or county; universities would base theirs on the state population. Most colleges will fall under the April 2026 deadline.
Between now and then, compliance will require investment in testing, infrastructure, and training. The DOJ’s final rule estimated a cost of more than $7 billion to the higher-ed sector for testing and remediation costs alone. (Sources note that these projections routinely underestimate the actual cost.)
While some are questioning whether the new rules will be enforced under the incoming Trump administration, advocates point out that colleges risk other costs — time-consuming and expensive legal complaints — if they don’t make meaningful progress. Past settlements in web-accessibility cases have cost colleges hundreds of thousands, even millions, of dollars.
Colleges can’t be “wringing their hands” on this, Risch said. “Doing nothing isn’t an option.”
Making websites and other digital content accessible is not a new concept, to be sure.
Since 1996 — the early days of the internet — the DOJ has repeatedly maintained that “services, programs, and activities” that public entities offer online are covered under the Americans With Disabilities Act. But the law never included a technical definition of what “accessible” meant.
Now, there is one: The Web Content Accessibility Guidelines (WCAG) 2.1, Level AA.
These standards, developed by the World Wide Web Consortium, are internationally recognized, and should be familiar to colleges, accessibility experts said. The 2.1 version came out years ago, in 2018, and is a common remediation requirement for colleges in ADA-related legal settlements.
Nonetheless, that hasn’t historically resulted in proactive implementation of these standards at colleges. The annual “Million” project from WebAIM, a nonprofit based at Utah State University, found an average of 26 errors on home pages with “edu” domains in 2024 through automated testing. Pope Tech, an IT services and consulting company, conducted its own WebAIM-inspired automated analysis, but extended the scope to up to 20 university-affiliated pages for more than 3,600 colleges. That analysis found an average of 16 errors per page.
So what are the kinds of errors a college might need to fix?
According to the technical standards, an error could be a video that does not include audio descriptions, which allow blind students to visualize what’s happening; or low-color contrast between text and background colors that makes it difficult for someone with low vision to decipher words on a page. It could be an audio file, like a podcast episode, that does not include captions and/or a transcript, for deaf or hard-of-hearing students. Or it could be or a lack of keyboard shortcuts for mouse commands — like using arrow keys to move up, down, left, or right — which help people with limited manual dexterity navigate a site.
The amount of work to be done does vary widely across colleges.
States have developed their own patchwork of legislation on digital accessibility. Many already cite WCAG as the state standard (in most cases, the older 2.0 version, which, among other things, doesn’t address mobile applications). A number of colleges have also had to improve web accessibility through audits, new hires, and training as part of legal settlements.
But web-accessibility experts said there are several shared challenges when it comes to remediation. And they have to do with higher ed’s propensity for content generation and knowledge-sharing, its decentralized nature, and its increasing reliance on third-party partners and tools.
For one, a college’s digital reach — especially if it’s a larger state institution with a growing catalog of online courses and programs — can include thousands of university-affiliated websites and a litany of site owners. Different administrative teams may be in charge of running different sites. Faculty members and researchers may create their own sites for courses and academic projects, often without clear directives or savvy about how to make those sites fully accessible.
The result can be a “wild, wild west” environment, said Mark Pope, a web-accessibility specialist at Pope Tech.
At one point last year, Indiana University, for example, reported having 2,186 university-affiliated websites across its campuses, with 964 “site stewards.”
Such decentralization means that it’s also tricky to discern what actually falls under a university’s purview. The University of California at Berkeley, for example, thought it “owned” 600 or 700 sites, but determined with a third-party testing tool that the number is more than 1,600, said Lucy Greco, a web-accessibility evangelist at the institution.
A number of colleges The Chronicle spoke with still don’t know for sure how many websites they have and are actively in the discovery process.
(Past legal settlements offer a sense of how the U.S. Department of Education’s Office for Civil Rights defines university-owned web pages. For example: “URLs on the College’s domain,” and “all URLs outside of the College’s domain” that are “used by the College to communicate or facilitate its programs, services, and activities to members of the public.”)
Another reality is that higher ed loves documents — especially PDFs, a much-maligned format among accessibility advocates. PDFs are, for example, often missing style “tags,” which define elements like headings, paragraphs, and tables, making them effectively unintelligible to assistive technologies like screen readers.
Indeed, Max Bronsema, director of web-communication technologies at Western Washington University, said he considers remediating documents like PDFs “the largest challenge” in complying with the new regulations.
Fixing PDFs is a manual, “brutal” process, Greco said. And as a blind person, she added that it’s a real “psychological burden” to deal with inaccessible documents and web interfaces on a day-to-day basis. She’s a proponent for alternatives to PDFs, like HTML files.
Colleges aren’t just dealing with content their employees create, though. They will be accountable, too, for the accessibility of digital content and apps they license, contract, or use from vendors. And that reality is sounding alarms: The annual EDUCAUSE conference for IT professionals in October featured a handful of sessions on talking with vendors and making sure products are accessible before adopting them.
Institutions “will literally be unable to comply with those regulatory requirements without support and buy-in from the broader vendor community,” said Kyle Shachmut, co-lead of Educause’s IT-accessibility community group and director of digital accessibility at Harvard University.
Are vendors bought in? Anecdotally speaking, it appears to be a mixed bag.
To date, “there’s been a lot of, ‘Yes, we hear you’ from vendors, but then not much action,” Bronsema said. Chris Law, executive director of Standard Accessibility Reporting, Inc., a nonprofit that’s developing an accessibility scoring system for vendor products, said he’s heard from colleagues that some companies have pumped the brakes post-election.
But for Sue Cullen, the director of universal design and digital accessibility at Tech for All, there’s reason to be optimistic. The consultancy, which works with higher-ed vendors, has seen an increase in clients requesting annual audits and training support. (Cullen said she’s hearing most from vendors that provide classroom-based services, such as learning-management systems and courseware.)
Some of these companies have a sense of moral obligation, she said. But there’s also a clear strategy. “They’re starting to recognize it’s a marketing thing,” she said. That “they’re going to increase their buyership if they adhere to this.”
On top of remediation, accessibility staffers at colleges underscored another hurdle: Putting infrastructure in place — personnel, protocols, training — so that content will meet the technical standards right out of the gate.
Brittni Wendling, a digital-accessibility systems analyst at Iowa State University, sees this shift as especially “daunting.” Right now, the work falls to four full-time employees on a campus of 3,500 faculty and staff members and more than 30,000 students.
The team has requested funds to hire additional staff next fiscal year and help roll out required basic training on digital accessibility for all faculty, staff, and students, among other things, said Cyndi Wiley, digital-accessibility lead at the university. They also intend to offer more specialized training to employees like instructional designers and web developers.
“Technical knowledge, like remediating a PDF — I don’t expect a faculty member to do that,” Wiley said. The message the team hopes to send is: “You don’t have to do everything differently, you just need to make some alterations.”
Sources said they know of some colleges that, overwhelmed by the work and investments ahead, are considering waiting to see how likely it is that the rule will be enforced, especially under a second Trump presidency.
Disability-rights advocates acknowledge that Trump’s election promises to usher in a wave of government deregulation. Still, advocates say colleges should at least try to make progress toward compliance.
Undoing the regulations would require another rule-making process (and, as a former DOJ attorney postulated in a recent blog post, disability-rights laws will likely “be low on the priority list of laws for getting overturned”). Champions of accessibility like Greco, at UC-Berkeley, also pointed out that it was a Republican administration, under George H.W. Bush, that first signed the Americans With Disabilities Act into law, in 1990.
Even if government enforcement is wanting — politics aside, the DOJ did acknowledge in its final rule that it “has limited enforcement resources” — experts say the biggest risk to colleges once the deadline passes is a surge in private complaints and litigation from students and disability-rights organizations.
“I guarantee we’re going to see lots of complaints filed” with the Office for Civil Rights once the deadline passes, said Axelrod, the former president of AHEAD, who’s now director of disability resources at Northern Arizona University. (The OCR handles Title II enforcement on behalf of the DOJ.)
When that happens, colleges lose something they prize, said Risch at Grand River Solutions: control. “You’re losing control of the time frame, and it’s going to be much more expensive,” she said. In that way, working toward compliance is “risk management.”
One advocacy organization watching this space closely is the National Association of the Deaf.
“Should enforcement be challenged or delayed, we will leverage our advocacy network and, if necessary, pursue enforcement strategies to ensure that the rights of Deaf and hard-of-hearing students are upheld,” the group’s interim CEO, Bobbie Beth Scoggins, wrote in an email.
Mike Harding, the digital-accessibility coordinator at California State University at Fresno, believes many colleges want to do right by students with disabilities.
In conversations, “I’m not getting the cynicism of, ‘Why should we do that?’” he said. Rather, people he talks to are wrestling with what it’s going to take to do it.
Accessibility experts The Chronicle spoke with offered some tips for institutions that feel they’re rushing to play catch up.
Risch said that, to start, colleges should identify priority areas. They should look at their data analytics: What are the most heavily-trafficked sites and the ones that are likely to draw the most diverse group of users? (Think admissions, financial aid, etc.) Those could be made compliant first. Conversely, colleges could consider starting to archive the lowest-trafficked sites and pages — a webpage hosting a conference agenda from 2005, for example.
The same goes for dealing with vendors and reviewing tools. Consider how many users a certain product or software has, the types of users, and whether use is required for essential services (like a course).
Rob Carr, the strategic accessibility coordinator at WebAIM, added that creating guidelines and policies could prevent inconsistent approaches to compliance across an institution. A number of accessibility policies already exist that define access, scope, and who’s responsible, for example.
Axelrod noted that past settlement letters (available for filtering here) are a “great resource,” too, because they effectively outline the types of policies, procedures, and training the government looks for. They “give us a framework,” he said.
Greco, at UC-Berkeley, underscored that the goal should be progress, not perfection.
“Accessibility is a moving target,” she said. What matters is “to work on accessibility, and to think about accessibility from the start.”
