The ADA Title II Website Compliance Checklist Every College and University Needs Right Now

Written By Michelle Harris

The deadline is real, it is approaching, and most institutions are further behind than they realize. Public colleges and universities are now operating under a federal mandate to make their websites and digital content accessible to people with disabilities — and the clock is running.

If your institution has not yet started a formal accessibility program, this checklist is your starting point. If you have started, use it to identify the gaps your team may have missed.

What the Law Actually Requires

In April 2024, the Department of Justice published a final rule under Title II of the Americans with Disabilities Act requiring state and local government entities — including all public colleges and universities — to bring their websites and mobile applications into conformance with WCAG 2.1 Level AA.

In April 2026, the DOJ extended the compliance deadlines by one year. The current deadlines are:

  • April 26, 2027 — Public institutions serving populations of 50,000 or more. This covers nearly all four-year public colleges and universities.

  • April 26, 2028 — Smaller public entities and special district governments serving populations under 50,000.

The extension does not change what is required. It only changes when it is due. Institutions that wait until early 2027 to begin will not have enough time to complete the work. The institutions that are in the strongest position right now are the ones that started 12 to 18 months ago.

A note for private institutions: Title II applies to public entities only. Private colleges and universities are covered under ADA Title III as places of public accommodation. There is no federal deadline for private institutions, but litigation risk is significant and growing. Courts use WCAG 2.1 AA as the standard for Title III claims, so the checklist below applies to you as well.

The Compliance Checklist

Work through each category below. If you cannot answer yes confidently, that area needs attention before your compliance deadline.

1. Website and Web Content

  • All pages on your primary institutional website have been audited against WCAG 2.1 Level AA

  • All meaningful images have descriptive alt text

  • All videos have accurate captions (not auto-generated captions alone)

  • All videos with meaningful audio have transcripts

  • All forms are properly labeled and can be completed using a keyboard

  • Color contrast on all text meets the WCAG minimum ratio of 4.5:1 for normal text and 3:1 for large text

  • Page heading structure is logical and sequential (no skipped heading levels)

  • All pages have a single, descriptive H1

  • Navigation can be completed using a keyboard alone

  • Focus indicators are visible when tabbing through the page

  • Error messages in forms are descriptive and tell users how to correct the problem

  • Pages have skip navigation links so screen reader users can bypass repeated content

  • No content flashes more than three times per second

  • Page language is defined in the HTML

2. Documents and PDFs

  • All PDFs linked from your website are tagged and readable by screen readers

  • Scanned PDFs have been OCR-processed and tagged — scanned images of text are not accessible

  • PDF forms can be completed digitally, not just printed and filled by hand

  • Word documents and PowerPoint files posted to your site meet accessibility standards

  • A process exists for reviewing new documents before they are posted

3. Course and Learning Management Systems

  • Your LMS (Canvas, Blackboard, Moodle, etc.) has been evaluated for accessibility

  • Course materials posted by faculty have been reviewed for accessibility

  • Third-party tools embedded in courses (simulations, publishers, video platforms) have been evaluated with Voluntary Product Accessibility Templates (VPATs)

  • Faculty have received training on creating accessible course content

  • A process exists for students to request accessible alternatives when a course tool is not fully accessible

4. Mobile Applications

  • All mobile apps provided or required by your institution have been audited for accessibility

  • Apps work with VoiceOver (iOS) and TalkBack (Android)

  • All interactive elements in apps are reachable and operable without touch gestures alone

5. Third-Party Tools and Vendor Contracts

  • All third-party platforms your institution uses have been evaluated for WCAG 2.1 AA conformance

  • VPAT documentation has been requested and reviewed for all major vendors

  • New vendor contracts include accessibility requirements and conformance expectations

  • Vendors with known accessibility gaps have documented remediation timelines

  • An equally effective alternative is available for any tool that cannot meet accessibility requirements

6. Governance and Policy

  • Your institution has a published digital accessibility policy referencing WCAG 2.1 AA

  • A designated web accessibility coordinator or office has been identified

  • Roles and responsibilities for accessibility have been defined across IT, communications, academic affairs, and procurement

  • An accessibility committee or task force has been established with budget authority

  • A documented remediation plan exists with prioritized fixes tied to the compliance deadline

  • A process exists for handling accessibility complaints and accommodation requests related to digital content

7. Content Creation and Training

  • Communications and marketing staff have received training on creating accessible web content

  • Faculty have received guidance on accessible course materials

  • Procurement staff understand how to evaluate accessibility in vendor tools

  • Web editors across departments have been trained on your CMS accessibility requirements

  • Accessibility standards are included in your editorial and brand guidelines

8. Monitoring and Ongoing Compliance

  • A recurring audit schedule has been established for your primary website

  • A process exists for reviewing new content before it goes live

  • Automated scanning tools are in place for continuous monitoring

  • Manual testing is conducted periodically, since automated tools identify only 30 to 40 percent of real accessibility issues

  • Progress is being documented so your institution can demonstrate a good faith compliance effort

Where Most Institutions Fall Short

After working with colleges and universities on accessibility, a few areas come up consistently as the most common gaps:

PDFs. Institutions often have thousands of documents linked from their websites, many of them scanned images that a screen reader cannot parse at all. A financial aid document, a housing application, or a student handbook that is not accessible is not just a compliance problem — it is a barrier to a core institutional service.

Decentralized content. Large institutions have dozens of departments, colleges, and offices publishing content independently. A central web team may have the homepage in good shape while departmental sites, faculty pages, and athletic microsites have never been reviewed.

Third-party tools. The platforms your institution did not build are still your institution's responsibility under Title II. If a student cannot use your LMS or a required simulation tool because it is not accessible, the fact that a vendor built it does not limit your liability.

Course materials. A compliant website and a non-compliant course are still a compliance problem. Faculty-posted content including syllabi, lecture slides, and readings must meet the same standard as your public website.

The Most Defensible Position Right Now

Even if your institution cannot achieve full compliance before the deadline — and many cannot, given the volume of content involved — the most defensible position under the law is a documented program. That means a current audit with findings on record, a prioritized remediation plan tied to the deadline, and a monitoring cadence that demonstrates ongoing good faith effort.

Waiting until 2027 to begin is not a strategy. The institutions that are in the strongest legal and operational position are the ones building that documentation now.

Ready to Know Where Your Institution Stands?

Shine Media Studio works with colleges, universities, and K-12 schools on website accessibility audits, remediation consulting, and staff training. We deliver findings in plain language your communications team can act on — not a technical report that sits in someone's inbox.

If your institution does not yet have a current audit on record, that is the right place to start. We offer a free homepage scan for institutions that want an initial picture before committing to a full engagement.

Schedule a discovery call to talk through your situation, or request a free homepage scan as a first step.

This post reflects publicly available information about ADA Title II requirements as of June 2026, including the DOJ's April 2026 interim final rule extending compliance deadlines. It is provided for informational purposes only and does not constitute legal advice. Institutions with specific compliance questions should consult qualified legal counsel.

Michelle Harris
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