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ADA compliance for university and college websites

Public universities face a WCAG 2.1 AA date in April 2027; private ones answer to Title III and Section 504. What applies and where course sites fail.

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Pavel Charkasau

ADA compliance for a university website depends first on who runs the university. A public college is part of a state or local government, so it falls under ADA Title II and the Justice Department's 2024 web rule. That rule names WCAG 2.1 Level AA as the standard for web content and mobile apps, and after the April 2026 extension the compliance date for nearly every state university is April 26, 2027 (ADA.gov).

A private college has no dated web rule. It is still covered: Title III lists an "undergraduate, or postgraduate private school, or other place of education" as a public accommodation (42 U.S.C. § 12181(7)(J)). And almost every college, public or private, also sits under Section 504 of the Rehabilitation Act once it takes federal money.

So the working target is the same on both sides of the line: WCAG 2.1 AA on every page a student, applicant or member of the public uses, including the ones behind the campus login.

Does the ADA apply to university websites?

Yes, through one of two titles. Public institutions are Title II entities. Private institutions are Title III public accommodations under subparagraph (J) of the statute's definition, the same list that names hotels and shops. A private university therefore never has to argue about whether a website counts as a "place". The question is only which standard proves the site is accessible, and Title III has no regulation that names one. Our ADA overview explains how that gap gets filled in practice.

Section 504 runs alongside both. It bars disability discrimination in "any program or activity receiving Federal financial assistance", and the statute defines "program or activity" to include "a college, university, or other postsecondary institution, or a public system of higher education" as a whole (29 U.S.C. § 794). Federal student aid counts. The Supreme Court held in 1984 that a college receives federal financial assistance when its students pay with federal grants (Grove City College v. Bell, 465 U.S. 555), and Congress later amended Section 504 so coverage reaches the entire institution rather than only the financial aid office.

InstitutionRuleStandard namedDate
Public university or community collegeADA Title II, 2024 web ruleWCAG 2.1 AAApril 26, 2027 (state population 50,000+)
Private college or universityADA Title IIInone in regulationin force, no deadline
Any college taking federal fundsSection 504none for the webin force, no deadline

When is the Title II deadline for a public university?

For a state university it is April 26, 2027. The DOJ's interim final rule of April 20, 2026 moved the date for entities with a population of 50,000 or more from April 24, 2026 to April 26, 2027, and the date for smaller entities to April 26, 2028 (91 FR 20902). We covered that change in detail in the Title II deadline extension.

The part universities misread is how "population" is counted. It is not enrollment. ADA.gov gives the exact example: a state university with 40,000 students in a state of 6,000,000 people has a population of 6,000,000 for the rule, because "the number of students that attend the university does not determine the university's population" (ADA.gov). Every state has more than 50,000 residents, so a state university is on the 2027 date. A community college run by a small county or district may land on 2028, and checking which government it belongs to is worth ten minutes before anyone plans around the later date.

Is course content in the LMS exempt?

No, and this is the single most important line in the rule for higher education. ADA.gov states it plainly: "There is no exception for educational course content." If a school uses a learning management system, the portal and "all of the course content added to the portal or LMS" generally need to meet WCAG 2.1 AA (ADA.gov).

The final rule has five exceptions, and none of them is a course exception (ADA.gov rule summary):

  • archived web content that meets all four archive conditions
  • preexisting conventional electronic documents (PDFs, Word files, slides, spreadsheets posted before the compliance date)
  • content posted by third parties without a contractual arrangement with the school
  • individualized, password-protected documents about one person or account
  • social media posts made before the compliance date

The second exception does less than people hope. A syllabus PDF from 2019 that is still sitting in a live Canvas course is preexisting, but the moment someone revises it for spring 2027 it becomes new content. Faculty re-upload materials every term, so in practice the exception shrinks each semester.

The third exception is narrow too. A lecture-capture vendor, a proctoring tool or an e-textbook platform the university licenses is posting under a contract, so it is not "third-party content" in the rule's sense. Student posts in a discussion forum are.

What have the higher education cases actually required?

The best-known cases are about captions and public content, which tells you where reviewers look first.

The Justice Department investigated UC Berkeley's free online content from 2014, issued findings in August 2016, and filed a Title II complaint with a consent decree in November 2022, which the court approved on December 2, 2022 (DOJ). Berkeley agreed to make all future and "the vast majority of its existing online content" accessible, including BerkeleyX courses and its YouTube and podcast channels. It also agreed to designate a web accessibility coordinator, test its content and hire an independent auditor.

On the private side, the National Association of the Deaf sued Harvard and MIT in 2015 under the ADA and Section 504 over missing or inaccurate captions on public video. Harvard settled in November 2019, and the court approved the MIT settlement on July 21, 2020, which requires captions across MIT.edu, its YouTube and Vimeo channels, MITx and OpenCourseWare (DREDF).

Neither case turned on an obscure success criterion. They were about video without accurate captions, which maps to WCAG 1.2.2 Captions (Prerecorded) and 1.2.4 Captions (Live) (W3C).

Which parts of a university site usually fail?

The public marketing site is the part that gets scanned, and it is the smallest part of the problem. These are the flows I would check by hand on any campus:

  1. The single sign-on page. If the MFA code field blocks paste, it fails WCAG 2.2's 3.3.8 Accessible Authentication (Minimum) (W3C). That criterion is not in 2.1, but it is the one students hit every day.
  2. Course registration. Class search results are usually a data table, and without header cells a screen reader reads "MWF 10:00, 3, Open" with nothing to say which column is which.
  3. Lecture video. Auto-generated captions with no human edit are where the Berkeley and MIT matters started.
  4. Scanned PDFs in course shells. A photocopied chapter uploaded as an image is a picture of text, so it needs OCR and tagging before it is readable at all.
  5. Math and STEM content. An equation pasted as an image with alt="equation" gives a blind student nothing to work with.
  6. Application portals and financial aid forms, often run by a vendor on a separate subdomain that nobody included in the audit.

A homepage scan reports none of the six; that gap is the theme of why homepage scans miss risk. On a campus the homepage is admissions marketing. The service lives in the LMS and the student portal.

Should a university target WCAG 2.1 or 2.2?

Build to WCAG 2.2 AA. W3C states that content conforming to 2.2 also conforms to 2.1 (W3C), so you meet the Title II rule and pick up the criteria that land hardest on login and form flows. Stopping at 2.1 is legal under the rule and leaves the paste-blocking MFA field in place. The reasoning behind treating WCAG as the benchmark when no rule names it is in does the ADA require WCAG.

Research universities that sell software or services to federal agencies get a third request in procurement: a conformance report against Section 508, which is a separate track again.

What should a university do first?

Here is my opinion, stated once: the accessibility office cannot fix this alone, and a plan that relies on faculty "being careful" will miss 2027. Course content is created by hundreds of people every term. The fix has to sit in the systems they publish through.

A workable order:

  1. Inventory every system with a login: SSO, the LMS, registration, the student portal, admissions, financial aid, library search, lecture capture. Note who the vendor is for each.
  2. Ask each vendor for a current accessibility conformance report, and read the "Partially Supports" rows. Those gaps become your gaps the moment students use the tool.
  3. Scan the templates and the public site to size the problem. Our WCAG checklist lists the criteria in order if you want to triage by hand.
  4. Put the check where content is created. Caption review before a lecture video goes live, and an accessibility check before a course shell opens each term.
  5. Publish an accessibility statement with a working way to report barriers. It records your effort and gives students a route to ask for help; it does not certify the result.

Be honest about tooling. Deque's study of more than 2,000 audits found automated testing detected about 57% of issues by volume, while counting by success criteria gives a figure closer to 30% (Deque). Full conformance needs human review. Our scanner will find the unlabeled icon button in your registration tool and the 3:1 contrast on the course catalog. It will not tell you whether a caption says "chiral" or "tyrol". Somebody has to watch the video.

FAQ

Do private universities have to follow the ADA Title II web rule?

No. The 2024 rule covers state and local government entities, which includes public colleges. Private colleges are Title III public accommodations under 42 U.S.C. § 12181(7)(J), with no dated web regulation, and most are also covered by Section 504 through federal student aid.

What is the ADA Title II deadline for a state university?

April 26, 2027. ADA.gov explains that a state university's population for the rule is its state's population, not its enrollment, so every state university falls in the 50,000-or-more group (ADA.gov).

Is password-protected course content exempt from the Title II rule?

No. ADA.gov states that "there is no exception for educational course content," so the LMS and the course content inside it generally need to meet WCAG 2.1 AA. Only individualized documents about one specific person or account are exempt.

Are old PDFs in a course exempt?

Only while they stay unchanged. Conventional electronic documents posted before the compliance date are exempt, but a file revised and re-posted after that date is new content and must meet WCAG 2.1 AA (ADA.gov).

Can a scanner make our campus site ADA compliant?

No tool can do that alone. Automated testing catches roughly 30 to 57% of issues depending on how you count (Deque); captions, reading order and screen-reader use of the LMS need a person.

Scan your admissions pages, course catalog and registration flow to see the exact selectors that fail, then plan the work before April 2027: run a free accessibility scan.

Written by Pavel Charkasau, founder of wcagc.com. I read the Title II rule guidance and the Berkeley consent decree page end to end, so every date here traces to a published source.

Last updated: October 1, 2026

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