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AGB Policy Alert: ADA Digital Accessibility Rule Requires Full Compliance by April 2026

By AGB August 15, 2025 AGB Alerts

This AGB Policy Alert is based on policy developments current as of the date posted. Given the evolving nature of legislative and judicial activity, content may become outdated. For the most recent updates and guidance, please refer to the latest AGB Policy Alerts available at AGB.org/Advocacy/Policy-News.

On April 24, 2024, the U.S. Department of Justice (DOJ) finalized a new rule under Title II of the Americans with Disabilities Act (ADA), imposing significant digital accessibility requirements on public entities, including public colleges and universities. This rule requires all covered institutions’ web content—including distance education courses, public-facing websites, and online resources—to comply with the Web Content Accessibility Guidelines (WCAG) 2.1 by April 24, 2026.

Key Requirements and Deadlines

  • All academic course content and institutional web materials must meet the WCAG 2.1 standards and implementation deadline of April 24, 2026.
  • Institutions are responsible for ensuring that third-party vendors’ public-facing materials also comply.
  • This marks a departure from prior “accommodation on request” standards toward comprehensive, proactive digital accessibility.

Urgent Action Required

The rule requires significant operational and financial attention, particularly for smaller colleges and universities and those with fewer resources (e.g., Minority-Serving Institutions). Large online institutions may already meet these standards, but many others will need to act quickly to assess compliance gaps and invest in expertise and infrastructure.

Key Implications for Governing Boards

AGB members should view this as a critical issue at the intersection of technology, innovation, student success, and public policy. Governing boards must:

  • Ensure strategic oversight of institutional readiness for April 2026.
  • Support investments in expertise, training, and technology to meet accessibility standards.
  • Monitor contracts and partnerships to confirm third-party vendor compliance.
  • Prioritize implementation, recognizing that accessible digital environments benefit all learners.

Strategic Recommendations for Governing Boards

  • Convene immediate briefings with presidents, IT leaders, academic affairs administrators, and legal counsel to assess institutional preparedness.
  • Review the regulations with your institution’s and/or foundation’s internal compliance office to consider impacts on enrollment and student advancement and determine the best course of action.
  • Conduct a thorough audit of all public-facing and course-related web content.
  • Engage external accessibility experts, if needed, to guide the compliance process.
  • Consider the budgetary implications as part of financial planning and risk oversight.
  • Communicate proactively with campus communities about digital accessibility as a core institutional commitment.

Critical Policy Deadline

April 24, 2026, is not far off. Institutions must act now to meet this federal directive and avoid potential penalties and reputational risk.

For additional information and a primer on institutional responsibilities, see this Level Access guide.

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