What Higher Ed Needs to Know (and Do) About the DOJ’s New Title II Web Accessibility Rule

Accessibility is now a mandate, not a “nice to have”

Digital experiences have become essential public infrastructure. For colleges and universities, that means every student, parent, faculty member, and stakeholder must be able to access institutional websites and apps without barriers. With the Department of Justice’s (DOJ) new rule under Title II of the Americans with Disabilities Act (ADA), public institutions are now legally required to ensure their digital experiences are accessible.

Accessibility in higher education spans physical environments, signage, communication, and more. But this article focuses specifically on digital accessibility — websites, mobile apps, and online content. The institutions that thrive under this rule won’t treat accessibility as a checkbox project. They’ll embrace it as a digital operating model, one that improves user experience, compliance posture, and long-term digital performance.

A quick breakdown of 2024 Title II requirements

The DOJ’s final rule applies to state and local government entities, including public colleges and universities. It requires that all digital programs, services, and activities (whether on the web or in mobile apps) be accessible to individuals with disabilities.

Key requirements include:

• Use of WCAG 2.1 Level AA as the technical standard
• Accessibility across websites, web apps, documents, videos, and mobile applications
• Compliance deadlines that vary by institution size, with the first deadline set for April 24, 2026

Common barriers to digital accessibility compliance

Most institutions aren’t starting from scratch, but recurring obstacles within their digital ecosystems continue to put compliance at risk. These include:

• Decentralized web teams
• Fragmented domains
• Legacy PDFs
• Inaccessible videos
• Third-party tools

Without strong governance, accessibility debt builds every day. Worse, content continues to be created in non-compliant ways. Waiting to address it means digging a deeper hole. Even the best CMS tools can’t solve this without clear processes and accountability.

Laying the foundation for sustainable accessibility

Digital accessibility isn’t something that can be addressed once and set aside. It requires institutional commitment, cross-functional coordination, and repeatable processes. The good news is that building a sustainable program is possible with the right structure in place. Here’s where to begin:

Establish ownership

• Assign a digital accessibility lead or working group
• Secure sponsorship from institutional leadership
• Define WCAG 2.1 Level AA as your north star

Define processes

• Create a regular cadence for training, monitoring, and review
• Build accessibility considerations into content workflows and publishing guidelines

Inventory and prioritize

• Document all digital properties: websites, subsites, mobile apps, PDFs, and media libraries
• Triage by impact: prioritize content critical to student success (apply, register, pay, request support)

Proving progress: Documentation that defends and builds trust

Demonstrating good-faith efforts is critical not only for legal defensibility but also for building institutional credibility. While the primary goals are usability and inclusion, these same steps are also your best protection against ADA-related lawsuits. When schools document progress and act transparently, they strengthen their position should legal challenges arise — showing a clear commitment to meeting federal accessibility standards.

Institutions should be prepared to show:

• A public-facing accessibility statement and internal accessibility policy
• Logs of audits, training sessions, and issue backlogs
• Records of vendor accessibility reviews and remediation sprints
• A feedback loop for reporting and responding to barriers

Prioritization strategies: Where to start when everything feels urgent

Not all content is equally critical. Here’s a practical way to tackle accessibility without getting overwhelmed:

1. Critical student pathways: admissions, registration, payment, accommodation requests, portals
2. High-traffic content: landing pages, program information, financial aid, academic policies
3. Transactional experiences: forms, payment flows, scheduling tools
4. Document-heavy content: course catalogs, student handbooks, policy libraries
5. Everything else: governed backlog with regular cycles of review and remediation

Accessibility tools, tactics, and must-haves

A well-rounded accessibility program includes both the right tools and a focus on the fundamentals of WCAG 2.1 AA. Institutions should prioritize the following.

Tools and workflows:

• Automated scanners for global and template-level checks
• Manual spot checks for screen reader compatibility and form validation
• CMS guardrails: accessible templates, checklists, and heading/link standards
• Ticketing systems to track issues, exceptions, and fixes
• Vendor procurement workflows with accessibility reviews built in

WCAG 2.1 AA essentials:

• Keyboard navigation and visible focus states
• Adequate color contrast
• Logical heading structure
• Descriptive link text and meaningful alt text
• Forms with clear labels and instructions
• Captions and transcripts for all media content

How Collegis can help

While schools are ultimately responsible for their own compliance, Collegis can support institutions in developing accessibility strategies that scale. We help our partners:

• Build prioritized remediation roadmaps
• Integrate accessibility into digital governance frameworks
• Implement monitoring workflows and training programs
• Evaluate tools and vendors with accessibility in mind

Digital accessibility also supports stronger SEO (search engine optimization) and AEO (answer engine optimization). In fact, just like optimizing for search or AI, making your content accessible helps machines consume and interpret it — whether it’s assistive technology, search engine crawlers, or generative AI systems.

Take the first step toward an inclusive digital strategy

The best time to act on digital accessibility was yesterday. The second-best time is now. Start with an inventory and a review of top student pathways. Establish clear ownership and repeatable processes.

Remember: Accessibility is more than compliance — it’s a commitment to usability, inclusion, and digital readiness. When institutions invest in accessibility, they improve user experience, strengthen their SEO and AI visibility, and align with their mission to serve all learners.

Collegis is here to help you take the next step. Let’s build a more accessible, inclusive digital future together.