At the start of 2025, we published Resolutions for a Safer, More Accessible University Website. Just a year ago, accessibility was treated as a best practice: important, but often treated as a gradual improvement rather than an operational priority. 

Twelve months later, the situation has shifted significantly. 

Digital accessibility is now a defined regulatory requirement, with firm compliance deadlines approaching. Educational institutions must rethink how accessibility fits into their broader digital strategy. Not as a final checkpoint, but as a foundational component of how digital experiences are planned, built, and maintained. 

For many colleges and universities, these deadlines affect years of accumulated content, multiple platforms, and digital systems that students rely on every day. A single student task, like applying for financial aid or registering for classes, often spans several portals, documents, and vendors. If even one step in that journey is inaccessible, the entire experience can break down.

ADA Title II, WCAG 2.1 AA, and What Has Changed Since 2025

Digital accessibility is now clearly defined by law.

In April 2024, the US Department of Justice finalized a new rule under Title II of the Americans with Disabilities Act (ADA). For the first time, federal regulation clearly requires websites and mobile apps operated by public institutions must meet specific accessibility standards.

Under this rule, public colleges and universities must comply with WCAG 2.1 Level AA, the internationally recognized standard for digital accessibility. This requirement extends far beyond marketing websites.

Accessibility now covers the full digital ecosystem, including:

• Public-facing websites
• Mobile applications
• Admissions and student portals
• Learning management systems (LMS)
• PDFs and digital documents
• Videos, audio, and other media

This rule removes much of the uncertainty institutions previously faced. Accessibility expectations are no longer shaped primarily by lawsuits or interpretation; they are now written into federal regulation.

While this specific rule applies to public institutions under Title II, private colleges and universities are still required to provide accessible digital experiences under other federal laws, including Title III of the ADA and Section 504 for institutions that receive federal funding. The regulatory details may differ, but the expectation of accessibility does not.

Understanding the 2026 and 2027 Accessibility Deadlines

The accessibility requirements remain consistent across public institutions. The primary difference is timing.

• April 24, 2026 applies to public entities serving populations of 50,000 or more, including most large state colleges and universities.
  
• April 26, 2027 applies to smaller public entities serving fewer than 50,000 people.
  

The technical standard remains unchanged: WCAG 2.1 Level AA. The extended timeline for smaller organizations is intended to provide additional preparation time, not reduced expectations.

Accessibility Requires More Than Periodic Audits

Historically, accessibility efforts often focused on audits or post-launch fixes. While audits are still an important guide, they are no longer sufficient on their own.

The new ADA rule makes it clear that accessibility is an ongoing responsibility. Institutions must consider how new content is created, how digital tools are selected and configured, and how accessibility is sustained as platforms evolve.

For many institutions, this represents a shift from project-based remediation to operational integration. Accessibility increasingly requires defined ownership, governance processes, and long-term accountability across digital teams and content contributors.

A Realistic Scope, Not a Panic Button

The 2026 and 2027 deadlines do not require institutions to remediate every piece of content ever published.

The rule includes exceptions for certain archived materials and pre-existing social media posts, provided they are not actively used to deliver services or information. The focus is on current, active, and student-facing content.

This distinction helps make accessibility more achievable. Institutions are expected to demonstrate meaningful, sustained progress toward compliance rather than attempting to solve every issue all at once. 

Why Accessibility Must Be Built In From the Start

The most effective way to meet accessibility requirements is to integrate them into digital systems from the start.

When accessibility is built into digital systems from the beginning:

• Design systems rely on accessible components by default
• Content creators understand how to publish accessible materials
• Issues are identified early, not after launch
• Long-term maintenance becomes simpler and more cost-effective

Retrofitting accessibility after deployment is often slower, more complex, and more expensive. Designing accessible systems from the beginning supports stronger outcomes for institutions and students alike.

Accessibility Is Also About Student Experience

Accessibility is not solely a compliance initiative; it directly shapes how students interact with their institution.

When digital tools create barriers, students may struggle to apply, register for courses, access learning materials, or engage with campus services. These challenges can directly impact academic progress and institutional trust.

Accessible digital experiences consistently:

• Reduce barriers for students with disabilities
• Improve usability for all students
• Support equity and inclusion initiatives
• Simplify access to institutional information and services

Accessibility improvements frequently benefit the entire student population, not just those who require accommodations.

A Global Shift Toward Accessibility

Accessibility regulations are expanding beyond the United States.

In the European Union, the European Accessibility Act began taking effect in June 2025. Similar regulatory efforts are emerging worldwide, with enforceable standards and defined compliance timelines.

For institutions with international students, global partnerships, or overseas programs, accessibility expectations are becoming increasingly universal.

From Remediation Projects to Sustainable Digital Systems

The shift facing higher education is clear.

Previous approach: Address accessibility issues after launch
Current expectation: Integrate accessibility into every stage of digital planning, design, and development

By 2026, accessibility will be treated alongside security, privacy, and performance as a baseline digital requirement.

Your Next 4 Steps

Institutions do not need to wait until 2026 or 2027 to begin preparing. Meaningful progress often starts with targeted, high-impact actions.

1. Confirm Your ADA Compliance Deadline 

Do not base your deadline on student enrollment. ADA Title II deadlines are determined by the Census population of the government jurisdiction that operates your institution.

State universities should plan for the April 24, 2026 deadline. City or county-operated colleges must confirm whether their jurisdiction exceeds 50,000 residents. Many institutions will find that April 2026 applies.

2. Audit Your Front Door

Evaluate your most frequently visited pages and admissions application workflows first. These touchpoints typically represent the highest-impact student interactions and provide a clear starting point for remediation reminders.

3. Train Your Content Creators

Ensure staff responsible for publishing PDFs, updating webpages, and uploading media understand foundational accessibility requirements. A significant portion of accessibility issues originates at the content creation level.

4. Evaluate Your Vendors

Engage with software providers (including portal, calendar, and learning platform vendors) to confirm their alignment with WCAG 2.1 Level AA standards. Accessibility responsibility extends beyond vendor contracts and requires institutional oversight.

Accessibility compliance represents only part of the challenge. The broader opportunity lies in building digital ecosystems that remain accessible as content, platforms, and student expectations continue to evolve.

Mindgrub partners with education institutions to design and develop accessible, sustainable digital experiences from the ground up. If your institution is reassessing how accessibility fits into its broader digital strategy, we’d love to chat.