In April 2026 or 2027, public schools across the United States are required to ensure that the digital educational materials they provide, as well as most of their other web and digital materials, are accessible. Here, “accessible” means that these materials conform to the Web Content Accessibility Guidelines (WCAG) as specified in Title II of the Americans with Disabilities Act (ADA). In this post, we’ll shed light on both the ADA and WCAG.
Title II of the ADA
The ADA is a civil rights law that aims to prevent disability-based discrimination in several areas of life, including employment; state and local government programs, services, and activities; private businesses open to the public; and telecommunications. Each of these is addressed in separate Titles, or sections, of the ADA. Title II of the ADA focuses on programs, services, and activities provided by state and local government entities. This includes state and local educational agencies (SEAs and LEAs) and the digital educational materials they provide for the classroom.
In April 2024, the Department of Justice published a new rule that specifically addresses accessibility of websites and native mobile apps. This rule also applies to social media posts and digital documents, such as PDFs or slide decks. This means that SEAs and LEAs must now proactively account for accessibility in their educational technology (edtech) and other websites and apps. Critically, agencies must address accessibility in both the technology they create, such as digital materials teachers produce every day, and third-party technology they purchase or use.
This is a significant change for SEAs and LEAs that have operated under a reactive model based on Individualized Education Programs (IEPs) or Section 504 plans. While accommodating individual students’ needs is still a requirement, when it comes to the edtech students need, SEAs and LEAs must begin addressing accessibility from the start, if they haven’t already.
Key Components of the New Rule
There are several important elements of the rule that SEAs and LEAs need to understand. We’ll highlight them below. You’ll find a set of resources with more details at the end of this post.
A Technical Standard
Title II refers to WCAG version 2.1, Level AA as a technical standard for accessibility. This feature is not found in any other titles of the ADA. We discuss WCAG in the second half of this post.
Conformance Deadlines
Conformance deadlines are based on the census population served by SEAs and LEAs. Larger agencies serving an area with a population of 50,000 or more residents must comply by April 24, 2026. Agencies that serve less than 50,000 have an additional year, until April 26, 2027. Note that this count is not the number of students served, but the population of the area.
Parents with Disabilities
Under Title II, SEAs and LEAs must ensure that parents with disabilities have an equal opportunity to participate in their children’s education. Parents with disabilities are explicitly included in the new rule, both as members of the public and as family members with whom the school communicates. When a school or district uses websites, portals, learning platforms, or apps to deliver information or services related to a student’s education, those must be accessible to parents with disabilities.
The Web Content Accessibility Guidelines (WCAG)
WCAG is a set of technical guidelines that define what accessible websites, digital documents, and other digital content must look and act like. An international group called the Web Accessibility Initiative (WAI), which is part of the World Wide Web Consortium (W3C), maintains the standards.
WCAG has versions, with version 1 dating back to 1999. Each new version includes additional standards to fill gaps in the prior version and keep up with emerging technology. The minimum required version under the ADA is 2.1, meaning agencies can require a higher standard
WCAG also has three levels, labelled A, AA, and AAA. Each goes from the most fundamental (level A) to more advanced (level AAA). Level AA provides significantly enhanced accessibility without creating some of the logistical challenges that level AAA may. So, “WCAG 2.1, AA” means WCAG version 2.1, including levels A and AA.
Within WCAG, guidelines are organized into four principles: perceivable, operable, understandable, and robust (POUR):
Perceivable means that websites must provide multiple ways for people to perceive information. For example, alternative text added to images is used by a blind student accessing a digital material with a screen reader.
Operable means that people can use the website they visit. If a student with a physical disability uses speech-to-text to interact with a website form, then the form must be built to support that interaction.
Understandable means that people must be able to understand both the information and interactions on a website. Students with cognitive disabilities must be able to derive meaning from the digital educational materials proved by schools.
Robust means that websites must work with current and future assistive technologies used by students, as well as parents with disabilities.
Within each guideline are success criteria. These are specific and testable, providing the basis for content creators, software developers, and others to understand how to create and maintain accessible digital materials and identify accessibility barriers. They are also critical to automated accessibility testing tools and to manual accessibility evaluation, which is necessary to identify the barriers in a website or app.
Support from NCADEMI
NCADEMI’s Quality Indicators for the Provision and Use of Accessible Digital Educational Materials and implementation resources are specifically designed to help SEAs and LEAs meet obligations under the ADA Title II final rule. For targeted technical assistance, consider enrolling in our upcoming Professional Learning Group launching in early 2026.
Additional Resources
- The full Title II Digital Accessibility Rule includes commentary by the Department of Justice.
- A Title II Digital Accessibility Fact Sheet from the Department of Justice goes into less detail than the full rule.
- NCADEMI’s guide on Including Accessibility in All Components of Procurement outlines procedures for education agencies.
- NCADEMI’s ADA Title II Roadmap for State and Local Educational Agencies guides leaders toward compliance.
- NCADEMI hosted a webinar discussing the new rule, including an overview of the Roadmap.
- WCAG’s extensive documentation provides a roadmap for creating more accessible websites, software, and digital documents.
- This Web Content Accessibility Guidelines overview describes the structure of the Guidelines.
- NCADEMI provides guidance about how to make different kinds of content accessible in our Accessibility Basics and Document Accessibility Starter Kit.
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