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Digital accessibility: New federal rule

In April 2024, the Department of Justice published a new rule on digital accessibility under Title II of the Americans with Disabilities Act. This new regulation requires that public entities, including the University of ����ӰԺ System, provide fully accessible digital content by April 24, 2026.

Digital accessibility isn’t just about compliance — it’s about empowering all users, including those with disabilities. By ensuring that websites, mobile apps, and technologies are usable by everyone, we create inclusive experiences that benefit users with vision, hearing, physical, and cognitive conditions. 

The scope of the new regulations is extremely broad because so much of our work and communication in higher education takes place online. Complying with the new federal rule will require substantial collaboration and partnership to ensure that all digital content — websites, web apps, mobile apps, course content, and other electronic content — is readily usable by all.

Several departments — including communications, IT, and online learning — are collaborating closely to create implementation plans based on priorities, and each campus has launched a task force dedicated to digital accessibility.

����ӰԺ the rule

Requirements

The new regulations require that “public entities shall ensure that web content and mobile apps made available directly or through contractual, licensing, or other arrangements, are readily accessible and usable by individuals with disabilities.” 

The UM System has had a Digital Accessibility Policy since 2022, but these new regulations set forth additional specific guidelines in addition to our existing policy. 

For more information, read this and the .

Technical standard

The rule establishes as the standard for all web and mobile content available to the public or used in our services, programs, and activities.

Examples include:

• Alternative text describing images
• Accurate captions for videos
• Sufficient color contrast and appropriate use of color
• Structuring a website in a way that allows a screen reader user to navigate the site

Scope of new regulations

These new regulations affect any content that users can access with a computer or smartphone, including but not limited to: 

• Websites
• Mobile, desktop and web applications
• Procured software
• Social media
• Videos
• Academic course content posted in Canvas
• Documents posted online, including PDFs

Essential definitions

• Web content: The information and sensory experience communicated to the user by means of a user agent, including code or markup that defines the content’s structure, presentation, and interaction. Examples of web content include text, images, sounds, videos, controls, and animations on websites.
• Conventional electronic documents: Web content or content in mobile apps that are in the following electronic file formats: Portable document formats (PDF), word processor file formats, presentation file formats, and spreadsheet file formats.
• Mobile applications: Software applications downloaded and designed to run on mobile devices, such as smartphones and tablets.

Exceptions 

In limited situations, some web and mobile app content may fall within an exception. The has more details on each of these limited exceptions:

1. Archived web content: Content that existed before the final rule, is not currently used, has not been altered since being archived by a public entity, and is kept only for reference, research, or record-keeping purposes.
2. Preexisting conventional electronic documents: Documents available on a website or mobile app created before the date of compliance and not currently used.
3. Third-party content: Content posted by third parties outside the university, unless the third party is posting due to contractual, licensing, or other arrangements with the university.
4. Individualized password-protected documents: Password-protected or otherwise secured documents that are individual to a specific person, property, or account.
5. Preexisting social media posts: Social media posts made before the date of compliance.

Responsibilities by role

Ultimately, everyone is responsible for ensuring the digital content they create or maintain for university business is accessible and meets WCAG 2.1 AA guidelines. However, your responsibilities may vary depending on your role.

Staff

All digital content created for university business must be accessible by April 24, 2026. Ideally, everyone who creates or maintains digital content will make that content accessible, but some units may centralize accessibility work. Work with your team, department or unit to clarify responsibilities.

Staff who procure content, like training courses, websites, platforms, software or apps, must ensure that content is accessible during the procurement process.

Instructors and faculty

All course content in use in an active course must meet WCAG 2.1 AA guidelines by April 24, 2026. Tools within Canvas, such as UDOIT Advantage, as well as other resources offered through , can assist faculty with making course content accessible.

Archived reference content, like courses from previous semesters, does not need to be accessible. However, if you reuse the course or content from the course, it must be made accessible.

Students

If you create digital content for university business, that content must be accessible by April 24, 2026. As a student, university business may include work you perform in a student job or content you create for a university-sponsored student organization or club. You are not required to make your schoolwork or personal content accessible.

Resources and support

Communications, IT, ����ӰԺ Online, and the Office of Accessibility and ADA are working together to develop a strategy plan to implement digital accessibility. 

Task Forces

Each UM System campus has created a task force focused on digital accessibility, and more information will be provided in the coming months.

University resources for digital accessibility

• : how-to guides for creating accessible digital content and other resources.
• : Canvas course accessibility.
• : adaptive technology consultations, alternative format services, accessibility reviews and more.