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Compliance Timeline

Key dates, deadlines, and milestones for digital accessibility at UA.

Digital accessibility is an ongoing responsibility for public institutions, including public higher education. This timeline highlights the major federal milestones that shape accessibility expectations for websites, web content, and mobile apps, and it reflects DOJ’s interim final rule, published April 20, 2026, which extended the original compliance dates by one year, to April 26, 2027 for public entities with a total population of 50,000 or more, including the University of Arizona, and to April 26, 2028 for smaller public entities and special district governments.

This page focuses on authoritative, published milestones. It does not include speculative future adoptions or unpublished internal targets. Where possible, each milestone should link directly to a primary source so readers can verify the requirement for themselves.

Why This Timeline Matters

Title II of the Americans with Disabilities Act applies to state and local governments, and DOJ’s web and mobile accessibility rule specifically covers public entities, including public universities. DOJ’s Small Entity Compliance Guide names public higher education institutions as examples of covered public entities.

For higher education, this means accessibility work is not limited to a single website redesign or a one-time review. It touches the digital experiences people rely on every day to learn, teach, work, communicate, and access services. DOJ’s current rule uses WCAG 2.1 Level AA as the technical standard for covered web content and mobile apps.

Federal Milestones

July 26, 1990 — Americans with Disabilities Act Signed Into Law

On July 26, 1990, President George H.W. Bush signed the Americans with Disabilities Act into law. Title II prohibits disability discrimination by state and local governments, including public institutions and the services, programs, and activities they provide.

1998 — Section 508 Added to the Rehabilitation Act

Section 508 established accessibility requirements for federal agencies’ electronic and information technology. While Section 508 is not the same thing as Title II, it remains an important reference point in digital accessibility because it shaped procurement and technical accessibility practices across government and higher education.

January 18, 2017 / January 18, 2018 — Revised 508 Standards Published and Compliance Required

The U.S. Access Board published the Revised 508 Standards on January 18, 2017. Federal agencies were required to comply beginning January 18, 2018. Those standards incorporate WCAG 2.0 Level AA for relevant web and software content.

June 5, 2018 — WCAG 2.1 Published by W3C

The World Wide Web Consortium published WCAG 2.1 on June 5, 2018. WCAG 2.1 added success criteria that strengthened support for mobile accessibility, low vision, and cognitive accessibility. DOJ later selected WCAG 2.1 Level AA as the technical standard in its Title II web and mobile rule.

October 5, 2023 — WCAG 2.2 Published by W3C

W3C published WCAG 2.2 on October 5, 2023. WCAG 2.2 is newer guidance and is also published as ISO/IEC 40500:2025, but it is not the accessibility standard DOJ adopted in the Title II web and mobile rule. DOJ’s current rule remains based on WCAG 2.1 Level AA.

April 24, 2024 — DOJ Publishes the Title II Web and Mobile Accessibility Rule

On April 24, 2024, DOJ published its final rule on accessibility of web information and services of state and local government entities. The rule became effective on June 24, 2024 and adopts WCAG 2.1 Level AA as the technical standard, with limited exceptions described by DOJ.

April 20, 2026 — DOJ Extends the Compliance Dates by One Year

On April 20, 2026, DOJ published an interim final rule extending the original compliance deadlines by one year. This change is important because many public-facing timelines still reflect the earlier 2026 and 2027 dates.


 

April 26, 2027 — Compliance Date for Larger Public Entities

Public entities with a total population of 50,000 or more must comply with the Title II web and mobile accessibility rule by April 26, 2027.

April 26, 2028 — Compliance Date for Smaller Public Entities and Special District Governments

Public entities with a total population of fewer than 50,000, as well as special district governments, must comply by April 26, 2028.

What This Means for Higher Education

For colleges and universities, the compliance timeline should be viewed as a planning horizon, not as permission to wait. DOJ’s implementation guidance encourages public entities to identify the web content and mobile apps they provide, evaluate barriers, understand which content is covered by the rule, and prioritize work that has the greatest impact on people using core services.

In practice, this means accessibility work should include governance, training, procurement, content review, remediation, and regular quality assurance. Institutions should build accessibility into new work while also identifying and reducing barriers in existing systems. DOJ’s guidance emphasizes evaluating existing content, determining what is covered, and planning for conformance rather than treating accessibility as an afterthought.

A Practical Approach for University Teams

University teams should begin with the services people depend on most. That usually includes admissions, registration, learning platforms, student support services, employment, public-facing websites, and mobile tools used to access university programs and services.

A strong compliance approach usually includes:

  • an inventory of covered websites, web content, and mobile apps;
  • a process for finding and fixing barriers;
  • accessibility requirements in procurement and contracts;
  • training for people who create and publish digital content;
  • clear ownership, escalation paths, and timelines for remediation; and
  • a public way for users to report accessibility barriers.

DOJ’s First Steps guidance points public entities toward this kind of inventory-and-remediation model, including identifying covered content, evaluating current barriers, and prioritizing remediation work.

Important Clarification About Standards

This page intentionally distinguishes between current legal requirements and newer technical guidance.

  • Current DOJ Title II rule: WCAG 2.1 Level AA.
  • Current Section 508 reference point: WCAG 2.0-based Revised 508 Standards for federal agencies.
  • Current W3C recommendation: WCAG 2.2 is the most recent WCAG version and the current ISO/IEC 40500:2025 standard.

Because these are not identical, public timelines should avoid claiming that WCAG 2.2 has already been adopted into DOJ’s rule or that Section 508 has already moved to WCAG 2.1 or 2.2. Those claims are not supported by the current primary sources.

How to Read This Timeline

This timeline is intended to help campus leaders, content owners, developers, instructional teams, procurement staff, and support units understand the broader compliance landscape. It is not a substitute for policy, legal guidance, or implementation planning, but it can help establish a common factual baseline for campus decision-making.

As new federal guidance is issued, this page should be updated promptly. Legal dates, standards references, and implementation guidance should always be checked against primary sources before being reused elsewhere on the site.

Authoritative References

  • Americans with Disabilities Act, Title II regulations.
  • DOJ Title II web and mobile accessibility rule overview.
  • DOJ Small Entity Compliance Guide.
  • DOJ First Steps Toward Complying with the Rule.
  • U.S. Access Board, Revised 508 Standards.
  • Section508.gov applicability and conformance guidance.
  • W3C WCAG Overview and publication history.
  • DOJ Interim Final Rule extending the compliance dates.

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