Short answers to the questions we hear most about the U.S. Department of Justice’s ADA Title II rule for web content and mobile apps. For the full picture, read the Title II Brief and the Compliance Timeline.
What is the rule?
The DOJ published a rule on April 24, 2024 that sets a technical standard for the web content and mobile apps that state and local governments, including public universities, provide. The standard is WCAG 2.1 Level AA. The University already had to provide equal access under the ADA and Section 504; the rule says exactly what that means for websites, documents, videos and apps.
When does the University of Arizona have to comply?
By April 26, 2027. As a state university, the University of Arizona is in the group of public entities with a total population of 50,000 or more. Smaller public entities and special district governments have until April 26, 2028.
What changed in April 2026?
On April 20, 2026, the DOJ published an Interim Final Rule in the Federal Register that moved both compliance dates back by one year. It did not change the standard or what has to be accessible.
Which standard: WCAG 2.1 or 2.2?
Federal requirement: the ADA Title II rule requires WCAG 2.1 Level AA.
University direction: the University of Arizona targets WCAG 2.2 Level AA, which builds on 2.1 and goes beyond the federal requirement. Content that meets 2.2 AA also meets 2.1 AA. See WCAG 2.2 AA Highlights.
Does it apply to my course, PDF, video, social media post or app?
Usually, yes. The rule covers web content and mobile apps that the University provides or makes available, including content provided for the University by a vendor or contractor. That includes:
- web pages and online course materials, such as files and pages in Brightspace (D2L)
- documents posted online, such as PDFs, Word files, slides and spreadsheets
- videos and audio, which need accurate captions or transcripts
- social media posts made on or after the compliance date
- mobile apps the University offers, including apps run by a company for the University
Are there exceptions?
There are five limited exceptions. Each applies only when every one of its conditions is met:
- Archived web content: created before the compliance date, kept only for reference, research or recordkeeping, kept in an area marked as an archive, and not changed since it was archived.
- Preexisting documents: PDF, word processing, presentation or spreadsheet files that were online before the compliance date. This does not cover documents people still use to apply for, access or take part in a service, program or activity, such as a current application form.
- Content posted by third parties: for example, a comment a member of the public posts. It does not cover content the University, its vendors or its contractors post, or the tools and platforms the University adds to its sites.
- Individualized, password-protected documents: documents about a specific person, property or account, such as a bill, kept behind a login.
- Preexisting social media posts: posts made before the compliance date.
Even when an exception applies, the University must still provide effective communication. If someone asks for an accessible version, provide one.
We use a vendor’s tool or platform. Is that covered?
Yes. Calendars, forms, payment systems, maps and other third-party tools that the University puts on its sites are covered, and so is content a contractor posts for the University. Check accessibility before you buy: see Accessible Procurement Process.
Does this replace accommodations?
No. Students, employees and visitors can still request accommodations through the Disability Resource Center. Accessible content means fewer people need to ask.
What should I do first?
- Make everything new accessible from the start.
- List what you own: pages, documents, videos, forms and apps.
- Fix what people use most, and anything they need to apply for or take part in something.
- Remove or archive what nobody needs any more.
- Check your work with the Accessibility Testing Toolkit, and start with Quick Wins.
The DOJ also publishes First Steps Toward Complying with the Title II Web and Mobile Application Accessibility Rule.
Where can I get help?
See Get Help, or email accessibility@arizona.edu. To report something that is not accessible, use Report an Accessibility Barrier.
Sources
- U.S. Department of Justice: Fact Sheet: New Rule on the Accessibility of Web Content and Mobile Apps Provided by State and Local Governments (ADA.gov, checked October 14, 2026)
- U.S. Department of Justice: State and Local Governments: First Steps Toward Complying with the ADA Title II Web and Mobile Application Accessibility Rule (ADA.gov)
This page is general guidance, not legal advice.