ADA Digital Accessibility Center

Preparing for the New ADA Title II Digital Accessibility Requirements

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Introduction

On April 24, 2024, the Department of Justice (DOJ) published a new rule addressing digital accessibility under Title II of the Americans with Disabilities Act.  The new rule significantly expands digital accessibility requirements for Ohio State as a public institution, impacting all university units and functions, including academic, administrative, athletic, research, and patient care. The revised rule mandates that all web content and mobile apps (digital content) must be:

  1. Readily accessible to and useable by people with disabilities upfront; and
  2. Fully conformant with the Web Content Accessibility Guidelines 2.1, Levels A and AA (WCAG 2.1, AA) by April 24, 2026.

The revised regulation applies to all public-facing, student-facing, and employee-facing content, whether provided directly by the university or through third parties.

How Units Can Best Prepare for New Title II Digital Accessibility Changes

  • Identify and take inventory of the unit’s existing digital information and systems. Determine which content is still actively used and which content can be deleted or archived (to qualify under the archive exception).  Determine if content actively being used needs to remain in its current format, or if it can be converted to a more accessible format (e.g. converting an inaccessible PDF to accessible HTML).
  • Conduct evaluations of the unit’s existing digital information and systems—website, mobile apps, and third-party platforms, for compliance with the university’s Minimum Digital Accessibility Standards (MDAS); identify gaps and prioritize high-impact areas for remediation. For the unit’s public websites, ensure all sites are being scanned regularly within PopeTech, and all full manual evaluations are uploaded to the public website inventory in MyRME, which provides critical evidence of the unit’s and Ohio State’s proactive efforts to fulfill our legal obligations under federal law and important for internal and external audits, including by federal regulators.
  • Develop and implement written accessibility procedures to ensure accessibility is built into the content creation and procurement processes from the beginning. Develop and implement written and formal procedures for the maintenance of accessible digital information and systems (e.g. developer testing, QA processes, etc.).  This includes clear guidelines for web developers, content creators, and external vendors.  If written and formalized processes and procedures already exist, ensure that this information is distributed and understood within the unit.  Re-evaluate effectiveness of established processes and procedures on at least an annual basis.  Accessibility cannot be an afterthought.
  • Ensure that employees are effectively trained to create accessible digital content. Assign the accessibility skills trainings and education that are available to units in BuckeyeLearn. If your unit does not already have any OSU Certified Accessibility Evaluator(s) on its staff, encourage staff member(s) to sign up and participate in the 2025 Web Accessibility Certified Tester (W-ACT) program
  • Procure accessible digital information and systems. Ensure that you’ve explored all products that meet business need to determine which one is the most accessible.  Continue to push on third-party vendors with whom you’re working to ensure that they are taking the appropriate strides to ensure their content will fully conform with WCAG 2.1 AA by April 24, 2026, except when it is not technically or legally possible.  Incorporate digital accessibility language in all contracts with external vendors.
  • Reach out to the ADA Digital Accessibility Center (accessibility@osu.edu) with questions or if you would like a presentation or overview to your department.