The Americans with Disabilities Act Title II was updated in April 2024 to include web accessibility standards. The update gives universities of Carolina’s size until April 2026 to come into compliance with the new rule. Thankfully, Carolina already sports a culture of accessibility that we have nurtured over the past five years. The Digital Accessibility Office (DAO) believes that Carolina’s work has set us ahead of many other institutions, and we remain committed to continuing our efforts to support all units in building on this strong foundation.
Understanding ADA Title II Web Accessibility Rule
The ADA Title II is designed to ensure that state and local government services, including public universities, are accessible to people with disabilities. This means that all digital content, like websites and mobile apps, must be designed so that everyone can access them regardless of ability, disability, or use of assistive technology. The standard UNC Chapel Hill will be following is WCAG 2.2 which is newer than the 2.1 standard that the ADA implemented.
Everyone has a role
Each unit within the university must ensure that their digital materials meet the minimum accessibility requirements as required by ADA Title II and UNC digital accessibility standards. This includes making sure that websites, applications, IT services, online content, digital documents, presentations, and online learning materials are accessible.
The Digital Accessibility Office (DAO) will guide the effort to meet or surpass ADA compliance. We have created a scalable compliance plan, expanded access to trainings, introduced several workshops, and curated a collection of tools and resources. We also provide many direct services such as consulting, office hours with a member of our team, website/course accessibility reviews. These efforts aim to empower all Tarheels to develop their technical skills.
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. The Digital Accessibility Office offers guidance and support for vendor management and procurement.
Instructors and faculty
All course content must meet WCAG 2.2 AA guidelines by April 24, 2026. This includes third-party content. For example, if you link to or embed a YouTube video in your course, that video must have a non-audio alternative such as correct captions or a transcript with audio description. This applies even if you are not the owner of the video.
Archived reference content, like courses from previous semesters, may be exempt from compliance. 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.
For example, if you have a work-study job creating social media posts for a department, those social media posts must be accessible and meet WCAG 2.2 Level AA. Ask your supervisor to clarify any responsibilities you have as you create and post content. You do not have to retroactively make old posts accessible. Or, if you maintain a website for a University-sponsored student organization that is registered with UNC Student Life and Leadership, that web content will need to meet accessibility requirements. If you create or maintain that content, you are responsible for making it accessible.
Exceptions to the Rule
Any exception must be approved by the Digital Accessibility Office. It’s important to note that these exceptions are not a blanket exemption and do not apply if doing so would result in a failure to provide an equal opportunity to access the services, programs, or activities offered by the public entity. Institutions should always aim to provide accessible alternatives where possible.
- Archived Web Content: Content that is not currently used, may be outdated, not needed, or repeated elsewhere and is archived on the website. This content does not need to meet WCAG 2.1, Level AA if all of the following is true:
- The content was created before the date the state or local government must comply with this rule, or reproduces paper documents or the contents of other physical media (audiotapes, film negatives, and CD-ROMs for example) that were created before the government must comply with this rule, AND
- The content is kept only for reference, research, or record keeping, AND
- The content is kept in a special area for archived content, AND
- The content has not been changed since it was archived.
- Third-Party Content: Content posted by a third party on a public message board, for example, generally does not need to comply with the technical standard. However, this exception does not apply if the state or local government is using the linked web content to offer its service, program, or activity.
- Password-Protected Content: Content associated with specific classes or courses that is password-protected generally would not need to comply with the technical standard. However, if a student with a disability who needs accessible content is enrolled in the class or course, then the content must be made accessible.
- PDFs: Some exemptions include PDFs, but this does not mean organizations have a “free pass” on making them accessible. Generally, any PDF that is currently used or relevant to more than one person will need to be accessible.
Common Questions
- What does the new ADA rule cover? The rule makes sure that websites and mobile apps provided by state and local governments (including public universities) are accessible to people with disabilities.
- What are the technical standards for compliance? The rule requires websites and mobile apps to meet the Web Content Accessibility Guidelines (WCAG) Version 2.1 Level AA standards. However, UNC’s standards on Digital Accessibility require a higher level of compliance at WCAG 2.2. This will help future proof our work and ensure the best level of accessibility for our community.
- Who needs to comply with the new rule? The rule applies to all websites and mobile apps offered by public entities, whether they provide them directly or through other arrangements.
- Are there any exceptions to the rule? Yes, there are exceptions. The above section on this page covers these exceptions and their very limited use.
- What is the timeline for compliance? Public entities have two years from the rule’s effective date to make their websites and mobile apps accessible.
Compliance Plan
The DAO has created a flexible compliance plan to help departments get started. This plan provides a flexible approach to help departments of any size comply with new legal requirements for digital accessibility. It emphasizes a new, efficient way of working rather than adding more tasks. By following these steps, your department can smoothly transition to the new guidelines for digital content authored by and for the University.
Conforming Alternate Versions
In cases where existing digital material cannot be made accessible, the University must provide a conforming alternate version. This acts as a temporary way of providing access to digital content that hasn’t or can’t be made accessible. Units are only allowed to do this when technical or legal constraints make it impossible to ensure accessibility. The DAO must approve these alternate versions.
Conclusion
By following these guidelines, the University can ensure that it is providing an inclusive environment for all students, faculty, staff, and the public, and is in compliance with the new ADA Title II web accessibility rule.
Please email the DAO if you need further assistance or specific details on anything related to this initiative.