WCAG Rules and Regulations

New ADA Rule on Digital Accessibility

On April 24, the Department of Justice (DOJ) updated its ruling on Title II of the Americans with Disabilities Act (ADA) to ensure that state and local government services, programs, and activities offered via web content and mobile apps are accessible to individuals with disabilities. The ruling, titled Nondiscrimination on the Basis of Disability; Accessibility of Web Information and Services of State and Local Government Entities, establishes new accessibility standards for digital content.

The University of Vermont has been implementing website and mobile accessibility into its policies and practices for many years. The university will have approximately two years to comply with the new accessibility requirements. Below are key highlights of the ruling:

Standards

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  • WCAG 2.1 Level AA is the required technical standard for web and mobile accessibility under Title II of the ADA.
  • To comply, web content and mobile apps must conform to 30 Level A and 20 Level AA success criteria outlined in WCAG 2.1.

Electronic Documents

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  • The ruling defines electronic documents as web content or content in mobile apps that is in a PDF, word processor, presentation, or spreadsheet file format.
  • Database files are not included in this definition.

Social Media

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  • Public entities’ social media posts must generally conform to WCAG 2.1 Level AA.
  • Entities must use available accessibility features on social media platforms to ensure compliance.
  • If a public entity does not provide a social media platform as part of its services, it is not responsible for ensuring the platform’s accessibility.

Captions

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  • Live audio content in synchronized media must have captions (WCAG 2.1 Level AA Success Criteria 1.2.4).
  • The DOJ allows entities flexibility in selecting captioning methods and believes the compliance timeline is sufficient for securing necessary resources.

Course Content

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  • Password-protected course content at public educational institutions must comply with WCAG 2.1 Level AA.
  • Content posted by third parties on course websites may be exempt if the third party is not posting under a contractual or licensing agreement with the institution.

Third-Party Content

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  • Web content and mobile apps created or posted on behalf of a public entity fall within the scope of this rule.
  • Linked content falls outside the scope if it is truly unaffiliated with the entity and not provided under a contractual, licensing, or similar arrangement.
  • This exception also applies to third-party documents filed in legal or administrative proceedings and made available on a public entity’s website or app.

Next Steps

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The Office of Accessibility Services will provide guidance and education over the coming months to assist the University of Vermont community in understanding and implementing these new requirements. Additional resources and training opportunities will be made available to ensure compliance with the ADA’s digital accessibility standards.

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