What to know about ADA Title II Digital Accessibility

Created 09/10/2025

What to know about ADA Title II Digital Accessibility

Who this applies to: All Virginia Tech departments/units/offices that publish content online (all digital content that is actively used such as course materials, websites, video recordings, apps, and even documents like Word, PowerPoint, Google Docs, and PDFs)

Enforcement date: April 24, 2026


What is the regulation?

What it is:

  • A federal Department of Justice (DOJ) rule under ADA Title II that requires state and local governments, including public universities, make web content conform to WCAG 2.1 Level AA standards
  • Active content on VT public websites and documents posted for the public; If a document is linked from a webpage, assume it must comply

What it is not:

  • Not optional guidance, it is a legal compliance requirement with a set deadline of April 24, 2026
  • Not limited to websites - mobile apps and online documents are in scope
  • Not a blanket requirement to retrofit all historic/archived content

Bottom line: If your office creates information online, you are required to ensure it is accessible and usable for people with a wide range of needs, including those with disabilities.

Whose responsibility is this?

Creating accessible materials is the responsibility of the content owning office.

Offices/departments like Civil Rights Compliance, TLOS, SSD, Division of IT, and BAMS provide guidance, tools, training, and support but cannot “make accessibility happen” without accessible source content and sustained practices within each office.

Exceptions (what likely does not need immediate attention)

  • Archived web content (not current/active, kept only for recordkeeping)
  • Your own documents that you do not intend to share
  • In some cases, password protected sites (things like Canvas are not exempt)

Even when an exception applies, VT still must provide an accessible copy when requested.

Do‑This‑First

FAQ

Do all PDFs have to be fixed now? According to the Title II regulation, any documents that are not clearly marked “archive,” and contained within an archive folder, will be considered “active” and need to be remediated by the April 24, 2026 deadline. Prioritize remediating current, commonly used documents that are public facing. Anytime an archived document is updated, it needs to be remediated and is no longer considered “archive.”

Who decides if content is “archived”? Your office should document what is not actively used, and retained only for recordkeeping.

Are videos included? Yes. Provide captions for prerecorded video and transcripts for audio‑only.

Our vendor built the site/app. Are we covered? No. VT remains responsible for ensuring accessibility.

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