Friday Follow Up

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About the DOJ Accessibility “Deadline”

The post “The Other Regulatory Time Bomb” about the upcoming DOJ accessibility rules, with effective dates of April 2026 and April 2027 (depending on population served) has stirred up a lot of conversation. The basic idea is that public institutions need to comply with WCAG 2.2, Level AA, which means accessibility requirements for all actively-used website information (including on LMS and other password-protected sites) - and the two biggest issues for universities is remediating hundreds of thousands of PDF files and the new audio description requirements. Few colleges and universities are prepared, and few vendors are fully supporting the requirements.

Perhaps the biggest question I hear is whether this is truly a deadline (hence the scare quotes), in other words, whether all content and websites need to be compliant as of April. A lot of people believe that there will be an on-ramp period, where institutions can show progress and have processes in place and this will be enough. Other people believe April is a true deadline and full remediation is due in six months.

The more I look at the details, the more I believe the latter position is (mostly) correct. Full remediation. Why do I say this?

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