Accessibility Frequently Asked Questions

Answers

1. Why do we have an IT Accessibility Policy?

This Policy is intended to ensure that the UC complies with its federal obligations under Title II of the Americans with Disabilities Act and Section 504 of the Rehabilitation Act of 1973. These statutes generally require the UC's digital content to be accessible to individuals with disabilities.

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2. Why does the Policy require an update in 2025?

In 2024, both the United States Department of Justice (DOJ) and the Department of Health and Human Services issued new regulations. These regulatory updates clarify the longstanding obligation to ensure that web content and mobile applications are accessible to individuals with disabilities. The new regulations also establish an Accessibility Standard, which outlines technical criteria web content and mobile applications must meet to be accessible and establishes other requirements. The Policy has been updated to mirror the latest legal requirements for digital content and creates the necessary processes to comply with the regulation.

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3. What is the Accessibility Standard set by the 2024 regulatory updates?

The Accessibility Standard requires that all digital content and mobile applications meet WCAG 2.1 AA by April 24, 2026.

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4. To what types of digital content does this Policy apply?

This Policy applies to all of UC's Information Technology (IT) unless an exception applies under the Policy. It includes websites, web and mobile applications, digital content, software (including Software as a Service; SaaS), Learning Management Systems, educational tools, videos/livestreams/podcasts, and electronic documents (e.g., PDFs, Word/Excel/PowerPoint, spreadsheets, slide decks), including "Emerging Technologies." (See "Information Technology" in the Definitions Section of the policy for a complete list.) It also includes content posted by a third party pursuant to a contract, license, or other arrangement with the UC.

Limited exceptions include, for example, archived content (meeting certain criteria), and social media posts before April 24, 2026. Questions about whether an exception applies should be directed to your campus ADA Coordinator.

This Policy applies to University programs and services including IT accessed by students, faculty, academic personnel, staff, patients, and/or members of the public.

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5. Are there extensions to the federally mandated compliance deadline of April 24, 2026?

No. All UC locations must comply with the ITAP no later than April 24, 2026.

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6. How did the University determine which compliance deadline applies?

According to the Department of Justice rulemaking materials, the "population size for educational entities is determined not by the size of those entities' student bodies, but rather by reference to the Census-calculated total population of the jurisdiction of which the educational entity is an instrumentality." For example, "a public State university located in a town of 20,000 within a State with a population of 5 million would be considered a large public entity for the purposes of this rule because it is an instrumentality of the State"—and subject to the April 2026 compliance deadline.

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7. I am a faculty member, academic personnel, or staff member who teaches a course to students, staff, patients or guests of the UC. Does the Policy apply to my work as an instructor?

Yes. All digital course materials must be accessible at the time of publication. The policy requires locations to establish an Accessible Course Content Program to provide support to faculty, academic personnel, and staff who are now required to proactively create accessible course content.

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8. If it will be challenging to ensure all courses, including digital instructional material and online training (i.e., compliance training, professional development training), are accessible by April 24, 2026, how should my team prioritize the remediation efforts?

Course content owners should develop a prioritization plan for remediation. Per the Policy, locations should prioritize the accessibility evaluation and remediation of the following course content:

1. High-volume gateway courses;
2. New courses;
3. Pre-existing courses that are Materially Altered, as that term is defined in the Policy;
4. General Education (GE) courses;
5. Courses with a high number of individuals with Disabilities who receive Reasonable Accommodations;
6. Fully online courses; and
7. Mandatory training (i.e., compliance training, professional development training).

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9. I am an instructor or other member of faculty, academic personnel, or staff and need assistance in learning about making my course accessible. Where can I find support?

The Policy requires locations to create an Accessible Course Content Program. The individual(s) responsible for that Program varies by Location. Please contact your location's ADA Coordinator for more information about accessibility support for academic personnel.

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10. Is the University responsible for ensuring that third-party content meets the Accessibility Standard of the Policy?

The University is responsible for ensuring the following digital content meets the Accessibility Standard:

1. Third-party digital content that the University provides or makes available;
2. Third-party digital content to which the University links; and
3. Digital content posted by a third party to a University website pursuant to a contract, license, or other arrangement. Examples of products or services include website development or design, databases, course materials, mobile applications, software, or other services, tools, or resources.

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11. What does "access a University program or service" mean?

Accessing University programs and services means any UC Community member who must use University provided content (including via a third-party vendor) to engage with University programs and services.

Examples of accessing online University programs and services include, and are not limited to:

1. Accessing educational, instructional, employment, academic, healthcare, and research materials
2. Reviewing online information about University programs and services
3. Submitting information to apply for, pay for, or obtain services
4. Conducting online research for academic, healthcare, or employment purposes
5. Reviewing information about and participating in meetings and events, whether remote or in person
6. Participating in healthcare services
7. Participating in University-sponsored or organized research
8. Creating academic- or employment-related work products

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12. If a department or program believes compliance with this policy is impossible, what are necessary steps in evaluating this?

Section V.C.4. of the Policy outlines the Exception Process when compliance with the Policy is not possible. In instances where a UC location approves an exception to the Accessibility Standard, the policy requires locations to attempt remediation of the IT and implement an "Equally Effective Alternative Accommodation Plan" (EEAAP). That plan ensures people with disabilities can still meaningfully access the same information, services, or activities while remediation proceeds.

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13. Aside from establishing an accessibility standard, does the policy update create any new requirements for UC locations?

Yes, the policy outlines an Information Technology Accessibility Policy Program (ITAPP) that UC locations must implement. Some new requirements were established to assist campuses in complying with all aspects of the new regulations. For example, the policy requires an explicit exception process as required by law and establishing an Accessible Course Content Program to ensure that locations provide support to faculty, academic personnel, and staff who are now required to proactively create accessible course content. UC locations may take steps above and beyond the ITAPP.

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14. I have created an "archive" section on my website, and the files are currently supporting a University service, program, or activity. Does the archived content exception apply?

The archived content exception is narrow. The archived content exception applies only to content that meets all of the following four criteria:

1. Was created before April 24, 2026, reproduces paper documents created before April 24, 2026, or reproduces the contents of other physical media created before April 24, 2026;
2. Is retained exclusively for reference, research, or recordkeeping;
3. Is not altered or updated after the date of archiving; and
4. Is organized and stored in a dedicated area or areas clearly identified as being archived.

Questions about whether an exception applies should be directed to your Location's ADA Coordinator.

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15. Why does the Policy require various programs?

This Policy defines various programs (e.g. procurement, course content, software/web development, etc.) to provide structure and accountability for ensuring compliance with the various regulatory requirements.

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16. Why does the Policy have an Exceptions Process?

Using the Exceptions Process in this Policy provides consistency to ensure exceptions are reviewed by subject matter experts who understand accessibility requirements and this Policy prior to a decision. In addition, following the Exceptions Process allows the University to retain documentation of consultation and decisions in the event of a complaint.

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17. Does an approved exception expire?

Yes. Initial exceptions are approved for a two-year duration. Renewals for exceptions are required every two years thereafter. Throughout the initial two-year exception period, the individual(s) responsible for Exceptions Coordination, or their Designee, must regularly communicate with the department that was granted an exception to ensure there is meaningful progress toward making the excepted IT Accessible via a remediation plan, as described in the Policy, Section V.C.4.c.

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18. If a department is granted an exception, must the department still ensure an individual with a disability can still access University programs and services?

Yes. Exceptions do not relieve location programs or services of their obligations to ensure individuals with disabilities can access the service, program, or activity. Where there is a known accessibility barrier, locations must create and implement Equally Effective Alternate Accommodation Plans (EEAAPs) in a prompt and equitable manner. Locations must use the EEAAP (link forthcoming) to ensure consistent processes systemwide.

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19. Does an Accessibility statement suggest that my website may be Inaccessible?

No. You should always have an Accessibility statement because no matter how Accessible a website may be at any given moment, a seemingly minor change may render the website Inaccessible. An Accessibility statement ensures the user can alert you to Accessibility issues. See Section V.C.5. Complaint Process.

Sample language: If you are unable to access this content due to a disability, please email name@campus.edu for assistance.

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