Accessibility Frequently Asked Questions

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.

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.

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.

The Accessibility Standard requires that all digital content and mobile applications meet WCAG 2.1 AA.

There are three different compliance deadlines set by both federal regulations and University policy.

1. The Information Technology Accessibility Policy (IMT-1300) generally requires digital content to meet WCAG 2.1 AA by April 24, 2026.
2. Similarly, the amended Title II regulations require large public entities, like the University, to ensure their digital content meets WCAG 2.1 AA by April 26, 2027. These deadlines are generally applicable to digital content unless an exception applies.
3. Section 504 of the Rehabilitation Act imposes a compliance deadline of May 11, 2027.

These deadlines are generally applicable to digital content unless an exception applies.

The federal regulatory updates apply to all of UC's Information Technology (IT) unless an exception applies. The policy definition of "Information Technology" 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.

The regulatory updates provide for limited exceptions that include, for example, archived content (meeting certain criteria), and social media posts before April 26, 2027. Questions about whether an exception applies should be directed to your campus ADA Coordinator.

The regulatory updates apply to University programs and services including IT accessed by students, faculty, academic personnel, staff, patients, and/or members of the public.

Yes. Both Title II and Section 504 apply to all digital content, whether it is public-facing or "internal" content behind password authentication. Content in internal documents and PDFs, department websites, and password-protected instructional courses must meet the same WCAG 2.1 AA standard the University's public-facing digital content.

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

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.

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 26, 2027, compliance deadline.

Some exceptions—such as archived web content, preexisting conventional electronic documents, and preexisting social media posts—require digital content to be created before a specific date for those exceptions to apply. Those exceptions apply to content created before three different dates:

• April 24, 2026 – Information Technology Accessibility Policy (IMT-1300).
• April 26, 2027 – Title II of the Americans with Disabilities Act. With the extension of the Title II compliance deadline, the relevant date for analyzing exceptions under Title II was changed.
• May 11, 2027 – Regulations for Section 504 of the Rehabilitation Act.

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.

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.

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.

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.

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;
7. Mandatory training (i.e., compliance training, professional development training).

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.

The policy incorporates the definition of "archived web content" from the federal digital access regulations, including Title II of the Americans with Disabilities Act and Section 504 of the Rehabilitation Act. The applicability of any exception, including the archived web content exception, should be determined on a case-by-case basis for each discrete category of content in consultation with counsel and other relevant stakeholders. The broad application of any exception to large swaths of digital content increases the risk of legal liability for the University.

Archived web content is IT that meets each 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; AND
2. Is retained exclusively for reference, research, or recordkeeping; AND
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.

With respect to the first criterion, note that while the paper documents and other physical media must pre-date April 24, 2026, the web content reproducing the paper documents or physical media may be created after April 24, 2026.

Archived web content must be "retained exclusively for reference, research, or recordkeeping." This primarily refers to "historic web content that, while outdated or superfluous" is maintained "for reference, research, or recordkeeping." Web content that is currently used to provide a University service, program, or activity is unlikely to satisfy this criterion of the archived web content exception. For example, academic courses or continuing medical education courses still in use would not meet the requirements of the second criterion.

Under the fourth criterion, archived web content must be organized and stored in a dedicated area clearly identified as being archived. When discussing this criterion, the Department of Justice rulemaking emphasizes the importance of predictability and flexibility. The paramount consideration when deciding how to label archived content is predictability for individuals with disabilities. Predictability means that disabled individuals are able to easily and clearly detect where there is digital content they may not be able to access. The University has broad flexibility in how it chooses to identify archived content. For example, the University may choose to house archived content on a separate webpage or website. Alternatively, the University may clearly identify specific sections on webpages that contain archived content, even if the webpage contains non-archived content in other sections.

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

While some social media platforms have limited accessibility features, University locations must use available accessibility features to ensure that their social media posts conform with WCAG 2.1 AA. For example, if a University location posts an image to a social media platform that allows users to include alt text, the location should ensure that appropriate alt text accompanies that image so that screen reader users can access the information.

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

1. Third-party digital content that the University directly provides or makes available; and
2. Digital content posted by a third party pursuant to a contract, license, or other arrangement with the University. Examples of products or services include, but are not limited to, University websites or mobile apps developed, maintained, or managed by third parties; third-party payment systems used by the University; and third-party websites or mobile applications used to make appointments for University medical services or to manage employee benefits.

Examples of Electronic Hardware include kiosks used to pay for parking or check in for medical appointments. In the policy paragraph about Electronic Hardware and/or Emerging Technologies, "discriminate" means preventing individuals with disabilities from fully using a location's services, programs, or activities; denying them the benefits of those services, programs, or activities; or giving them access that is not equal to what others receive.

Locations must ensure their use of Electronic Hardware and/or Emerging Technologies does not discriminate against individuals with disabilities. One way to do that is to provide prompt staff assistance to help someone complete a task on a kiosk, while protecting the person's medical and financial privacy. Another option is to use kiosks that include accessibility features, such as a 3.5 mm audio jack port that reads screen content aloud and tactile controls, like physical buttons or keypads, that allow users to fully navigate a system.

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.