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 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.

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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. What constitutes "archived web content" under the Policy?

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.

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15. 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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16. 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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17. 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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18. 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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19. 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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20. 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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21. What can Locations do to ensure their use of Electronic Hardware does not discriminate against individuals with Disabilities?

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.

22. Is YouTube considered a "social media platform" under the Title II of the Americans with Disabilities Act and Section 504 of the Rehabilitation Act digital access regulations?

Yes, probably. The federal digital access regulations provide an exception for social media posts on social media platforms made before April 2, 2026, stating that such posts do not need to conform to WCAG 2.1 AA. See 28 C.F.R. § 35.201(e). The Title II rulemaking explains that "social media platforms" refer to third-party websites or mobile applications "whose primary purpose is to enable users to create and share content in order to participate in social networking (i.e., the creation and maintenance of personal and business relationships online through websites and mobile apps like Facebook, Instagram, X (formerly Twitter), and LinkedIn)." 28 C.F.R. Pt. 35, App. D.

While the non-exhaustive list of "social media platforms" in the Title II rulemaking does not include YouTube, there is a good-faith argument that YouTube is a "social media platform" as that term is used in the Title II and Section 504 digital access regulations. The primary purpose of the YouTube platform is to enable users to create, upload, share, and interact with content, and to engage in social networking through subscriptions, comments, live chats, community posts, and other interactive features. Like the platforms listed in the Title II rulemaking, YouTube facilitates the creation and maintenance of personal and organizational relationships online.

Accordingly, University locations may decide to treat YouTube as a social media platform for purposes of applying the exception for social media posts made before April 24, 2026. The University's YouTube videos posted before April 24, 2026, do not need to conform to WCAG 2.1 AA. If a University location receives a request to make a YouTube video posted before April 24, 2026, accessible, it should do so if conformance with WCAG 2.1 AA would not constitute a fundamental alteration or undue burden. University locations should continue to ensure that new YouTube content posted after April 24, 2026, conforms to WCAG 2.1 AA.

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23. What should I do if a social media platform does not allow certain accessibility features, like the ability to add audio description or captions to social media posts?

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.

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