Accessibility

Federal Digital Accessibility Requirements

The Department of Justice (DOJ) issued a new rule for digital accessibility under Title II of the Americans with Disabilities Act (ADA) to ensure that all available state and local government services, programs, and activities are accessible to everyone, including people with disabilities.

By April 24, 2026, ADA Title II stipulates that all public entities, including public institutions of higher education, must ensure that their digital resources (web and mobile applications) comply with Web Content Accessibility Guidelines (WCAG) 2.1, Level A and AA.

Inclusions

ResourceDefinition
General Web ContentThis refers to any information and sensory experiences communicated to a user by means of a user agent—including code or markup—that defines the content’s structure, presentation, and interaction. Examples include but are not limited to text, images, sounds, videos, controls, animations, and conventional electronic documents.
Electronic Documents and MaterialsThis refers to web content that is in a portable document format (PDF), word processor, presentation, or spreadsheet file format. Examples include e-books, academic journals, digital newsletters, and email communications.
Mobile Applications and Social MediaThis refers to web content in a mobile application that is made available via a social media platform or software applications downloaded and designed to run on mobile devices, such as smartphones and tablets.
Multimedia ContentThis refers to multimedia content and includes online course content and platforms; web-based textbooks; web-based and mobile tools for submitting assignments, participating in discussions, and taking exams; video conferencing tools used for virtual classrooms, etc.

Exceptions

In limited situations, some kinds of web and mobile app content may not have to meet the technical standard. Some of these exceptions 1 include:

  • Archived Web Content → This applies only to content created before April 24, 2026; kept only for reference, research, or recordkeeping; kept in a special area for archived content; kept in a special area for archived content; that has remained unaltered since it was archived.
  • Preexisting Documents → This applies only to word processing, presentation, PDF, or spreadsheet files that are available online before April 24, 2026 and are not currently being used to apply for, access, or participate in PSU services, programs, or activities.
  • Third-Party Content → This applies only to content that is posted by a third party where the third party is not posting due to contractual, licensing, or other arrangements with PSU.2
  • Password-Protected Content → This applies only to word processing, presentation, PDF, or spreadsheet files that are about a specific person, property, or account and are password-protected or otherwise secured.
  • Old Social Media Posts → This applies only to old, preexisting social media posts created and posted before April 24, 2026.

1Note that most exceptions to the new federal rule must meet several points in order to not meet WCAG. 2.1 Level A and AA. Reference Summary of Exceptions (ada.gov) for more information.

2Note that if PSU contractually relies on a contractor or another third party to post content on its behalf or on behalf of its community, PSU retains responsibility for ensuring the accessibility of that content. Reference Content Posted by a Third Party (federalregister.gov) for more information.

Technical Guidelines

WCAG. 2.1 Level A and AA is now the federally mandated technical standard for digital accessibility conformance under Title II of the Americans with Disabilities Act (ADA). All PSU digital resources must conform to the 30 Level A and 20 Level AA success criteria.

What counts as “web content and mobile apps?”

  • Audio, video, and multimedia
  • Cloud and software applications
  • Digital forms and surveys
  • Electronic documents
  • Email and enewsletters
  • Instructional content
  • Learning management systems
  • Social media content
  • Websites and web applications

What are “Level A and AA success criteria?

Learn more about the World Wide Web Consortium’s Web Content Accessibility Guidelines (WCAG) and success criteria via the Web Accessibility Initiative's WCAG 2 Overview.

World Wide Web Consortium Logo

Shared Responsibility

Portland State University (PSU) is committed to maintaining an accessible digital presence, in accordance with our philosophical principle to provide equitable access to quality education, and in accordance with federal laws and regulations. PSU’s Digital Accessibility Policy (new policy updates are currently in progress) establishes the requirement for procuring, designing, and managing accessible Digital Resources on behalf of PSU.

Meeting WCAG. 2.1 Level A and AA requires transformative change in how PSU approaches digital accessibility, transitioning from a reactive to a proactive digital accessibility approach—engaging in a distributed, collaborative effort to design and procure accessible digital resources from the start, proactively address legal risk, embed accessibility knowledge across the institution, and solidify the university’s continued commitment to digital inclusion for all students, staff, and faculty. 

Additional Resources

  • DOJ ADA Fact Sheet: A high-level summary of the new tule on the accessibility of web content and mobile applications
  • Final DOJ Ruling: The full length rule on web and mobile applications accessibility as published in the Federal Register
  • WCAG 2.1 Level A and AA: The technical standard for conformance with web and mobile accessibility under ADA Title II

Last Reviewed: January 14, 2026