Final Rule on Web Accessibility

The Department of Justice (DOJ) filed a final rule to provide additional regulatory requirements for implementing Title II of the Americans with Disabilities Act. The final rule outlines specific requirements that public entities, including the University of Washington, must follow to ensure web content and mobile applications (apps) are accessible to people with disabilities. DOJ has a fact sheet that summarizes the rule and this webpage will be updated as more information is available to share with the UW community.

Background

Public entities often deliver services and programs through websites and mobile apps, which can create access barriers for people with disabilities when not designed with accessibility in mind. For example, blind individuals may rely on screen readers to interpret visual information on a website. However, if a website lacks alternative text to describe the image, these users cannot access publicly available information. The new rule aims to ensure that all people with disabilities have full and equal access to public entities services, programs, and activities available on mobile apps and websites.

Key Components of the Rule

Requirements

Public entities shall ensure that web content and mobile apps made available directly or through a contractual, licensing, or other arrangements, are readily accessible and usable by individuals with disabilities.

Technical Standard

Public entities shall comply with the technical standard set by the Web Content Accessibility Guidelines (WCAG) Version 2.1, Level AA for web content and mobile apps. Public entities are required to adhere to these standards for all web and mobile content available to the public or used in services, programs, and activities.

Essential Definitions

• Web Content: The information and sensory experience communicated to the user by means of a user agent, including code or markup that defines the content’s structure, presentation, and interaction. Examples of web content include text, images, sounds, videos, controls, animations, and conventional electronic documents.
• Conventional Electronic Documents: Web content or content in mobile apps that is in the following electronic file formats: Portable document formats (“PDF”), word processor file formats, presentation file formats, and spreadsheet file formats.
• Mobile applications: Software applications downloaded and designed to run on mobile devices, such as smartphones and tablets.

Exceptions 

In limited situations, some kinds of web and mobile app content may not have to meet the technical standard. The DOJ fact sheet has more details on each of these exceptions:

• Archived web content: Content not currently used or altered since being archived by a public entity, and kept only for reference, research, or record-keeping purposes.
• Preexisting conventional electronic documents: Documents available on a website or mobile app before the date of compliance.
• Third-party content: Content posted by third parties, unless the third party is posting due to contractual, licensing, or other arrangements with the public entity.
• Individualized password-protected documents: Password-protected or otherwise secured documents about a specific person, property, or account.
• Preexisting social media posts: Social media posts made before the date of compliance.

Compliance Timeframe 

Public entities with populations of 50,000 or more persons, including the University of Washington, must comply with the federal regulations by April 24, 2026.

Preparing for the Final Rule at the UW

The Office of the ADA Coordinator has been taking proactive steps with institutional partners to ensure digital accessibility across University systems, including UW Medicine. Key initiatives include establishing a new Deputy ADA Coordinator for Digital Accessibility in the Office of the ADA Coordinator and redefining the role of Director of Digital Accessibility within Information Technology. UW-IT is in the process of procuring enterprise-wide tools to support the assessment of University websites and mobile apps against the technical standards. In terms of strategic planning, the Office of the ADA Coordinator is collaborating with University leaders and partners to further develop UW-IT’s digital accessibility plan and help guide enterprise-wide efforts. Key groups involved to date include but are not limited to: Office of the ADA Coordinator Advisory Groups, ADA & Accessibility Steering Committee, UW Medicine, and the UW-IT Accessibility Taskforce.

Frequently Asked Questions