Digital Accessibility

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.

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.

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.

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.

In limited situations, some kinds of web and mobile app content may not have to meet the technical standard. These exceptions, described in Rule Guidance and FAQs, include:

Archived web content

Content not currently used or altered since being archived by a public entity, and kept only for reference, research, or recordkeeping 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.

The DOJ fact sheet has more details on each of these exceptions.

• DOJ fact sheet: A high-level summary of the new rule provided by the Department of Justice.
• Final DOJ Rule: The full length rule on web and mobile app accessibility as published in the Federal Register.
• ADA Rule Slides: Powerpoint slides created to raise awareness of the new rule.
• Recorded Presentation on the Rule: A presentation created by the Office of the ADA Coordinator to supplement the slide deck on the rule.

The new rule will require both enterprise-wide and local unit efforts to ensure that web content and mobile apps comply with the technical standards. All owners, managers, and creators of web and mobile app content will need to understand how to comply with the technical standards. Staff and faculty will play a critical role in helping the University meet accessibility standards by taking steps to create and deliver accessible digital content.

We are aware that some staff and faculty have raised concerns about their ability to meet the standards and whether they would be legally responsible if digital content is found to be inaccessible. Please be assured the University will stand behind staff and faculty who act in good faith by following policy and guidance on meeting accessibility expectations.

Acting in good faith includes making reasonable efforts to:

• Follow best practices and guidance from the ADA Digital Accessibility Initiative on how to improve accessibility in your digital content.
• Use accessibility checkers when available and respond to their feedback.
• Use approved, centrally supported tools such as Canvas, Panopto, Office 365, and Zoom.
• Collaborate with central accessibility offices when issues are complex or when they arise through the accommodation process.

Together, with steady progress, we can meet not only our legal obligations but our commitment to ensuring equal access and inclusive experiences at the UW.

Actions on the federal level regarding the interpretation and enforcement of other civil rights laws have prompted questions about potential impact on enforcement of the new ADA rule, effective April 2026. ​

The University remains committed to providing individuals with disabilities equal access to its programs, services, and activities. The work of the ADA Digital Accessibility Initiative will continue to ensure that the UW’s digital content is accessible and meets compliance obligations under state and federal regulations and policies. If new guidance on how to meet state and/or federal obligations is issued or the legal landscape changes, we will update the UW community.

What we know:

• No executive orders have been issued to pause enforcement action relating to disability.
• The digital accessibility rule is a final rule that has already been issued. A new full rulemaking process​ would be required to revoke and replace it. No indicators point to this.
• Even if the DOJ does not make enforcement of the rule a priority in 2026, individuals and organizations may file lawsuits under the rule​.
• No legal challenges to the rule have been filed.

The University also must comply with state laws and policies regarding disability access and accessibility. Washington state is in the process of updating its Digital Accessibility Policy, which sets technical standards for web content that state agencies and entities must follow.

Digital course content is to be treated like any other web or mobile app content. This would include digital content such as syllabi, readings and textbooks, recorded lectures and videos, slide decks, Canvas pages, assignments and handouts, images and diagrams, and course websites.

The Teaching @ UW website has guidance and resources focused on common types of course materials used across disciplines. More information will be available starting spring 2025, as the Academic Course Content Action Team shares recommendations.

UW Medicine content is to be treated like any other web or mobile app content under these standards.

In addition to the DOJ’s new rule under Title II of the American with Disabilities Act, UW Medicine also falls under the guidance of the Department of Health and Human Services (HHS). In April 2024, HHS also issued a final rule to strengthen the implementation of Section 504 of the Rehabilitation Act of 1973. According to this rule, all websites and mobile applications linked to health and human services, including those utilized by UW Medicine, must now adhere to the WCAG 2.1, AA technical standards.

UW-IT is implementing an enterprise-wide tool, DubBot Web Accessibility Checker, to support the assessment of University websites against the technical standards. The Ally in Canvas courses tool checks for accessibility issues in course content. UW-IT Accessibility Technology Services has a IT Accessibility Checklist that outlines the principles of WCAG to support web designers, developers, and content creators, in creating accessible content.

Visit our What You Can Do Now page that provides steps that faculty and staff can take now to prepare for this important transformation.

Over the past decades, federal regulations and guidelines have played a crucial role in promoting digital accessibility and ensuring equal access to information for individuals with disabilities. These include, but are not limited to, Section 504 of the Rehabilitation Act of 1973, the Americans with Disabilities Act of 1990, Amendment Section 508 of the Rehabilitation Act in 1998, and Web Content Accessibility Guidelines (WCAG) 1.0 in 1999. Despite these legislative milestones, ongoing efforts are needed to address evolving technologies and challenges that remain in the digital world across various sectors.

To learn more, read the Level Access article Key Milestones in Website Accessibility Law.