A large university website commonly runs to tens of thousands of pages, maintained by hundreds of content editors across academic departments, administrative offices, research centers, and student services. The central web team, when one exists, typically consists of two to five people who are responsible for the content management system (CMS), the primary templates, and the institution's overall web standards, while having limited authority over the content that departments publish within those templates. This is the structural condition that makes university accessibility difficult: the web team cannot review every page, the content editors were not hired for their web expertise, and the institution is legally responsible for all of it.
The Legal Landscape
University websites sit at the intersection of multiple accessibility requirements, and the enforcement landscape has accelerated since 2023.
Title II of the Americans with Disabilities Act (ADA): The Department of Justice (DOJ) published a final rule in April 2024 requiring state and local government entities (including public universities) to make their web content conform to Web Content Accessibility Guidelines (WCAG) 2.1 Level AA. On 20 April 2026 the DOJ published an interim final rule extending both compliance dates by one year, so the operative deadlines are now 26 April 2027 for public entities whose jurisdiction has a total population of 50,000 or more, and 26 April 2028 for those under 50,000 and for special district governments. The 50,000 figure describes the population of the government the institution belongs to, meaning the state, county, or city that established it, and not the size of the student body. A campus of 12,000 students that is an instrumentality of a populous state falls under the earlier deadline, not the later one, so confirm which jurisdiction figure your institution is measured against before you plan against a date. This is no longer guidance or best practice; it is a regulatory requirement with a specific conformance standard and a specific deadline.
Section 504 of the Rehabilitation Act: Applies to institutions that receive federal financial assistance. Section 504 has long prohibited disability discrimination in programs and activities, and the Office for Civil Rights (OCR) within the Department of Education has consistently interpreted "programs and activities" to include websites, learning management systems, and digital course materials. OCR resolution agreements are the most common enforcement mechanism: the university agrees to remediate its digital properties, establish an accessibility policy, provide training, and report progress over a multi-year period.
Private litigation: Title III of the ADA (which applies to private universities as "places of public accommodation") has generated a sustained volume of demand letters and lawsuits against higher-education institutions since 2018, though no authoritative public count of higher-education-specific filings exists. The most common targets are admissions portals, financial aid applications, and course registration systems, all high-stakes pages where inaccessibility has immediate, measurable impact on a prospective or current student's ability to participate.
After Reading This Section
Determine which deadline applies to your institution, which means identifying the jurisdiction your institution is an instrumentality of and using that population rather than your enrollment (26 April 2027 where that jurisdiction has 50,000 or more people, 26 April 2028 below that threshold and for special district governments). Confirm whether your institution has received any OCR complaints or resolution agreements. If you are a private university, review whether your state has adopted web accessibility requirements that go beyond federal law.
Where to Start: The Highest-Impact Pages
A university cannot make 30,000 pages accessible simultaneously, and attempting to do so typically results in shallow fixes applied everywhere rather than thorough remediation applied where it matters most. The more productive approach is to prioritize by impact: which pages, if inaccessible, cause the most harm to the most people?
The pages listed above share a common property: they are transactional. A user is trying to do something (apply, register, pay, enroll), and the page is the mechanism for doing it. When a transactional page is inaccessible, the user cannot complete the task, and the consequence is concrete and immediate. Informational pages (department descriptions, faculty bios, event listings) matter too, especially when they contain essential information available nowhere else, yet the transactional pages are where inaccessibility inflicts the most direct harm.
The CMS Problem
Most university websites run on a CMS (Drupal, WordPress, Terminalfour, OmniUpdate, or a proprietary system) that provides templates, editing interfaces, and publishing workflows. The CMS is simultaneously the university's greatest accessibility asset and its greatest accessibility liability, because it determines the baseline accessibility of every page published through it.
What the CMS controls
The templates that the CMS provides to content editors define the page structure: the landmark regions (<header>, <nav>, <main>, <footer>), the heading hierarchy, the navigation patterns, the skip links, the focus management, and the color palette. When these templates are accessible, every page published through them inherits that accessibility as a baseline. When they are not, every page inherits the failures, and no amount of content-level remediation can fix a template-level problem.
What the CMS cannot control
Content editors can override the accessible baseline in ways the CMS cannot prevent. They paste formatted text from Word documents, creating inline styles that break the heading hierarchy. They insert images without alternative text. They build tables by merging cells in ways that destroy the header-cell relationship. They embed third-party widgets (maps, calendars, social media feeds) that introduce their own accessibility barriers. They upload Portable Document Format (PDF) documents that are untagged, scanned, or both. The CMS provides the structure; the content editors provide the content; and the content is where most accessibility failures actually live.
What to do about it
The highest-leverage fix is to make the CMS enforce accessibility at the template level: require alternative text before an image can be published, restrict heading levels to maintain hierarchy, flag insufficient color contrast in the editor, and provide accessible defaults for common components (accordions, tabs, carousels) rather than requiring content editors to build them from scratch. The second-highest-leverage fix is to train content editors, not on WCAG as an abstract standard, yet on the specific actions that produce accessible content within the specific CMS they use every day.
After Reading This Section
Run an automated accessibility scan on your homepage and three high-traffic templates. If the same failures appear across all of them (missing landmarks, broken heading hierarchy, absent skip links), those are template-level issues that the web team owns. If the failures vary by page, they are content-level issues that require editor training and CMS enforcement.
The Document Problem
Universities publish an extraordinary volume of PDF documents: course syllabi, financial aid guides, academic policies, research publications, committee reports, event flyers, and institutional records. The 2024 DOJ rule treats conventional electronic documents, meaning PDF, word processor, presentation, and spreadsheet files, as web content, so documents you publish from your compliance date onward carry the same WCAG 2.1 AA obligation as the pages around them. The rule does not require you to remediate everything already sitting on your servers. Under 28 CFR 35.201(b), conventional electronic documents that were already published before your compliance date are excepted, unless they are currently used to apply for, gain access to, or participate in a service, program, or activity. Editing or re-uploading such a file after the compliance date removes the exception. Section 35.201 separately excepts archived content and individualized password-protected documents. For a university sitting on a large document backlog, the practical consequence is that active forms, applications, and course materials matter far more than volume.
Most university PDFs are inaccessible. They are untagged (no structural information for assistive technology), scanned without optical character recognition (no text layer at all), or auto-tagged with incorrect structure (the tag tree exists formally yet the reading order, heading hierarchy, and table headers are wrong). The volume is the challenge: a university that publishes 5,000 PDFs per year cannot remediate them individually at a sustainable cost.
The practical approach has three layers. First, establish a document accessibility standard that all new documents must meet before publication, and provide templates in Microsoft Word and Adobe InDesign that produce accessible PDF output by default. Second, prioritize retroactive remediation by impact: syllabi, financial aid documents, admissions materials, and official policies first, because these are the documents that students most need and that litigation most frequently targets. Third, identify documents that should not be PDFs at all, because the content would be better served as a web page, and convert them.
Building a Sustainable Program
An accessibility initiative that depends entirely on the central web team will not scale. A university website is too large, too distributed, and too constantly changing for a small team to audit, remediate, and maintain on its own. Sustainability requires distributing responsibility to the people who create content, while providing them with the tools, training, and support to do it well.
Central Web Team
Owns templates, CMS configuration, global navigation, and accessibility standards. Provides accessible components and documentation. Runs automated monitoring.
Department Editors
Create and publish content within CMS templates. Need training on alt text, heading structure, link text, and document accessibility. Most common source of content-level failures.
IT / Development
Build custom integrations, manage third-party vendor relationships, handle authentication systems. Responsible for keyboard operability, focus management, and ARIA implementation in custom code.
Disability Services
Receives accommodation requests, identifies real-world barriers, provides user-testing perspective. Essential feedback loop that connects technical accessibility work to the students it affects.
Accessibility champions
The model I find most convincing for universities is the accessibility champion network: one person per department (usually the primary content editor, occasionally a staff member with a personal interest in the topic) who receives additional training, serves as the first point of contact for accessibility questions within their department, and participates in a monthly meeting with the central web team. This model works because it acknowledges the reality that the web team cannot be in every department, while creating a channel for accessibility knowledge to flow outward from the center and for accessibility problems to flow inward from the edges.
Automated monitoring
Automated accessibility scanning tools (Siteimprove, Pope Tech, Monsido, or open-source tools like axe and Pa11y) can monitor thousands of pages continuously and flag regressions. They will not catch everything: published studies put automated detection somewhere between roughly 13% and 40% of WCAG barriers, and the spread is driven as much by how the denominator is counted as by which tool is used. They are, however, indispensable for a university website, because the alternative is not catching regressions at all. The most useful configuration is a weekly scan with automated alerts when new high-severity issues appear, combined with a quarterly manual audit of the highest-impact pages.
Training that sticks
Accessibility training for content editors fails when it is a single session delivered once during onboarding and never reinforced. Training that works is specific to the CMS the editor uses, focused on the five most common content-level failures (missing alt text, broken heading hierarchy, non-descriptive link text, inaccessible tables, untagged PDFs), and delivered in short sessions (30 minutes maximum) with hands-on exercises in the actual editing environment. Follow-up matters more than the initial session: a monthly email with one accessibility tip tied to a real example from the university's own website is more effective than an annual compliance webinar.
After Reading This Section
Identify whether your institution has a named accessibility coordinator. If it does, determine whether that role has budget authority, institutional support, and a reporting line that reaches senior leadership. If it does not, make the case for creating one: the DOJ compliance deadline requires a sustained program, and a program without a named owner will not survive the first leadership transition.
Procurement: The Upstream Fix
Every third-party product a university purchases (the learning management system, the student information system, the library catalog, the event registration platform, the virtual tour, the chatbot) becomes part of the university's digital experience and falls under the same accessibility requirements. When a vendor's product is inaccessible, the university inherits that inaccessibility as its own legal liability.
The highest-leverage point for accessibility in higher education is the procurement process, because it is the moment where the institution has the most power to require accessibility before a contract is signed, rather than discovering inaccessibility after the product is deployed and the switching cost is prohibitive.
Effective procurement requires three elements. First, include specific accessibility requirements in every Request for Proposal (RFP): require vendors to demonstrate WCAG 2.1 AA conformance with a Voluntary Product Accessibility Template (VPAT) or equivalent documentation, and specify that the VPAT must be current (within the last 12 months) and specific to the version being offered. Second, test the product with assistive technology before signing: a VPAT is a self-assessment, and vendor self-assessments are frequently optimistic. Ten minutes of keyboard-only testing and screen reader testing will reveal whether the product's accessibility claims match its actual behavior. Third, include accessibility maintenance requirements in the contract: a product that is accessible at purchase and inaccessible after an update is a procurement failure, and the contract should require the vendor to maintain conformance and remediate regressions within a specified timeframe.
The Compliance Checklist
This checklist is not comprehensive, yet it covers the actions that most universities need to take first. Each item is a concrete step that a web team can complete, delegate, or schedule.
University Accessibility Checklist
- Confirm which DOJ compliance deadline applies (26 April 2027 or 26 April 2028, determined by the population of the jurisdiction your institution belongs to rather than by enrollment)
- Publish an accessibility statement with a contact method for reporting barriers
- Run an automated scan of the top 100 highest-traffic pages
- Audit the six highest-impact transactional pages with keyboard-only testing
- Verify that CMS templates include proper landmarks, skip links, and heading hierarchy
- Require alt text before images can be published in the CMS
- Establish a document accessibility standard for all new PDFs
- Audit existing PDFs by impact: syllabi, financial aid, admissions, policies first
- Review vendor VPATs for the learning management system (LMS), student information system (SIS), and library catalog
- Add accessibility requirements to the procurement RFP template
- Train content editors on the five most common content-level failures
- Designate accessibility champions in departments with the most web content
- Set up automated monitoring with alerts for new high-severity issues
- Schedule quarterly manual audits of the highest-impact pages
- Establish a reporting line from the accessibility coordinator to senior leadership
What Sustainability Looks Like
A sustainable university accessibility program is one that survives staff turnover, budget cycles, and leadership changes. It has three characteristics.
First, it is embedded in process rather than dependent on individuals. The CMS enforces accessibility at the template level. The procurement process requires accessibility documentation. The publishing workflow includes an accessibility check. When these systems are in place, accessibility continues even when the people who built the program move on.
Second, it is measured. The web team tracks a small set of metrics (automated scan score over time, number of pages with critical issues, percentage of new documents meeting the accessibility standard, mean time to resolve reported barriers) and reports them to leadership quarterly. Measurement creates accountability, and accountability creates budget.
Third, it is connected to the people it serves. The disability services office, the students who use assistive technology, and the community members who interact with the university's digital services are not abstract beneficiaries; they are the program's most important evaluators. A quarterly conversation with disability services about what barriers students are actually encountering is worth more than any automated scan, because it reveals the problems that the metrics cannot see.
After Reading This Section
Ask yourself whether your institution's accessibility work would continue if the person leading it left tomorrow. If the answer is no, the most important next step is not technical; it is organizational. Build the program into the institution's processes before building it into the website's code.
This guide references the DOJ's April 2024 final rule on web accessibility under Title II of the ADA (89 FR 31320), Section 504 of the Rehabilitation Act, and the Web Content Accessibility Guidelines (WCAG) 2.1 Level AA. The compliance deadlines cited (26 April 2027 and 26 April 2028) reflect the DOJ interim final rule published 20 April 2026 (91 FR 20902), which extended the original implementation timeline by one year. Universities should consult legal counsel for institution-specific compliance obligations, as state laws may impose additional requirements.