Digital Accessibility

What Must Be Compliant*

*Not an exhaustive list

Public-Facing Websites

• All pages, online documents, and interactive elements on district websites.

• Includes calendars, announcements, enrollment forms, and portals.

• Videos (YouTube captions are not enough - these are not compliant)

• Audio-only / Visual-only Content

• Online Learning Management Systems

• 3rd Party Publisher Content (eBooks & Curriculum)

• New Social Media Posts

   

Mobile Applications

• Apps used by students, parents, and staff for communication, learning, or administration. Digital Instructional Materials

   

Online learning platforms, course content, and homework portals.

• Online Exams / Quizzes

• PDFs, presentations, and multimedia are posted for student use. Administrative and Public Service Content

• Online payment systems, registration forms, and employment applications.

• Any digital service provided to the public.

   

Exceptions (Review exceptions in actual legal rule with a lawyer)

• Pre-existing Conventional Electronic Documents

• Content posted by a third-party (i.e. message board where content is posted by a parent, for example, etc.)

• Individualized Documents that are password protected

• Pre-existing social media posts

• Ask lawyer about 'Safe Harbor' clause (for very specific instances)

Regarding Archived Content

**This information is provided as a courtesy from Region 14 ESC. We highly recommend you check with your district legal department for complete and final details.

Archived content does not need to be made accessible — only if it meets all four required conditions (listed below) of the ADA Title II archive exemption.

Four Conditions that must be met for Archived Content

1. It was created before April 24, 2026 (the compliance deadline), or is a reproduction of physical media created before that date. --- AND ---
2. It is kept ONLY for reference, research, or recordkeeping. --- AND ---
3. It is not altered or updated after being archived. --- AND ---
4. It is stored in a clearly identified, dedicated archive area.

If any of these four criteria above are not met, the content must meet WCAG 2.1 AA.

NOTE:

• “Old” content is not automatically archived.
• Content still used in a current service, program, or activity must be made accessible, regardless of age.
• If it is public-facing, it must be accessible, no matter how old it is.
• If content is not stored in a dedicated archive area (i.e. the main website area), it must be accessible.
• Even exempt archived content must be remediated if an individual requests it.

Location of Archived Content

The DOJ does not mandate a specific technical structure, but it does require that archived content be:

• Clearly separated from active content
• Clearly labeled as archived
• Not mixed into normal navigation or current program pages

DOJ guidance explicitly states that public entities may:

• Create separate pages or sections
• Create separate archive areas or even separate archive sites
• Use clear labeling to signal archival status  DOJ Deep Dive Part 2

Archive Best?Practice Website Placement (Strongly Recommended)

Most districts use one of these models:

Option A: Archive Section Within Main Site

district.org/archived-content/

district.org/about/archive/

Option B: Separate Archive Subdomain

archive.district.org

records.district.org

Both models above are acceptable.
DOJ does not require the word “archive” in the URL— but clarity is essential.
Using /archive/ in the URL is:

• Strong evidence of intent
• Easier to defend in audits or complaints
• Easier for users and staff to understand

If a user could reasonably mistake the content as “current,” you are at risk.

Archived pages should include a visible notice, such as:

"Archived Content
This page is maintained for historical and recordkeeping purposes only and may not meet current accessibility standards. If you need this content in an accessible format, please contact [Accessibility Contact]."

DOJ guidance stresses that labeling is part of compliance, not a courtesy

Archived content:

• May remain publicly accessible
• Must not be presented as current guidance, instructions, or services
• Should be reached through:
  • “About,” “Records,” “History,” or “Archived Content” links
  • Not through homepage banners, current program pages, or search prioritization

Compliance Checklist for School Districts

Text and Structure

• Provide alt text for all images, charts, and graphics.

• Use descriptive headings and maintain a logical reading order.

• Ensure lists and tables are properly formatted for screen readers.

Navigation and Interaction

• Hyperlinks

• All functionality must be keyboard accessible (no mouse-only actions).

• Include skip navigation links for long pages.

• Ensure focus indicators are visible when tabbing through content.

Visual Design

• Maintain a color contrast ratio of at least 4.5:1 for text and background colors.

• Avoid using color alone to convey meaning (e.g., red for errors).

• Allow text resizing up to 200% without loss of content or functionality.

Multimedia

• Provide captions for all videos and transcripts for audio content.

• Videos (YouTube captions are not enough)

• Avoid auto-playing media; if unavoidable, include pause/stop controls.

Forms and Interactive Elements

• Label all form fields clearly and associate labels programmatically.

• Provide error messages and instructions for corrections.

• Ensure time-limited activities have adjustable time settings.

Mobile Apps

• Verify touch targets are large enough and properly spaced.

• Ensure screen reader compatibility for all app elements.

• Test with both iOS and Android accessibility tools.

Testing and Monitoring

• Run automated accessibility checks (e.g., WAVE, Axe).

• Conduct manual testing with screen readers (NVDA, JAWS).

• Document compliance progress and remediation plans.

1. Conduct an inventory of digital assets to identify accessibility gaps.

2. Develop and implement an accessibility roadmap and policies.

3. Provide accessibility training for staff. (Region 14 can assist with training)

4. Incorporate accessibility requirements into procurement contracts with third-party vendors (VPAT, VADSIR).

5. Prioritize remediation of issues, and, in cases where digital material cannot be made accessible, provide a conforming alternative version, with approval from the Disability Rights Office.

Suggested High-Priority Items to Remediate First

More Information & Sources

Extension of Compliance Dates for Nondiscrimination on the Basis of Disability; Accessibility Web Information and Services of State and Local Government Entities

ADA.gov – Fact Sheet: New Rule on the Accessibility of Web Content and Mobile Apps Provided by State and Local Governments

ADA.gov – State and Local Governments: First Steps Toward Complying with the Americans with Disabilities Act Title II Web and Mobile Application Accessibility Rule

Accessibility of Web Content and Mobile Apps Provided by State and Local Government Entities: A Small Entity Compliance Guide

Final Rule Text - Federal Register Document number 2024-07758

Census.gov Programs-Surveys - SAIPE

Americans with Disabilities Act Title II Regulations Supplementary Information

Web Content Accessibility Guidelines - Version 2.1