ADA Title II update

In April 2024, the Department of Justice issued a new ADA regulation. This rule requires Cal State University Los Angeles to ensure that all websites, webpages, web services, academic course content, and digital media (such as PDFs and videos) are accessible and meet the mandated WCAG 2.1 Level AA standards by April 24, 2026. The rule advances the ADA’s commitment to building a more inclusive and equitable society.

For those who prefer a video overview, the U.S. Department of Justice has provided a recording: Webinar: Webinar: Americans with Disabilities Act Title II Web & Mobile Application Accessibility Rule

Key Requirements of the Rule

Minimum Standards and Technical Compliance

Under ADA Title II, all web content and mobile applications must comply with the Web Content Accessibility Guidelines (WCAG) 2.1, Level AA, which set the minimum technical accessibility standards.

Web content and mobile apps include:

  • Websites and web applications, including electronic documents hosted on them
  • Mobile apps (e.g., for phone, tablet, wearable devices, and future mobile technology), including electronic documents hosted on them
  • Digital course materials, including content made available online or provided to students as a requirement towards completion of a course or program (e.g., video, online textbook)
  • Social media posts (not the platforms themselves), including electronic documents in the posts

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 are 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 designed to run on mobile devices, such as smartphones and tablets, which can be downloaded through app stores or accessed via mobile browsers. 

Exceptions

  1. Archived Web Content: Material that is three years old or older, retained for reference, research, or record-keeping purposes, and clearly labeled as archival. This content must be placed in a designated archive section of the website and may not be modified once archived.
  2. Conventional Electronic Documents: PDFs and other files archived for reference, research or record-keeping that are no longer relevant to accessing programs, services or activities of the campus. This is defined broadly; if this provides information to engage in any educational or shared governance, student or public-focused service, or otherwise supports an active program, service, or activity, it must be accessible. This is primarily to reduce the burden of remediating outdated documents like previous year annual reports, schedules, and event flyers.
  3. Third-Party Content: Content posted by third parties with no contract with the university, like public comment forms and bulletin boards.
  4. Password-Protected Documents: Bills, transcripts, or files for individuals.
  5. Old Social Media Posts: Posts made before April 24, 2026, do not need to be updated.

Upon request, we are required to provide remediated versions of these excepted documents within a reasonable amount of time. For most archival content, 5 business days is a reasonable response time.  We must provide an effective method of communication, which is provided by the accessibility statement for our Drupal environment.

ADA Deadline Preparation Tips

  • Follow best practices for creating new content.
  • Use HTML pages instead of downloadable documents like PDFs whenever possible.
  • Review and resolve accessibility issues in accessibility reports sent to content owners. Reports for your content, whether associated with Drupal or not, are available. Please contact ATI Compliance for assistance.
  • Remove any content, especially downloadable documents, that are no longer needed. Old downloadable files can be hot-linked, which may be found even if deprecated.
  • Move any videos used to a department-managed YouTube account or Panopto to simplify captioning. (We are reviewing options for captioning services and will notify the campus if it becomes available.)
  • Any software used by students or the public must go through the PCR process, even if there is no cost.