
Most educators know that making digital resources accessible is important. Many also know about the Americans with Disabilities Act (ADA) that has been around since 1990. Some might even know about the Department of Justice’s Title II ADA recent ruling that mandates digital accessibility for state and local governments—including education systems.
But did you know the deadline for that mandate is coming up quickly? And is your school district ready?
Think someone else in your district is ensuring compliance? Think again.
“Everyone in a school district owns this responsibility,” says Luis Perez, Senior Director of Disability and Accessibility at CAST. With eight years of experience applying the CAST-developed Universal Design for Learning (UDL) framework, which has accessibility as a foundation, Perez stresses that this is no longer just a “best practice”—it is a legal mandate with a ticking clock.
Perez shares an overview of this landmark update to Title II of the ADA, along with a five-step plan your district can implement to ensure compliance.
What is Title II?
Title II of the ADA specifically governs state and local government entities, which includes public K-12 school districts, public universities, and community colleges. The core mission is simple: all services, activities, and programs provided by these institutions must be accessible to people with disabilities.
A recent ruling has introduced a rigorous, specific standard for digital content into the ADA. Public schools are now required to ensure their web and mobile content meets the international benchmark for accessibility: WCAG 2.1 Level AA.
Compliance is not a distant goal. For many, the deadline is fast approaching. The timeline is dictated by the population of the area the district serves:
- Districts serving > 50,000 people: Deadline is April 24, 2026.
- Districts serving < 50,000 people: Deadline is April 26, 2027.
An important note: “population” refers to the local census data (e.g., the 2020 Census) of the town or county, not the number of students enrolled in the schools.
A Shared Responsibility: The Cross-Functional Team
A common misconception is that accessibility is a “tech problem” for the IT department to solve. Perez emphasizes that true conformance requires a cross-functional team. While a leadership-level point person (such as a CIO or ADA Coordinator) must steer the ship, the responsibility is shared across:
- Curriculum and Instruction: Ensuring digital lesson plans are readable by screen readers and meet other accessibility requirements.
- Procurement: Vetting third-party software for accessibility before purchase.
- Special and General Education: Aligning classroom tools with student needs.
- Families and Community: Providing feedback on the user experience.
The Five-Step Plan for Conformance
Achieving WCAG 2.1 Level AA compliance might seem overwhelming, but it doesn’t have to be. Perez outlines a five-step approach to make the process manageable:
- The Audit: Conduct a comprehensive review of all technology properties to understand the current “state of the union” and the scope of work required.
- The Roadmap: Create a clear timeline to bridge identified gaps. Focus on “high-leverage” items—mission-critical systems like enrollment portals and high-traffic pages identified through web analytics.
- Procurement Reform: Update Request for Proposals (RFPs) to include strict accessibility requirements. This shares the burden of compliance with vendors.
- Staff Training: Build internal capacity. When teachers and staff know how to create accessible content from the start, you stop the “leaky bucket” of inaccessible materials.
- Documentation and Public Statement: Document every action taken. A public accessibility statement on the district website communicates transparency and progress to the community.
Tech & Learning also recently published Becoming More Digitally Accessible: Practical Steps Toward WCAG-Aligned Design, which offers more specific advice and tips.
The Role of the Vendor
School districts rely on a vast ecosystem of educational technology vendors. Under the new ruling, vendors must be proactive partners. Perez has this advice for companies selling to school districts:
- Maintain a public Accessibility Statement.
- Designate a clear point of contact for accessibility queries.
- Provide an Accessibility Conformance Report (ACR), generated through the Voluntary Product Accessibility Template (VPAT).
This documentation allows districts to evaluate whether a tool is a help or a hindrance to their compliance goals.
Why It Matters: Beyond Legal Liability
The consequences of ignoring these deadlines are significant. Beyond the threat of costly investigations, legal complaints, and lawsuits, there is the matter of reputational damage.
However, Perez encourages districts to look beyond the fear of litigation. Accessibility should not be viewed as a one-time “snapshot” or a checkbox for compliance. Instead, it is about creating a sustainable, continuous process that ensures every student has equal access to education.

