Colleges and universities ยท ADA Title II and Section 504
Accessible documents for colleges and universities
The deadline lands before most spring finals. Under the Justice Department’s ADA Title II rule, public colleges and universities have until April 26, 2027 to make the documents they post online meet WCAG 2.1 Level AA. That means syllabi, catalogs, forms, minutes and reports, not just web pages.
Most public colleges have one date: April 26, 2027.
The rule sorts schools by the population of the government they belong to, not by enrollment. A state university counts its whole state’s population, so it falls in the first group. Enrollment does not count.
| Your institution | Comply by |
|---|---|
| Public universities, state college systems, and colleges that belong to a government of 50,000 or more | April 26, 2027 |
| Colleges that belong to a government under 50,000, and special district governments of any size | April 26, 2028 |
Who the rule covers
ADA Title II applies to state and local governments and the agencies that belong to them. The Justice Department names community colleges and public universities among them. In April 2024 it set a technical standard for their websites, mobile apps and online documents: WCAG 2.1 Level AA. In April 2026 it moved both compliance dates back one year. The new dates are in the table above.
The Justice Department has said it may propose changes to the rule. It has also said that if it does not, it “fully anticipates” enforcing the rule on the new dates. As of late October 2026 it has published no proposal. Plan on April 26, 2027.
Community college districts
A district’s date depends on how it is set up. A college that belongs to a state system or to a county uses that government’s population. A district that is its own special district government, with its own administrative and fiscal independence, falls in the later group, whatever its size. The rule does not say which kind any particular district is, so ask your counsel which date applies to you.
Private colleges
Title II does not cover private colleges, so its dates do not apply to them. But ADA Title III treats private schools as public accommodations, and Section 504 applies to any college that receives federal financial assistance, including federal student aid its students use to pay. Both laws bar disability discrimination, and both can be enforced in court. A private college with HHS funding also falls under the HHS rule below.
Section 504 applies too
Section 504 of the Rehabilitation Act bars disability discrimination in any program that receives federal financial assistance. The law defines a program to include “a college, university, or other postsecondary institution, or a public system of higher education.” The Department of Education’s Office for Civil Rights enforces Section 504 and Title II at schools and colleges.
Federal student aid counts. The Justice Department’s civil rights guidance says schools are recipients of federal financial assistance “when they accept payments from students who directly receive federal financial aid.” Once a college is a recipient, Section 504 reaches all of its operations, not just the financial aid office. The Department of Education says the laws its Office for Civil Rights enforces cover “all public schools and most public and private colleges and universities.”
If your institution receives funding from the Department of Health and Human Services, such as NIH research grants, HHS’s own Section 504 rule also applies. It sets the same WCAG 2.1 Level AA standard, with compliance dates of May 11, 2027 for recipients with 15 or more employees and May 10, 2028 for those with fewer. Read our guide to the HHS rule.
What has to be fixed
The rule covers PDFs, Word files, slide decks and spreadsheets that you post online or in an app. On a campus that usually means:
- Course documents: syllabi, readings, handouts and slides, including those inside your learning management system. The Justice Department says plainly that there is no exception for course content.
- Catalogs and handbooks: course catalogs, student handbooks and program guides.
- Governance records: agendas and minutes for the board of trustees or regents and the faculty senate.
- Forms: admissions, financial aid, registrar, housing, human resources and purchasing forms.
- Financial and research reports: budgets, audits, annual and institutional reports, and research publications you post.
- Scanned pages: a scan is a picture to a screen reader. It needs text recognition and a check of the numbers.
What can wait
The rule has exceptions for archived content and for documents posted before your compliance date, but both are narrow. Archived content must have been created before your compliance date, kept only for reference, research or recordkeeping, left unchanged, and stored in an area clearly labeled as archived. An older document loses the exception if people currently use it to apply for, gain access to, or take part in a program. Read how the archived content exception works.
Start with the documents students and the public use to apply, enroll, pay and register. Those are the ones the exceptions do not reach.
How colleges buy this work
Campuses usually buy document remediation in one of three ways:
- Approved vendor lists. Many accessibility and disability resource offices keep a list of remediation vendors that departments can hire directly.
- State and cooperative contracts. Some systems and states buy through statewide or cooperative purchasing agreements.
- Purchase orders and purchasing cards. Smaller jobs often go through a department purchase order or a purchasing card, under the school’s small purchase limit.
Celsari is not on any state or cooperative contract today. We work by purchase order, purchasing card or invoice, and we are glad to go through your vendor approval process. If your office keeps a vendor list, tell us what it takes to be added.
The Starter Fix
A fixed price way to clear your most used documents first.
$1,950
Up to 350 PDF pages of the documents you choose, delivered within five business days after you approve the file list.
Every file comes back meeting WCAG 2.1 Level AA and PDF/UA:
- Tags and a correct reading order
- Alt text for images, charts and figures
- Table headers that a screen reader can announce
- Real text for scanned pages, with the numbers checked
- Labeled, fillable form fields
- A document title and language set in every file
Every file is remediated and quality checked before it comes back to you. Larger jobs are priced by the number of pages we find when we scan your documents, so you pay for the work you have, not a guess. Want to see our work first? We will fix one of your files at no cost.
Celsari remediates documents. We do not certify that a website or an institution complies with the law.
Start with one file
Pick a document your students or the public use every day. We will fix it at no cost so your team can check the result before you buy anything.
Sources
- Federal Register, 91 FR 20902 (April 20, 2026), extension of the Title II compliance dates
- eCFR, 28 CFR part 35, subpart H (web and mobile accessibility)
- eCFR, 28 CFR 35.104 (definitions, including total population and special district government)
- ADA.gov, fact sheet on the web and mobile app rule
- ADA.gov, web rule first steps (the state university example and course content)
- 29 U.S.C. 794 (Section 504 of the Rehabilitation Act)
- 42 U.S.C. 12181 (ADA Title III, private schools as public accommodations)
- U.S. Department of Education, Office for Civil Rights, disability discrimination
- U.S. Department of Education, how to file a discrimination complaint with OCR (which institutions the laws cover)
- U.S. Department of Justice, Title VI Legal Manual, section V (federal student aid as federal financial assistance)
- eCFR, 45 CFR 84.84 (HHS Section 504 web and mobile compliance dates)
Checked against these sources on October 31, 2026. This page explains federal rules in plain language. It is not legal advice. Check the current text of the rules, and ask your institution’s counsel about your own situation.