ADA Title II and course video: what has to be accessible by April 2027

The dates

DOJ's 2024 rule sets WCAG 2.1 Level AA as the standard for the web content and mobile apps of state and local governments, and that includes public colleges and universities. An interim final rule published April 20, 2026 pushed the compliance dates back one year and changed nothing else. In DOJ's words, "the amendments do not alter any other provisions of the 2024 final rule."

Sources: DOJ interim final rule, 91 FR 20902; HHS interim final rule, FR Doc 2026-09266; ADA.gov fact sheet.

"Large" means population, not enrollment

The size test uses the census population of the state or local government the college belongs to, not its student count. A state university counts the whole state. The University of Arizona, for example, uses Arizona's population and lands on the 2027 date. Whether a community college district counts as a "special district government" depends on state law, so check with counsel if you're relying on 2028.

Source: University of Arizona Digital Accessibility.

What WCAG 2.1 AA asks of course video

Four success criteria apply to prerecorded video. Live captioning is a fifth, and only matters for live streams.

Sources: WCAG 2.1; W3C, Understanding 1.2.3; W3C, Understanding 1.2.5.

The detail most teams miss: not every video needs a separate description track. W3C's guidance for 1.2.5 says that if all of the important visual information is already conveyed in the audio, no additional description is necessary. An instructor who says "this graph shows enrollment falling by half since 2015" while the graph is on screen has described it. One who says "as you can see here" has not.

Is your old course video in scope?

Most of the confusion is about exceptions. Five questions settle it for video.

1. Is it behind an LMS password? Still in scope. DOJ's 2023 proposal included two exceptions for password-protected course content. The final rule dropped both.
2. Is it a "preexisting conventional electronic document"? No. That exception covers word processing, presentation, PDF and spreadsheet files. Video isn't on the list.
3. Is it archived? Only if all four conditions hold: created before the compliance date, kept only for reference, research or recordkeeping, held in a special area for archived content, and not changed since. Reuse the course next term and the archive status is gone.
4. Did a vendor or contractor make it? Still yours. Content a contractor posts for you is not exempt, and DOJ expects you to make sure vendors comply.
5. Is it someone else's YouTube video embedded in your course? Universities read this strictly. UNC's position is that it needs accurate captions or a transcript with description even if you don't own it.

Sources: 2024 final rule text and appendix; ADA.gov fact sheet; ADA.gov small entity compliance guide; UNC Digital Accessibility FAQ.

Archived content still comes with a duty to respond. DOJ's own example: if someone asks for an archived video, caption it and send it to them.

Captions: are auto-captions enough?

The rule points to WCAG 2.1 AA. DOJ's fact sheet does not name a caption accuracy percentage, so campuses are setting their own bar. The University of Washington says machine captions "currently do not meet accessibility standards" and uses 99% and 97% accuracy tiers by priority. Cal State Long Beach tells faculty captions must be 100% accurate. Either way, unedited auto-captions on technical content, names and formulas are the first thing an accessibility review will flag.

Sources: UW video and audio report; CSULB, ADA Title II and you.

Audio description: what it costs, and the cheaper path

Description is where course video budgets break. Published and negotiated per-minute rates, checked October 3, 2026:

Run the math on one program. Forty hours of course video is 2,400 minutes. At $9 a minute that is $21,600 for a synthesized standard track. At $35 it is $84,000 for voice-artist extended description. The University of Washington modeled 2 million minutes and got $14.7 million for standard human description and $22 million for extended.

There are two cheaper paths, and they work together. First, fix the video so the narration carries the visuals: rewrite "as you can see here" into a sentence that says what is on screen, rebuild unreadable slides, and add short spoken bridges. W3C's guidance means a lesson built that way needs little or no separate description. Second, avoid the two-file trap. UW reports that the Canvas, Zoom, YouTube and Vimeo players do not support a description track, so a bolted-on track usually means publishing a second, described version of every video and keeping both in sync.

Remediate, remaster or retire

The University of Washington's plan is the clearest published approach: fix what will be used after the deadline, archive what won't, and set retention rules so dead recordings don't pile up. Here is how we sort a catalog.

The checklist below turns this into a one-page inventory you can hand to department chairs.

Private colleges and Section 504

Title II covers public entities only. Private colleges fall under Title III, which has no adopted technical standard for websites yet. If a private college takes federal funds, Section 504 applies, and the Online Learning Consortium expects those schools to be held to similar standards. HHS has already written WCAG 2.1 AA into its Section 504 rule for HHS funding recipients, with deadlines of May 11, 2027 for organizations with 15 or more employees and May 10, 2028 for smaller ones. Check whether your institution holds HHS grants.

Sources: Online Learning Consortium; HHS interim final rule.

Frequently asked questions