In 2024, both the Department of Justice (DOJ) and the Department of Health and Human Services (HHS) finalized updates for the Americans with Disabilities Act (ADA) Title II and Rehabilitation Act of 1973 Section 504 (Section 504) regulations. These updates require identified entities to ensure that any web content and mobile apps they provide or make available are accessible to specific technical standards. All public colleges and universities, and many private ones, have local compliance plans, fact sheets, and checklists for campus-wide efforts. The documents below take different approaches because local guidelines will fulfill most generalized needs.

Regulation Updates

The DOJ published an interim final rule on April 20, 2026 to revise the ADA Title II regulations.

• Summary of change: Extends the compliance dates for the ADA Title II web content accessibility regulations by one year.
  • Public entities that serve a total population of 50,000 or more: now April 26, 2027 (instead of April 24, 2026).
    *Alliance public member institutions meet this definition.
  • Public entities that serve a total population of less than 50,000: now April 26, 2028 (instead of April 26, 2027).
• Summary of reasons:
  • Identifies “significant litigation risks” for entities that are unable to comply by the original deadline.
  • Determines that the provided defenses (fundamental alteration or undue burden) “should not guide the Department’s decisions in setting the rule’s compliance deadlines.” The DOJ also indicated they preferred to provide additional time for compliance efforts instead of developing defense documentation.
  • Recognizes that the initial expectations for “advancement and availability of technology” made in 2024 have not met the reality in the two years since the final rule was published.
  • Determines that the one-year extension is consistent with communications shared in the 2023 Notice of Proposed Rulemaking (NPRM) and comments shared in the section-by-section analysis from the 2024 final rule.
  • Considers that the one-year extension would “help resolve some confusion over proposed exceptions in the 2023 NPRM for certain course content used by public institutions” that was then removed in the 2024 final rule.
  • Indicates “plans to engage in future rulemaking processes related to the substantive requirements of the 2024 final rule.” The DOJ indicates a possible NPRM process, but does not guarantee this will happen. They also note if they do not issue an NPRM, and if there are no reasons for additional extensions, they plan to implement the regulation at the new deadline (April 26, 2027 or April 26, 2028).
  • Affirms that existing obligations of ADA Title II remain — “services, programs, and activities offered using web content and mobile apps are accessible to individuals with disabilities in accordance with existing obligations.”

Summaries

• ADA Title II Summary. This four-page Google Doc summarizes the DOJ’s 2024 revision to the ADA Title II regulations and highlights sections that are especially relevant to academic libraries. The document includes the final rule’s background and core premise, requirements, definitions, exceptions, additional compliance guidelines, and library-specific responses from the DOJ’s section-by-section analysis and response to public comments.
  *This document will be updated to reflect the deadline extensions from the interim final rule once the rule is published.
• HHS Section 504 Summary. This four-page Google Doc summarizes the HHS 2024 updates to the Section 504 regulations and highlights sections that are especially relevant to academic libraries. The document includes the final rule’s background and core premise, requirements, definitions, exceptions, additional compliance guidelines, and library-specific items from the HHS section-by-section responses to public comments.

Centralized Support

• Alliance All-In Member Programs: Accessibility. In licensing and managing web applications and content on behalf of member institutions, the Alliance has implemented systematic processes and requirements for oversight of vendors’ compliance with the ADA Title II and HHS Section 504 web content accessibility regulations.
• Alliance Electronic Resources Program (ERP): ADA Title II Compliance Statement. The Alliance ERP facilitates e-agreements on behalf of Alliance members for commercially-published electronic resources. These agreements address several aspects of content accessibility, which are outlined in this compliance statement.
• Archives & Manuscripts Collections Service: Accessibility Conformance Report (ACR) for Archives West (PDF). The Alliance published and will maintain an ACR for Archives West, our web-based archival finding aid aggregator. The ACR is based on the Voluntary Product Accessibility Template® (VPAT®) Version 2.5.
• Selected Resources. A curated list of resources for accessibility support across library functional work areas. A separate undue financial or administrative burden section takes a deeper look at considerations and resources for the undue burden defense.

Considerations

The considerations document (a five-page Google Doc) explores proposed connections and questions to consider for some of the more complex or situational aspects of digital accessibility for web content and mobile apps provided by academic libraries. The questions are organized in three sections (organizational commitments, contextualizing content, and cooperative relationships), which offer perspectives to identify how a library’s local contexts align with the updated regulations. Because the questions cross multiple areas of library work, responses will likely be contributed by multiple library workers. (There is only one considerations document because the updates for both ADA Title II and Section 504 align regarding requirements, exceptions, and related compliance guidelines.)

Comparison

The comparison spreadsheet (Google Sheet) reviews the updates for ADA Title II and HHS Section 504 by both the language in the final rules and the identified entities.

• The Regulation Comparisons sheet frames the final rules based on four sections:
  • Requirements: who, what, how, when
  • Exceptions: overview; archived web content; preexisting conventional electronic documents; content posted by a third party; individualized, secured electronic documents; preexisting social media posts
  • Additional compliance guidelines: conforming alternate versions, equivalent facilitation, fundamental alteration or undue burden, effect of technical noncompliance
  • Library-specific responses: archived web content, libraries as identified entities, intellectual property law, EPUBs and digital textbooks, content from third-party vendors
• The Identified Entities sheet determines identified entity status for Alliance members for both ADA Title II and HHS Section 504.
  • ADA Title II: public entities
  • HHS Section 504: recipients of Federal financial assistance from the Department of Health and Human Services
    Limited to estimates (noted as Possibly, Maybe, and Unknown) due to multiple unknown factors: fund distribution may obligate the entire institution or a specific unit; grants or contracts may or may not continue/renew; an institution may receive other forms of HHS funds (e.g., Medicare or Medicaid) directly or through contractual, licensing, or other arrangements