What Documents Need to Be Accessible Under ADA Title II?

Under ADA Title II, all digital content that a public entity makes available online or uses to deliver services must be accessible. This includes PDFs, Word documents, PowerPoint presentations, Excel spreadsheets, videos, forms, and any other content published on websites, learning management systems, or student-facing portals. The rule does not distinguish between document types — if it's digital and public-facing, it's in scope.

That's the short answer. But for compliance officers and administrators trying to scope a remediation project across an entire university, the details matter. Let's break down exactly what's covered, what's commonly missed, and how to prioritize.

Documents That Are Definitely in Scope

If your institution publishes any of the following digitally — on a website, in a portal, or through a student-facing system — they must meet WCAG 2.1 Level AA standards by the compliance deadline:

• Admissions materials — applications, program brochures, requirement summaries, and any PDF or web content prospective students interact with
• Financial aid forms — FAFSA instructions, scholarship applications, award letters, and cost-of-attendance documents
• Course catalogues and academic policies — degree requirements, grading policies, academic integrity statements
• Student handbooks — codes of conduct, housing policies, grievance procedures
• Syllabi — every syllabus for every course, including those uploaded into an LMS
• Committee minutes and governance documents — faculty senate minutes, board meeting materials published online
• Annual reports and institutional data — accreditation documents, strategic plans, budget summaries
• Public-facing PDFs of any kind — if a user can download it from your website, it needs to be accessible
• Web page content — all HTML pages across every department and subdomain

This is a broad mandate. For a mid-sized university, the document count can easily reach tens of thousands.

What's Often Overlooked

The documents above are where most institutions start. But some of the highest-volume accessibility gaps live in places that compliance teams initially miss.

Course Materials Inside Your LMS

Yes, content inside Canvas, Blackboard, and Moodle is in scope. This is one of the most common misunderstandings. The LMS platform itself may be WCAG-compliant — the navigation, the grade book, the discussion forums. But the content that faculty upload into the platform must also be accessible.

That means every lecture slide deck, every PDF reading, every assignment handout, and every embedded video within a course is covered. For most universities, this is where the largest volume of inaccessible documents lives. A single department can generate hundreds of inaccessible PDFs and PowerPoints per semester.

Video Content

Videos require captions — not auto-generated captions, but accurate, synchronized captions. This applies to lecture recordings, promotional videos, webinars, and any video content embedded on university pages or within the LMS. Audio descriptions may also be required where visual content is not described in the narration.

Faculty-Uploaded Documents

Individual faculty members regularly upload documents to course sites, department pages, and shared drives. These documents are in scope even if they weren't created by a central communications team. This is a governance challenge as much as a technical one.

Department Websites and Microsites

Every department website, research center page, event site, and project microsite falls under ADA Title II. Many institutions have dozens or hundreds of these, often maintained by staff with limited accessibility training.

Event Flyers and Announcements

Digital flyers, newsletters, and announcements — whether posted as PDFs, images, or web content — must be accessible. Image-only flyers without alt text or readable text layers are a common violation.

Archived Content: Is It in Scope?

The rule applies to content that is currently available to users. If a document is published on your website or accessible through a portal, it's in scope — regardless of when it was created.

However, if content has been genuinely archived and is no longer publicly available (removed from the website, taken down from the LMS, moved to an internal-only storage system), it may fall outside the scope of the requirement. The key question is: can a student, prospective student, or member of the public currently access it? If yes, it needs to be accessible.

For many universities, this creates a practical decision point. Old syllabi, outdated policy documents, and past event materials that remain published on legacy pages are technically in scope. You'll need to decide whether to remediate them or remove them.

Third-Party Content

If your university publishes or makes available content created by third parties — textbook publisher materials, vendor-provided forms, software documentation — there is a question of responsibility. Generally, the institution is responsible for ensuring that content it makes available to its community is accessible. This means you may need to work with vendors to obtain accessible versions, or provide accessible alternatives when vendor content falls short.

This applies to embedded content as well. If a third-party widget, form, or document viewer is integrated into your website or LMS, its accessibility becomes your concern.

Internal Documents

Documents used purely for internal administrative purposes — staff meeting notes shared only among employees, internal policy drafts, HR forms for staff — are less clearly within the scope of ADA Title II, which primarily addresses public-facing services and programs. However, documents provided to students, prospective students, or the public are definitively covered. When in doubt, treat it as in scope.

How to Prioritize Remediation

Given the scale, you cannot fix everything at once. Here's a practical approach to scoping your remediation effort:

1. Start with high-traffic, high-impact documents. Admissions materials, financial aid forms, and the main university website affect the most people and carry the most legal risk.

2. Address student-facing content next. Syllabi, course materials in the LMS, and student handbooks directly affect enrolled students — the population most likely to need accommodations and most likely to file complaints.

3. Audit department websites. Identify which departments have the most public-facing content and prioritize based on volume and traffic.

4. Establish a go-forward policy. Require that all new documents meet accessibility standards before publication. This stops the problem from growing while you work through the backlog.

5. Make a decision on legacy content. For old documents that remain published, decide whether to remediate or remove. Removal is faster and cheaper for content that's no longer relevant.

6. Scan everything. You cannot prioritize what you haven't measured. An automated scan of your document library gives you a complete picture of what needs attention, organized by severity and volume. Without this, you're guessing.

If you're trying to scope this work and the numbers feel overwhelming, you're not alone. Most universities find they have far more in-scope documents than they initially estimated. The April 2027 deadline is firm (extended from 2026 via the IFR), and the consequences of missing it are real — but a structured approach makes the work manageable.

Aelira can scan your entire document library to identify what needs fixing, then remediate at scale — start a free pilot. You can also learn more about how to make individual PDFs accessible or explore our higher education solutions.