What Documents Need to Be Accessible Under ADA Title II?

Documents can be web content under the DOJ Title II rule when covered public entities provide or make them available through websites, mobile apps or relevant service arrangements. Include the LMS and student-facing services in the inventory rather than examining only the public homepage.

The DOJ Title II rule sets WCAG 2.1 Level AA requirements for covered state and local government web content and mobile apps, subject to the rule's scope and exceptions. The April 2026 IFR extends the dates to April 26, 2027 for public entities with a population of 50,000 or more and April 26, 2028 for smaller public entities and special district governments. Determine the institution's cohort using DOJ's population rules; enrollment and federal funding alone do not determine it. Existing accessibility obligations continue before those dates.

Inventory documents students and service users need

Examples include application forms, course readings, assessment instructions, policies and lecture material. Record where each file is available, when it was posted or changed, its current use and its owner. Content behind authentication is not automatically outside the rule.

Assess exceptions carefully

The DOJ fact sheet describes limited exceptions, including qualifying archived content, some preexisting conventional electronic documents, certain third-party posts and secured individualized documents. Each has conditions. Archived content must meet all specified conditions; simply labeling an active course file an archive is not enough.

Preexisting documents used to apply for, gain access to or participate in a public service, program or activity have an important limitation on that exception. Third-party material supplied under contractual or licensing arrangements should not be treated as an unconnected public post.

Even where a technical-standard exception applies, continuing duties such as effective communication, reasonable modifications and equal opportunity can remain. Review internal and employee-facing material under its actual use and applicable obligations rather than declaring it exempt by location alone.

Plan the work

Address known barriers and current tasks, obtain accessible sources, and assign unsupported or complex work to specialists. Record untested areas and unresolved cases. Automated inventory and scanning can assist, but a scanner cannot provide a complete legal scope or accessibility determination for an entire library.

Aelira Core is beta software. Supported workflows can apply eligible partial fixes and record outcomes, but some inputs need manual work or cannot produce a downloadable remediated file. Review the actual saved output, unresolved findings and content preservation before publication. Automated scores describe implemented checks rather than accessibility conformance. Inspect the public source and release documentation and evaluate a representative authorized sample before planning a rollout.