ADA Title II Compliance
Introduction
ADA Title II is part of the Americans with Disabilities Act (ADA), a federal civil rights law passed in 1990. ADA protects the rights of individuals with disabilities—including people with visual, hearing, cognitive, and motor disabilities—by requiring equal access to public programs, services, and activities.
What ADA Title II covers
Title II specifically applies to state and local government entities, which includes public universities and their programs and services. Under current U.S. Department of Justice regulations, this also extends to digital content and technologies used to deliver services and information.
This includes:
- University Websites & Mobile Applications
- Learning management systems (e.g., Canvas, Blackboard)
- Digital documents (e.g., PDFs, Word docs, PowerPoints)
- Videos, audio, and other multimedia Content
- Digital communications (e.g., Social media, Outlook, Gmail, etc.)
What this Means in Practice
In simple terms, ADA Title II requires that digital content be designed so that everyone can access and use it, including people who rely on assistive technologies such as screen readers, captions, or keyboard navigation.
Upcoming Compliance Timeline
The university has until April 26, 2027, to achieve WCAG 2.1 Level AA compliance under an extension granted by the U.S. Department of Justice (DOJ) in April 2026. For additional information on the ADA Title II deadline extension, please refer to our announcement below and the official DOJ rule updates.
Planning Ahead at UIC
To support this transition, units are encouraged to use the UIC ADA Title II Roadmap Template. This tool helps teams:
- Identify key accessibility milestones.
- Assign responsibilities within units.
- Track progress toward compliance requirements.
- Plan improvements to digital accessibility over time.
ADA Title II Deadline Extended to April 26, 2027.
Key Requirements Under ADA Title II:
The ADA requires public entities (such as UIC) to ensure that individuals with disabilities, including those with visual, hearing, cognitive, and motor impairments, have equal access to public programs, services, and activities.
1. University Websites & Mobile Applications
- Must be perceivable, operable, understandable, and robust.
- The user interface (UI) should have sufficient color contrast (4.5:1), keyboard accessibility, clear focus indicators, with compatibility for screen readers & screen magnifiers.
2. Learning Management Systems (e.g., Canvas, Blackboard)
- Interactive content (quizzes, discussions, assignments) must be navigable by keyboard.
- All images require alt text, media must have captions/transcripts, and headings should be structured logically for screen reader navigation.
- Timed activities must provide adjustable time limits or alternatives.
3. Digital Documents (e.g., PDFs, Word docs, PowerPoints)
- PDFs must be tagged and structured for accessibility.
- Word/PowerPoint files must use built-in heading styles, list structures, descriptive hyperlink text, and sufficient color contrast.
- Tables should include headers identified in markup for assistive technologies.
4. Video, Audio & Other Multimedia Content
- Captions are required for all pre-recorded video with audio.
- Transcripts are required for audio-only media.
- Audio description should be provided when important visual information is not conveyed in the audio.
5. Digital communications (e.g., Social Media, Outlook, Gmail, etc.)
- Emails should use accessible HTML (proper headings, semantic lists, descriptive links).
- Attachments should meet accessibility requirements (e.g., tagged PDFs, structured Word/PowerPoint files) and have descriptive file name.
- Ensure color contrast when highlighting text and avoid using color alone to convey meaning.
Who is responsible for making content accessible?
Accessibility is a university-wide effort. Ensuring that content is accessible is not just an IT or compliance issue—it’s a shared responsibility across all departments and part of our mission at UIC. Whether you’re creating course materials, updating a webpage, sending out a newsletter, or designing a document, accessibility should always be a priority.
Please feel free to reach out to the Digital Accessibility team at accessibility@uic.edu to request accessibility reports & consultation support.
Content Creators (e.g., Faculty, Staff, and Students, etc.)
- Create accessible materials, documents, and communications.
- Ensure media includes captions, transcripts, and alternative text.
- Apply accessibility best practices in everyday content creation.
IT & Design Professionals (e.g., Developers, Designers, etc.)
- Design, develop, and maintain accessible websites, applications, and systems.
- Ensure compliance with accessibility standards (e.g., WCAG 2.1 AA).
- Monitor websites for accessibility issues using the accessibility report provided by the Digital Accessibility team, and remediate identified issues to meet the WCAG 2.1 Level AA standards.
Administrative Offices (e.g., HR, Procurement, and Campus Leadership, etc.)
- Establish and uphold accessibility policies, standards, and expectations.
- Ensure accessibility is integrated into procurement, contracts, and resource allocation.
- Promote accountability and a culture of accessibility across the university.
Are there any exceptions for ADA Title II?
Title II includes limited exceptions (link opens in a new tab) for certain web content that does not have to meet WCAG 2.1 Level AA.
Examples of exceptions include:
- Archived web content
- Preexisting conventional electronic documents
- In order for the documents to be considered as “Preexisting conventional electronic documents” under the exceptions, they must meet ALL of the following conditions:
- The documents were created prior to April 26, 2027, AND
- The documents are not currently used to apply for, gain access to or participate in University of Illinois Chicago programs, services, or activities (Paragraph 34), AND
- The documents are word processing, presentation, PDF, or spreadsheet files.
- In order for the documents to be considered as “Preexisting conventional electronic documents” under the exceptions, they must meet ALL of the following conditions:
- Content posted by a third party
- Individualized conventional electronic documents that are password-protected
- Conventional electronic documents are also not required to be accessible if the documents meet ALL of the following criteria:
- The documents are word processing, presentation, PDF, or spreadsheet files, AND
- The documents are about a specific person, property, or account, AND
- The documents are password-protected or otherwise secured.
- Please note that units using either of these exceptions may still need to provide the documents in an accessible format upon request (Paragraph 805).
- Conventional electronic documents are also not required to be accessible if the documents meet ALL of the following criteria:
- Preexisting social media posts
Fact Sheet: ADA Title II Exceptions
Frequently Asked Questions
Can content simply be labeled “archived” or “inactive” to qualify for an exception?
No. Labeling content as “archived” is not sufficient on its own. The content must meet all four regulatory criteria to qualify for the archived content exception, including being:
- Created before the compliance deadline,
- Not actively used,
- Stored in a designated archive area, and
- Unchanged since archiving.
If any condition is not met, the exception does not apply.
Are there any exceptions where even older social media content might still need to be accessible?
Yes! While pre-existing posts created before the compliance deadline are generally exempt from WCAG 2.1, accessibility obligations may still apply if:
- The content is actively reused for current services or programs, or
- It is required to provide access to an ongoing activity or benefit
In such cases, the entity may need to ensure the information is accessible in context, even if the original post itself is not remediated.
Are older PDFs and documents automatically exempt from accessibility requirements?
Not always. Preexisting conventional electronic documents (such as PDFs, Word docs, or PowerPoint presentations) are generally exempt only if they were available before the compliance date.
This exception does not apply if the document is:
- Currently used to apply for services, or
- Required to access a program or participate in an activity.
In those cases, the document must be accessible or replaced with an accessible version.
Workshops and Training
The Digital Accessibility team offers various resources to support members of the UIC community in creating accessible digital content:
- Accessibility Workshops: Check out our upcoming events for workshops and training opportunities, or email us at accessibility@uic.edu to request an accessibility workshop for your unit.
- Accessibility Resources: Visit our Training and Resources page for additional self-paced learning materials and guidance.