Overview
Federal disability law has long required local governments—including schools—to make their websites and mobile apps accessible to students with disabilities. In 2024, the U.S. Department of Justice (DOJ) published a final rule specifying how to measure compliance, relying on the Web Content Accessibility Guidelines (WCAG). Enforcement dates were set based on population size, with the first deadline for entities over 50,000 residents approaching. However, in early 2025, the DOJ issued an interim final rule extending that deadline by one year. This extension offers schools a critical opportunity to get ready, not a reason to pause. This guide walks you through the steps to achieve and maintain accessibility, avoiding common pitfalls and protecting your institution from lawsuits and compliance failures.
Prerequisites
Before diving into implementation, you need the following:
- Leadership commitment: Buy-in from administrators and IT decision-makers.
- Accessibility team: Assign a coordinator or task force (could include IT staff, content creators, procurement officers, and disability services personnel).
- Budget allocation: Funds for training, audits, tools, and remediation.
- Basic understanding of WCAG: Familiarity with the four principles (Perceivable, Operable, Understandable, Robust) and Level AA success criteria.
- Inventory of digital assets: List all websites, web applications, and mobile apps used by the school (including LMS, portals, forms, and third-party vendor tools).
- Procurement policy review: Understand how new tools are vetted for accessibility.
Step-by-Step Instructions
Step 1: Conduct a Comprehensive Accessibility Audit
Start by evaluating your current digital landscape. Use automated tools like WAVE, Axe, or Lighthouse to scan your websites and mobile apps. Automated checks catch about 30% of issues, so manual testing is essential. Pair these tools with manual reviews by people with disabilities and screen reader testing (NVDA, JAWS, VoiceOver). Document all findings in a report, prioritizing issues by severity and frequency. For example, missing alt text on images is common but easy to fix; keyboard trap errors require more work.
Step 2: Develop a Remediation Plan with Milestones
Based on the audit, create a phased timeline. Tackle high-impact, low-effort items first—like color contrast fixes and form labels. Then address complex problems such as dynamic content, PDF accessibility, and video captioning. Assign ownership for each task. Use the extra year wisely: aim for full WCAG 2.1 AA compliance within 12 months, but have partial compliance done by the original deadline to show good faith. Consider an accessibility consultant if internal resources are limited.
Step 3: Implement Training for All Content Creators
Accessibility isn't just an IT problem. Train teachers, administrators, and staff who create documents, videos, or web pages. Cover topics: writing meaningful alt text, using heading structures, ensuring enough color contrast, providing captions and transcripts, and avoiding auto-play media. Make training mandatory and recurring. Use micro-learning modules or workshops. Glenda Sims of Deque Systems emphasizes that “the extra time is a chance to get accessibility right”—and training is the foundational investment.
Step 4: Revise Procurement Policies
Every new digital tool purchased—from LMS plugins to communication apps—must meet accessibility standards. Update your procurement process to require vendors to provide VPATs (Voluntary Product Accessibility Templates) and include accessibility clauses in contracts. Test vendor tools before purchase. This step prevents endless remediation cycles later. Sambhavi Chandrashekar, global accessibility lead at D2L, notes that investing in procurement systems now will “set institutions up to avoid an endless cycle of accessibility audits and remediation.”
Step 5: Build a Maintenance System
Accessibility isn’t a one-time fix. Establish ongoing monitoring: schedule quarterly automated scans, annual manual reviews, and a clear process for reporting issues (e.g., a help desk ticket category). Assign an accessibility lead to oversee updates. When new content is added, ensure it’s created accessibly from the start. Create a style guide or template that enforces accessibility by design.
Step 6: Engage with the Community
Involve students with disabilities and their families in testing. Their lived experience is invaluable. Partner with disability organizations for feedback. This not only improves your product but also builds trust—especially important given the surge in accessibility lawsuits (over 3,000 filed last year). Remember that under the current administration, federal support is uncertain, so being proactive protects your school.
Common Mistakes
- Waiting until the last minute: Many schools assumed the original deadline wouldn't move. Now that it’s extended, don’t treat it as free time. Start immediately.
- Relying solely on automated tools: They miss context-dependent issues (e.g., ambiguous alt text). Always pair with human testing.
- Ignoring mobile apps: The DOJ rule covers mobile apps, not just websites. Ensure native apps are also accessible.
- Overlooking third-party content: If you embed YouTube videos or use a vendor’s calendar widget, you are responsible for their accessibility. Vet everything.
- Not updating legacy content: Old PDFs, outdated course materials, and archived pages must also comply. Prioritize high-traffic content first.
- Failing to document efforts: In case of a lawsuit, evidence of good-faith progress matters. Keep logs of training, audits, remediation activities.
- Thinking it’s only about vision disabilities: Accessibility covers deaf, motor, cognitive, and other disabilities. Consider captions, keyboard navigation, plain language, and flexible timing.
Summary
The DOJ’s extension gives schools a critical one-year buffer to achieve website accessibility compliance. By following this guide—auditing, planning, training, updating procurement, maintaining accessibility, and engaging users—you can meet WCAG standards and protect your institution from legal and reputational risks. The time to act is now, not next year. Remember, accessibility benefits every student and builds a more inclusive digital environment.