The Department of Justice’s ADA Title II digital accessibility compliance date has been extended by one year, shifting the timeline for many public colleges and universities. For many higher ed institutions, that news may have landed as a quiet exhale—more time, more flexibility, less immediate pressure.
But let’s be clear: this is not a pause. It’s a window.
A rare opportunity to move beyond reactive remediation and toward something far more sustainable—embedding accessibility into the way your institution actually operates.
So the question isn’t “What can we delay?” It’s “What can we finally do right?”
If all of this is new to you, check out these related blog posts first:
- The Clock is Ticking: Is Your Institution Ready for the ADA Title II Final Rule?
- WCAG, ADA, EAA: Decoding the Soup of Digital Accessibility Compliance in Higher Education
1. From One-Time Fixes to Ongoing Accessibility Practice
In the rush toward compliance, it’s easy to frame accessibility as a project: run an audit, fix the issues, check the box. But accessibility doesn’t behave like a project. Websites evolve. Courses update. Content is constantly created, revised, and replaced. Treating accessibility as a one-time effort almost guarantees you’ll be back in the same position a year from now.
The more durable approach is to treat accessibility as a continuous practice, something that lives inside your content lifecycle:
- Create
- Review
- Publish
- Maintain
When accessibility is part of how content is made, compliance becomes a byproduct, not a scramble.
2. Rebuild Your Content Governance Model
If you step back, most accessibility issues aren’t purely technical. They’re structural.
Higher education institutions often operate with highly decentralized publishing models. Departments manage their own pages. Faculty upload their own materials. Marketing, IT, and academics move on parallel tracks. That flexibility comes at a cost: inconsistent standards and distributed risk.
This extra year is an opportunity to bring clarity where there’s currently fragmentation:
- Who owns accessibility at the institutional level?
- Who is responsible at the unit or department level?
- Who has publishing access and what expectations come with it?
Establishing governance doesn’t mean centralizing everything. It means creating shared standards and accountability, so accessibility isn’t left to chance.
3. Strengthen Your Design and Development Systems
One of the most effective ways to scale accessibility is to stop solving the same problems over and over. Design systems and component libraries are powerful leverage points. When built accessibly, they reduce the burden on every downstream contributor.
This is where the extra time can pay real dividends:
- Ensure core components like navigation, forms, buttons, and modals meet accessibility standards
- Document not just how components look, but how they behave accessibly
- Align designers, developers, and content creators around shared patterns
When your foundation is accessible, your teams don’t have to reinvent accessibility with every new page or feature.
4. Turn Training Into Behavior Change
Most institutions already offer some form of accessibility training. The challenge is that training alone doesn’t always translate into better outcomes. A single annual session, no matter how well-intentioned, rarely changes day-to-day behavior.
A more effective approach is to make training role-based and continuous:
- Faculty need practical guidance on creating accessible course materials
- Marketing teams need clarity on web and social content practices
- Developers need deeper implementation standards
Even more important: embed that guidance into the tools people already use. Because the goal isn’t just awareness. It’s making the accessible way the default way.
5. Move Beyond the “PDF Problem”
If there’s one area where institutions feel the weight of accessibility, it’s documents. Years and years of PDFs, many of them inaccessible, scattered across websites and learning platforms. Trying to fix everything is rarely realistic. But ignoring the problem isn’t viable either.
The more strategic path forward is deliberate:
- Create new content in accessible HTML whenever possible
- Fix documents that are actively used or mission-critical
- Remove or archive content that no longer serves a purpose
This approach reduces risk, and it reduces volume. That’s what makes accessibility sustainable.
6. Strengthen Procurement and Vendor Accountability
Not all accessibility issues originate inside your institution. Third-party tools like virtual tours, application systems, and learning platforms are deeply embedded in the student experience. And they can introduce significant risk.
This extended timeline is a chance to mature how you approach procurement:
- Set clear accessibility expectations for vendors upfront
- Critically evaluate VPATs
- Build accessibility into vendor selection and renewal processes
- Collaborate and build leverage with other institutions by communicating accessibility needs and expectations to vendors as a group
Accessibility isn’t just a content challenge. It’s a supply chain consideration. Most institutions start their fiscal year in the summer. Take the next few months to ensure you have the financial resources and budget that are needed to implement lasting changes over the coming year.
7. Monitor Continuously, Not Periodically
A one-time audit can tell you where you are. It cannot guarantee where you’ll be. Your digital ecosystem is constantly changing, which means accessibility must be continuously monitored.
A strong approach blends:
- Automated testing for ongoing issue detection
- Regular manual testing for deeper, experience-level validation
- Focus on high-impact user journeys like applying, enrolling, and accessing coursework
The goal is not perfection at a single point in time. It’s consistency over time.
8. Define What Success Actually Looks Like
Compliance is important, but it’s not the only measure that matters. If accessibility is going to become part of how your institution operates, it needs to be measurable in ways that reflect progress and sustainability.
Consider tracking:
- Reduction in accessibility issues over time
- Percentage of new content created accessibly from the start
- Training participation tied to improved outcomes
- Time to resolve reported accessibility barriers
What you measure shapes what your institution prioritizes. And what you prioritize is what improves.
9. Center Real User Experience
It’s possible to meet technical standards and still fall short of a usable experience. That’s why the most mature accessibility efforts go beyond compliance and into usability.
This is where institutions can use the extra year to deepen their approach:
- Include people with disabilities in usability testing
- Evaluate real student journeys, not just individual pages
- Integrate accessibility into broader UX research and design decisions
The question shifts from “Is this compliant?” to “Does this actually work?”
10. Build a Culture That Sustains the Work
Tools, policies, and training all matter. But long-term success depends on something less tangible: culture. When accessibility becomes part of how decisions are made, not just how problems are fixed, it starts to sustain itself.
You’ll see it when:
- Leadership actively supports and prioritizes accessibility
- Teams raise accessibility considerations early, not late
- Collaboration happens across marketing, IT, faculty, and procurement
Institutions that succeed won’t be the ones that simply use the extra year to catch up. They’ll be the ones who use it to change how they work.
Final Thoughts
The deadline has been extended. Expectations have not. This moment offers something higher education doesn’t often get: time to be intentional.
A year from now, institutions will arrive at the same compliance date from very different places. Some will still be racing to remediate. Others will have built systems, habits, and cultures that make accessibility part of their foundation.
The difference will not be how early they started. It will be how thoughtfully they used the time they were given.
Carnegie’s award-winning website development and digital teams work together to help you create and sustain digital experiences that are as compelling as they are accessible and user-friendly. From strategy and design to development and ongoing optimization, we partner with institutions to build digital ecosystems that perform.
Ready to take your online presence to the next level? Reach out and start a conversation.
Frequently Asked Questions
Has the ADA Title II digital accessibility compliance deadline actually been extended?
Yes, the Department of Justice extended the compliance deadline by one year for public colleges and universities. The extension shifts the timeline, but it does not reduce or change the underlying accessibility requirements.
Does the deadline extension mean institutions can slow down their accessibility efforts?
No. The extension is not a pause but a window to build more sustainable accessibility practices. Institutions are still expected to make meaningful progress toward full compliance.
What technical standard do higher education institutions need to meet under ADA Title II?
Public colleges and universities must meet WCAG 2.1 Level AA standards for their digital content and web properties. That requirement has not changed with the extended deadline.
How should institutions handle the large volume of inaccessible PDFs and documents?
A strategic approach involves creating new content in accessible HTML whenever possible, prioritizing fixes for actively used or mission-critical documents, and removing or archiving content that no longer serves a purpose.
What role do third-party vendors play in a higher ed institution’s accessibility obligations?
Third-party tools like virtual tours, application systems, and learning platforms can introduce significant accessibility risk. Institutions should set clear expectations for vendors upfront and build accessibility requirements into procurement and renewal processes.
How should institutions measure accessibility progress beyond compliance?
Useful metrics include the reduction in accessibility issues over time, the percentage of new content created accessibly from the start, training participation tied to improved outcomes, and time to resolve reported accessibility barriers.
What does a mature accessibility program look like in higher education?
A mature program goes beyond technical compliance to include usability testing with people with disabilities, role-based and continuous staff training, strong content governance, and a culture where accessibility is considered early in every decision.
