Public colleges and universities across the United States are legally required to make both digital and physical environments on campus accessible to people with disabilities. In recent years, however, many students have found themselves at a disadvantage as institutions neglected to be proactive about accessibility when procuring new web-based educational technologies.

For decades, public colleges accessibility has been a matter of broad civil rights principles, but a landmark 2024 update to the Americans with Disabilities Act (ADA) Title II has turned those principles into concrete deadlines (starting in 2026) that institutions can’t afford to miss.

Schools are no longer permitted to wait for an accommodation request; they must ensure their websites, mobile apps, and digital course materials are accessible by default.

Understanding how these longstanding disability rights laws now intersect with these looming deadlines is essential. It ensures that schools remain in legal compliance while giving every student, regardless of ability, a fair shot at success in our increasingly tech-dependent society.

The following federal and state laws impact public universities as follows:

The Americans with Disabilities Act (ADA)

The Americans with Disabilities Act (ADA)

The Americans with Disabilities Act (ADA) is a comprehensive civil rights law designed to ensure that individuals with disabilities have the same rights and opportunities as everyone else. It requires specific entities to provide equal access to public services, programs, and activities.

While the ADA consists of five titles, Title II and Title III are the most relevant to public colleges accessibility and the student experience.

Title II: State and Local Government Activities

The timeline for compliance depends on the size of the population served by the public entity:

• April 24, 2026: Deadline for large public entities (serving populations of 50,000 or more*).
• April 26, 2027: Deadline for smaller public entities and special districts*.

* Note: this number reflects the population of the jurisdiction the entity resides in, not the number of students enrolled. For example, a university in a city with a population of 100,000 would qualify as a large entity, even if they have less than 50,000 students enrolled.

For state-run universities, the jurisdiction is usually the entire state. Since every state has a population over 50,000, almost all flagship and state-system universities will fall under the April 24, 2026 deadline.

Both Title II and Section 504 of the Rehabilitation Act are enforced by the U.S. Department of Education’s Office for Civil Rights (OCR). Failure to meet these deadlines can potentially result in federal investigations or loss of funding.

Title III: Public Accommodations

Title III of the ADA applies to commercial entities and “public accommodations,” which include most places of lodging, recreation, entertainment, transportation, education, and medical care, among other things.

Under Title III, no individual may be discriminated against on the basis of disability with regards to the full and equal enjoyment of the goods, services, facilities, or accommodations of any place of public accommodation.

Public-facing websites everywhere, including those of public universities, are increasingly being considered places of public accommodation by disability rights groups, courts, and official government entities.

Massive open online courses (MOOCs) from both public and private universities have been considered places of public accommodation under Title III of the ADA in recent court cases.

The Rehabilitation Act

Enacted in 1973, the Rehabilitation Act is a federal anti-discrimation law that implicates federal and federally-funded programs. It originally emphasized equal employment practices, reasonable accommodations, and federally subsidized programming for individuals with disabilities.

With the advent of the Internet, an amendment (Section 508) was signed into law in 1998, expanding the Rehabilitation Act to include equal access to electronic and information technology.

Section 504

Section 504 of the Rehabilitation Act is widely considered to be the first statute to declare civil rights for individuals with disabilities. Under Section 504, an individual with a disability must have equal access to all programs, services, and activities receiving a federal subsidy. Web-based communications for public educational institutions are covered by this as well.

By definition, public institutions receive and depend on federal funding, so they must comply with Section 504. That means they are required to make accommodations for equal access, including providing users who are deaf or hard of hearing with closed captioning for educational video content.

Section 508

Section 508 mandates that federal agencies make electronic information accessible to members of the public with disabilities, as well as employees with disabilities. Section 508 applies to certain public colleges and universities that receive federal funding, such as through the Assistive Technology Act.

State Laws

Also under the umbrella of federal accessibility laws are individual state laws that mirror or add to the accessibility requirements outlined in the ADA and the Rehabilitation Act.

Many states require conformance with some or all of WCAG 2.0, the international standard for web accessibility, which requires closed captioning and audio description for video. A lot of states also have what are known as “little 508s” — laws that essentially reinforce the requirements of Section 508 of the Rehabilitation Act.

A Closer Look: Miami University, Ohio

Following statements from the Department of Justice in the support of the blind student, the university settled the case and agreed to a consent decree in which they agreed to ensure that web content and services are fully accessible to students with disabilities.

Achieving Legal Compliance with 3Play Media

With the first major ADA Title II compliance deadlines arriving on April 24, 2026, institutions no longer have the luxury of reactive, request-based accessibility.

To meet the required WCAG 2.1 Level AA standards, universities must proactively audit and remediate their entire digital libraries, including lecture captures, promotional videos, and live-streamed events.

3Play Media simplifies this transition by offering a centralized, scalable platform for all your video accessibility needs. Our 99% accurate closed captioning, patented AI-driven audio description, and seamless live captioning services are designed to help you clear your “compliance debt” without breaking the budget.

By integrating directly with platforms like Canvas, Kaltura, and Panopto, we ensure your institution is not only meeting federal deadlines but also fostering a truly inclusive campus for every student.

See if your digital content meets ADA Title II’s WCAG standards by downloading our Title II checklist:

---