With the April 2026 ADA Title II compliance deadline fast approaching, public colleges and universities must ensure that all programs, services, and digital materials are accessible to individuals with disabilities.

Because video content plays such a central role in modern learning and can be especially challenging to make accessible, it’s essential for institutions to take a proactive approach to remediation.

Challenges around ADA video compliance include creating accurate captions, adding audio descriptions, and providing properly formatted transcripts for students who rely on assistive technologies.

Institutions now face the dual challenge of auditing existing content and budgeting effectively for accessible media. This guide will walk universities through the key steps to plan, budget, and audit video content, helping them meet compliance requirements while fostering a more equitable learning environment.

Key Takeaways

• Start early: Audit all video and digital content now to meet upcoming Title II deadlines in April 2026.
• Plan strategically: Categorize content and build a budget that covers both backlog and ongoing accessibility needs.
• Leverage the right tools: Use 3Play Media’s captioning, transcription, and audio description to simplify compliance and ensure inclusion.

Table of Contents

• The Countdown to ADA Video Compliance
• Phase 1: Conducting a Content Audit
• Phase 2: Building a Budget for Title II Compliance
• Summary Action Plan
• What’s Next?
• ADA Video Compliance FAQs

The Countdown to ADA Video Compliance

Title II of the Americans with Disabilities Act (ADA) requires all public entities (including state and local governments, public colleges, and universities) to ensure that their programs and services are accessible to individuals with disabilities.

In the digital age, this includes online and multimedia content such as videos, course materials, and virtual events. Whether a lecture is streamed live, archived in an LMS, or shared publicly on YouTube, it must be made accessible through tools like captions, transcripts, and audio description.

To meet compliance standards, universities are expected to align their digital content with WCAG 2.1 Level AA guidelines, which provide internationally recognized standards for making web and video content perceivable, operable, understandable, and robust for all users.

Simply put: Title II extends the same accessibility expectations that exist for physical spaces to the digital spaces where learning and communication now happen every day.

Why ADA Video Compliance Matters for Higher Education

ADA Title II marks an important shift in how universities approach accessibility. Instead of waiting for individual students to request accommodations, the new ruling requires institutions to proactively ensure that digital and video content is accessible from the start.

According to the CDC, 15.7% of US adults have difficulty hearing, and 18.0% have difficulty seeing, highlighting the need for a proactive approach to accessibility.

This legislation helps not only those who identify as having a disability, but also the millions of people who don’t consider themselves disabled and wouldn’t think to request an accommodation, but would benefit from accessibility features.

It also reduces the burden on disability services teams and faculty who often scramble to retrofit content and creates a more consistent, inclusive experience for all learners.

By embedding accessibility into everyday workflows, universities can support students more effectively, minimize legal risk, and build a campus culture centered on equity rather than exceptions.

Upcoming Title II Deadlines

Here’s a breakdown of the Title II deadlines:

Deadline	Applies To	Notes
April 24, 2026	Public entities (state & local governments, public colleges/universities) serving a population of 50,000 or more.	Includes institutions with small student populations if they reside in a jurisdiction with a large population.
April 26, 2027	Public entities serving a population less than 50,000	Gives smaller jurisdictions extra time, but compliance still required by this date.

Important note: These deadlines apply to existing content, not just new uploads. That means auditing, remediation, staffing, and budgeting all need to begin now to meet the timeline.

Phase 1: Conducting a Content Audit

Before creating a budget, it’s essential to understand the full scope of content that requires remediation. For large universities, the total amount of video needing captions and audio descriptions can easily reach millions of minutes.

Knowing the scope is crucial for institutions estimate costs accurately and allocate resources effectively.

We’ll now cover the steps you need to take to efficiently audit your content.

1. Assemble a Compliance Team

The first step in auditing content for Title II compliance is to bring together a dedicated compliance team. Accessibility is not just an IT or disability services issue, it requires collaboration across multiple departments.

• Administrative leadership – to oversee budgeting, resource allocation, and cross-department coordination

Clearly defining roles and responsibilities at the outset ensures that everyone knows their part in the process. This collaborative approach also helps universities respond efficiently to accessibility gaps and streamline remediation efforts.

2. Conduct a Video Content Inventory

Once your compliance team is in place, the next step is to identify and catalog all video assets across the university. Conducting a thorough content inventory provides a clear picture of what exists, where accessibility gaps may lie, and how much content will require remediation — critical information for budgeting and planning.

Key steps for an effective content inventory include:

• Identify all content sources: Look across learning management systems (Canvas, Blackboard, Moodle, etc.), public websites, online video platforms (YouTube, Vimeo, etc.), social media channels, video libraries, archived lectures, virtual events, and webinars. Don’t forget embedded third-party content, such as guest lectures, vendor videos, or integrated learning tools.
• Categorize content by type and format: Note whether videos are live-streamed, recorded lectures, short clips, or multimedia presentations. This helps determine the specific accessibility services required, which we will expand on in step #3.
• Record ownership and usage: Track who owns the content, how often it is used, and which courses or departments rely on it. This information helps prioritize remediation efforts and assign responsibilities.
• Flag high-priority assets: Identify videos that are essential for student learning, public-facing, or frequently accessed. These should be addressed first to minimize compliance risk and maximize impact.
• Centralize documentation: Maintain a single, organized record of all content, including file locations, formats, accessibility status, and notes on remediation needs. This centralized inventory supports ongoing compliance tracking and reporting.

3. Assess Accessibility of Each Asset

After completing your content inventory, the next step is to categorize each video asset based on the accessibility features it requires. This helps universities prioritize remediation and allocate resources efficiently.

Key elements to review during an accessibility assessment include:

• Captions: All spoken content should have synchronized captions that identify speakers and include important non-speech sounds.
• Audio Descriptions: Videos with critical visual information should include audio descriptions for students who are blind or have low vision.
• Transcripts: Provide complete, screen reader–friendly transcripts that serve as a text alternative for all audio and visual content.
• Video Player Accessibility: Ensure players are compatible with assistive technologies and support keyboard navigation, screen readers, and adjustable playback features.
• Third-Party Content: Review external videos and embedded tools to confirm accessibility, and coordinate with vendors to obtain captions, transcripts, or audio descriptions if needed.

Tools to Conduct an Accessibility Audit

Conducting an audit can be done with manual review and automated tools to increase efficiency. Combining the two helps universities find obvious accessibility problems quickly while also checking harder-to-spot issues, like complex visuals.

Automated Accessibility Tools

These tools quickly scan websites, LMS platforms, and video content to detect common accessibility issues such as missing captions, poor color contrast, or inaccessible headings.

Examples include WAVE, Siteimprove, Axe, and SortSite, which provide detailed reports and recommendations for fixes.

There are also LMS-native tools designed specifically to scan course content for accessibility issues. Examples include:

• Blackboard Ally — integrates with multiple LLMs including Blackboard Learn, Canvas, and Moodle
• UDOIT (Universal Design Online Content Inspection Tool) — Canvas’ built-in accessibility tool
• Moodle’s Accessibility Starter Toolkit — Moodle’s built-in accessibility tool

Phase 2: Building a Budget for Title II Compliance

Once the initial audit has quantified your compliance debt, the next crucial step is translating those minutes into a sustainable financial plan. This plan must address both the cost of fixing existing content and the cost of maintaining compliance for new content going forward.

A. Cost Modeling: Vendor vs. In-House

The first decision in budgeting is determining your primary fulfillment strategy. The costs associated with each model are calculated differently and have different risks.

1. Vendor Model (e.g., 3Play Media)

This is the most straightforward and reliable approach for meeting regulatory requirements.

• Cost Metric: Cost Per Minute (CPM).
• Budget Calculation: (Total Minutes from Audit) x (Vendor CPM Rate) = Total Remediation Cost.
• Pros:
  • Guaranteed Accuracy: Vendors can support the specific accuracy requirements you have across different video formats.
  • Scalability: Ability to handle large batches of content quickly, reducing the timeline for compliance.
  • Turnaround Time: Faster processing, often within 24-48 hours, essential for course materials.
• Cons: Requires dedicated funding commitment.

2. In-House Model

This involves using internal staff (e.g., student workers, instructional designers) to handle captioning and transcription.

• Cost Metric: Fully Loaded Staff Hour Rate (Salary + Benefits + Overhead).
• Budget Calculation: (Total Minutes from Audit) x (Estimated Minutes per Hour for Manual Work) x (Staff Hour Rate) = Total In-House Cost.
  • Note: Manual captioning/transcription often takes 5 to 10 times the video length.
• Pros: Seemingly lower upfront cost.
• Cons:
  • Hidden Costs: High staff turnover, training overhead, and critical quality assurance (QA) needed to ensure 99% accuracy.
  • Risk: Quality issues can still expose the institution to legal risk.

Recommendation: Use a reliable vendor for all high-priority, public-facing, and academic content where accuracy is non-negotiable. Only use in-house resources for quality review or very low-stakes internal materials.

B. Identifying Budget Components

Your annual compliance budget should be structured around two primary cost buckets to ensure completeness:

Remediation Costs (One-Time / Project-Based)

This budget is solely for tackling the existing backlog identified in the audit. It should be treated as a project with a defined scope and timeline (e.g., a 12-to-24 month remediation window).

• Example: $50,000 to caption the 5,000 minutes of high-risk archival lectures.

Ongoing Production Costs (Annual / Sustained)

This is the most critical component for future-proofing compliance. It covers the cost of captioning every new video created during the fiscal year. This cost is ideally estimated based on historical trends (e.g., “The university produces approximately 1,200 new hours of video annually”).

• Example: Allocating $40,000 annually for new credit-bearing course videos.

C. Funding Strategies: Centralized vs. Decentralized

How the budget is managed and sourced determines the success and consistency of your compliance efforts.

Strategy	Description	Pros	Cons
Centralized	A single department (e.g., IT, Provost’s Office, or Disability Services) holds the entire compliance budget.	Ensures quality control and consistency; allows the institution to benefit from volume pricing with vendors.	Can strain the central budget if not adequately funded by executive leadership.
Decentralized	Compliance costs are pushed down to individual departments, schools, or PIs (Principal Investigators).	Encourages individual departments to be more mindful of content creation.	Leads to inconsistent quality, delays, and a high likelihood of budget shortfalls in smaller departments, creating compliance gaps.
Hybrid Model	Central fund pays for all required academic content (courses); Departments pay for optional public outreach or marketing videos.	Shares the financial burden while maintaining a core standard of compliance.	Requires clear policy guidelines to define what is “required” versus “optional.”

D. Leveraging Dynamic Accuracy for Efficiency

Traditional compliance budgeting is a trade-off: either you risk non-compliance with cheap automated captioning, or you budget heavily for human captioning on everything.

3Play Media offers a way to eliminate this “all or nothing” dilemma by leveraging data science to manage risk and budget simultaneously.

The Predicted Caption Accuracy model allows a university to drastically reduce expenditure on human services without sacrificing captioning compliance quality.

3Play’s dynamic approach means your budget is no longer wasted paying for human editors to review videos the AI already nailed.

Instead, you pay for human services only where the risk of non-compliance is demonstrably high, enabling maximum efficiency within your allocated compliance funds.

Summary Action Plan

The budgeting phase is complete when you can present a clear, defensible financial plan to executive leadership. Use the following action items to bridge your audit data with your final budget request:

1. Quantify the Total Compliance Debt

The audit’s final tally of non-compliant minutes is the core of your budget request. Present this to leadership not as a list of failures, but as the total scope of work (SOW) required to mitigate legal risk.

• Action: Calculate the total number of minutes that require remediation (High Priority + Medium Priority content).
• Result: A clear, quantifiable SOW (e.g., “The institution has a compliance debt of 15,000 minutes of lecture content and 3,000 minutes of public-facing media.”).

2. Establish Minimum Accuracy Thresholds

Not all video carries the same legal or academic risk. Applying the concept of dynamic accuracy allows you to set variable service requirements, which dramatically optimizes costs.

• Action: Define accuracy requirements based on content type.
• Example:
  • 99% Accuracy (Human Service): Mandatory for credit-bearing courses, official commencement, executive statements, and mandatory HR training.
  • 90% Accuracy (Machine + Light Review): Acceptable for departmental archives, non-essential internal announcements, and faculty self-produced content.
• Result: A policy document that justifies different price points for different video types, ensuring you only pay for human-level services where legally necessary.

3. Create a Two-Part Financial Request

To ensure long-term sustainability, separate the budget request into two distinct categories. This prevents the ongoing problem of compliance debt continuing to accumulate.

Part 1: Remediation Budget (One-Time): A project-based budget dedicated only to clearing the existing compliance debt identified in the audit. This should be a large, fixed sum requested once.

Part 2: Production Budget (Annual/Sustained): An operating expense budget dedicated to captioning all new content created this year and every year thereafter. This prevents future compliance backlogs.

What’s Next?

Preparing for ADA Title II compliance may feel overwhelming, but with the right strategy and tools in place, universities can move from reactive fixes to a sustainable, proactive approach to accessibility.

By auditing your content and building a realistic budget, you create a strong foundation for long-term inclusion and smoother compliance workflows.

We have several Title II resources such as our Title II Compliance Checklist and our Title II Video Compliance 101 webinar that can help you in this process. See all of our Title II resources.

3Play Media also offers key services that directly support the core requirements of video accessibility under Title II:

• Captioning: Our captioning solutions are built for accuracy, speaker identification, and correct timing to meet WCAG 2.1 AA and ADA requirements.
• Audio Description: We provide high-quality, AI-enabled audio description that helps you meet Title II requirements while scaling affordably to match your volume. AI-enabled audio description that ensure you achieve Title II compliance while affordably scaling to meet your needs.

As the Title II deadlines approach, having an experienced accessibility partner can make all the difference. With 3Play Media, universities gain the tools and expertise needed to build a more inclusive, compliant, and student-centered digital environment.

Chat with a member of our team to see if 3Play is a good fit for your institution:

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ADA Video Compliance FAQs

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