(Updated May 28, 2026)
What’s New
The Department of Justice (DOJ) will enforce the new rule regarding the
accessibility of web content and mobile applications under Title II of the
Americans With Disabilities Act (ADA) starting in April 2027. The new rule
requires compliance with the Web Content Accessibility Guidelines (WCAG) 2.1,
Level AA technical standards for creating accessible websites and mobile apps. While
the DOJ ruling and regulation for Title II is new, the WCAG technical standards
are not. Title II is primarily focused on state and local government entities,
which includes public colleges and universities. However, under Section 504 of
the Rehabilitation Act, any public or private college or university that
receives federal funding has always been required to follow these accessibility
guidelines for web content and mobile apps.
Extended Deadlines
The deadlines announced by the DOJ on April 20, 2026 for state and local government entities are:
- April 26, 2027 for entities with a total population of 50,000 or more
- April 26, 2028 for entities with a total population less than 50,000, or any special district government
The extension does not change Orbis policy or response to requests for remediation of partner-created materials outside of new or formal redevelopment.
Orbis Compliance
Orbis web content has been compliant with accessibility
guidelines since 2018. In other words, nothing has changed for Orbis; our
policy for digital course assets and accessibility conformance reports (ACRs) are
kept current by the product development team and are approved by Orbis legal
counsel.
As a third-party vendor to our partners, we are required to state
how we meet ADA requirements. Orbis policy outlines how we meet requirements
for digital course materials, and our ACRs address learning objects, extended reality
(XR) assets, and the Electronic Hospital Records (EHR) Simulation. In addition,
our policy and ACRs are based on WCAG Version 2.2, Level AA (the latest version).
As a third-party vendor, we are not responsible or obligated
to ensure partner-created materials outside of new development or formal
redevelopment are accessible. We are responsible for making Orbis-created digital
materials accessible when used in a course.
Partner Support
Orbis does not support or correct accessibility issues with
course materials created by the SME, faculty, or instructor outside of new development
or formal redevelopment. If a partner asks for help or guidance to remediate
materials, they should be referred to their institution’s accessibility support
resources to ensure they follow the institution’s ADA compliance guidelines. If there is a desire to provide customer
service by fulfilling a request to make partner-created materials compliant, a
discussion among the ID, ELS, VPP, and VPN teams is required. Decisions to
support the request will consider resource availability, accessibility needs,
and risk management.
Resources
Read the following to learn more about the DOJ announcement,
its impact on higher education, and the WCAG technical standards.
- New
Federal Digital Accessibility Requirements: What Higher Ed Needs to Know
and Do Now (Online
Learning Consortium)
- Fact Sheet: New Rule on
the Accessibility of Web Content and Mobile Apps Provided by State and
Local Governments (U.S. Department of Justice Civil Rights Division)
- WCAG 2 at a Glance (W3C)
Review these resources for
more information about Orbis policy, ACRs, and support tools.
- For
an overview of the Orbis policy, read the What Is
Our Policy? article.
- Orbis Education Accessibility
Policy for Digital Course Assets contains
our standards based on guidelines for web-delivered content.
- ACRs for learning objects, XR assets, and the EHR Simulation demonstrate our degree of conformance to
WCAG 2.2, Level AA criteria.
- Quality
Gauge Dashboards provide
an at-a-glance resource to check a partner’s accessibility compliance
score from the last QA review of the courses represented on the dashboard.