Title II of the Americans with Disabilities Act (ADA) requires state and local governments to make sure that their services, programs, and activities are accessible to people with disabilities. Title II applies to all services, programs, or activities of state and local governments, from adoption services to zoning regulation. This includes the services, programs, and activities that state and local governments offer online and through mobile apps.
To be compliant with Title II of the ADA, our website and other digital content must be compliant with the WCAG 2.1, Level AA standard.
What Is WCAG?
WCAG is the Web Content Accessibility Guidelines created by the World Wide Web Consortium, or W3C. It is a standard that is used to measure accessibility compliance.
The WCAG 2.1 has 13 guidelines. For each guideline, there are testable success criteria. The success criteria are at three levels: A, AA, and AAA. The success criteria are what determine “conformance” to WCAG. To meet WCAG, the content needs to meet the success criteria.
A full explanation of critieria can be found at the W3C website. For those who are editing our website or creating digital documents, Silktide provides detailed explanations of the criteria and how to address them when reviewing issues that have been flagged. This can be a much better resource for everyday content management.
ADA Title II Final Rule
On April 24, 2024, the Federal Register published the Department of Justice’s final rule updating its regulations for Title II of the Americans with Disabilities Act (ADA). The final rule has specific requirements about how to ensure that web content and mobile applications are accessible to people with disabilities.
Under Title II of the ADA, public entities are required to ensure that certain pre-existing digital content is made accessible by April 24, 2026. The key factor is not the format of the content, but how the content is used. Any digital content created after this date must be accessible.
Required Accessible Digital Content Remediation
Pre-existing electronic documents must be remediated by April 24, 2026, if they are currently used to apply for, gain access to, or participate in a UMB service, program, or activity.
This includes documents hosted on UMB public websites and other public digital platforms, regardless of file type.
Examples include:
- Policies, procedures, or forms required to access UMB services or facilities
- Application forms, registration materials, or instructions
- Documents related to public programs, events, or offerings
- Public-facing PDFs, Word documents, spreadsheets, or other files that are actively used
- Images on public websites that convey information and require alternative text
If a member of the public needs the content in order to understand, apply for, access, or participate in something UMB offers, that content must be accessible by the deadline.
Digital Content with Deferred Remediation Priority
Some content may not need to be remediated by April 24, 2026, including:
- Archived public content that is no longer actively used and is not required to access a current service, program, or activity
- Past event materials, outdated reports, or historical documents that are not referenced for current use
- Internal, employee-only working documents that are not used to provide access to a service, program, or activity
Content owners are responsible for determining whether their materials are still in active use or should be archived or removed.
UMB is actively prioritizing high-risk, public-facing content and working with schools and units to address it. Additional guidance, training resources, and tools are available to support this work.
When to Archive Content
Many pre-existing electronic documents are still made available for reference purposes. There is a exemption for remediating these documents by the deadline. According to the ADA.gov website:
Web content that meets all four of the following points would not need to meet WCAG 2.1, Level AA:
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- The content was created before April 24, 2026, or it reproduces paper documents or the contents of other physical media that were created before the deadline, AND
- The content is kept only for reference, research, or recordkeeping, AND
- The content is kept in a special area for archived content, AND
- The content has not been changed since it was archived.
Any documents that qualify with these criteria must be placed in a page that is clearly marked as an archive. If an older document is no longer needed or relevant, it can also be removed from the website entirely.
Institutional Implications for UMB
The U.S. Department of Justice’s Title II rule requires state and local government entities to ensure that their digital content is accessible under the Americans with Disabilities Act (ADA). For UMB, this means that public-facing websites, mobile applications, and other digital content used to deliver services, programs, or activities must meet established accessibility standards. The technical standard adopted by the DOJ is the Web Content Accessibility Guidelines (WCAG) Version 2.1, Level AA.
This requirement is about more than technical compliance. It reflects UMB’s obligation to provide equal access to information, services, and opportunities for people with disabilities. Digital barriers can prevent individuals from applying for programs, accessing services, understanding policies, or fully participating in university activities. Addressing those barriers is essential to fulfilling our role as a public institution.
Digital accessibility is not a one-time effort or a single project. It is an ongoing institutional responsibility that requires sustained attention, shared accountability, and consistent practices across the university. While central teams provide guidance, tools, and coordination, accessibility is ultimately shaped by the day-to-day decisions made by faculty and staff who create, manage, and publish digital content.
Whether you are creating documents, updating web pages, sending communications, managing events, or using digital tools to deliver services, your work plays a role in ensuring equitable access. The resources and guidance provided here are intended to support you in meeting these responsibilities and in advancing UMB’s commitment to inclusive, accessible digital experiences.