Title II of the Americans with Disabilities Act (ADA) requires public entities, including universities, to ensure that their digital content is accessible to people with disabilities. The U.S. Department of Justice’s (DOJ) 2024 Title II Final Rule establishes accessibility requirements and sets expectations for addressing existing digital content that does not yet meet those requirements. Meeting these requirements involves remediating required digital content, ensuring that newly published content is accessible, prioritizing updates to materials that remain in active use, and determining when older content should be archived. These expectations shape how digital content is created, maintained, and managed across the University of Maryland, Baltimore (UMB).
Title II Accessibility Requirements and Timeline
On April 24, 2024, the Federal Register published the DOJ’s final rule updating its regulations for Title II. The final rule establishes requirements for ensuring that web content and mobile applications are accessible to people with disabilities who access the services and programs of State universities.
On April 20, 2026, the DOJ issued an interim rule extending the compliance deadline to April 26, 2027. This provides additional time to complete remediation efforts and postpones federal enforcement of the Web Content Accessibility Guidelines (WCAG) 2.1, Level AA standard under Title II by one year.
This extension does not change the requirement that digital content must be accessible. UMB will continue advancing this work and build on current progress. Content used to provide access to services, programs, or activities remains the highest priority for remediation.
Required Accessible Digital Content Remediation
Pre-existing electronic documents must be remediated 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 to understand, apply for, access, or participate in something UMB offers, that content must be accessible. This expectation remains in place as the University continues progressing toward full compliance.
Digital Content with Deferred Remediation Priority
Some content may not require immediate remediation, 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.
Read the conditions and requirements for archiving web content.
Institutional Implications for UMB
The DOJ’s Title II rule requires state and local government entities to ensure that their digital content is accessible under 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 required under Title II is WCAG 2.1, Level AA.
While the federal compliance timeline has been extended, UMB remains committed to continuing this work and building on current progress. UMB is guided by its Policy on Web Accessibility (X-99.22(A)) and its commitment to inclusiveness. Faculty and staff are expected to continue making steady progress toward accessibility across all digital content.
This requirement is about more than technical compliance. It also 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, nor 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 ultimately is 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 webpages, 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 advancing UMB’s commitment to inclusive, accessible digital experiences.