Digital Accessibility

ADA Title II Digital Accessibility Requirements

Fitchburg State University is committed to ensuring equal access to digital information and services. Under the Americans with Disabilities Act of 1990 (ADA), as amended, and its implementing regulations (28 CFR § 35.200), the university must provide accessible online content so that individuals with disabilities can obtain the same information, engage in the same interactions, and receive the same benefits and services as individuals without disabilities.

The U.S. Department of Justice (DOJ) has issued new Web and Mobile Accessibility regulations (28 CFR Part 35, Subpart H). These require that by April 24, 2026, all public entities serving populations of over 50,000 people, including public colleges and universities, comply with the Web Content Accessibility Guidelines (WCAG) 2.1, Level AA (WCAG 2.1).

WCAG 2.1 Level AA is the benchmark for digital accessibility under ADA Title II. It requires websites, documents, and apps to be perceivable, operable, understandable, and robust for all users, including those with disabilities. This includes providing text alternatives for images, captions, and transcripts for audio/video, using headings and structure properly, ensuring keyboard navigation, maintaining clear and consistent design, ensuring sufficient color contrast, and ensuring compatibility with assistive technologies. Meeting Level AA ensures digital content is usable and accessible to the broadest possible audience.

To support campus-wide compliance, Fitchburg State has assembled a Digital Accessibility Working Group (DAWG). This group includes representatives from Personnel Services, Disability Services, Equal Opportunity, Academic Affairs, Student Affairs, Marketing and Communications, and the Technology Department. Updates and resources will be posted on this page as they become available.

Application and Scope

The regulations apply broadly to all digital content:

  • Websites and web applications
  • Conventional electronic documents (PDFs, Google Docs, MS Word, Excel, PowerPoint, etc.)
  • Email communications and digital newsletters
  • Mobile applications (apps)
  • Course materials in Blackboard, including third-party embedded content (e.g., YouTube videos)
  • If you post or distribute digital content in any form, it must have an accessible alternative (e.g., captions, transcripts, alt text)
  • Third-party digital information and services provided or made available through contractual, licensing, or other arrangements with the university

University Technical Standards

  • WCAG 2.1, Level AA is the required technical standard  
    • Fitchburg State University requires all software and system vendors to submit a current Voluntary Product Accessibility Template (VPAT®) as part of the procurement process. The VPAT must demonstrate conformance with WCAG 2.1 Level AA or higher, clearly outlining accessibility features, known limitations, and plans for addressing any gaps. No purchase will be executed without a compliant VPAT on file.
  • The university has adopted the same benchmark as the Massachusetts Enterprise Digital Accessibility Policy
  • Accessibility must be proactive: digital content should be accessible from the start, not addressed later only through accommodations

Minimum WCAG 2.1 standards include:

  • Perceivable: Text alternatives for non-text content, captions for audio/video, adaptable presentation
  • Operable: Keyboard accessibility, enough time to read/use content, and no seizures triggered by flashing content
  • Understandable: Clear navigation, readable text, predictable web page behavior
  • Robust: Compatible with assistive technologies

Guidelines for Creating Content

Should Your Document Be a Document?

Before creating or remediating a file, ask: Would this content be more accessible as a web page (HTML), knowledge article, or news post instead of a document? Web pages are often easier to make accessible and work better across devices.

Use PDFs Sparingly

  • PDFs require extra tagging for screen readers and limit resizing for low-vision users
  • When possible, share information in its source format (Word, Excel, Google Docs) or as HTML
  • If you must publish a PDF, it needs to be made accessible and may require third-party remediation
  • Not all PDFs can be remediated—complex documents may be rejected

Best Practices for Authors

  • Use headings, lists, and tables correctly
  • Add document titles and specify the language of the document
  • Provide descriptive hyperlinks
  • Add alt text for images, charts, and graphs
  • Ensure sufficient color contrast
  • Caption all videos and provide transcripts for audio

Tools and Resources

Training Opportunities

None at this time.

Frequently Asked Questions

A. Each unit within the university must ensure that its digital materials meet the minimum accessibility requirements as required by ADA Title II. At Fitchburg State, we are all responsible for our digital communications. Whether you author or request web content, email to distribution lists, use apps or systems to chat or share documents with a group, or teach using an electronic course shell, you are the owner and manager of the information you share. To support this university-wide initiative, training and tools will be shared for all to access and utilize.

A. We recommend that your department or group begin by identifying all of your digital sources of information.

  • Do you post information on the website?
  • Do you utilize an additional website, social media, or other public-facing system to communicate information?
  • Do you post or send PDFs electronically?
  • Do you have charts, images, or videos online? 

Once you have established an inventory, determine which content is still actively used and which content can be deleted or archived. Then you are ready to conduct a basic assessment of your online content against the new regulations.

A. Web Content Accessibility Guidelines (WCAG) 2.1, Level AA

A. The university is searching for a document scanning tool to enable and support employee compliance with the regulations. The new scanning tool will be able to review content uploaded to Blackboard and to our website to identify items that do not meet the standards. The tool must also be able to provide guidance to correct issues, generate alternate formats for instructional content, and provide reports for leadership and key stakeholders.

Websites can be scanned using the free WAVE tool https://wave.webaim.org and WAVE browser extension https://wave.webaim.org/extension.

A. Some examples include instructional content hosted in the Blackboard or Canva learning management system, online textbooks, all department webpages (including websites behind a login), online portals for registration and other transactions, library databases, forms, mobile apps, emails, online videos, webinars, live-streamed and recorded events, digital documents and materials (i.e. PDF files and PowerPoint presentations) and information shared through software and web-based platforms that the university manages.

A. As these standards will be enforced nationwide, we are hopeful vendors will be prepared to ensure they can meet the standards.  Third-party digital information and services provided or made available through contractual, licensing, or other arrangements with the university must be readily accessible and conform to WCAG 2.1, just as all other digital information and services. Legal responsibility for ensuring the accessibility of third-party digital content falls to the university.

If your department contracts with a third party to provide information, they may be able to provide verification of compliance with WCAG 2.1. New contracts must include language to ensure compliance with federal law.  The Technology Department and Procurement must review all new and renewed contracts before executing. 

A. The enhanced requirements do not apply to these five (5) categories of online content: 

  1. archived web content
  2. preexisting conventional electronic documents that are no longer used (e.g. a nursing handbook published before April 2026 that is no longer in use)
  3. individual password-protected documents for a specific person
  4. preexisting social media posts
  5. and content posted by a third party

A. Older digital content that meets specific criteria may be archived on the website. This exception is used sparingly to enable continued access to historical and reference content.  It reduces the need to remediate content no longer in active use while maintaining accessibility for people with disabilities through alternative formats when needed. 

A. To apply this exception, the content must meet all four of these requirements:

  1. Created before 04/24/2026, or is a reproduction of something that was (such as a scanned handout, audiotapes, film negatives, or CD) created before that date; AND
  2. Used only for research, reference, or recordkeeping. It is not being kept for use in current instruction, programs, services, or public communication; AND
  3. Stored in a clearly labeled archive section, so users understand it may not meet accessibility standards; AND
  4. Not changed after being archived. Any edits, however minor, disqualify the content from this exception

A. Guides and checklists are available here:  https://www.mass.gov/info-details/creating-accessible-electronic-documents-and-communications

A. In these cases, the university must provide a conforming alternate version. This acts as a temporary way of providing access to digital content that hasn’t or can’t be made accessible. Units are only allowed to do this when technical or legal constraints make it impossible to ensure accessibility. The Disability Services Office must approve these alternatives.