In April, the U.S. Department of Justice extended the ADA Title II digital accessibility compliance deadlines by one year. For most state and local government entities—including public universities—the new deadline for ensuring websites and mobile apps are accessible to people with disabilities is April 26.
This should be understood as exactly what it is—an opportunity to get accessibility right, in what is still a very tight timeline. The key takeaway is that this change is about prioritizing compliance.
Achieving ADA compliance can be complicated, and eight months is not much time to complete the required work. You must proceed strategically to meet the deadline.
Your organization is responsible
Procurement should be one of your first priorities. Higher education increasingly runs on technology that your institution did not build and cannot directly fix.
Gartner predicts that by 2028, 75% of higher-ed IT installations will be managed through cloud-based services and solutions. That makes accessible procurement much more than a purchasing practice. It is one of your most important accessibility controls.
The challenge is multi-pronged. You have to ensure that every vendor-sourced thing is accessible—and not just the software you’re going to buy in the future, but what you already have. This requires new testing approaches and processes.
You have to understand risk levels associated with the student-facing software you’ve already bought and figure out how to reduce that risk through testing. At the same time, you must evaluate and update your procurement processes to ensure every new purchase meets requirements.
Remember, your organization is directly responsible for the accessibility of your websites and apps—even if an accessibility issue originates with a third-party provider’s code. This makes getting the right procurement processes in place one of the most important things a public university should do right now.
If that’s not enough to cue the urgency, here’s something else to factor in: the National Federation for the Blind has already filed a lawsuit challenging the ADA deadline extensions. If successful, those deadlines could snap back to their original dates at any time.
Vetting digital accessibility
If this all seems daunting, don’t panic. Vetting digital accessibility compliance isn’t all that different from how you manage privacy and security. Bring that same rigor to digital accessibility, and you’ll make the deadline.
For the third party software you already have, the work is comparatively straightforward:
- Understand your current state. This means inventorying all third-party digital technology that supports your public and customer programs and services—websites, mobile apps, LMSs, student systems, library systems, classroom tools, SaaS products, plugins, open-source components, and more. You need to know where to look for accessibility issues, and who to flag them to.
- Pressure-test accessibility claims. You can’t rely on vendor documentation for this. You need to decide when products need accessibility testing, demonstrations, assistive-technology testing, or usability testing with people with disabilities before renewal. And remember that automated testing alone cannot determine accessibility. You must use a combination of automated and manual assessment.
- Track whether vendors actually fix any accessibility issues. You need to monitor vendor responsiveness and assess whether they have credible roadmaps—especially for critical and serious barriers. This is where procurement becomes an ongoing governance function rather than a one-time RFP checkbox.
Focus on 6 priorities
As for your procurement processes going forward, focus on six imperatives: inventory, requirements, verification, contracts, risk management, and monitoring. Know what you use and require accessibility before buying it. Verify vendor claims and put requirements into contracts. Formally manage unavoidable exceptions, and monitor vendors and outcomes over time.
Your goal is to stop acquiring new accessibility problems. You can do this by establishing accessibility requirements for new purchases, licenses, renewals, and major upgrades now.
This is the prevention piece of the framework: don’t keep introducing inaccessible technology into the environment while simultaneously trying to manage your existing estate.
One of the most complex pieces of the procurement puzzle—and one of the strongest arguments for keeping your foot on the pedal even with the deadline extension—is contracts.
It is crucial that you put digital accessibility requirements into your vendor contracts. Move accessibility from a vendor promise to an enforceable vendor expectation. This includes technical requirements, testing, required remediation timelines, reporting, and detailed roadmaps for what happens when accessibility issues surface.
Step one is to review existing contracts and assess high-risk vendors. Determine which contracts expire or renew before April 2027, and which vendors need remediation commitments.
For now, the expectation is that the extended deadlines will hold. Use the months you have to make meaningful, measurable progress.
Prioritizing procurement as a target for digital accessibility compliance will take you a long way toward meeting your ADA obligations, and success depends on starting the work immediately.
The image above was created with AI.
