Document Accessibility Transformation

ADA Title II — Population ≥ 50,000

State and local governments and the public colleges and universities they operate must conform to WCAG 2.1 Level AA

ADA Title II — Population < 50,000

Smaller public institutions receive a one-year extension on the same standard

ADA Title III + Section 504

Private colleges, universities, and recipients of federal funding face parallel obligations under the Rehabilitation Act

Financial Data Transparency Act

Issuers of public debt must publish machine-readable, structured, accessible financial disclosures

Preexisting Documents Exception

Only applies to documents publicly available before the rule and unaltered since. Most institutions that believe their archive is exempt are wrong

12+ State Laws

CA ($4K/violation), CO, IL, MA, MN, MO, NY, NC, OK, TX, VA, WA — independent statutes with stricter standards, broader scope, or higher penalties

DOJ + OCR Escalation Since 2023

Complaint investigations, resolution agreements, consent decrees, litigation with fee-shifting, loss of federal funding, reputational exposure in accreditation reviews