Accessibility compliance isn’t just a legal checkbox anymore. For public colleges and universities, ADA and WCAG compliance is now a specific federal requirement with a firm deadline attached. The Americans with Disabilities Act (ADA) requires public-facing websites and apps to be accessible. Since 2024, the Department of Justice has spelled out exactly what that means: WCAG 2.1, Level AA. This is a defined set of 50 technical success criteria, due by April 2027 or 2028, depending on institution size. Private institutions and corporations fall under a different part of the law without a codified deadline. However, that doesn’t mean the risk is any lower.
If you’re responsible for equipment reservation software, room scheduling, or any other patron-facing system, here’s what that means for you.
The ADA, in Plain English
The ADA is the country’s foundational civil rights law for accessibility. It prohibits discrimination against people with disabilities in “places of public accommodation.” For over a decade, courts have consistently ruled that websites and mobile apps count as public accommodations too.
Here’s the catch: when the ADA was signed in 1990, nobody had defined what an “accessible website” truly looked like. That left a lot of institutions guessing, until WCAG stepped in to fill the gap.
Where WCAG Fits In
WCAG (Web Content Accessibility Guidelines) is the technical standard the W3C developed to define what accessibility means online. Think of the ADA as the law and WCAG as the rulebook that tells you how to follow it.
WCAG defines three conformance levels: Level A (minimum), Level AA (the standard most institutions target, and the one now required by federal law for public entities), and Level AAA (the most restrictive). Level AA conformance covers criteria like:
- All functionality is operable by keyboard alone, no mouse required
- Text can be resized up to 200% without breaking the layout
- Text has sufficient contrast against its background (4.5:1 for normal text, 3:1 for large text)
- Live and prerecorded video includes captions
These aren’t suggestions. Instead, they’re specific, testable benchmarks that auditors and courts use to determine whether an equipment reservation system, or any patron-facing tool, is accessible.
The 2024 DOJ Rule Changed the Conversation
For years, the honest answer to “is WCAG legally required?” was “it’s complicated.” For public institutions, that’s no longer true.
On April 24, 2024, the DOJ finalized a rule under Title II of the ADA. It covers state and local government entities, including most public colleges and universities, and formally adopts WCAG 2.1 Level AA as the required technical standard. In April 2026, the DOJ issued an interim rule extending the original deadlines: April 26, 2027, for public entities serving populations of 50,000 or more, and April 26, 2028, for smaller entities and special districts.
A few things worth knowing:
- The deadline is based on the population of the surrounding state or municipality your institution belongs to, not student enrollment.
- The rule applies to websites, mobile apps, and digital documents your institution “provides or makes available,” including third-party and vendor-hosted equipment reservation software.
- There are limited exceptions (for example, if full compliance would cause undue financial and administrative burdens), but institutions still carry an ongoing obligation to make services accessible even where an exception applies.
If your organization is private — a private university, corporation, or media company — Title II’s hard deadline doesn’t apply to you directly. However, Title III of the ADA, which covers private businesses, has driven a steady wave of web accessibility lawsuits for years, independent of any DOJ rule. As a result, WCAG 2.1 AA remains the standard courts point to when deciding those cases.
What Happens If You’re Not Compliant
The risks generally fall into three buckets:
- Legal exposure. Web accessibility lawsuits and DOJ/OCR complaints have risen sharply, and public entities now have a specific rule, not just case law, to be measured against.
- Excluded users. Students, faculty, and staff with visual, auditory, motor, or cognitive disabilities may be unable to use a scheduling or checkout system that isn’t built with accessibility in mind. This undercuts the whole point of offering the service.
- Reputational risk. Accessibility failures are visible, screenshot-able, and increasingly reported on by campus newspapers and advocacy groups.
Accessibility in WebCheckout
If your institution hasn’t audited its equipment reservation software against WCAG 2.1 AA yet, now’s the time. The 2027/2028 deadlines will arrive faster than they feel. Talk to our team about how Patron Portal approaches accessibility, and see what accessible equipment scheduling looks like in practice.
Frequently Asked Questions
Does the WCAG requirement apply to private universities?
Not with the same hard 2027/2028 deadline — that applies specifically to Title II (state and local government) entities. Private institutions fall under Title III, which doesn’t have a DOJ-codified deadline but carries ongoing litigation risk tied to the same WCAG 2.1 AA standard.
What is WCAG 2.1 Level AA?
It’s the middle of three WCAG conformance levels (A, AA, AAA) and the technical standard the DOJ adopted in 2024. It includes 50 success criteria covering things like keyboard navigation, color contrast, resizable text, and video captioning.
Who decides my institution’s compliance deadline?
The deadline is based on the population of the state or municipality your institution is part of — not your enrollment size. A state university uses its state’s population; a city or county institution uses that city’s or county’s population.
Does third-party software count under the rule?
Yes. The rule covers web content and mobile apps your institution “provides or makes available,” which includes vendor-hosted equipment reservation software and scheduling tools.