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The (ADA), signed into law on July 26, 1990, established a civil rights framework prohibiting discrimination against people with disabilities across public life. Central to that framework is , which prohibits disability-based discrimination by state and local government entities, including public schools, colleges and universities, in their services, programs, and activities, including digital content and services.

In the nearly 36 years since the ADA’s passage, the digital landscape and public education with it, has transformed dramatically. Schools now rely on technology for instruction, communication, educational resources, and administrative tasks. From course registration and classroom teaching to notifying families about school closures, nearly every aspect of education now involves technology.

In April 2024, the Department of Justice (DOJ) issued establishing clearer technical standards for digital accessibility. The rule adopts the as the baseline accessibility standard and created phased compliance deadlines – April 24, 2026, for public entities serving populations over 50,000 and April 26, 2027, for all others. These standards are particularly significant in K-12 education where . Furthermore, according to principles of , accessible digital design can improve usability and learning outcomes for all who interact with the public education system, including parents, caregivers, educators, and students without disabilities.��

On April 20, 2026, just days before the first compliance deadline, the DOJ issued an interim final rule delaying implementation by one year and signaling that additional regulatory changes may follow. Importantly, the delay did not change public entities’ existing obligations – digital accessibility still remains a legal requirement under the ADA. It did, however, raise questions about the current status of compliance. Additionally, the DOJ signaled that more substantive changes to the rule could be forthcoming.��

To better understand how states and school systems are responding, �鶹������ý’s Teaching, Learning, and Tech team conducted a 50-state and territory scan examining state-level implementation efforts in public K-12 schools and institutions of higher education, along with interviews with six district leaders, disability and education advocates, and state officials. While not representative of all K–12 experiences, interviewees consistently supported the regulations’ goals but raised concerns about schools’ capacity to meet the original timeline. Their experiences underscore the need for clear guidance, sustained technical assistance, and strong implementation strategies to advance digital accessibility across education systems, regardless of the compliance date.

Key Findings

Higher Education Leads While K – 12 Lags in Compliance Readiness��

Across all 50 states and territories, every state had at least one institution of higher education that has explicitly referenced the WCAG 2.1 Level AA standard in their accessibility statements�� and shared plans to meet compliance requirements by the original deadline. Many colleges and universities, such as the and , have already begun building substantial accessibility infrastructures, including detailed guidance documents, training resources, and review processes.��

Institutions and states have also developed innovative approaches to making digital accessibility more approachable for educators and the public. The University of Illinois Urbana-Champaign recently launched their “” which provides digital accessibility support to university professors through a gamified challenge. and the state of Idaho’s provide accessibility evaluation services to review digital material and advise on accessibility criteria and standards.��

In contrast, the scan found relatively little public-facing guidance directed toward K-12 systems. Few state education agencies publicly acknowledged the updated rule, and public resources specifically designed to help local education agencies were limited. Interviews with small and large school district leaders suggest that some guidance is being shared internally but these efforts often lack visibility and centralized coordination.

K – 12 Supports Accessibility Goals but Need Resources and Support��

District leaders, teachers, and advocacy organizations consistently expressed support for the intent of the regulations and broadly agreed that improving digital accessibility is necessary. In response to the delayed implementation timelines, has publicly noted that although federal timelines have shifted, “this change should not be interpreted as a pause in accessibility efforts… [it is] additional time for our institution to thoughtfully plan, implement, and sustain accessible digital experiences.” This sentiment has been echoed more broadly by state governments, such as the which states that the new rule “does not change the importance of accessible digital services.”

At the same time, many K – 12 stakeholders described feeling overwhelmed by the scope of implementation. Several interviewees reported learning about the updated regulations late in the process leaving them with little time to ensure digital material met the WCAG minimum standards. District leaders reported wanting stronger and more sufficient guidance from their state agencies. However, all interviewed districts did report receiving some form of guidance from peer networks, the most helpful being from other school districts and organizations such as and the Center on Inclusive Technology & Education Systems (CITES) .��

Some interviewees described a gap between the special education and the general education system’s preparedness for implementation. For many general education teachers and administrators, the updated regulations represent a more significant shift in practice. District leaders emphasized that successful implementation will require sustained training for all teachers and institutional buy-in, particularly in settings where familiarity with accessibility standards may be more limited.��

Stakeholders also raised concerns about third-party vendors that manage critical school functions such as enrollment, meal payment systems, and even course instruction. Although schools and districts will be held accountable for ensuring digital accessibility standards are met, they often have limited control over the design of a vendor’s system once contracts are signed. Many described vendor compliance as one of the most difficult aspects of implementation, particularly for smaller districts with limited procurement capacity.��

Stakeholders across interviews described digital accessibility as a systemwide responsibility that requires coordination across multiple levels of governance. District administrators noted needing clearer support from state leaders in procurement and implementation planning, while teachers often needed more support from school leadership on accessible instructional practices and curriculum design. Many stakeholders described existing systems of support as fragmented or underdeveloped.��

Recommendations

Despite the critical protections the ADA affords individuals with disabilities, the federal government does not provide financial assistance to public entities to assist in compliance. It can, however, provide technical assistance and support.��

Interviews and state scan findings suggest that schools broadly support the goals of the updated regulations but need more resources, clearer guidance, stronger coordination, and more practical implementation support.��

Four steps can be taken to improve compliance:��

• The Department of Justice, the Department of Education, and the Office of Civil Rights should provide additional technical assistance and support. Joint sub-regulatory guidance should be issued to further clarify implementation expectations and provide practical guidance on issues such as procurement, staff training, content remediation, and more.��
• State education agencies should play a stronger coordination role in supporting K-12 districts. District leaders consistently reported peer learning from other school systems was among the most valuable forms of support. States can more effectively create opportunities for this by creating formal channels for collaboration and resource sharing across districts. States should also work to create stronger connections between the K-12 system and the higher education systems in their state given that many colleges and universities have already created robust accessibility infrastructures.��
• State and local leaders should work to bridge the gap between general education and special education. More integrated professional development and cross-functional planning would help better equip all educators to act on this shared institutional responsibility.��
• The Department of Justice, the Department of Education, and the Office of Civil Rights should facilitate procurement reform and technical assistance that supports greater accountability from EdTech developers and third-party vendors. Greater attention should be paid during development of EdTech products to ensure they meet minimum standards of digital accessibility. Furthermore, federal agencies should provide clearer guidance to schools on how to hold vendors accountable through the procurement and contracting process.

Conclusion��

The updated Title II regulations reaffirm a central promise of the ADA – people with disabilities have a right to equal access to public education and public life including digital technologies. In an educational environment increasingly shaped by digital technologies, digital accessibility makes learning and engaging with the school system better for all students and their families, not just those with disabilities.��

The recent delay in implementation of the rule will give schools more time to build infrastructure, train teachers, and align accessibility standards to the WCAG 2.1 Level AA. However, as underscored by several stakeholders, it’s imperative that schools do not pause or delay their work towards compliance. At the same time, government agencies can and should do more to support school leaders and teachers on the ground.��

Ultimately, these regulations are about more than just compliance. They are about creating an educational environment where all students and families can fully participate and thrive.��