What Is ADA Title II?
Title II of the Americans with Disabilities Act (ADA) prohibits discrimination on the basis of disability by state and local governments, including public colleges and universities. It requires public entities to provide equally effective communication to people with disabilities.
For decades, courts and the U.S. Department of Justice (DOJ) have interpreted that requirement to include websites and digital content. In April 2024, the DOJ issued a final rule that, for the first time, set a specific technical standard for what "accessible" means online.
The 2024 DOJ Rule, In Plain Language
The rule says that public entities — including the Foothill-De Anza Community College District — must make their web content and mobile applications conform to Web Content Accessibility Guidelines (WCAG) 2.1, Level AA.
WCAG 2.1 AA covers things like:
- Text alternatives for non-text content (alt text on images)
- Captions and transcripts for audio and video
- Sufficient color contrast between text and background
- Content that can be navigated with a keyboard alone
- Pages that can be resized and reflowed
- Form fields with clear labels
- Page structure that screen readers can interpret (proper headings, lists, landmarks)
Compliance Deadlines
On April 20, 2026, the DOJ issued an Interim Final Rule extending the original deadlines by one year:
- Public entities serving populations of 50,000 or more: April 26, 2027
- Public entities serving populations under 50,000, and special district governments: April 26, 2028
The Foothill-De Anza Community College District falls under the April 26, 2027 deadline. The technical standard, the scope of what's covered, and the underlying obligation to provide accessible digital services have not changed — only the dates.
What's Covered
The rule applies broadly to digital content the district provides, including:
- Public-facing websites and the content within them
- Web applications and portals
- Mobile applications
- Documents posted on our sites (PDFs, Word, PowerPoint, Excel)
- Video and audio content
- Course content delivered through district systems
Limited Exceptions
The rule includes a small number of narrow exceptions. The most commonly referenced ones are:
- Archived web content — content kept only for reference or record-keeping that is not currently used in programs or services and is clearly identified as archived
- Pre-existing electronic documents — documents posted before the compliance date, unless they are still being used for current programs or services
- Third-party content — content posted by third parties that is not under the district's control (such as user comments)
- Individualized password-protected content — content created and shared with a specific individual (this exception is narrow and does not cover most password-protected institutional content)
These exceptions are narrower than they may sound. As a rule of thumb, if content is actively used or actively linked from active pages, it should be made accessible.
What This Means For ETS-supported Sites
Educational Technology Services is working through a remediation plan that addresses templates, page structure, and existing content across our sites. The fastest way to make district-wide progress, though, is for everyone who creates or edits content to apply accessible practices going forward.
The Quick accessibility tips page is the best next step if you'd like to start making your own content more accessible today.