Background
In the spring of 2024, new federal web accessibility rules for state and local government entities were finalized. The rules take effect for all public universities, including the University of Oregon, on April 24, 2026 (new regulations under Title II of the Americans with Disabilities Act, from the U.S. Department of Justice) and May 11, 2026 (new regulations under Section 504 of the Rehabilitation Act, from the U.S. Department of Health and Human Services.
Basic Requirements
Under these rules, web content from state and local government entities is required to meet Web Content Accessibility Guidelines (WCAG) 2.1 AA standards as of April 24, 2026 (both new content published after that date and existing content that is still on the web after that date). Web content is defined as anything viewed with a web browser, including:
- Websites and web pages (including public-facing sites, internal sites, and password-protected sites)
- Digital documents made available on the web (PDFs, word processing files, presentations, and spreadsheets)
- Streaming videos and multimedia on the web
- Course materials accessed via the web, regardless of course modality (including all content in Canvas and MyTrack)
- Third-party websites and web-based systems that the university has a contract, license, or other arrangement for
Additionally, two other types of web-connected systems are covered by the rules:
- Mobile apps
- Kiosks
The rules apply to all new and existing web content, regardless of the audience. For assistance in determining how to prioritize materials for remediation, visit the Accessibility Prioritization Guidance page.
Core Exceptions
If content meets any of the exceptions below, it is not required to be made accessible at the time of publication (or remediated proactively, if the content already exists), but must still be made accessible in a timely manner when an individual with a disability indicates that they need it.
- Archived web content. To qualify, content must meet all of the following criteria:
- Created prior to April 24, 2026 or reproduces paper documents or the contents of other physical media created prior to April 24, 2026
- Not altered or updated after the date of archiving
- Organized and stored in a dedicated area or areas clearly identified as being archived
- Retained exclusively for reference, research, or recordkeeping
- Archived documents. To qualify, documents must meet all of the following criteria:
- Conventional electronic document (PDF, word processor file, presentation file, or spreadsheet file) created and posted on the web prior to April 24, 2026
- Not used to apply for, gain access to, or participate in any of the university's services, programs, or activities
- Unaffiliated third-party content. To qualify, content must meet the following criteria:
- Created or posted by a person, company, government, or other entity that has no contractual, licensing, or other arrangement with the University of Oregon
- Individualized, secured documents. To qualify, documents must meet all of the following criteria:
- Conventional electronic document (PDF, word processor file, presentation file, or spreadsheet file) posted on the web
- About a specific individual, their property, or their account
- Password-protected or otherwise secured
- Preexisting social media. To qualify, content must meet the following criteria:
- Posted on a social media platform prior to April 24, 2026
Other Exceptions
- Undue burden. When making content fully accessible would result in an undue financial or administrative burden on the university, an exception may be granted. Undue burden determinations must consider all university resources, not just the resources currently allocated to a particular department or unit. Lack of sufficient funding, in isolation, does not generally qualify for an exception. Undue burden determinations can only be made by the university's ADA/504 Coordinator or President or their designee.
- Fundamental alteration. When making content fully accessible would undermine or change the essential nature of the content and prevent it from satisfying the original intent, an exception may be granted. Web content cannot typically qualify for a fundamental alteration exception. Fundamental alteration determinations can only be made by the university's ADA/504 Coordinator or President or their designee. If either of the above exceptions are granted, content is still required to be made as accessible as possible without causing an undue burden or fundamental alteration, and reasonable accommodations must be provided to disabled individuals who need the content and experience barriers.
If either of the above exceptions are granted, content is still required to be made as accessible as possible without causing an undue burden or fundamental alteration, and reasonable accommodations must be provided to disabled individuals who need the content and experience barriers.