Letter to Vendors Regarding New Accessibility Rules

The text copied below is being sent to technology vendors who do business with the University of Oregon in the fall of 2024.

From: Abhijit Pandit, Vice President and Chief Information Officer; Greg Shabram, Chief Procurement Officer

RE: New Digital Accessibility Rules Conformance Requirement – April 24, 2026

We value your service and products provided to the University of Oregon. One key component to continuing our relationship is your company’s ability to provide products and services that conform to the WCAG 2.1 AA standards for digital accessibility by April 24, 2026. Given the reach of your products in our environment, we will need to know which products will meet this requirement or if we will need to consider other alternatives well in advance of the compliance deadline. Please help us achieve compliance to these digital accessibility requirements. Before the end of this year, if not sooner, we would like you to share your conformance report and plan to address any outstanding items that does not meet the WCAG 2.1 AA.

Additional Information:

This past spring, the U.S. Department of Justice (DOJ) approved new rules for digital accessibility under Title II of the Americans with Disabilities Act that apply to all state and local government entities, including all public higher education institutions. At the same time, U.S. Department of Health and Human Services (HHS) approved new rules for digital accessibility under Section 504 of the Rehabilitation Act that apply to all recipients of HHS funding, which includes most higher education institutions. Full compliance is required by April 24, 2026 for the DOJ rules and May 11, 2026 for the HHS rules (some very small entities have until 2027, but all public colleges/universities and most community colleges only have until 2026). The University of Oregon, along with our peer institutions around the country, is subject to both sets of rules.

Under these new rules, all University of Oregon web content, mobile apps, and kiosks must fully meet WCAG 2.1 AA standards, including systems that are only used internally by employees, content that is behind a login, and systems that we license or procure from third-party vendors. The products and services you provide to UO may fall within these categories. While the rules don't directly apply to third-party businesses themselves, we and our peers may not be able to continue to use noncompliant third-party products and services, as we will be held responsible for the compliance of that content under the new federal rules.

Action Requested:

We are hopeful that you will be able to bring your products and services into compliance with WCAG 2.1 AA before April 24, 2026, so that your products continue to meet our needs. We are reviewing a number of different tactics to get into compliance, and you will likely hear from us again on this requirement during other contracting cycles such as renewals. In preparation for these changes, we recommend that you:

  • Prepare a WCAG 2.1 AA or WCAG 2.2 AA Accessibility Conformance Report (ACR) in 2025 using the latest version of the VPAT for all of your web, mobile, and kiosk systems that we use. Third-party ACRs are preferred.
  • If there are gaps, prioritize bringing your systems into compliance with WCAG 2.1 AA by April 24, 2026.
  • Prepare a remediation plan for bringing any WCAG 2.1 AA violations into compliance prior to April 24, 2026.
  • Be ready to send your latest Accessibility Conformance Report, remediation plan, and answers to all HECVAT 3.06 accessibility questions (ITAC-01 to ITAC-09) when requested and at any upcoming contract renewals.
  • Review the Big Ten Academic Alliance's Digital Accessibility Vendor Cookbook.

Thank you again for your attention to this matter.