This post urges institutions to stop waiting until accessibility problems arise. Instead, it suggests building accessibility into their systems from the beginning. All digital content—websites, apps, PDFs, videos, and social media—should be accessible as soon as it is created. According to the Department of Justice’s ADA Small Entity Compliance Guide, institutions are responsible for their own content and for third-party content. This includes content from vendors and contracted technologies. Recent enforcement actions, such as the UC Berkeley consent decree, show the risks of noncompliance. For example, inaccessible online lectures led to major fixes, new policies, and ongoing oversight. The main takeaway is clear: if you share content with the public, you must make it usable or provide an equally effective alternative.
To point out several common compliance challenges for institutions. These include inaccessible PDFs and Microsoft Office documents, missing captions and transcripts for media, poorly designed online forms, inaccessible course materials, and mobile apps that do not meet web standards. The risk grows when content is created by different departments, faculty, or social media teams. This is especially true if training and oversight are inconsistent. Vendor platforms might also be a problem if the ADA Small Entity Compliance Guide requirements are not included in procurement.
To address these challenges, the article suggests applying the ADA accessibility policies across the institution. It also recommends detailed audits of digital assets and keeping inventories to track who owns what and where risks exist. Other steps include checking accessibility before publishing, setting up monitoring and reporting systems, and updating vendor contracts to require WCAG compliance, indemnification, and access testing. Ideally, general counsel should lead these efforts. Support from teams throughout departments is also necessary.
The ADA Small Entity Compliance Guide will result in More Hiring
Human resources plays an important role in making sure employment systems are accessible and in managing accommodation processes for all staff. The article highlights the need for role-specific training for content creators, developers, faculty, and procurement staff. This training helps embed accessibility into everyday operations. It also calls for transparency by publishing accessibility statements, offering ways to report issues, and keeping compliance records. While there are some exceptions for legacy or third-party content or cases of undue burden, these are limited and do not change the need for equal access. This primarily applies to public institutions. However, private colleges should also prepare, as Section 504 and the ADA create similar responsibilities and legal risks.
Federal agencies have made it clear that digital accessibility is a priority through their enforcement actions. The post ends by saying that institutions that act early with clear governance, scheduled audits, strong procurement controls, and targeted fixes will be best prepared. This helps them meet the requirements of the ADA Small Entity Compliance Guide.