Digital Accessibility Policy and Procedures

The Digital Accessibility Policy (HOP 3-3014) was created to reaffirm the University’s commitment to providing a learning and working environment in which all users can meaningfully participate and reflects the current legal standards relating to the accessibility of digital information. The policy applies to all digital resources and information technology (IT) used for University business, including but not limited to websites, electronic documents, software, multimedia files, social media, and online instructional content. These procedures are a living document and will be updated and expanded as needed.

The policy applies to (1) University content, which is any digital content created, posted, distributed, or published for University business (this includes mobile apps and social media posts made by the University); (2) University Electronic Information Resources (EIR), which includes EIR purchased, developed, or deployed for University business and, in the case of web-based applications and websites, is hosted on a University-owned or controlled domain. 

Digital Accessibility Standards for University Business Activities

University business is defined to include activities carried out by University faculty, staff, and sponsored student organizations in their official capacities. It does not include activities organized or conducted by students or registered student organizations. The “Standards” in the policy refer to the technical standards outlined in Subpart H of the Title II of the Americans with Disabilities Act (ADA) regulation 28 CFR Part 35, which requires that public entities adopt the World Wide Web Consortium’s Web Content Accessibility Guidelines, Version 2.1, Level AA Conformance (WCAG 2.1, Level AA) for websites and web-based applications and services. In the case of digital hardware interfaces, the Standards also include the Federal Section 508 Standards described in Chapter 4 of Appendix C CFR Part 1194, whether or not such instances of hardware are covered by this regulation.

Accessibility Compliance Requirements Effective March 1, 2026

Starting March 1, 2026, University content must conform with the Standards unless it qualifies for an exception. University EIR purchased, licensed or internally developed after this date must meet the Standards at the time of rollout or implementation. Non-web-based software and services should conform to the Standards to the fullest extent possible.

Accessibility of Third-Party Platforms and Public Content

The policy also includes third-party content and non-University created platforms, products, and services used for University business. Unsolicited content posted by the general public does not need to be compliant unless the content is being posted due to a contractual, licensing, or other such agreement with the University.

University personnel responsible for purchasing or procuring University EIR must ensure that vendors developing or providing EIR are aware of this policy. Contracts should hold vendors accountable to the Standards to the fullest extent possible. When soliciting bids for EIR development, departments should obtain information about potential vendors’ compliance with the Standards as part of the Request for Proposal (RFP) process.

Vendor Accessibility Requirements

In accordance with UT System Policy, all vendors will be asked to provide a current Accessibility Conformance Report (ACR) or Voluntary Product Accessibility Template (VPAT) that shows their compliance with the Standards. Vendors must also agree to the EIR Accessibility Warranty in the contract terms and conditions before the contract is executed. Vendors who will not agree to this warranty may suggest alternative language for review by Institutional Accessibility and Accommodation (IAA). If this language is insufficient and/or the ACR/VPAT does not show substantial compliance with the Standards, the purchase may not go forward without an exception approved by IAA. 

EIR Accessibility Exception Request Process and Review Criteria

Departments can initiate the EIR Accessibility Exception Request process by completing EIR Exception Request Form. The form routes to IAA, who will initiate routing of the EIR Exception Request Form via DocuSign. Once the form is completed, IAA will work in tandem with the Digital Accessibility Center (DAC) to review the information provided and the VPAT/ACR to determine whether an exception is appropriate. The expense or time to make EIR or digital content compliant will not be considered a valid basis for exceptions except in rare and exceptional cases approved by the Digital Accessibility Steering Committee. Likewise, the inconvenience of needing to conduct business operations differently than they have been done in the past will generally not be considered a fundamental alteration of a program or activity. Approved exceptions do not eliminate the EIR owner’s responsibility to provide access to the EIR by an alternate method or in an alternate format. Even if an exception is granted, this does not prevent a person with disabilities from filing a lawsuit against the University due to an inaccessible EIR.

Website accessibility involves several key responsibilities for site owners, including ensuring their platforms are usable by individuals with disabilities. This includes proactively evaluating websites through both automatic scanning tools like Optimize and manual testing methods. Site owners must also respond promptly to reported accessibility issues and take appropriate steps toward remediation. To maintain ongoing compliance and improvement, bimonthly accessibility reports are generated, helping track progress and identify areas needing attention.

All video content published to University-managed websites and platforms must include captions that are synchronized and accurate. Where appropriate, descriptive audio should be provided to enhance accessibility. Audio-only content, such as podcasts, must be accompanied by a complete and accurate transcript to ensure equivalent access for all users. 

University websites and platforms must include captions for all pre-recorded video and audio content. Captions should include highly accurate transcription, proper punctuation, speaker identification, and the identification of meaningful sounds other than speech. Captions should be synchronous in time with the audio, complete, and properly placed. The quality of captioning provided for videos and audio should strive to meet the industry standard of 99% accuracy rate, which applies to elements such as spelling, punctuation, grammar, and matching the exact words used by the speaker.

Audio-only content, such as speeches or podcasts, must be accompanied by a complete and accurate transcript. Transcripts must include proper punctuation, speaker identification, and mention of relevant non-speech audio. Transcripts should be posted with the audio or linked within the description text associated with the audio.

When video content includes essential visual information, such as on-screen text, graphics, or actions not conveyed through audio, this information should be described to ensure accessibility for individuals who are blind or have low vision. Whenever feasible, content creators should plan ahead to incorporate descriptions of meaningful visual elements directly into the script or narration. In cases where visual information cannot be integrated into the primary audio track, additional audio description may be necessary to provide equivalent access. Providing meaningful content alongside the video, such as snippets, graphs, tables, or image descriptions, can enable users to engage with the video information at their own pace and support a more complete experience.  

All documents created and shared as part of university operations, whether posted on Canvas, published on public websites, or distributed internally, should strive to meet accessibility standards. To support this goal, document authors and editors are encouraged to use built-in tools like Microsoft’s Accessibility Checker, which will identify accessibility issues and offer recommendations for improvement. Faculty and staff who have access to Adobe Acrobat can address accessibility issues within PDFs using the Adobe Accessibility Checker.

University accounts should ensure the content shared on social media is accessible to all audiences within the limitations of the platforms themselves. When sharing content, follow best practices, including adding image descriptions, captions, and addressing color contrast when posting. Creating Accessible Social Media offers guidance on making social media accessible.

For internal communications, it is recommended to use university-licensed platforms, such as the Microsoft Office suite, which are supported by institutional technical services. When sharing content, follow accessibility best practices, such as providing image descriptions, writing clear and descriptive link text, and using emojis thoughtfully to ensure clarity. Creating Accessible Email Messages provides strategies for enhancing accessibility in communications.

It is the responsibility of Instructors to provide accessible content within their courses, including documents, video, audio, and externally sourced materials. Instructors should make a good-faith effort to ensure that all materials shared in courses, regardless of their origins, follow digital accessibility best practices.  In cases where the content as found elsewhere does not include these accessibility assets, the Digital Accessibility Center can consult with instructors about ways to address accessibility.

Integrated into Canvas, the Ally Accessibility Platform provides real-time accessibility feedback and alternative formats for uploaded content. Instructors can view a course score and individual indicators for files and pages. Ally provides insights into the current state of accessibility in a course, offers guidance on how to address issues, and provides an overall score that improves as the issues are resolved. Within the Ally help feature, Instructors can request assistance on documents from the DAC.

The following types of University Electronic Information Resources (EIR) and content are not required to conform with the Standards.

Archived Web Content

Content created before March 1, 2026 that is stored and preserved in a digital archive, is not actively used or modified, and only kept for reference, research or record keeping. As an example, web content that meets all the following criteria would not need to meet the Standards:

• Was created before March 2026 and
• Is only used for research, reference, or record-keeping and
• The content is kept in a designated area for archived content and
• Has not been changed since it was archived

EIR for National Security

Federal regulations concerning EIR accessibility provide that such regulations do not apply if the EIR is “any electronic and information technology operated by agencies, the function, operation, or use of which involves intelligence activities, cryptologic activities related to national security, command and control of military forces, equipment that is an integral part of a weapon or weapons system, or systems which are critical to the direct fulfillment of military or intelligence missions.” However, such regulations state that any “[s]ystems which are critical to the direct fulfillment of military or intelligence missions do not include a system that is to be used for routine administrative and business applications (including payroll, finance, logistics, and personnel management applications).” UT System has determined that this “national security” federal exception should also apply to EIRs procured by the University. Exceptions of this type need to be reviewed and approved by IAA.

EIR in Maintenance and Monitoring Areas

EIR located in areas accessed only by service personnel for maintenance, repair, or occasional equipment monitoring are not required to meet the federal government’s EIR accessibility standards. UT System has determined that this federal exception should also apply to EIRs procured by the University. Exceptions of this type need to be reviewed and approved by IAA.

Embedded Information Resources

If the University is obtaining EIR equipment that contains embedded information resources that are used as an integral part of the product, but the principal function of which is not the acquisition, storage, manipulation, management, movement, control, display, switching, interchange, transmission, or reception of information, then Texas law excepts that EIR from compliance with the DIR Accessibility Rules and it is not expected to comply with the policy. Examples of such EIRs include thermostats or temperature control devices or other heating, ventilation, and air conditioning equipment. However, if the embedded information technology has an externally available web or computer interface, that interface is considered EIR and therefore such an interface is not covered by this exception.

Medical Equipment

If the University is obtaining an item of medical equipment in which EIRs are integral to its operation, then the DIR Accessibility Rules do not apply to such equipment, and it is not expected to comply with the policy. However, if the medical equipment has an externally available web or computer interface, that interface is considered EIR and the interface is not covered by this exception. Exceptions of this type need to be reviewed and approved by IAA.

Password-Protected or Secured Documents

Individualized, password-protected, or otherwise secured conventional electronic documents do not need to meet the Standards if they meet all the following:

• Are word processing, presentation, PDF, or spreadsheet files and
• Are about a specific person, property, or account and
• Are password-protected or otherwise secured.

For example, a PDF of an employee’s pay stub hosted behind EID authentication would not need to meet the Standards unless the individual requests an accessible version. However, a Microsoft Word document about upcoming insurance changes hosted securely behind EID authentication would need to meet standards because it is not specific to a certain individual, property, or account.

Pre-Existing Conventional Electronic Documents (e.g., PDFs)

Documents that are not currently being used to apply for, gain access to, or participate in University services, programs, or activities. For example, a PDF flyer for an event that was posted online in 2022 would not need to be made accessible because the event is over and not recurring. However, a PowerPoint presentation created by a faculty member in 2024 that continues to be modified and used for instruction in 2026 would need to be accessible.

Pre-Existing Social Media Posts

Posts made prior to March 2026 do not need to comply with the current Standards and should be archived. Starting March 2026, all new social media posts must fully adhere to the Standards.

Unsolicited Public Submissions

Unsolicited content posted by members of the general public that does not relate to University business and/or third-party content does not need to meet the Standards unless the third party is posting due to a contractual, licensing, or other such arrangement with the University. For example, a message that a member of the public posts on a message board for admitted students does not need to meet the Standards. However, a website that is created by a third-party vendor and used for University business does.

The Digital Accessibility Center (DAC) is a centralized resource within Enterprise Technology that provides captioning and transcription, document remediation, web accessibility scanning, and digital accessibility consultation and training for the campus community. For training, resources, or support, the DAC team can be contacted by emailing digital.accessibility@utexas.austin.edu.