Digital Accessibility Policy: Frequently Asked Questions

The Digital Accessibility Policy (HOP 3-3014) reaffirms the University’s commitment to providing a learning and working environment in which all users can meaningfully participate. It also aligns with current legal standards for digital accessibility, specifically the technical requirements outlined in Subpart H of Title II of the federal regulations implementing the Americans with Disabilities Act (ADA), found at 28 CFR Part 35 (the “Standards”). This policy is designed to be adaptable, allowing for future updates as accessibility technologies and standards continue to evolve.

For this policy, the University follows the technical standards outlined in the Standards, which require 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. This includes mobile apps and social media posts made by the University. Software and services that are not web-based should conform to WCAG 2.1 Level AA to the fullest extent possible.

Digital hardware interfaces must, at a minimum, comply with the federal Section 508 standards described in Chapter 4 of Appendix C to 36 CFR Part 1194.

University content must conform to the Standards starting in March 2026 unless it qualifies for an exception. University EIR purchased, licensed, or internally developed after March 2026 are expected to comply with the Standards at the time of roll-out or implementation.

Starting March 2026, all social media posts need to be compliant. 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.

All University websites must comply with the policy. To request an accessibility scan of your website(s), contact: accessibility-assessments@utlists.utexas.edu. 

Yes, the policy applies to all information or communication accessed or displayed in a digital format or medium, including but not limited to text, image, audio, or video. Hosted or embedded third-party content needs to meet the Standards if you have a contractual or licensing agreement with the third party.

WCAG stands for the Web Content Accessibility Guidelines. They are an internationally recognized set of standards for web accessibility established by the World Wide Web Consortium (W3C). WCAG is organized around four principles (Perceivable, Operable, Understandable, Robust) and each version is comprised of several Success Criteria that outline specific metrics used to determine whether a site meets the guidelines. Each Success Criteria is classified as A, AA, or AAA which correspond to three possible levels of conformance. Level A represents the minimal level of conformance; Level AA means that a site is conformant with Level A and AA; and Level AAA means that a site complies with all Level A, AA, and AAA Success Criteria. Find more information about WCAG, including  WebAIM’s WCAG checklist.

Accessibility is an institutional responsibility in which all colleges, schools, and units play a part. The following individuals and departments have specific responsibilities:

• Digital Accessibility Center (DAC): The DAC, based in Enterprise Technology, actively supports faculty and staff who create and maintain digital content, applications, and web spaces across the University’s digital environment. The DAC provides training, information, and resources on the Standards and best practices and provides guidance to University purchasers, content creators, and developers on creating an accessible and usable digital landscape. The DAC provides captioning, transcription, and document remediation services and scans course Canvas pages and University web sites for accessibility. Through these efforts, the DAC helps build a more accessible digital landscape for all users.
• Digital Accessibility Steering Committee: The Digital Accessibility Steering Committee serves as an advisory group to the DAC and provides guidance and assistance to Institutional Accessibility and Accommodation (IAA) on EIR Accessibility Exception Requests. Committee members are appointed by the DAC.
• Digital Accessibility Liaisons: Digital Accessibility Liaisons are appointed by IT leadership in the colleges and schools. They help coordinate local accessibility efforts and provide progress reports to the DAC that help guide the work of the Digital Accessibility Steering Committee and ensure compliance with this policy.
• Disability and Access (D&A): D&A determines eligibility and implements academic accommodations for students with disabilities at the University. D&A provides assistance and access to assistive technology resources and refers students to the DAC for digital accessibility support (e.g., text conversion).
• Institutional Accessibility and Accommodation (IAA): IAA is in University Risk and Compliance Services and has oversight authority for concerns that fall under the Americans with Disabilities Act (ADA), the Pregnant Workers Fairness Act (PWFA), and Sections 504 and 508 of the Rehabilitation Act, including EIR. IAA has the final authority to approve exceptions under this policy. The Associate Vice President of IAA serves as the University ADA and EIR Coordinator.

The DAC regularly scans University websites for accessibility using a scanning tool called Acquia Optimize. Content creators can view these scores at any time, and those scores are sent to University leadership every other month by the University EIR Coordinator. To gain access to Acquia Optimize, email accessibility-assessments@utlists.utexas.edu.

While automatic scanning tools are helpful for identifying potential accessibility issues, they are not sufficient on their own to ensure full compliance with accessibility standards. These tools can flag possible errors, but it is up to the user to manually review and determine whether the content is truly compliant. Manual testing plays a critical role in the accessibility evaluation process. It ensures that content is not only technically accessible but also usable by individuals with disabilities. Automated tools may miss nuanced issues related to user experience, navigation, and interaction, areas where manual testing provides essential insight.

The DAC offers training, information, and technical support to help web content managers improve their web accessibility scores. Email digital.accessibility@austin.utexas.edu for assistance.

The University uses the Ally Accessibility Platform which is integrated into Canvas to scan the accessibility of course Canvas pages. Faculty can contact the DAC digital.accessibility@austin.utexas.edu for assistance and review the resources posted in Canvas.

The DAC provides information, training, and technical assistance to the University community on the accessibility of digital information. Contact the DAC by emailing digital.accessibility@austin.utexas.edu.

Inaccessible content can be reported through the Report a Barrier form  or by contacting the DAC directly by emailing digital.accessibility@austin.utexas.edu.

University personnel involved in purchasing or procuring EIR must ensure that vendors are aware of and comply with the University's accessibility policies.

• Vendor Awareness: Vendors developing or providing EIR must be informed of the University's accessibility standards. Contracts should hold vendors accountable to these standards to the fullest extent possible.
• Solicitation and Evaluation: When soliciting bids for EIR development, departments should request information about each vendor’s compliance with the standards as part of the Request for Proposal (RFP) process. Vendors are required to submit a current Accessibility Conformance Report (ACR) or Voluntary Product Accessibility Template (VPAT) to demonstrate compliance.
• Contract Requirements: Vendors must agree to the EIR Accessibility Warranty in the contract terms and conditions before the contract is executed. If a vendor cannot agree to the warranty, they may propose alternative language for review by Institutional Accessibility and Accommodation (IAA).

"Access by Individuals with Disabilities” is the official clause title used in UT System and UT Austin contracts to address accessibility compliance. It ensures that all Electronic and Information Resources (EIRs) procured or developed under University contracts comply with:

• Texas Administrative Code, Title 1, Chapters 206 and 213
• Web Content Accessibility Guidelines (WCAG) 2.1, Level AA
• UT System Board of Regents’ Rules
• Applicable state and federal accessibility laws

Where It Appears

• Included in the Addendum to Agreement (UT Procuring a Service).
• Required for third-party contracts involving EIR.
• Part of the standard contract addendum used across UT institutions.

Web content created before March 2026 that is stored and preserved in a digital archive, is not actively used or modified, and kept only for reference, research, or record-keeping purposes does not need to conform to the Standards.

For example, web content that meets all of the following criteria would be exempt from the Standards:

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

Documents that are not currently being used to apply for, gain access to , or participate in University services, programs, or activities do not need to meet the Standards. 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.

Unsolicited content posted by members of the general public that is not related to University business does not need to conform to the Standards. Third-party content is also exempt unless the third party is posting as part of a contractual, licensing, or similar arrangement with the University. For instance, a message posted by a member of the public on a message board for admitted students does not need to meet the Standards. However, a website created by a third-party vendor for University business must comply.

Individualized conventional electronic documents that are password-protected or otherwise secured 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.

Posts made before March 2026 do not need to meet the Standards and should be archived. Effective March 2026, all social media posts need to be compliant.

If the University is obtaining EIR equipment that contains embedded EIRs 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.

If the University purchases medical equipment where EIRs are built into its core functions (like internal software or controls), that equipment is exempt from the DIR Accessibility Rules and does not need to meet accessibility standards. However, if the equipment includes an external interface, such as a web portal or computer application that users interact with, that interface is considered an EIR and must comply with accessibility standards. Exceptions for medical equipment need to be reviewed and approved by IAA.

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 “[systems] 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. Requests for exceptions for national security-related EIRs need to be reviewed and approved by IAA.

EIRs located in maintenance, repair, or occasional monitoring spaces, such as utility rooms or mechanical areas, are generally not required to meet accessibility standards, because they are not intended for regular public or user interaction. Requests for exceptions of this type need to be reviewed and approved by IAA.

Accessible alternative versions (conforming) are only appropriate only when there is a technical or legal reason the original University content or EIR cannot be made accessible or the content qualifies for one of the exceptions noted above. 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. A key goal of the policy is to ensure users with disabilities have the same experience interacting with digital information as users without disabilities.  This means they should be able to engage with the content or EIR in the same manner, without relying on separate or alternative versions.

An exception request may be submitted to IAA when conformance with the Standards is not technically feasible, would result in a fundamental alteration in a service, program, or activity, or would create an undue hardship. Departments or users requesting an exception must demonstrate: (1) how bringing the EIR into compliance would not be technically feasible, would result in a fundamental alteration to a program or activity, or would create an undue hardship; (2) whether there are accessible alternatives available; and (3) how they will provide alternative access to users who are unable to use the EIR because of disability. The expense or time required 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 conducting business operations differently than they have been done in the past will generally not be considered a fundamental alteration of a program or activity. Find more information about the exception process on the EIR webpage.