Frequently Asked Questions

WCAG, the Web Content Accessibility Guidelines, is a set of guidelines that say what is needed for web accessibility. WCAG is developed by the World Wide Web Consortium. You can find more information about why the Department of Justice picked WCAG 2.1, Level AA as the technical standard for state and local governments’ web content and mobile apps in the federal rule in the section of the appendix called “Technical Standard—WCAG 2.1 Level AA.”

These requirements will go into effect on April 24, 2026.

The UM System has had a Digital Accessibility Policy since 2022, but these new regulations set forth additional specific guidelines, establishing Web Content Accessibility Guidelines (WCAG) Version 2.1, Level AA as the standard for all web and mobile content available to the public or used in our services, programs and activities.

Ultimately, everyone is responsible for ensuring the digital content they create or maintain for university business is accessible and meets WCAG 2.1 Level AA guidelines. Several departments — including marketing and communications, IT, teaching and curricular excellence, and university libraries — are collaborating closely to create implementation plans based on priorities, and S&T has launched a task force dedicated to digital accessibility.

The regulations are enforceable by the Department of Justice and Office for Civil Rights as they have the authority to investigate complaints, conduct audits, and take legal action against institutions that fail to comply.

Any content created or maintained by Missouri S&T that users can access with a computer or smartphone must meet WCAG 2.1 Level AA. This includes websites, mobile apps, academic course content, digital forms, documents posted online (including PDFs), social media, videos and procured software.

If it is publicly available or essential to accessing public services provided by S&T, then yes it must be accessible. This includes any digital documents and instructional materials posted online or distributed to students.

Yes, any mobile application that is developed/operated by or procured by Missouri S&T that is used to deliver services, content or communication must be digitally accessible.

If a student worker is acting on behalf of the university or department (e.g., updating a website, posting social media), the content must be accessible. The responsibility of compliance lies with the department overseeing the content.

Generally, yes. In this context student generated content is third-party content being made available, or hosted online, by Missouri S&T. If the student generated content is made publicly available (university website, shared during a class session, or submitted for peer review) the content must meet accessibility standards.

For example, if part of a lesson involves students creating presentations and then being peer reviewed by their classmates, the content created is required to be digitally accessible. It is important to provide students with clear guidelines and tools to proactively create digital accessible content, not just for the sake of compliance but to instill inclusive design habits that will benefit them in their future careers.

If the university has a contract, license, or partnership with a third-party tool/ service (e.g., interactive maps, mobile app, learning platform/ educational technology vendors) then that content must be accessible.

If a third-party tool/ service is being used without a formal contract, license, or partnership, but is used in a way that is required for participation in a program or activity, then that content must be accessible.

Most vendors will have an Accessibility tab on their website addressing ways they meet accessibility standards, often citing what level of WCAG (Web Content Accessibility Guidelines) they are meeting. If that information is not publicly listed, contact the vendor to inquire about their accessibility guidelines to ensure they are compliant.

In limited situations, some kinds of web and mobile app content do not have to meet WCAG 2.1, Level AA in advance. If a person with a disability requests access to any of the following exempted materials, then they must be made accessible in a timely manner for the individual. The exemptions are as follows:

Archived web content: For many websites there is often content that is not currently used or relevant. Whether the information is out of date, not needed, or repeated elsewhere, sometimes the information is archived on the website.

Web content that meets all four of the following criteria does not have to meet WCAG 2.1, Level AA.

1. The content was created before the date the state or local government must comply with this rule, or reproduces paper documents or the contents of other physical media (audiotapes, film negatives and CD-ROMs for example) that were created before the government must comply with this rule, AND
2. The content is kept only for reference, research or recordkeeping, AND
3. The content is kept in a special area for archived content, AND
4. The content has not been changed since it was archived.

Pre-existing conventional electronic documents: It is not uncommon to find old documents, like PDFs left on a website. Documents that meet both of the following criteria usually do not need to meet WCAG 2.1, Level AA.

1. The documents are word processing, presentation, PDF or spreadsheet files; AND
2. They were available on the website or mobile app before the compliance date (April 24, 2026.)

“Usually?” When does the exception not apply?
Documents that are currently being used to apply for, access or participate in Missouri S&T services, programs or activities do not fall under the exception, even if the documents in question were posted before the compliance date. This is because the ADA requires that state and local governments must provide individuals with disabilities with effective communication, reasonable modifications and an equal opportunity to participate in or benefit from their services, programs and activities. So even when web content or content in mobile apps does not have to meet WCAG 2.1, Level AA, a state or local government would likely still need to provide the content to a person with a disability who needs it in a format that is accessible to them.

Content posted by a third party where the third party is not posting due to contractual, licensing or other arrangements with a public entity: Sometimes third parties post content on state and local government websites or mobile apps, typically online public message boards or forums.

To clarify, third parties are members of the public or others who are not controlled by or acting for state or local governments. Meaning in the scope of the UM System, individuals who are not employees, contractors or vendors that are not posting on behalf of UM System, and are not bound by any agreement with the university to post content online.

If a state or local government has a message board platform on their website, the platform itself would be required to meet WCAG 2.1, Level AA standards, however content posted to the board by third parties would likely be exempt. 

Individualized documents that are password-protected: Many public entities use websites or mobile apps to share documents like bills, reports or notices that are specific to individual users. For example, a tuition invoice in PDF format, available only after logging into Joe’SS or a downloadable financial aid statement tailored to the individual student, behind a login wall.

As these documents are individualized and securely accessed, and not every recipient will require an accessible version, this exemption allows flexibility. Public entities are still required to provide an accessible version upon request. Documents that meet all three of the following criteria do not need to meet WCAG 2.1, Level AA:

1. The documents are word processing, presentation, PDF or spreadsheet files, AND
2. The documents are about a specific person, property or account, AND
3. The documents are password-protected or otherwise secured.

Note: While these documents are exempt from proactive remediation, if a student with a disability requests them in an accessible format, the university must provide one in a timely manner.

Preexisting social media posts: Making previously posted social media posts accessible in some cases may be impossible, and there may be very little use to making old posts accessible as they were usually intended to provide updates about things happening at the time of posting.

For these reasons, social media posts made by a UM System institution before the compliance date (April 24, 2026) do not need to meet WCAG 2.1, Level AA.

Yes. The ADA Title II ruling sets the expectations that accessible materials will be available as the standard to ensure digital accessibility.

Yes, lecture videos uploaded online for future reference and use by students are required to be captioned to meet WCAG 2.1, Level AA Guidelines. While not required, providing transcripts is best practice for accessibility.

The best course of action would be finding another video that fits your course content needs and has captions.

Noting the difficulty therein, under § 35.202 there is flexibility for use of conforming alternate versions, as defined by WCAG 2.1, to comply with § 35.200 only where it is not possible to make web content directly accessible due to technical or legal limitations. In this example, a faculty member cannot edit or add captions to a video they do not have ownership of.

A conforming alternate version for an uncaptioned YouTube video would be to provide a transcript with a full textual description of the video’s spoken content, including important non-verbal elements and audio descriptions where necessary.

No, you do not have to type your lecture notes and post them online, but depending on the situation there are best practices to make your course content more accessible. This largely depends on how reliant on the visual content your lectures are. If the notes as visual content are essential for understanding and are not otherwise accessible to students with disabilities, then there must be an equivalent way to access the information being shared.

Consult S&T’s student accessibility and testing services to work with the student to find a method that best supports their learning. This could look like allowing them to record lectures so they have an audio support to refer to later, or using a live transcription to then have typed out access to your lecture notes to share with the student later.

Yes, live lectures conducted via platforms like Zoom or Teams are required to have live captions. Details on how to turn on this feature can be found with each respective platform’s accessibility settings. This requirement is in line with WCAG 2.1, Level AA.

There are a variety of resources available to help you better understand best practices to make your course accessible. Missouri Online has different resources to assist with accessibility in Canvas course creation and there are Percipio trainings relating to web accessibility.