# ADA Title II Digital Accessibility for Course Content: The 2027 Deadline

> Higher Education · ibl.ai
> Source: https://ibl.ai/courses/higher-education/ada-title-ii-course-accessibility
> Last updated: 2026-11-14

*The 2027 Deadline*

**A higher education course from ibl.ai (self-paced, 10 to 12 hours, free).** ADA Title II web accessibility for course content: the 2027 and 2028 deadlines, WCAG 2.1 AA, five exceptions, and AI-assisted remediation with human QA.

- **Price:** Free
- **Format:** Self-paced, online
- **Time:** 10 to 12 hours
- **Pace:** 3 hours per week
- **Level:** Intermediate
- **Language:** English
- **Subject:** Compliance

[Enroll](https://lms.ibl.ai/platform/highereducation/courses/course-v1:highereducation+ada-title-ii-course-accessibility+self-paced)

## Course description

ADA Title II web accessibility became a hard requirement for public colleges when the Department of Justice adopted WCAG 2.1 Level AA in April 2024, and the Interim Final Rule of 2026-04-20 moved the compliance dates to 2027-04-26 for public entities of 50,000 people or more and 2028-04-26 for smaller entities and special districts. This course covers the part of the rule that lands on instructional staff: the content inside the LMS. You will learn what the rule requires, which of its five exceptions apply to course materials (the proposed course-content exception was removed from the final rule), how to read the WCAG 2.1 AA criteria behind most course-content failures, and how to inventory, prioritize and remediate with AI drafting and human quality assurance. Why now: the clock runs from a fixed date, and correspondence cited in the IFR says generative AI cannot reliably automate remediation of STEM materials at scale. By the end you will have a WCAG 2.1 AA checklist, an accessible PDF checklist, a scored inventory of a sample course and a repeatable remediation workflow.

### About this course

ADA Title II web accessibility became a hard requirement for public colleges when the Department of Justice adopted WCAG 2.1 Level AA in April 2024, and the Interim Final Rule of 2026-04-20 moved the compliance dates to 2027-04-26 for public entities of 50,000 people or more and 2028-04-26 for smaller entities and special districts. This course covers the part of the rule that lands on instructional staff: the content inside the LMS. You will learn what the rule requires, which of its five exceptions apply to course materials (the proposed course-content exception was removed from the final rule), how to read the WCAG 2.1 AA criteria behind most course-content failures, and how to inventory, prioritize and remediate with AI drafting and human quality assurance. Why now: the clock runs from a fixed date, and correspondence cited in the IFR says generative AI cannot reliably automate remediation of STEM materials at scale. By the end you will have a WCAG 2.1 AA checklist, an accessible PDF checklist, a scored inventory of a sample course and a repeatable remediation workflow.

### What you will be able to do

- State the compliance date that applies to your institution under the DOJ Title II IFR or the HHS Section 504 IFR, and cite the Federal Register document for it.
- Apply the five exceptions in 28 CFR 35.201 to a set of course materials and explain, with the regulatory text, why typical LMS content is not excepted.
- Map the twelve WCAG 2.1 success criteria that dominate course-content failures to the file types that trigger them, and test a document, a slide deck, an image and a video against them.
- Produce a prioritized inventory of a course's content, using the DOJ action steps, that separates archived material, third-party content and content that must conform.
- Run an AI-assisted remediation pass (alt text, captions, document structure) with a documented human review step, and measure the error rate of the AI draft before and after review.
- Draft the accessibility policy, request process and training plan the DOJ guidance recommends, including the contract language for vendors that supply course content.

### Who this course is for

**Roles:** provosts and deans responsible for compliance, CIOs and directors of teaching and learning, accessibility and disability services staff, instructional designers, LMS administrators, and faculty who build their own course sites.

**Institutions:** public colleges and universities and community college districts covered by ADA Title II; private institutions that receive HHS funds and are therefore covered by the Section 504 rule on the same technical standard; state systems planning across many campuses.

**Before you start:** familiarity with an LMS and with the file types faculty upload (PDF, slides, documents, video). No coding or prior accessibility training is required; the WCAG criteria are introduced in the course.

### Format

- Estimated time: 10 to 12 hours.
- Level: intermediate. No prior accessibility work assumed; legal reading is guided.
- Hands-on: three labs on a sample course export supplied with the course (a syllabus PDF, three slide decks, a scanned reading, twelve images, two lecture videos and a quiz). Learners inventory the course, remediate it with an agent that drafts and a person who approves, and score the result. The labs run on a hosted agent; ibl.ai supplies the sandbox and the WCAG checks, and the workflow transfers to any platform that can run the same checks with a review step.
- Structure: 4 sections, each ending in an AI conversation assessment, then a capstone assessment.

Self-paced. Every lesson is taught by an AI tutor that opens with a short story and works through one idea and one question at a time. Each section ends with an AI conversation assessment, and the course closes with a capstone assessment. Section assessments count for 60% and the capstone for 40%; 70% passes. There are no multiple-choice quizzes.

### Currency of this course

Last verified 2026-09-28. The compliance dates in this course come from the Department of Justice Interim Final Rule published and effective 2026-04-20 (Federal Register document 2026-07663) and the HHS Section 504 Interim Final Rule published 2026-05-11 (2026-09266). Rules are still moving: the DOJ comment period closed 2026-06-22 and no further rule had appeared in the Federal Register as of this date, but the Department has signalled further review. Many pages online still show the superseded April 2026 date. Check the Federal Register entries in the reading list before quoting a deadline.

## Outline

### Section 0 · Start here

- 0.1 Orientation

### Section 1 · Know the rule and the dates

- 1.1 What the 2024 rule requires
- 1.2 The deadline extension and how to read it
- 1.3 Section 1 assessment

### Section 2 · Apply the exceptions and limits to course content

- 2.1 The five exceptions in 28 CFR 35.201
- 2.2 Alternate versions, minimal impact and the burden defence
- 2.3 Section 2 assessment

### Section 3 · Test course materials against WCAG 2.1 AA

- 3.1 The criteria that account for most failures
- 3.2 Documents and media
- 3.3 Section 3 assessment

### Section 4 · Inventory, remediate and govern

- 4.1 Inventory and prioritization
- 4.2 AI-assisted remediation with human QA
- 4.3 Policy, requests and training
- 4.4 Section 4 assessment

### Section 5 · Capstone & wrap-up

- 5.1 Capstone
- 5.2 Capstone assessment
- 5.3 Wrap-up

## Instructors

- ibl.ai Higher Education, Course team (ibl.ai)

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