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Higher education website accessibility: Title II, Section 504, LMS, and syllabi PDFs

Public colleges and universities are state and local government entities under ADA Title II. The DOJ April 2024 Title II web rule requires WCAG 2.1 Level AA conformance for all public-entity web content and mobile apps, with deadlines of April 2026 (for entities serving populations of 50,000 or more) and April 2027 (for entities serving fewer than 50,000). Private colleges and universities that receive federal financial assistance (Pell Grants, Title IV student loans, federal research grants, ROTC funding, or any HHS grant for the campus medical center) are covered by Section 504 of the Rehabilitation Act, which the HHS May 2024 final rule made WCAG 2.1 Level AA explicit for. Section 508 applies to any technology the institution procures for use. The OCR (Office for Civil Rights) has been the most active enforcement venue in higher education for the last fifteen years and has resolved hundreds of complaints with Voluntary Resolution Agreements that require WCAG 2.1 Level AA conformance. Site Brace audits any higher-ed website for $149 flat.

The rules that apply to colleges and universities

1. ADA Title II (public institutions)

State universities, state colleges, community colleges, public university systems, and K-12 districts run by elected boards are Title II entities. The DOJ April 2024 web rule is the controlling regulation. The standard is WCAG 2.1 Level AA. The deadlines are population-based and firm. There is no general exemption for "legacy content"; archival materials that remain on the website are in scope.

2. Section 504 (any institution with federal funding)

Section 504 prohibits disability-based discrimination by entities receiving federal financial assistance. Nearly all US colleges and universities, including private institutions, receive federal funding through Pell Grants, Title IV student loans, federal research grants, or USDA / HHS programs at the campus level. The HHS May 2024 final rule on Section 504 adopts WCAG 2.1 Level AA as the standard. Section 504 enforcement at universities runs through the Department of Education OCR, which is one of the most active web-accessibility enforcement venues in the federal government.

3. ADA Title III (private institutions with public-facing campuses)

Private colleges and universities that operate physical campuses members of the public visit are subject to ADA Title III as commercial public accommodations. The plaintiffs' bar in higher-ed accessibility cases is smaller than in e-commerce or auto, but cases do happen, and OCR investigations frequently surface during Title III demand-letter discovery.

4. Section 1557 (campus medical centers and student health)

If the institution operates a campus medical center, student health clinic, or counseling center that accepts insurance or federal health funding, Section 1557 applies to the digital surfaces serving those programs. See the healthcare website ADA guide for the full Section 1557 framework.

5. State higher-education accessibility statutes

Several states have higher-education-specific accessibility laws on top of the federal framework. California Government Code section 7405 references Section 508 standards for state higher-education institutions; New York State Office of Information Technology Services Policy NYS-P08-005 sets state-government accessibility expectations that state-college websites follow; Texas Administrative Code Chapter 206 sets a similar bar for Texas state universities.

The high-risk surfaces specific to higher-ed sites

Admissions application portal

The admissions application is the highest-stakes single surface on a higher-ed site. Most institutions use Common App or Coalition, which are third-party platforms with their own accessibility profiles; some run a homegrown application portal or Slate. The portal is one of the few surfaces an OCR complaint can directly trace to documented denial of equal opportunity if it fails accessibility for a prospective student with a disability.

Course catalog and schedule of classes

Most institutions publish a course catalog as a large, paginated set of department pages, with the schedule of classes generated from the SIS (Banner, PeopleSoft Campus Solutions, Colleague, or Workday Student). The schedule-of-classes table is data-heavy and frequently fails table-header accessibility (`th-has-data-cells`, `td-headers-attr`).

LMS pages and syllabi PDFs

Canvas, Blackboard, Brightspace, Moodle, and D2L all have a public-facing layer (login page, course finder, sometimes public syllabus PDFs) that is in scope for a website audit. The authenticated LMS interior is a separate accessibility surface that requires a different scope of review. Syllabi PDFs are almost always exported from Word or InDesign without accessibility tagging, leaving screen-reader users unable to navigate course requirements.

Library catalog and databases

Library websites embed third-party database interfaces (EBSCO, ProQuest, JSTOR, Gale, Springer) and discovery layers (Primo, Summon, EDS). Each third-party tool has its own accessibility profile. The library is responsible for the rendered experience even when the underlying tool is third-party. Many library sites also publish LibGuides via Springshare, which ship templates with consistent accessibility patterns.

Financial aid calculator

Net price calculators are required by federal law (Higher Education Opportunity Act). Most institutions use a vendor product (Net Price Calculator from Ardeo, RNL, or a Common App-aligned tool) or a homegrown calculator built on JavaScript. The calculator is the single most-used decision tool for prospective students; an inaccessible calculator excludes a population from making informed enrollment decisions.

What we typically find on a higher-ed website

Notes on higher-ed CMS and SIS platforms

Drupal (the higher-ed standard)

Drupal is the dominant higher-ed CMS, often deployed as part of OpenScholar, Acquia Cloud Site Factory, or Pantheon multisite. Drupal core accessibility is strong; the variance is in the theme and the contributed modules. Older Drupal 7 sites still in production have meaningful accessibility debt.

WordPress (smaller institutions, departments, and centers)

Department and center sites at larger universities often run on WordPress (CampusPress, WP Engine, or self-hosted) under the parent-domain Drupal site. The accessibility variance across these sub-sites is wide because the host institution rarely enforces a brand-template that includes accessibility.

SIS-driven pages (Banner, PeopleSoft, Colleague, Workday Student)

The schedule of classes, course catalog, and student records pages are generated by the SIS. Banner-generated pages in particular tend to have well-known accessibility issues that vendors have improved over time but that older Banner installations still serve. The institution carries responsibility for the rendered experience even when the markup is vendor-generated.

Why overlays are a poor fit for higher education

Accessibility overlays are marketed to higher-ed accessibility offices as a "first step" while the institution plans real remediation. We have written about why accessibility overlays do not make sites WCAG-compliant in detail. For higher-ed specifically:

• Overlays do not enter the LMS, the SIS, or the library databases. The largest accessibility surface on a campus is precisely the surface overlays cannot reach.
• OCR Voluntary Resolution Agreements require WCAG 2.1 Level AA conformance with substantiation evidence; an overlay subscription is not evidence.
• The DOJ April 2024 Title II rule named overlays as insufficient and required actual content conformance rather than overlay-based "fixes."
• The FTC's $1 million settlement with accessiBe in April 2025 makes overlay-based compliance claims a documented liability that university general-counsel offices and accreditation reviewers are tracking.

How Site Brace audits a higher-ed website

The standard page mix for a higher-ed audit on the main institutional website:

• Homepage
• Admissions overview and the application portal landing page
• Academic programs index and 2-3 program detail pages
• Course catalog index and 1-2 department-catalog pages
• Schedule of classes page (the SIS-driven listing)
• Financial aid landing and the net price calculator page
• Student life landing
• Library homepage and the catalog or database-search page
• News and announcements landing and 1 article
• Events calendar and 1 event detail page
• Faculty or staff directory plus 1 profile page
• Accessibility statement (if one exists)

That mix covers up to 25 pages for a typical college or university. The audit runs axe-core 4.10 against each page, captures element-level screenshots of every contrast failure, opens linked syllabi or policy PDFs and notes their tagging state, and packages the findings into a written report with copy-paste fix code and 12 re-scans included over 12 months. The authenticated LMS interior is out of scope and would need separate scoping.

Pricing is $149 flat, one-time. To see what the report looks like, view a sample report we built for a fictional municipality. The higher-ed findings overlap heavily in shape with public-sector audits (PDFs, large content surfaces, third-party iframes, brand-color contrast) even though the entity type is different.

Start a higher-ed website audit, $149

Related:

• DOJ Title II web rule primer - the controlling rule for public colleges and universities
• Healthcare website ADA compliance - applies to campus medical centers, student health, and counseling under Section 1557
• Free single-page WCAG check
• Why accessibility overlays do not make sites WCAG-compliant
• aria-label on a div: why screen readers ignore it