Case In Point

Volume 18 Issue 03 | March 2026

Each month in Case in Point we attempt to highlight new and emerging risks. The accessibility of our online content is facing heightened scrutiny with the recent updates to Title II of the ADA. We could see increased enforcement actions in the near future in this area. I've asked our Director of Institutional Compliance & Privacy, Kristin Roberts, who has been coordinating the effort here at Auburn, to provide some practical guidance.

With the ADA Title II impending deadline April 24, we are feeling the pressures of digital accessibility requirements. However, public institution risk managers should treat digital accessibility as a continuous compliance effort—not a one-time remediation sprint. Your goal is to strategically prioritize efforts to reduce near-term exposure and user harm while building a repeatable program that can withstand audits, complaints, and future waves of content generation.

Here are eight items to focus on to strengthen your WCAG compliance posture:

1. Conduct an internal accessibility audit: confirm what is in scope (websites, web apps, documents, digital marketing, LMS content, third-party tools, etc.) and who “owns” the content.
2. Name an executive sponsor: identify a single program owner and a cross-functional working group (IT, disability services, communications, procurement, academic affairs, faculty support, general counsel) to coordinate efforts.
3. Prioritize your highest-traffic/highest-risk entry points: public-facing, virtual “doors” to your institution (admissions, enrollment, employment, libraries, athletics) and student-facing portals (LMS, housing, dining, advising, student organizations) are hotspots.
4. Evaluate PDFs: What are critical documents? Can the content be provided in an alternative format (HTML)? Can you archive preexisting content that is only for research or reference purposes? Do you still need the content at all? Consider a third-party tool or AI to assist in the PDF remediation process.
5. Fix the low-hanging fruit: correct titles, headings/structure, color contrast, alt text, captions/transcripts, and create accessible templates using these core tenets of accessibility.
6. Deliver training: the most sustainable option is teaching your people how to fish. At some level, people are just going to need to know how to make their own content accessible. Everyone needs a minimum knowledge of accessibility.
7. Put third parties on notice: document vendor accessibility commitments, collect VPATs/ACRs where available, and create interim alternatives for tools you can’t fix.
8. Create a plan: publish a clear accessibility statement and reporting channel, and document an internal playbook for acknowledging, triaging, and remediating issues on a defined timeline.

It is difficult, if not impossible, to achieve 100% digital accessibility compliance living in an environment where content changes rapidly and hundreds of people in your organization create content daily. What regulators and users look for is a credible, resourced plan—standards you follow, training that reaches content owners, checkpoints in your publishing lifecycle, and proof that issues get fixed. Build accessibility into “how we work” (authoring templates, procurement gates, QA before launch, routine scanning, and quarterly reporting) and document your decisions and timelines so you can show good-faith progress. The deadline is real, but the best approach is an operating model that keeps you moving toward accessibility every week after April 24.

Thank you, Kristin, for this great information and advice. Achieving accessibility requires continual improvement and risk mitigation like many other compliance challenges we face. Therefore, we invite you to review the events of the prior month with a view toward proactively managing risks. As always, we welcome your feedback.

Kevin Robinson
Vice President
Institutional Compliance & Security