Laws & Deadlines

WCAG (Web Content Accessibility Guidelines) are standards developed by the World Wide Web Consortium (W3C) that help make digital content perceivable, navigable, interactive, and able to be understood by all users.

These standards define how to make web content accessible to people with disabilities, including visual, auditory, physical, speech, cognitive, language, learning, and neurological disabilities; in practice, these standards also improve usability for all people.

Implementation of these standards is split into three compliance levels: A, AA, and AAA. Under a revised federal mandate, school districts are required to meet level AA compliance, at the minimum.

Version 2.1 is the one named in the federal rule and in Illinois law. WCAG 2.2, published in 2023, keeps the 2.1 requirements and adds a few more, such as buttons and links large enough to tap, keyboard focus that isn’t hidden behind sticky headers, and logins that let people paste a password or use a password manager instead of solving a puzzle. Content that meets WCAG 2.2 AA also meets 2.1 AA, so new websites and new purchases can aim for 2.2.

Read the full WCAG 2.1 standard · See what’s new in WCAG 2.2

Often, successful WCAG implementation is contextual. However, there are several foundational practices that schools can utilize to build out a robust, compliant web content ecosystem.

Common examples include:

• High contrast between text and background colors (in both body text and titles)
• Descriptive alt text for images
• Proper use of headings
• Hyperlink text that describes where it leads
• Providing captions and written transcripts for all video content

Explore the Basics section for more details on these foundational practices →

K–12 school districts must make their public-facing web content and mobile apps meet WCAG 2.1 Level AA.

This mandate comes from an updated US Department of Justice ADA Title II rule, which adopts WCAG 2.1 AA as the accessibility standard for state and local government services (including schools). The purpose is to ensure that everyone who interacts with public services and institutions (including students, families, and the general public) has equitable access to important digital information.

The compliance date depends on the total population your district serves:

• Districts serving 50,000 or more residents must comply by April 26, 2027.
• Districts serving fewer than 50,000 residents must comply by April 26, 2028.

These dates come from an interim final rule the Department of Justice published on April 20, 2026, which moved each deadline back one year (from April 24, 2026 and April 26, 2027).

For an independent school district, the population is the Census Bureau’s Small Area Income and Poverty Estimates (SAIPE) figure for the district. For a district that is part of a city or county government, it is that city’s or county’s population.

The extension changes the dates, not the obligation. The ADA already requires districts to give people with disabilities equal access to their services, so a person who can’t use a page or document today can still raise a complaint.

This mandate applies to all public-facing digital content and web platforms, including (but not limited to): websites, documents, media, and online communications. Outside of your district website, assets including PDFs, social media, and educational tools also fall under this umbrella.

Districts are additionally responsible for ensuring that third party tools, apps, and vendors that host or communicate covered digital content meet these requirements.

The rule covers existing content as well as new content, with five exceptions (see “Do we have to fix every old document and social media post?” below). Content that is still in use must meet WCAG 2.1 AA by your compliance date.

Not necessarily. The rule has five exceptions. Each one has conditions, and none of them covers content people still need in order to use a district service.

1. Archived web content. Content created before your compliance date, kept only for reference, research, or recordkeeping, stored in an area clearly labeled as archived, and not changed since it was archived. It must meet all four conditions.
2. Older documents. PDFs, word processing files, presentations, and spreadsheets posted before your compliance date, unless people still use them to apply for, access, or take part in your programs (an enrollment form, a current handbook, a registration packet).
3. Content posted by third parties. For example, public comments on a district page. This does not cover content a vendor or contractor posts on your behalf.
4. Individual, password-protected documents. Documents about a specific person, property, or account, such as a report card or a bill, that are password-protected or otherwise secured.
5. Older social media posts. Posts your district made before your compliance date.

There is no general exception for content behind a login, such as course pages in a learning management system. And even when content is excepted, you still need to provide it in an accessible format when someone with a disability asks for it.

A practical approach: delete what’s outdated, move true archives to a clearly labeled archive page, and fix or replace anything people still use.

Read the Department of Justice’s summary of the exceptions

Yes, for online curriculum. Since August 1, 2022, the Illinois School Code (105 ILCS 5/10-20.75, added by Public Act 102-0238, with a matching section for Chicago Public Schools) has required every school district to make sure the third-party online curriculum it offers to enrolled students or the public meets WCAG 2.1 Level AA, or a later version. Build that requirement into curriculum purchases and vendor contracts.

The Illinois Information Technology Accessibility Act (IITAA) applies to state agencies and public universities, not school districts. Its IITAA 2.1 Standards, which are based on WCAG 2.1 AA, and the Department of Innovation and Technology’s testing guides are still useful Illinois references.

For free training and support, contact the Illinois Assistive Technology Program.

Primarily, noncompliance with this mandate exposes school districts to additional legal liability under the Americans with Disabilities Act (ADA). Guidance from your district’s legal counsel may be necessary to fully understand your district’s potential liability.

Beyond mandatory compliance, adherence to the principles and practices outlined in these legal requirements can significantly reduce barriers to accessing your district’s digital content. Continued adherence also promotes inclusivity within your educational community, ensuring people with disabilities – including students, parents, and community members – are provided equitable opportunities to engage with your district in digital environments.

Additionally, these digital accessibility best practices supplement efforts toward universal design. This curb-cut effect positively impacts access for all people, which orients your district’s digital content strategy toward proactive (rather than reactive) accessibility.

As with other regulations derived from the Americans with Disabilities Act (ADA), compliance