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Building Accessible Futures: Preparing Institutional Repositories for ADA Title II Compliance Karen Bjork, Head of Digital Libraries and Publishing, Virginia Commonwealth University Libraries [email protected]
Title II ADA background Title II of the ADA prohibits discrimination against people with disabilities by state and local governments, ensuring they have equal access to all of their programs, services, and activities. • Signed on July 26, 1990 as part of ADA (Title II timeline) • First website published August 9, 1991 July 26, 1990, President George H. W. Bush signs the Americans with the Disabilities Act during a ceremony in the Rose Garden.
Title II Digital Accessibility April 2024: Department of Justice issued rule § 35.205 “Accessibility of Web Information and Services of State and Local Government Entities.” • Requires “making accessible the services, programs, and activities offered….to the public through the web and mobile applications.” • The standard of accessibility is W3C’s WCAG 2.1 AA. • Entities serving populations of over 50,000 people have until April 24, 2026, to comply. • Most universities fall under this timeline as an institution serving their state. • Good background doc on ADA Title II requirements from New England ADA Center New: September 22, 2025, DOJ announced new regulatory agenda (Fed Register) • Will “publish a Notice of Proposed Rulemaking (NPRM) to reconsider whether some of the regulatory provisions imposed by the April 24, 2024, rule could be made less costly.” • The date for publication of this NPRM is “To Be Determined.” Source: Latia Ward Scholarly Kitchen October 27, 2025
Action Plan Focus on … ● Inventory what we have ○ Once we know what we have, we can then figure out how to perform accessibility audits to determine how much work exists. ● Prioritize work and develop a roadmap ● Document decisions ● Train, monitor, and maintain ○ Working with our partners and providing training
Project Management ● Developed a project tracker to keep up with what had been checked, what needed remediation (spoiler alert: almost all of it) and communication with authors to keep everyone in the loop
Accessibility Audit -What we Evaluated ● Accessibility Features Present: Such as captions, transcripts, alternative text, audio descriptions, metadata completeness, etc. ● Accessibility Issues Identified: Brief, actionable notes on missing or insufficient accessibility elements. ● Collection Size & Use: Number of items and number of downloads to help us understand impact and reach. ● Priority Level (Low / Medium / High): Based on a combination of resource cost, usage volume, and legal/ethical considerations. ● Reason for priority level ○ Example: “14 of the postcards have text written on the back, one is challenging to read. Rated high due to the limited number of postcards needing transcripts”
Accessibility check process ● Check each in Adobe Pro for PDFs and WAVE for HTML and make notes of any issues flagged ● We decided to check first, then remediate after rather than try to do both at once ● Template designed for beginners to accessibility - includes descriptions and links to definitions of accessibility criteria so they can remind themselves if needed
Accessibility Check Template
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