This is the second piece in a series focused on the final rule issued in 2024 for Title II of the Americans with Disabilities Act. This piece builds on the foundational coverage of and overarching recommendations for compliance efforts presented in the first piece in our Title II final rule series. Specifically, it addresses compliance considerations and recommendations applicable to the technical standard established in the Title II final rule. As described in the first piece in the series, the Title II final rule requires that web content and mobile apps conform to Level A and AA success criteria included in version 2.1 of the Web Content Accessibility Guidelines (WCAG).
Level A and AA Success Criteria in Online Course Development and Delivery
In order to comply with the ADA Title II final rule, web content and mobile apps must conform to all 50 Level A and AA success criteria included in WCAG 2.1. While reviews of and remediation efforts for web content can involve checklists including all 50 success criteria, certain success criteria often have outsized impacts for online courses specifically. Accordingly, when institutions are considering how to structure their compliance efforts, they may find it helpful to first target those highly relevant criteria.
The following list presents criteria we have found to be especially impactful in online course development and delivery across a broad range of disciplines. For each criterion, we have included a description along with general guidance for review and remediation.
1.1.1 Non-text Content (Level A)
This success criterion targets images, user interface controls, and other forms of content that do not consist of text. In the context of online course design, images are commonly incorporated not only into course pages but also into files such as PowerPoints. As such, this success criterion is often at the forefront of review and remediation efforts.
To ensure that students who cannot see non-text content can still access the information presented, alternative text needs to be incorporated into course materials. Well-crafted alternative text for an image conveys information contained in the image itself in a manner that allows that information to be interpreted by assistive technology. For further guidance on developing and implementing alt text, see the corresponding inclusion in the Envision Accessibility Resources section at the end of this piece.
1.2.1 Audio-only and Video-only (Prerecorded) (Level A)
In addition to images, online courses also frequently feature prerecorded multimedia. In many cases, prerecorded multimedia will consist of video with accompanying audio content (e.g., a lecture video featuring narration for a PowerPoint presentation). Sometimes, however, multimedia will consist of audio-only content (such as podcasts) or video-only content (such as animations that lack narration). To ensure students who cannot hear or see can still access the information presented in multimedia content, alternative presentations of that information are needed. For audio-only content, transcripts should be included. For video-only content, an accompanying text description or audio track should be included.
1.2.2 Captions (Prerecorded) (Level A)
Prerecorded videos need to include captions so students can access spoken content in text format on screen. Captions support students who are deaf or hard of hearing, and they also help many others, including multilingual learners and students watching in noisy or quiet environments.
The overarching WCAG documentation for captions explicitly highlights the need for accuracy, noting that auto-generated captions often contain errors and are thus insufficient for meeting this success criterion. While auto-generation can provide a useful starting point for captioning, captions need human review and refinement to ensure accuracy and attain conformance with this success criterion.
1.3.1 Info and Relationships (Level A)
“Info and relationships” is a broad success criterion with important implications for virtually all online learning experiences. In essence, this success criterion stipulates that the structure and meaning of content should be built into digital materials, not just implied visually. For example, headings, lists, table headers, and form labels need to be created with proper HTML formatting (e.g., ensuring that headings are marked as headings, rather than stylized to have the appearance of headings). Proper HTML formatting helps ensure that students using assistive technologies, such as screen readers, can understand the structure of a page as intended. For further guidance on accessible use of text, see the corresponding inclusion in the Envision Accessibility Resources section at the end of this piece.
1.3.2 Meaningful Sequence (Level A)
This success criterion stipulates that content should be presented in an order that still makes sense when read aloud by assistive technology or viewed in a simplified format. This is particularly significant when course pages, documents, or activities rely on columns, text boxes, or visual placement that could otherwise confuse the intended reading order. In developing PowerPoints, for example, individual inclusions in a slide that appear to be placed in the correct reading order based on a visual assessment alone may not, in fact, be read by a screen reader in the correct order if the true reading order set in PowerPoint does not match the visual appearance of a slide. This can occur for a variety of reasons, such as when new content is layered on top of existing slide inclusions, or when inclusions deviate from existing slide layouts.
1.3.3 Sensory Characteristics (Level A)
This success criterion specifies that instructions should not be solely dependent upon features like shape, color, sound, or size. Rather, instructions should be crafted with clear, text-based identifiers and descriptions to ensure that students who cannot perceive features like shape or size can still engage with course content as intended. This can be especially important when crafting instructional materials that incorporate graphs, tables, or other structurally complex elements.
1.4.1 Use of Color (Level A)
At first glance, one might think this success criterion broadly discourages the use of color. In actuality, this success criterion stipulates that color should not be the only way information is communicated. As emphasized in WCAG’s Understanding Success Criterion 1.4.1 documentation, color plays a valuable role in web design. Conformance efforts should thus focus on ensuring that information conveyed through color is also available to individuals who cannot perceive color. Often, this is accomplished through the inclusion of text-based labels or identifiers. For further guidance on accessible use of color, see the corresponding inclusion in the Envision Accessibility Resources section at the end of this piece.
1.4.11 Non-text Contrast (Level AA)
Simply put, this success criterion stipulates that important visual elements other than text need enough contrast to be easy to see. In the context of online course development, presentation and formatting of some non-text content, like user interface components in a learning management system, depend on code and administrative decisions that are outside the scope of course design and delivery. When it comes to course-specific visual elements like images, however, this success criterion can play a major role. To detect and address non-text contrast issues, we recommend incorporating the WebAIM contrast checker or a similar tool into review and remediation processes.
1.4.3 Contrast (Minimum) (Level AA)
Just as non-text content needs to have sufficient contrast to support perception, text also needs to have sufficient contrast to ensure readability. Low-contrast text, such as light gray font on a white background, can make digital content difficult or impossible to read, especially for students with low vision. In preparing course materials, it is essential to ensure that all text content has sufficient contrast. In many cases, using standard or default font colors when creating course files or pages in a learning management system constitutes a reliable path toward conformance with this success criterion.
1.4.5 Images of Text (Level AA)
This success criterion stipulates that text content should be formatted as real text, not embedded inside an image. Real text offers numerous advantages; it is easier to resize, read on different devices, and interpret with assistive technology, making it more usable for students across many contexts. Accordingly, course pages and assignments should be built with real text. That is, written page content and assignments should be typed directly into the learning management system rather than, say, presented as screenshots of text.
When engaging in course review and remediation efforts, it is important to keep the WCAG definition of an image of text in mind. Some images, such as maps, necessarily include text in addition to other essential visual content. Such images are not the target of this success criterion. Rather, it is images of pure text, like screenshots of text-based assignment instructions or equations, that should be the focal point of review and remediation efforts.
2.4.2 Page Titled (Level A)
All course webpages, as well as documents, need to have clear, accurate titles to support navigation and engagement. In online courses, which are often comprised of many individual webpages constructed within a learning management system, the consistent inclusion of clear and accurate page titles helps ensure that all students can readily access course materials and assessments. Depending on the configuration of the learning management system used, page titling may already be subject to some degree of standardization (e.g., if module templates are used, for example, many pages may feature descriptive titles by default). Course documents, however, are often likely to require manual checks and updates.
2.4.4 Link Purpose (In Context) (Level A)
This criterion specifies that each link included in digital content should be anchored with descriptive text that indicates its purpose, clarifying where the link will direct or what selecting it will do (e.g., download a file). It is valuable to note the “in context” dimension of this criterion. As specified in WCAG’s Understanding Success Criterion 2.4.4 documentation, meeting this success criterion entails ensuring that link purpose “can be determined from the link text alone or from the link text together with its programmatically determined link context.” The term “programmatically determined link context” refers to text content appearing in the same sentence, paragraph, list item, or table cell as the link. This stands in contrast to Success Criterion 2.4.9 Link Purpose (Link Only), which is a Level AAA success criterion, and thus outside the scope of the ADA Title II final rule.
In practice, we endorse striving for the greatest degree of accessibility possible, and thus recommend designing course content to conform with Success Criterion 2.4.9 by ensuring the purpose of all links is clear based on the link text alone. Doing so can augment navigation options for screen reader users, who may choose to view page links in a single, decontextualized list, and equip all users with more helpful information about linked content. For further guidance on link accessibility, see the corresponding inclusion in the Envision Accessibility Resources section at the end of this piece.
2.4.6 Headings and Labels (Level AA)
Headings and labels should be clear and descriptive so students can quickly understand the purpose of a section, field, or activity. It is valuable to note that this specific criterion does not mandate the inclusion of headings and labels. Rather, it specifies that when headings and labels are used, they should be informative. In practice, this involves ensuring headings and labels provide contextual guidance that can support successful navigation through and engagement with digital content.
3.1.1 Language of Page (Level A)
The primary language of webpages and documents needs to be identified to ensure that assistive technologies can interpret and present content correctly. For example, setting the primary language helps ensure that screen readers pronounce text content appropriately. In learning management systems, the primary language is often set by default, meaning course-specific adjustments to content pages are not needed. However, course documents, particularly PDFs, often need manual checks and updates. For further guidance on PDF accessibility, see the corresponding inclusion in the Envision Accessibility Resources section at the end of this piece.
3.3.2 Labels or Instructions (Level A)
This success criterion highlights the need for clear labels and instructions. In online courses, that means forms, quizzes, submission portals, and interactive tools should explain what is required so all students, including those with cognitive disabilities, can understand expectations and complete course tasks successfully.
Conclusion
The technical standard established in the final rule for Title II of the ADA encompasses a broad range of WCAG success criteria. This piece highlighted a subset of those criteria that tend to have particularly significant implications for online courses. Our third and final piece in this series will explore an additional subset of criteria.