By Tristia Hennessey, Senior Instructional Technology Strategist

The Department of Justice’s final rule updating Title II of the Americans with Disabilities Act (ADA), published April 24, 2024, requires all state and local governments to meet WCAG 2.1 Level AA standards for web content and mobile applications. This includes all agencies and departments of state and local governments, special purpose districts, Amtrak, and commuter authorities. If you manage learning and development for any of these entities, every piece of digital training you deliver falls under this rule.

Your compliance deadline:

  • Public entities with 50,000+ population: April 24, 2026
  • Public entities under 50,000 population and special district governments: April 26, 2027

Population is determined by Census Bureau data for your governmental entity, not by staff count or population served. For example, a county library is part of the county government, so it uses the county’s Census population even if individual branches serve far fewer people. According to the DOJ’s guidance (https://www.ada.gov/resources/web-rule-first-steps/), if your agency doesn’t have its own Census population, you use the Census population of the state or local government you’re part of.

No Training Exception

The rule includes five exceptions for certain content types. None apply to training and educational materials. Your LMS platforms, course materials, training videos, student portals, and mobile learning apps must all comply. The “preexisting documents” exception doesn’t apply because training materials are actively used to participate in government programs.

WCAG 2.1 Level AA requires proper color contrast, text alternatives for images, keyboard navigation, captions and transcripts for audio/video, screen reader compatibility, and accessible form fields. This means learners using screen readers must be able to navigate your courses, video content needs synchronized captions for deaf or hard-of-hearing learners, and color-blind users must be able to distinguish interface elements.

What L&D Leaders Need to Know & Do

Vendor relationships don’t transfer compliance responsibility. Your agency remains accountable for accessibility even when licensing third-party LMS platforms or purchasing course content. Verify WCAG 2.1 Level AA compliance before procurement and include accessibility warranties in vendor contracts.

Existing content requires review and potential remediation. Legacy courses, archived training materials, and older PDFs may need significant updates or conversion to meet current standards. New training development requires established processes and guidelines for ADA-compliant design, development, and testing from the start.

Test content using both automated tools and manual evaluation. Automated tools catch some accessibility issues but can’t test everything. Manual testing is required for complete evaluation. The W3C provides testing guidance at https://www.w3.org/wai/test-evaluate/preliminary/

Train your team by role. Instructional designers need training on accessible design principles. Content authors need training on writing accessible materials. Procurement staff need training on evaluating vendor accessibility claims. The W3C offers free accessibility curricula at https://www.w3.org/wai/curricula/

Create formal accessibility policies. Establish written standards that specify WCAG 2.1 Level AA compliance for all training materials. These policies should define who’s responsible for accessibility testing, what tools you’ll use, and when accessibility checks happen in your development workflow. Include accessibility requirements in your procurement policies for vendor-provided content and platforms.

Prioritize strategically. Focus first on frequently accessed content and any new courses in active development. Address template-based materials early since fixing templates corrects multiple courses simultaneously.

Plan for ongoing compliance. This isn’t one-and-done. After your deadline, you must maintain compliance for all new and updated content.

This is a substantial undertaking, but L&D teams don’t have to do it alone. Evolve Solutions Group has extensive experience with government agencies large and small on accessibility compliance for learning programs. We audit content libraries, update existing or develop new training, establish ADA-compliant development processes, and train L&D teams on accessible course design. Contact us at info@evolve-sg.com to learn more.