UC Merced's digital accessibility program is grounded in federal civil rights law, federal procurement requirements, and state education mandates. This page explains the legal framework that makes digital accessibility a compliance obligation rather than an optional best practice.
Federal Law: ADA Title II
What It Is
The Americans with Disabilities Act (ADA) Title II prohibits discrimination against people with disabilities by state and local government entities, including public universities. Digital content and technology are considered "services, programs, and activities" under the law.
2024 Final Rule on Web and Mobile Accessibility
On April 24, 2024, the U.S. Department of Justice published a final rule under ADA Title II establishing specific technical standards for web content and mobile applications. This rule:
- Adopts WCAG 2.1 Level AA as the technical standard for web content and mobile app accessibility
- Sets compliance deadlines based on population served:
- Entities serving 50,000+ people: April 24, 2026
- Entities serving fewer than 50,000 people: April 26, 2027
- Requires that all web content and mobile applications be accessible, including content provided by third parties on behalf of the institution
- Provides limited exceptions for archived content, third-party content not under the entity's control, pre-existing conventional documents, and content that would fundamentally alter the nature of a service
Implications for UC Merced
As a public institution serving well over 50,000 individuals (students, employees, prospective students, and the public), UC Merced must ensure all web content and mobile applications conform to WCAG 2.1 Level AA by April 24, 2026.
Federal Law: Section 504 and Section 508
Section 504 of the Rehabilitation Act
Section 504 prohibits discrimination based on disability in any program or activity receiving federal financial assistance. As a recipient of federal research funding, financial aid, and other federal programs, UC Merced must:
- Ensure that individuals with disabilities have equal access to programs and services
- Provide reasonable accommodations and auxiliary aids when needed
- Not exclude or deny benefits to qualified individuals with disabilities
Section 508 of the Rehabilitation Act
Section 508 requires that federal agencies make their electronic and information technology accessible to people with disabilities. While Section 508 directly applies to federal agencies, it influences university practice because the UC receives substantial federal funding and must ensure accessibility in federally funded projects.
The Technical Standard: WCAG 2.1 Level AA
What Is WCAG?
The Web Content Accessibility Guidelines (WCAG) are developed by the World Wide Web Consortium (W3C) Web Accessibility Initiative (WAI). WCAG provides a globally recognized technical standard for making web content accessible.
WCAG 2.1 Level AA Requirements
WCAG is organized around four principles. Content must be:
| Principle | Description | Example Requirements |
|---|---|---|
| Perceivable | Information must be presentable in ways users can perceive | Text alternatives for images, captions for video, sufficient color contrast |
| Operable | Interface components must be operable by all users | Keyboard accessibility, sufficient time limits, no seizure-inducing content |
| Understandable | Information and operation must be understandable | Readable text, predictable navigation, input assistance |
| Robust | Content must be robust enough to work with assistive technologies | Valid HTML, proper ARIA usage, compatibility with screen readers |
WCAG has three conformance levels:
- Level A: Minimum accessibility (basic requirements)
- Level AA: Addresses the most common barriers (required standard)
- Level AAA: Highest level of accessibility (not required for conformance)
UC Merced's compliance target is WCAG 2.1 Level A and AA.
Why WCAG 2.1?
The DOJ's 2024 rule specifically adopts WCAG 2.1 because it:
- Includes mobile accessibility criteria not present in earlier versions
- Addresses cognitive and learning disabilities more comprehensively
- Reflects current technology and user needs
- Is already the UC systemwide standard under IMT-1300
Compliance Is Not Optional
Digital accessibility is a civil rights obligation. Unlike aspirational goals or best practices, accessibility requirements:
- Are enforceable by law with real consequences
- Apply to all digital content, not just websites
- Require documentation of conformance or exceptions
Key Takeaways
- ADA Title II requires WCAG 2.1 AA conformance by April 24, 2026
- Section 504 requires equal access in all federally funded programs
- WCAG 2.1 Level AA is the technical standard for measuring conformance
- IMT-1300 implements these requirements at the UC system level
- Content owners are responsible for the accessibility of content they create or procure
- Exceptions must be formally documented with alternative access plans
Resources
- DOJ Final Rule on Web Accessibility (April 2024)
- WCAG 2.1 Guidelines
- UC IMT-1300 Policy
- Section 508 Standards
- ADA.gov Guidance
UC Merced Office of Information Technology - Digital Accessibility Program
Last Updated: January 2026
