JMU Publishes Title II Web Accessibility Standards Update

Harrisonburg, Va. — James Madison University has published a web accessibility standards update addressing Title II of the Americans with Disabilities Act. The publication aligns the institution's digital publishing guidance with the Department of Justice's federal rule.

JMU enrolled 22,234 undergraduates and 1,944 graduate students in fall 2023, according to public enrollment data. The university posted the accessibility update on its web resources page.

What does Title II require in 2024 and 2026?

The Department of Justice published its Title II web accessibility final rule on April 24, 2024, setting WCAG 2.1 Level AA as the technical floor for state and local government web content and mobile applications. The rule took effect on June 24, 2024.

Compliance arrives in two phases:

• April 24, 2026 — general deadline for new and substantially modified web content
• April 24, 2027 — extended deadline for pre-existing web content meeting specified conditions

The DOJ's regulatory impact analysis places roughly 89,000 state and local entities within the rule's scope, including a large subset of public institutions of higher education.

What does WCAG 2.1 AA actually require?

Web Content Accessibility Guidelines 2.1 Level AA contains 30 success criteria across four principles: perceivable, operable, understandable, and robust. Specific anchors surface frequently in accessibility audits:

• Success criterion 1.1.1 — Non-text Content (alt text on images)
• Success criterion 1.4.3 — Contrast Minimum (4.5:1 ratio for normal text)
• Success criterion 2.1.1 — Keyboard (all functionality operable from keyboard)
• Success criterion 2.4.7 — Focus Visible (visible focus indicator)
• Success criterion 4.1.2 — Name, Role, Value (programmatic labels)

Designers verify these criteria through automated scanners such as axe-core and WAVE. Manual checks include keyboard-only navigation and screen-reader testing with NVDA on Windows or VoiceOver on macOS and iOS.

What does this change for campus web teams?

The Title II shift moves accountability upstream into publishing workflows. Editors at public universities verify accessibility at content upload rather than during periodic audits.

Procurement decisions for learning management systems, library databases, and video platforms now require vendor accessibility documentation. Vendors typically supply a Voluntary Product Accessibility Template (VPAT) 2.5 or 2.5 INT with bid responses.

Enforcement routes include DOJ investigations under Title II, complaints filed with the Department of Education's Office for Civil Rights, and private litigation under Section 504 of the Rehabilitation Act.

How does JMU fit in?

JMU's update reflects the institutional coordination the federal rule anticipates. Public universities typically centralize accessibility through dedicated offices. The published update treats web accessibility as a campus-wide publishing responsibility rather than a single-department concern.

What comes next?

Two open questions will shape compliance work over the next 18 months. First, the Department of Justice's application of WCAG 2.1 AA to higher-education-specific systems — course registration interfaces, lecture capture, student portals — remains untested in formal enforcement guidance.

Second, public universities that document remediation timelines and publish accessibility statements typically demonstrate better compliance postures during investigations. The next Department of Education enforcement cases will likely arrive before the April 24, 2026 deadline, sharpening the working definition of "substantially modified" content across the public-university sector.