What the Title II deadline extension means for UND

UND can and should make progress on digital accessibility ahead of new 2027 deadline for updated regulations, coordinator says

On Monday, April 20, the U.S. Department of Justice published an interim final rule extending the compliance date for new Title II regulations of the Americans with Disabilities Act.

These regulations included updated requirements and enhanced standards to ensure that web content and mobile applications are accessible to people with disabilities.

Originally set to take effect on April 26, 2026, for public entities serving populations of 50,000 people or more, the deadline has been extended by one year.

Also on April 20, Donna Smith, assistant vice president for Civil Rights & Title IX, issued a message to the campus community with this update.

Smith emphasized that UND’s commitment to digital accessibility is unwavering, even as the extension provides more time to work toward compliance.

“Accessibility remains a core responsibility, and our progress should not pause or slow,” Smith said. “Instead, this extended timeline gives us the opportunity to continue refining our practices, strengthening our infrastructure, and ensuring sustainable, long-term compliance.”

Judy Risch, a former member of the U.S. Department of Education’s Office for Civil Rights, now serving as a digital accessibility coordinator for UND, spoke with UND Today to further discuss the decision.

Notably, the legal obligation to provide accessible digital services has long been enshrined in the ADA, Risch said. The extension affects when public entities must meet the Web Content Accessibility Guidelines 2.1 Level A/AA, specifically.

“The extra time is going to make a big difference, but that doesn’t mean we get to stop,” Risch said. “UND has shown commitment in this regard, in that working to meet Title II isn’t a one-and-done thing … This is a push for progress, not perfection.”

UND has the means

The latest rule from the federal government recognized the constraints of the original timelines, concluding that it overestimated the abilities of state and local governments to comply on time.

The Department of Justice cited groups reporting limited budgets, insufficient staff and lack of technical expertise to meet the requirements.

There was also commentary on the manual nature of accessibility work, as automation through AI or other means isn’t currently possible.

Risch said most points expressed in the interim final rule are immaterial to the progress UND can make in the leadup to the new April 26, 2027, deadline.

The University has the tools and resources for students, staff and faculty to play their part in creating accessible web content, and Risch indicated that more is soon on the way to help with PDF remediation specifically.

The campus community can expect further announcements on remediation services this summer.

“We’re surveying faculty, and we surveyed staff this past month,” Risch said. “We got really good data that helped drive decision making. It’s helped us get a sense of the systemic issues affecting campus.”

For instance, in response to that data, the Teaching Transformation & Development Academy recently held sessions for staff on Microsoft Word, Microsoft Outlook and PDF, as well as a session on the basics of digital accessibility hosted by Risch. All session recordings are available to watch.

Risch is also seeking people to reach out to her directly if they use Adobe InDesign in their work, as it is a commonly used tool in graphic design that can create accessible material. She plans to organize training to help address this and other high-impact topics and subjects as time goes on.

“If people have needs and those needs are not being met, please talk to me,” Risch said. “I’ll try to do what I can to address it.”

For general information and guidance, the Accessible UND webpage contains links to several digital accessibility topics, from images and PDFs to documents and videos.

Everyone has a role to play

Risch regarded the road to compliance with Title II’s standards as a “million-mile journey,” and UND is well on its way.

With respect to the federal extension, she said, the voices amplified in that decision were just taking their first steps in the journey.

Through her experience with the Department of Education’s enforcement compliance program, Risch’s team resolved thousands of cases on digital accessibility and developed regulations.

“To me, a lot of the discussion preceding the extension focused on the desire for quick-fix solutions and easy buttons, and those don’t exist,” she said.

Shifting focus to UND’s part to play, Risch encouraged members of the campus community to think about their role, and to think about what they are adding to the web or to a learning management system such as Blackboard.

Thinking about the backlog of old material can be overwhelming, she added, so it’s crucial to stop the flow of inaccessible materials being added to UND’s digital presence.

“We’ve talked a lot about scores and percentages, and I look at this more holistically,” Risch said. “I look for progress. We want to take small steps. Campus has started, but have you personally started?

“The hardest part of that journey is the first mile.”