Title II Regulation Updates

All web content and mobile apps made available by the university directly or through contractual, licensing, or other arrangements, are readily accessible and usable by individuals with disabilities. The new rule requires conformance with an internationally accepted technical standard, the Web Content Accessibility Guidelines (WCAG) 2.1, Level AA. 

• Websites
• Web and Mobile apps
• Video and Audio
• Electronic documents that are on university websites or mobile apps
• Digital course and instructional materials
• Social media posts

Captioning is the term used to refer to subtitles, captions, and transcripts. Subtitles are the words spoken. Captions are the words spoken, the person who is speaking, the feel of the music, and sound effects. Transcripts are text files that may have captioning details. More information for captioning is available on the UofL Web Accessibility Additional Resources page. 

The W3C recommends the following for audio and video descriptions:

• 1.2.3 Level A: Audio Description or Media Alternative (Prerecorded): An alternative for time-based media or audio description of the prerecorded video content is provided for synchronized media, except when the media is a media alternative for text and is clearly labeled as such. More information to aid understanding of 1.2.3 is available at Understanding SC 1.2.3.
• 1.2.5 Level AA: Audio Description (Prerecorded): Audio description is provided for all prerecorded video content in synchronized media. More information to aid understanding on 1.2.5 is available at Understanding SC 1.2.5.

• Does the material have consistent structure and navigation
• Does the material have descriptive names of modules, folders, assignments, etc.
• Images have alternative (alt) text
• Pre-recorded videos are captioned
• Real time captions available for live video
• Videos have audio descriptions, if needed
• Audio-only files have transcripts
• Instructions and information do not rely on color
• Descriptive links
• Color contrast between text and background is at least 4.5:1
• Color contrast between non-text elements is at least 3:1
• Avoid images of text (except for logos)
• Materials have been reviewed for accessibility (i.e. Word, PDF, PowerPoint, etc.)
• Third party content (websites, online videos, publisher content, etc.) has been
  reviewed for accessibility

Note: This does not cover all requirements of WCAG 2.1 AA.

There are a few limited circumstances where the requirements and technical standards may except certain content. All new content needs to be proactively accessible. Some old archived content does not need to be accessible unless requested. Even with exceptions, UofL is required to ensure inaccessible content is provided in an accessible manner when requested. 

• Archived web content. This is content created before April 26, 2027, that is solely for reference, research, or record keeping and kept in a clearly identified archived section without modification.
• Preexisting conventional electronic documents. These are documents posted on websites or mobile apps before April 26, 2027. Unless these documents are currently used to apply for, gain access to, or participate in the university's services, programs, or activities. Conventional documents include the following file formats: word processing, presentation, and spreadsheets, as well as PDFs.
• Third party content. Content posted by a third party, unless the third party is posting due to contractual, licensing, or other arrangements with the public entity.
• Individualized, password-protected or otherwise secured conventional electronic documents. Documents about a specific person, their property, or their account that are secured via password or other authentication method.
• Preexisting social media posts. A public entity’s social media posts that were posted before April 26, 2027.

Key elements include: meaningful alternative alt text for images, sufficient text and background contrast, structuring emails with clear headings and lists, descriptive links (not “click here”), and running accessibility checkers for compatibility with screen readers and keyboard navigation. 

• Use a clear, concise, and descriptive subject line.
• Use real headings. Do not only bold a line or make the line bigger. Use the styles or heading menu. Using styles or headings creates a map for screen reader users to move between sections.
• Use true lists, i.e. the bulleted or numbered list buttons. Manually typing a dash (-) or an asterisk (*) does not tell a screen reader that a list has started.
• Use left alignment. Avoid "justified" text. Justified text creates uneven spacing which may make reading difficult for people with dyslexia or low vision.

Emails should use a logical heading hierarchy (H1, H2). Organize content into short paragraphs, bullet points, or numbered lists.

• Use real headings. Do not only bold a line or make the line bigger. Use the styles or heading menu. Using styles or headings creates a map for screen reader users to move between sections.
• Use true lists, i.e. the bulleted or numbered list buttons. Manually typing a dash (-) or an asterisk (*) does not tell a screen reader that a list has started.
• Use left alignment. Avoid "justified" text. Justified text creates uneven spacing which may make reading difficult for people with dyslexia or low vision.

Alt text describes the purpose of an image for those who cannot see the image. A meaningful (i.e. informative) image should include a concise description of the information the image is communicating. Informative images in email signatures should include descriptive alt text (i.e. University logos, social media icons, professional distinctions, headshots, etc.). 

• Use alt text for images. If there is an image, alt text must be included. The alt text describes the content in the image. If the image is decorative, i.e. not informative, mark the alt text as "decorative".
• Do not use text in images. Do not embed important information in an image. If information is embedded in an image, make sure that same information is in the body of the email.

Emails should not rely on color alone to convey information. Avoid flashing content. Use legible fonts. Review email stationery/themes. 

• Ensure a high color contrast between text and background (at least 4.5:1). Avoid light gray text on a white background.
• If using color, also use a symbol, such as an asterisk, or the word "required".
• Use 12-14 point font size. Use a clean, sans-serif font such as, Arial, Calibri, or Verdana.

In Outlook, select “File”, “Options”, and “Accessibility”. The accessibility checker helps the user identify and fix content in the message that may make it harder for people with disabilities to consume the content of the message. There are a number of options available to select for accessibility checking in the message. The user may want to select “Show me accessibility warnings while I work”. Users can also select feedback options. Other options include application display options, document display options (this is font, font size, font color, email stationery/theme, email signature).

An email is only as accessible as its attachments. If there is an attachment in the email, that document must also be accessible. Utilize the WCAG 2.1 Level AA standards for attachments. 

1. Source Matters

• Ensure the file source (e.g. Word, Power Point, Excel) is accessible. Evaluate if the file needs to be converted to a PDF. If the file needs to be converted to a PDF, make sure the file is accessible before converting the file to a PDF.
• Use live text rather than scanned images.

2. PDFs and Tagging

• A compliant PDF needs tags, labels that tell assistive technology what is a heading, paragraph, or a table.
• Use "document structure tags for accessibility" in the Word when saving the file as a PDF.  
• Avoid "print to PDF" as this method typically removes the accessibility tags. 

3. Accessible Document Checklist

   Before the file is attached check that:

• There is a document title. The document title is different than the filename.
• Alt text is provided for images in the attachment.
• High contrast between text color and backgrounds.
• If tables are used, be sure there are table headers so a screen reader can associate the data cells with the appropriate labels. 

• Evaluate whether the document needs to be in a PDF. Consider if the PDF be a webpage.
• Consider the possibility of posting a locked or restricted original file source so the file cannot be changed instead of converting to a PDF.
• Avoid scanned PDFs. Scanned PDFs are usually images of texts and not actual text. Select the text to check if the PDF is image based. If you are not able to select the text, the PDF is not readable by an assistive device.
• Accessible PDFs need "tags" which identify required elements like headings, alt text, and table structure, among other elements.
• Use the original document file source to ensure as much accessibility as possible. It is harder to fix an inaccessible PDF than fixing the original file source and re-converting. 

PDF remediation is difficult and takes a lot of time. Identify your most used PDFs. Next, here are some things to consider for the best alternative format for your current and/or most used PDFs:

1. Is the PDF required as course material or other university business?

• If it is not required, remove it until the content can be in an accessible format.
• If the PDF is required course material or university business, do you have the original file source? Replace the PDF with an accessible original file source.

2. Could the document be a webpage?

• If the document could be a webpage, recreate the content directly as a webpage.

3. Could the content be available from another source?

• Link the content to a persistent link or permalink. For example, linking directly an article, library database, or journal subscription.

4. Is the document a form?

• If yes, recreate the form using Microsoft Forms or an accessible form platform/template. 

Put the flyer's or PDF's content in the body of the email message. Ensure that, if the flyer or PDF were no longer attached to the email, the recipient would still have all the information that is in the email.  

• Adobe Guidance on Creating Accessible PDFs
• WebAIM Adobe Acrobat Accessibility Tutorial
• WebAIM Adobe Acrobat Converting Documents to PDF 

This information pertains to creating accessible original file sources using Microsoft Office. Microsoft Office has a built in accessibility checker and you can create accessible Microsoft Office documents in specific Office applications like Word, Excel, SharePoint, PowerPoint, and more.

According to the Web Accessibility Standards, the responsibility of creating (and therefore remediating) accessible digital content resides with the unit or individual creating the materials. There are a number of vendors who can assist with PDF remediation. To date the university has permitted a decentralized approach wherein individual units have been allowed to purchase these solutions without oversight. At this time, a preferred PDF remediation vendor has not been identified by the university. Here is more information from the university about third party products and integrations. 

• Images have alt text.
• Videos have accurate, synchronized captions.
• Audio, any podcast or audio only post must have a complete transcript.
• Use #CamelCase for writing hashtags.
• Use descriptive links and indicate if the link opens to a video or PDF.
• Use emojis sparingly.

Alt text describes the purpose of an image for those who cannot see the image. A meaningful (i.e. informative) image should include a concise description of the information the image is communicating. Informative images in email signatures should include descriptive alt text (i.e. University logos, social media icons, professional distinctions, headshots, etc.). 

Captioning is the term used to refer to subtitles, captions, and transcripts. Subtitles are the words spoken. Captions are the words spoken, the person who is speaking, the feel of the music, and sound effects. Transcripts are text files that may have captioning details. More information for captioning is available on the UofL Web Accessibility Additional Resources page. 

The W3C recommends the following for audio and video descriptions:

• 1.2.3 Level A: Audio Description or Media Alternative (Prerecorded): An alternative for time-based media or audio description of the prerecorded video content is provided for synchronized media, except when the media is a media alternative for text and is clearly labeled as such. More information to aid understanding of 1.2.3 is available at Understanding SC 1.2.3.
• 1.2.5 Level AA: Audio Description (Prerecorded): Audio description is provided for all prerecorded video content in synchronized media. More information to aid understanding on 1.2.5 is available at Understanding SC 1.2.5.

Hashtags are phrases without spaces or punctuation. #CamelCase helps screen readers distinguish the words. 

Emojis should be placed at the end of a sentence, used sparingly, and should not replace a word. Emojis should not be used as bullets. 

A descriptive link is a hyperlink that clearly explains the purpose or destination of the link. A descriptive link uses meaningful words that make sense to the user even if the link is read out of context. 

Screen readers can navigate a webpage by moving link to link on the page. 

Best practices for creating descriptive links:

• Be specific
• Be concise
• Describe where the use is going rather than the action the user is taking

• Enables equal access to information and services.
• Improves usability for all users, including people in temporary situations (such as a broken arm or bright sunlight affecting screen visibility).
• Helps organizations meet legal and compliance requirements.
• Expands the potential user base.

• Screen readers 
• Support for larger text sizes
• High contrast modes
• Alt-text for images
• Color-independent information

• Captions and subtitles for video content
• Visual indicators for notifications and alerts
• Transcripts for audio content

• Large touch targets
• Voice control and speech input
• Keyboard and switch device support
• Gestures that do not require precise movements

• Clear and consistent navigation
• Plain language
• Predictable user interactions
• Reduced complexity and distractions

• Use descriptive labels for buttons (e.g., "Submit Order" instead of "Click Here")
• Ensure text can be resized without loss of functionality
• Maintain sufficient color contrast between text and backgrounds
• Make touch targets at least 44 × 44 points (iOS) or 48 × 48 dp (Android)
• Provide alternative text for images and icons
• Support both portrait and landscape orientations when appropriate

Apple's mobile accessibility interface guidelines 

Android's mobile accessibility interface guidelines

Mobile accessibility task force

Focus first on content that is actively used, promoted, assigned, or linked from current webpages. 

Begin identifying:

• Videos posted on department websites;
• YouTube, Vimeo, and social media content;
• Marketing and recruitment videos;
• Event recordings and livestreams; and
• Audio-only content such as podcasts.

Creating accessible content from the start is significantly easier and less costly than remediating content later. For newly created videos, plan for:

• Accurate captions;
• Review and correction of auto-generated captions;
• Audio descriptions when important visual information is not conveyed through narration; and
• Accessible hosting and playback options.

Videos Embedded on University Websites

Videos embedded on louisville.edu webpages should generally be treated as university web content and may need to meet accessibility requirements regardless of where they are hosted. 

YouTube and Social Media

Some existing social media content may qualify for federal exceptions if it was posted before April 26, 2027, and remains unchanged. However:

• Republishing content may create new accessibility obligations.
• Editing or modifying content may remove eligibility for an exception.
• Accessible versions may still need to be provided upon request. 

Audio-only content (podcasts, recorded announcements) generally requires a transcript.

Video-only content generally requires an accessible alternative describing the visual information.

Most videos with audio generally require captions and, when necessary, audio descriptions. 

If your Department maintains older videos that are no longer used for current operations, instruction, recruitment, or communications, archiving may be an option.

Archived content should generally:

• Be clearly identified as archived;
• Be retained for reference, research, or recordkeeping;
• Not be modified after archiving; and
• Include information about how to request accessible versions if needed. 

Even when content may qualify for an exception, the University may still be required to provide an accessible version upon request.

Departments should:

• Respond promptly;
• Contact appropriate accessibility resources if assistance is needed; and
• Consider the urgency and purpose of the request when determining next steps. 

By Spring 2027, Departments Should:

• Identify all public-facing video content.
• Determine which videos are still actively used or promoted.
• Establish a process for reviewing captions and accessibility before publication.
• Identify any future needs for audio description services.
• Consider whether older content should remain active, be remediated, or be archived.
• Designate a departmental contact responsible for video accessibility questions and requests.
• Ensure staff involved in creating, publishing, or managing video content receive accessibility guidance and training.

Answer: The exemption does not apply. Embedded pre- April 26, 2027, YouTube videos should be treated as web content. If your Department chooses to feature an old video on its webpage and/or mobile sites, social media, etc. it must be accessible and conform to the new standards.

Answer: Yes, videos posted on a Department’s website qualify as web content.

Answer: Yes, UofL's YouTube channel(s) qualify as a social media platform. YouTube is categorized as a social media platform, and nothing distinguishes YouTube from a platform such as Facebook or X. Social media platforms rely on user-generated content and community interaction. 

The University can rely on the exemption for pre-April 26, 2027, videos that are not altered after the effective date (e.g. on or after April 26, 2027). The University is still required to comply with effective communication and provide an accessible version of pre- April 26, 2027, videos in a timely manner upon request by an individual with a disability.

Answer: Yes. Any resharing, reposting, or editing should be treated as making a new post and, therefore, as creating new content. If an old video is added to a playlist for current purposes (e.g., orientation, recruiting, advertising, etc.) and not for archival or historical purposes, it should be considered active redistribution and should be remediated.

Answer: The Department should include a permanent notice informing visitors that the content is historical and has not been updated. The Department should also include an effective communication commitment with contact information for the Department/relevant office and an estimated turnaround for accessible versions of content. 

A record of the archived contents should include the material’s title, creation date, and archive date.

A compliant archive section:

1. Created before the date rules take effect.
2. Retained exclusively for reference, research, or recordkeeping.
3. Not altered or updated after date of archiving.
4. Organized and stored in a dedicated area clearly defined as being archived.

Answer: Recordings of livestreamed events that were posted April 26, 2027, and remain unchanged on a UofL social media platform may qualify for the pre-April 26, 2027, social media exception. However, if those recordings are embedded on a university website, featured as current content, modified, or republished after April 26, 2027, they should be treated as web content and must comply with the applicable accessibility requirements.

Answer: Events live-streamed after April 26, 2027, must comply with WCAG 2.1 Level AA. Live broadcasts require appropriate live captioning, and recordings retained for later viewing may need accurate corrected captions and audio descriptions where required.

Answer: Transcripts are required for audio-only and video-only. Audio and video require captions and may require audio descriptions when applicable.

Answer: HSC or Clinical Departments must comply with the earlier April 2027 deadline. The video requirements are identical. 

Answer: The University must respond promptly and provide accessible access in a timely manner based on the nature, purpose, and urgency of the request.

Answer: Responsibility rests with the Department that created or requested creation of the video, even if a vendor/3^rd party was used to create the content. Departments should designate a specific contact responsible for coordinating accessibility requests and remediation efforts.