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ADA Title II Urban Legends: Sorting Fact from Fiction About the 2024 Updates

This post has been authored by members of DLF’s Digital Accessibility Working Group. As the April 2026, Title II compliance deadline approaches, members of the DLF Digital Accessibility Working Group began comparing notes on the misconceptions, half-truths, and “urban legends” circulating about ADA enforcement and digital accessibility requirements. What started as a lively discussion evolved into a collaborative blog post aimed at separating fact from fiction. Drawing on shared institutional experiences and community expertise, this post addresses common myths about Title II and provides clear, accurate guidance along with helpful resources.

ADA Title II Urban Legends

  1. Only people who are blind use screen readers! 2
  2. Everyone who is blind can read Braille. 2
  3. Faculty are 100% personally responsible for remediating any content they teach with. 2
  4. I will have to strip my course of all engaging content (rather than spend the time learning how to make it accessible). 2
  5. Title II applies only to accessibility for the blind, and designing for screen reader accessibility will solve all accessibility needs. 3
  6. Title II applies to all disabilities, and all content must be made universally accessible for all disabilities in advance, so that no one ever needs to disclose or ask. 3
  7. Title II applies to all our buildings, and the campus has to have 100% physical accessibility by April. 4
  8. Title II applies to events, and ALL events must be hybrid in the future because in person events are not accessible. 4
  9. Title II applies to events and, because ALL virtual and hybrid events will require CART and ASL, no one will plan virtual or hybrid events anymore, because we can’t afford it. 4
  10. Title II applies to HR, and interviews held by phone or Zoom will require captions for all candidates, because you can’t ask them to disclose. 5
  11. Title II applies to internal staff meetings and clinic telemedicine visits, and captions must be enabled at the beginning of all meetings for all attendees, even if it is a confidential meeting. 5
  12. The library will withdraw and discard historic content that cannot be remediated. 6
  13. The library will withdraw and discard historic dissertations if the original author does not make them accessible (many of whom are dead). 6
  14. Everything we have in our digital collections and institutional repository is archival, so we get an exception. 6
  15. Full text in library databases already meets accessibility standards. 6
  16. Everything has to be made accessible to receive a passing grade from screening tools, even if the changes make something less accessible. 7
  17. AI will fix everything. 7
  18. ARIA roles are the solution to everything. 7
  19. Accessibility Overlays make websites accessible. 8
  20. STEM – I will not be able to use tables for data anymore 8
  21. If I add alt text to my quiz images, it will give away the answers. 8
  22. If it’s publisher/ 3rd party materials, I am not responsible for making accessible. 8
  23. People with disabilities do not go into [insert field here] so we don’t have to make content accessible. 9
  24. No disabled people use this library. 9
  25. The date Title II goes into effect depends on the size of your institution, so as of 2026, many schools have another year to go. 10
  26. Students are responsible to go through the accommodations process before the school or professors are responsible to make course content accessible. 10

 

In 2024, the Department of Justice released updates to Title II of the Americans with Disabilities Act (ADA). These updates provided specific requirements about how to ensure that web content and mobile applications (apps) are accessible to people with disabilities, stating that Web Content Accessibility Guidelines (WCAG) Version 2.1, Level AA was now the technical standard for agencies subject to Title II. They have until April of 2026 or 2027, depending on their state or local government size, to meet these requirements. As many institutions rushed to ensure compliance, misinformation and common urban legends about accessibility came to the surface. This post endeavors to answer some of these common questions and myths encountered by members of DAWG. Thanks to the members of DAWG who contributed. 

1. Only people who are blind use screen readers! 

  • Contributor(s): Karen Grondin
    • While it is true that people who are blind or low vision make up the majority of people who use screen readers, according to the WebAIM Screen Reader User Survey #10, just over 10% of screen reader users reported that their screen reader use was not due to a disability. Screen reader users also reported the following disability types: Cognitive or Learning (5.2%), Motor (2.2%), and Other (4.9%). 5.3% of users reported being both deaf/hard of hearing and blind disability types. 

   2. Everyone who is blind can read Braille.

  • Contributor(s): Jasmine Clark

3. Faculty are 100% personally responsible for remediating any content they teach with.

  • Contributor(s): Jasmine Clark
    • Agencies, universities, and other entities that fall under Title II are responsible for compliance. Employers are responsible for violations carried out by employees and contractors whose services they utilize (employer obligations are better outlined in “The ADA: Your Responsibilities as an Employer”). While a university may choose to mandate that faculty teach with accessible materials, the university is ultimately responsible for ensuring that happens. It is possible that a faculty member could be held liable if they refuse to comply with their university’s mandates, but that would most likely still be a case of joint responsibility. 

4. I will have to strip my course of all engaging content (rather than spend the time learning how to make it accessible).

  • Contributor(s): Jasmine Clark
    • Taking the time to think about ways to remediate content and incorporate universal design principles into your teaching will only benefit you. There are resources like Universal Design for Learning that are readily available to help you get started. In many ways, expanding the modalities available to your students will enhance the educational experience for all of them, not just disabled students.

5. Title II applies only to accessibility for the blind, and designing for screen reader accessibility will solve all accessibility needs.

  • Contributor(s): Jasmine Clark

6. Title II applies only to all disabilities, and all content must be made universally accessible for all disabilities in advance, so that no one ever neds to disclose or ask.

  • Contributor(s): Jasmine Clark; Jon B; PF Anderson
      • As stated above, the main changes made to Title II revolve around making state and local governments’ web and mobile apps meet the Web Content Accessibility Guidelines 2.1 (WCAG 2.1), Level AA. WCAG focuses on modalities and functional needs instead of medical diagnoses.
        • “Digital technology designed for people with a broad range of abilities benefits everyone, including people without disabilities. It is, therefore, important to consider the broad diversity of functional needs rather than categorize people according to medical classifications.” – From Diverse Abilities and Barriers
      • However, while the guidelines try to be as universally applicable as possible, there will be those who need additional accommodation. WCAG 2.1, Level AA is meant to be the minimum. As it is the universal standard that applies automatically, users do not need to disclose or request this. But needs that go beyond that baseline would still require an individual to disclose their disability to formally request an accommodation.
        • As PF Anderson put it:
  • “… there is no one-size-fits-all accessibility. Making something accessible is dependent on context and need. What improves accessibility for one person often creates new problems for someone else. We can make changes that have a high bang-for-the-buck ratio, things that tend to help more folk, however there is always someone who needs something that is a bit off the beaten path.”
    • ADA adheres to the principle of Reasonable Accommodation (RA). An RA is defined as “any change in the work environment or the way things are customarily done that provides an individual with a disability equal access to employment opportunities, benefits, and privileges. An RA can cover most things that enable an individual with a disability to apply for a job, perform the essential functions of a job, and/or have equal access to workplace opportunities, benefits, and privileges. There are three categories of RAs: 
      • 1. Modifications or adjustments to the job application process to permit an individual with a disability to be considered for a job; 
      • 2. Modifications or adjustments necessary to enable a qualified individual with a disability to perform the essential functions of the job; 
      • 3. Modifications or adjustments that enable employees with disabilities to enjoy equal benefits and privileges of employment.” – From Administrative Communications System U.S. Department of Education Handbook for Reasonable Accommodations (PDF)
    • RA’s have exceptions for undue hardship. “An undue hardship means that a specific accommodation would cause significant difficulty or expense to the employer. The determination of whether providing a RA would create an undue hardship for the Department is always made on a case-by-case basis. In making this determination, ED needs to consider factors such as: the nature and net cost of the accommodation, the Department’s overall size and financial resources, the type of operation, and the impact of the accommodation upon the operation, including the impact on other employees’ ability to perform their duties and the Department’s ability to conduct business. The Department bears the burden of proof to demonstrate that providing an accommodation would cause an undue hardship.” – From Administrative Communications System U.S. Department of Education Handbook for Reasonable Accommodations (PDF)
    • This process is inherently dependent upon disclosure and the request for accommodation. 

7. Title II applies to all our buildings, and the campus has to have 100% physical accessibility by April.

  • Contributor(s): Jasmine Clark; Wen Nie Ng
    • While Title II of the ADA broadly governs accessibility for state and local government services, programs, and activities across both physical and digital, the 2024 updates to Title II apply to state and local governments’ web and mobile apps. Not physical spaces.

8. Title II applies to events, and ALL events must be hybrid in the future because in person events are not accessible.

  • Contributor(s): Jasmine Clark; Wen Nie Ng
    • Title II does not require all events to be hybrid; it requires that events be accessible. Making events hybrid is one of multiple approaches to making them more accessible. However as stated above, the most recent updates to Title II apply to state and local governments’ web and mobile apps. Not physical spaces. So, if an event is  physical, it is not subject to the April deadline. If an event is virtual, the event must meet WCAG 2.1, Level AA. 

9. Title II applies to events and, because ALL virtual and hybrid events will require CART and ASL, no one will plan virtual or hybrid events anymore, because we can’t afford it.

  • Contributor(s): Jasmine Clark; Amy Drayer

10. Title II applies to H.R., and interviews held by phone or Zoom will require captions for all candidates, because you can’t ask them to disclose.

  • Contributor(s): Jasmine Clark
    • Employment and hiring fall under Title I and Subpart C of Title II specifies that public entities are subject to the regulations within Title I. Potential employers are required to meet the standard for Reasonable Accommodation (see definition in question 6). To summarize, WCAG 2.1, Level AA is meant to be the minimum. As it is the universal standard that applies automatically, potential employees do not need to disclose or request this. But needs that go beyond that baseline would still require an individual to disclose their disability to formally request an accommodation.

11. Title II applies to internal staff meetings and clinic telemedicine visits, and captions must be enabled at the beginning of all meetings for all attendees, even if it is a confidential meeting.

  • Contributor(s): Jasmine Clark; Jon B
    • Organizations that provide healthcare are classified as public accommodations under Subchapter III of Title III. They were already required to make their services accessible regardless of these changes to Title II. The only change these entities will have to make is updating to meet WCAG 2.1, Level AA.
    • See question 6. If an employee requests captions, they must be provided. For confidential meetings, provide captions through a secure, encrypted service or offer real-time transcription you can delete after the meeting. If there are no employees that require live captions, and maintaining an active subscription to a service would constitute an undue hardship, it would be wise to have a pre-approved vendor selected to provide services as needed. This would avoid delays and complications when accommodations are requested.   

12. The library will withdraw and discard historic content that cannot be remediated.

  • Contributor(s): Jasmine Clark
    • This would most likely be a library decision made after considering its weeding policies, not a Title II requirement. “Content” is a broad term and whether or not something can be remediated would have to be assessed on a case-by-case basis. There are exceptions depending on the format, purpose, and use of content.
      • Fact Sheet: New Rule on the Accessibility of Web Content and Mobile Apps Provided by State and Local Governments; see: Summary of the Exceptions

13. The library will withdraw and discard historic dissertations if the original author does not make them accessible (many of whom are dead).

  • Contributor(s): Jasmine Clark
  • Once again, this would most likely be a library decision, not a requirement under Title II. Dissertations can be remediated and, depending on their format and use, they may meet the requirements for an exemption. 
      • Fact Sheet: New Rule on the Accessibility of Web Content and Mobile Apps Provided by State and Local Governments; see: Summary of the Exceptions

14. Everything we have in our digital collections and institutional repository is archival, so we get an exception.

  • Contributor(s): Jasmine Clark
    • This depends on how these materials are used, when they were created, what format they are, and whether or not they are required to be used. If a faculty member is requiring materials be used for a course, they will have to be remediated and made accessible. Once again, review the exception criteria before deciding whether or not your collections are indeed exempt.
      • Fact Sheet: New Rule on the Accessibility of Web Content and Mobile Apps Provided by State and Local Governments; see: Summary of the Exceptions

15. Full text in library databases already meets accessibility standards.

  • Contributor(s):  D Krahmer
    • Even when a publisher provides an accessible file to a vendor, the vendor may reformat that information for their own databases in a way that actually destroys the accessibility. While more publishers AND vendors are shifting to epub and more accessible formats for digital content (such as EBSCO switching over to using LCP-DRM files), that doesn’t mean that material made public prior to the European Accessibility Act or the Title II updated regulations will be made accessible.

16. Everything has to be made accessible to receive a passing grade from screening tools, even if the changes make something less accessible.

  • Contributor(s): Jasmine Clark
    • Screening tools are just that, tools. Accessibility is meant to make content usable for people. While screening tools can help you identify potential barriers to access, they require actual people to verify whether there really is an issue and how to correct it. If you prioritize a passing mark from a screening tool and make something inaccessible, you will not be in compliance with Title II. 

17. AI will fix everything. 

  • Contributor(s): Karen Grondin; Jasmine Clark; Jon B
    • While AI can be helpful to people with disabilities it cannot fix everything. There are people who use things like  AI assisted smart glasses to help them tell if the medications given to them by the staff in assisted living facilities are indeed the correct medicines. However, this technology is out of reach for most due to cost (a pair of AI smart glasses costs a few hundred dollars, not including a subscription to the AI service). Several recent review studies examine this urban legend and both conclude that AI does not solve all accessibility issues. 
    • Some additional AI limitations: 
      • Synthesized auto-generated text can make up content wholly unrelated to anything being said or described.
      • The reading capability of AI is overstated and this can impact the ability to correct reading order and catch inconsistencies.
      • The costs of services can be high and are in the control of private companies that can cancel or increase the prices at will.
      • Privacy is a major risk, especially when dealing with health information.

18. ARIA roles are the solution to everything.

  • Contributor(s): D Krahmer; Wen Nie Ng
    • ARIA is a powerful tool, but it is not a universal solution and should be used with caution. It is a standard intended to work across assistive technologies. However, ARIA can behave differently across screen readers and may not always function as expected. When used incorrectly, it can create more accessibility issues than it solves. In general, native HTML semantics should be prioritized, and ARIA should be used only when necessary as a second option.

19. Accessibility Overlays make websites accessible.

20. STEM – I will not be able to use tables for data anymore

  • Contributor(s): Jasmine Clark
    • Tables aren’t inherently inaccessible. If you are using HTML and you’d like to learn how to create accessible tables, consider this tutorial from the Web Accessibility Initiative. If you aren’t working with HTML, consider looking up accessibility checkers and best practices in the applications you’re using. Research the software you’re using and the platform(s) where your data is published. 

21. If I add alt text to my quiz images, it will give away the answers.

  • Contributor(s): Jasmine Clark
    • Alt Text should convey the intent behind your image. For example, if you include a photo of the Mona Lisa for your student to identify, you would describe the painting (e.g. “a painting of a woman with dark hair,” etc.), not name it. This would be helpful to students who are visually impaired and need help with the details. In contrast, if you include the Mona Lisa as a hint to another question, with the understanding that students will know the painting, you would name the painting with appropriate context (e.g. “the Mona Lisa above a fireplace for scale”).

22. If it’s publisher/ 3rd party materials, I am not responsible for making it accessible.

  • Contributor(s): Jasmine Clark
    • The precedent set by PAYAN v. LOS ANGELES COMMUNITY COLLEGE DISTRICT (2021) would indicate otherwise. 2 blind students sued the Los Angeles Community College (LACC) claiming:
      • “…Plaintiffs identified accessibility barriers in LACC’s library research databases, many of which were not compatible with screen reading software. Despite the AMPP and her individual accommodations, Mason was unable to complete a research paper for a psychology course because the professor required use of an inaccessible research database for the assignment. Although some of the library’s online databases were accessible to blind students, the library did not conduct regular accessibility checks and did not test programs for accessibility before the library acquired them, as the AMPP required. Instead, accessibility was only tested when a blind student reported an accessibility problem”
    • The result: 
      • “The district court also found that LACCD discriminated against blind students as a matter of law based on the accessibility barriers present in the LACC websites and library database, but it declined to impose liability at that time because Plaintiffs had not yet met their burden to show reasonable modifications existed to remedy this discrimination.”
      • “Following the bench and jury trials, the district court entered a permanent injunction and final judgment in favor of Plaintiffs. The permanent injunction requires LACCD to: (1) come into compliance with its AMPP; (2) evaluate its library databases for accessibility and establish means of alternate access to inaccessible databases for blind students; (3) designate a Dean of Educational Technology; (4) make the LACC website and embedded programs accessible to blind students; and (5) assess educational materials for accessibility before acquisition and to establish means of providing accessible alternative materials to blind students in a timely manner.”
    • Website and content required for coursework must be accessible, even if it’s 3rd party. If a particular item is not accessible, accessible alternatives must be provided by the university.  

23. People with disabilities do not go into [insert field here] so we don’t have to make content accessible.

  • Contributor(s): Jasmine Clark
    • This is a horse cart issue. If a field is inaccessible, disabled people won’t go into it. Yes, there are fields with which people with certain disabilities are inherently incompatible. However, it is important that those specific examples are not used as an excuse to ignore much broader, fixable issues. For example, a retired surgeon, whose eyesight has diminished with age, may wish to look up materials they published years ago to share with a mentee or loved ones.     

24. No disabled people use this library.

  • Contributor(s): D Krahmer
    • If your library website is inaccessible, then people requiring accessibility will not use it. You’re losing 25% of your potential patrons by not building accessible websites.

25. The date Title II goes into effect depends on the size of your institution, so as of 2026, many schools have another year to go.

  • Contributor(s):  Jasmine Clark; Jon B
    • The deadline for the 2026 changes depends on the size of your state or local government, NOT your institution. A state university will have to adhere to the deadline set for its state. A public library in a small town in that same state will have to adhere to the deadline set for its town. 
      • Populations over 50,000: April 24, 2026 (2 years from the rule’s publication, April 24, 2024)
      • Populations under 50,000: April 24, 2027 (3 years from publication)
      • Fact Sheet: New Rule on the Accessibility of Web Content and Mobile Apps Provided by State and Local Governments; see: “How do you know the compliance date for other parts of government, like your city, state, or town police department or library?” under  How Long State and Local Governments Have to Comply with the Rule

26. Students are responsible to go through the accommodations process before the school or professors are responsible to make course content accessible.

  • Contributor(s): Jasmine Clark

27. My content is accessible, so the website is accessible, or vice versa.

  • Contributor(s): Wen Nig Ng
    • You can have perfectly accessible content within a poorly structured website, meaning a screen reader user may not be able to navigate to that content at all. Likewise, a well-structured site does not ensure accessibility if the content itself lacks alt text, includes inaccessible PDFs, or has uncaptioned videos.
    • The bottom line: both structure and content must be accessible. One without the other creates real barriers for users with disabilities and may lead to compliance gaps under Title II and WCAG standards.

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