ADA Title II and Digital Accessibility: What Schools and EdTech Need to Know

By Elizabeth Barker, Sr. Technical Program Manager, Accessibility

Why digital accessibility matters more than ever in education

Every week, sometimes daily, a friend or family member shows me some new tech update: an app that tracks even more exercise data, a game that adds new sound cues or visual effects, something small but clever that sparks my curiosity. And every time, I find myself wondering how to make that thing accessible. 

Even in this moment of rapid innovation, especially with AI pushing the boundaries of what’s possible, the foundational building blocks still matter. One of the most essential is digital accessibility.

What is ADA Title II and what does it require for schools?

In April 2024, the Americans with Disabilities Act (ADA) released its final Title II rule. This rule requires state and local governments, including preschools, K–12 schools, and colleges, to provide digital learning materials and tools that are accessible and truly usable for students with disabilities (whether on websites or mobile apps).

So what does that actually mean? Under Title II, digital content must meet the technical standards outlined in the Web Content Accessibility Guidelines (WCAG) 2.1, developed by the World Wide Web Consortium (National Center on Accessible Educational Materials, n.d.). Larger school districts must transition to compliant technology by April 2027, while smaller districts have until April 2028.

How ADA Title II impacts edtech and digital learning platforms

Many educational technology companies and organizations have been around for a long time, often well before ADA Title II was finalized. Unless an organization has focused on accessibility from the beginning, most products and content will need to be retrofitted. 

Even organizations that prioritized accessibility still need to ensure their efforts meet WCAG 2.1 AA. 

What does this mean? Accessibility is an ongoing commitment, not a one‑time, flashy update. Organizations must restructure processes to embed accessibility into their workflows. 

This may include, but is not limited to, automated accessibility checks followed by remediation of any failures. It does not stop there. Internal accessibility reviews, preferably conducted by a native assistive technology (AT) user or someone fluent with AT devices, are essential—and those reviews must be followed by a clear process for implementing fixes. 

User testing is critical: K-12 AT users are not only learning academic content, but many are also learning to be fluent with their AT devices. Understanding how that affects product usability is critical for true access. 

Lastly, an external audit of the platform and content should be conducted to verify alignment with WCAG 2.1AA. At its conclusion, a Voluntary Product Accessibility Template/Accessibility Conformance Report (VPAT/ACR) that details which elements of the standards are met, partially met, or not met, should be produced.

What schools and districts should look for in accessible edtech tools

When schools are procuring new products under ADA Title II, they should know what to look for. 

At a minimum, they should request a VPAT/ACR from the vendor and ask key questions, such as:

• Who conducted your ACR? 
• What were the findings? 
• Do you have a road map that shows which issues you’re committed to addressing and by when? 

Districts and schools should also be cautious of VPATs/ACRs completed internally by the company rather than by an independent, third‑party evaluator. 

They should be equally wary of any VPAT/ACR claiming full compliance or 100% alignment with WCAG 2.1 AA or WCAG 2.2 AA. This level of compliance is extremely difficult for any edtech product to achieve, and it’s important to understand how and why a vendor believes it met that standard. 

One may assume this is a straightforward process, but in reality, multiple factors make full compliance exceptionally difficult. For one, most educational materials are not new and must be retrofitted, meaning they may have originally been built on platforms with little to no accessibility consideration. Bringing these materials into compliance can require a complete overhaul of not only the content itself but also the underlying product architecture, which carries significant time and cost implications. Beyond the technical debt, building and coding with accessibility in mind is a specialized skill set that not all development teams possess. In addition, WCAG was not built for technical content, so markup such as MathML, which is used to make equations and math notations present correctly on the screen, does not easily weave into WCAG standards. 

Finally, schools should ask whether the product relies on an accessibility overlay. According to the Perkins School for the Blind, accessibility overlays are software tools that promise quick, inexpensive ADA compliance by adding user‑facing widgets or automated, behind‑the‑scenes fixes, but they are widely criticized by the disability community for being ineffective and often harmful. Overlays often claim to make a product fully accessible, but they aren’t typically usable for people who rely on assistive technologies. As a result, a product may appear to meet WCAG 2.1 AA standards without actually delivering meaningful accessibility for users.

Why digital accessibility matters beyond compliance

While meeting legal requirements is important, the real purpose of accessibility is to give students and teachers with disabilities the ability to actually use digital tools with assistive technology. An organization may claim alignment with WCAG 2.1 AA or ADA Title II, but what ultimately matters is the user experience.

It is easy to get caught up in checking compliance boxes, yet accessibility is about creating multiple ways for people to interact with digital materials so no one is excluded. Districts should absolutely verify WCAG alignment and confirm that a third-party vendor conducted the evaluation, but they should also talk directly with their assistive technology users about how the product works for them. That feedback is the most meaningful indicator of whether a tool will truly meet the needs of your school or district.

Lastly, elementary schools and districts serving younger learners should consider for whom the WCAG standards were originally designed. WCAG has its roots in supporting fluent assistive-technology users, which means the needs of beginner assistive-technology users are not always fully accounted for. As a result, even WCAG-aligned digital materials may not fully meet the needs of students who are just learning to use assistive technology.

What is Khan Academy doing to level up accessibility? 

At Khan Academy, accessibility is part of our mission to provide a free, world-class education to anyone, anywhere. Khan Academy is deeply committed to accessibility, and we continue to strengthen our digital materials and products by partnering with external accessibility experts and embedding accessibility practices into our processes. We have formally adopted WCAG 2.2 AA as our development baseline and proactively look for ways to improve. Our work includes prioritizing critical accessibility fixes, integrating accessibility tools and training into our workflows, and conducting annual third-party audits to identify and address gaps. An example of work and commitment to accessibility is our efforts to make our interactive graph widget accessible. We also complete yearly VPATs and Accessibility Conformance Reports (ACRs), often adding a mid-year check-in to measure progress and create annual accessibility road maps to resolve partial support areas. To support long-term improvement, we establish internal accessibility objectives and key results (OKRs) and maintain an internal review process that combines automated accessibility checks with manual evaluations of features, widgets, and web pages. Every team, from engineering to content to district partnerships, has an accessibility champion at the outset who helps us build with accessibility in mind.