1The rule
The Department of Justice's 2024 rule under Title II of the Americans with Disabilities Act requires public colleges and universities to make their web content conform to WCAG 2.1 at Levels A and AA. Web content includes the documents an institution posts or provides, including documents a vendor provides on its behalf. Course materials in current use are within scope.
| Compliance date | Applies to |
|---|---|
| April 26, 2027 | Public entities serving a population of 50,000 or more, which includes state university systems. |
| April 26, 2028 | Public entities serving fewer than 50,000, and special districts. |
An interim final rule of April 20, 2026 set these dates, one year later than the original rule. It did not change the standard or the content covered. The duty not to discriminate applies now; the dates are when WCAG 2.1 AA becomes the measured test.
The rule exempts archived web content, preexisting documents that are not in current use, content posted by third parties, and individualized password-protected documents.
2Deliverables
For each source document, Intex delivers three files. The PDF and the web page are written from one document tree, so their text, structure, numbering and formulas agree.
| File | Specification |
|---|---|
| Tagged PDF | Declares PDF/UA-2 (ISO 14289-2:2024), WTPDF 1.0 for accessibility and for reuse, and PDF/A-4 (ISO 19005-4) for archiving. Every formula carries MathML as an associated file and a spoken form. |
| Web page | HTML5 with every formula as MathML, valid under the Nu HTML checker. |
| Compliance report | Names each validator, its pinned version and its result for this document. It states validator output and the standards by name, and makes no other claim. |
After delivery, Intex keeps the source it received and the delivered files for two weeks, so that a lost file can be sent again, and then deletes them. At checkout the institution can ask for deletion on delivery instead. Posting the delivered files, and keeping them, rests with the institution.
3Criteria and checks
The WCAG 2.1 success criteria that a document can fail are listed below. Each is met by construction, and each is confirmed by a check that does not share code with the part that did the work.
| Criterion | How it is met | Checked by |
|---|---|---|
| 1.1.1 Non-text content A | Formulas carry MathML and speech. Images receive alt text grounded in the document; an image is marked decorative only on evidence. | Formula counts in every build; the review stage's lint, claim trace and second reading |
| 1.3.1 Info and relationships A | Headings, lists, tables with header cells, theorems and formulas are tagged from the structure of the source. | veraPDF PDF/UA-2; the check stage |
| 1.3.2 Meaningful sequence A | Content is written in reading order. | veraPDF; copy and paste in three PDF engines |
| 1.4.3 Contrast (minimum) AA | The contrast of coloured text is measured and recorded. | The check stage |
| 2.4.2 Page titled A | The title is set in the metadata and shown as the window title. | veraPDF; the check stage |
| 2.4.4 Link purpose A | Every link has a spoken name, such as “Equation 3” or “Theorem 2.1”. | The check stage |
| 3.1.1 Language of page A | The document's language is declared from the source. | veraPDF; the check stage |
| 3.1.2 Language of parts AA | Passages in another language are marked as such. | The check stage |
| 4.1.2 Name, role, value A | Every element maps to a standard PDF 2.0 structure type. | veraPDF PDF/UA-2 |
4Acceptance conditions
A document is delivered only when every condition below holds. A document that fails any condition is not delivered: it is held back, and its report names the condition and the cause, for example a figure file missing from the source.
- The PDF passes veraPDF's PDF/UA-2 profile and the WTPDF accessibility and reuse profiles, and the web page passes the Nu HTML checker.
- Every formula has MathML and a spoken form. No formula is kept as an image or as LaTeX code.
- Every formula copied from the PDF reads back as the same formula, in each of three PDF engines.
- Every image has alt text whose claims trace to the document or to the image itself.
- Every printed number, for sections, theorems, equations, figures and citations, matches the number TeX prints for the original.
- The web page agrees with the PDF, and no content of the source is left out.
5Fidelity and reproducibility
Two further properties hold for every delivered document, beyond what the rule requires.
- Paste-back. A formula copied from the PDF and pasted into a LaTeX document produces the same formula.
- Reproducibility. Building the same source again gives the same file, byte for byte, so a delivered document can always be shown to be the one that was checked.
6Sources
- Nondiscrimination on the Basis of Disability; Accessibility of Web Information and Services of State and Local Government Entities, 28 CFR part 35, subpart H (2024), and the interim final rule of April 20, 2026.
- W3C, Web Content Accessibility Guidelines (WCAG) 2.1.
- ISO 14289-2:2024, PDF/UA-2; ISO 19005-4, PDF/A-4; PDF Association, Well-Tagged PDF (WTPDF) 1.0.
Questions about this measure: team@intex.university.