An ADA Title II Digital Accessibility Fact Sheet
Target audience: Faculty, Instructional Designers
Purpose: This document provides best practices when linking to external websites or digital resources that may not meet accessibility standards required under Title II of the ADA. The goal is to ensure access for all students, including those with disabilities.
Note: This guidance does not constitute formal legal advice. Rather, it is intended to support faculty and staff in aligning their practices with the requirements of ADA Title II compliance.
Legal context
Title II regulations of the Americans with Disabilities Act (ADA) require public institutions to ensure that all programs, services, and activities—including digital content—are accessible to individuals with disabilities. This includes instructional materials, regardless of whether they are hosted internally or externally.
Risks and responsibilities
External websites may not be designed with accessibility in mind. Common issues include:
- Lack of captions or transcripts for audio/video
- Missing alt text for images
- Inaccessible navigation for screen readers
- Color contrast or font issues
While instructors may not control external content, they are responsible for ensuring students can access required and referenced materials.
Requirements and best practices
- Evaluate accessibility of websites before linking to them.
- Use accessible alternatives.
- If the external digital resource is not accessible, provide:
- A summary or transcript
- An alternative accessible version (e.g., PDF, HTML)
- A similar resource from a vetted accessible source
- Examples of accessible alternatives:
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Original Resource
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Accessible Alternative
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YouTube video without captions
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Captioned version and transcript
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Complex infographic
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Text-based summary or data table
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Interactive simulation requiring specific senses
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Descriptive walkthrough or narrated video with captions and transcript
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- Use the following recommended language when linking to external sites:
Note: This link leads to an external website not maintained by Texas A&M University. It may not meet accessibility standards under Title II of the ADA. If you encounter any barriers accessing this content, please contact [insert designated contact here] for assistance or alternative formats.
- Do not make inaccessible resources mandatory. Even if using digital resources as optional resources, if they cannot be made accessible, do not provide them to students unless equivalent accessible options are available at the same time and in a similar fashion to the original version.
- Coordinate with subject matter experts
- Work with your institution’s accessibility subject matter experts to vet resources and develop alternatives when necessary.
- Report inaccessible content so it can be addressed proactively.
External links decision tree
Step 1: Is the linked web content a public-facing website or web application; used by students in an academic setting; or critical for accessing programs, services, or emergency notifications? (If any applies, the answer is yes.)
✅ Yes; ADA Title II applies; proceed to Step 2.
❌ No; Accessibility is considered a best practice, but it is not required under ADA Title II. (Note that other state or federal laws may apply. For instance, Section 504 applies to nondiscrimination for employees of public entities. When in doubt, contact your academic liaison as a first step.)
Step 2: Is the linked web content legally or technically required to be presented in its current format?
Examples:
- The technology used to create or deliver content inherently lacks the capability to meet accessibility standards
- Legal constraints prohibit modification of the digital resource:
- Digitally signed legal documents
- Scanned court records
- Redacted public records
✅ Yes; Provide a Conforming Alternate Version (CAV) to be made available at the same time and in a similar way to the original web content.
❌ No; Go to Step 3.
Step 3: Is the linked web content accessible with WCAG 2.1 AA standards when using automated and manual testing on multiple device sizes (laptop, tablet, and mobile)?
✅ Yes; The linked content is compliant; proceed to Step 5.
❌ No; Proceed to Step 4.
❓ Unknown; Contact your academic liaison for assistance or next steps, then revisit this question and answer yes or no.
Step 4: If linked web content is not accessible, is there an accessibility limitation disclosure notice with support contact information provided?
- Example of an accessibility limitation disclosure notice with support contact information provided:
This link leads to an external website not maintained by Texas A&M University. It may not meet accessibility standards under Title II of the ADA. If you encounter any barriers accessing this content, please contact [insert designated contact here] for assistance or alternative formats.
- Important: In this instance, the designated contact must be prepared to provide an alternative accessible format in a timely manner.
✅ Yes; Proceed to Step 5.
❌ No; Include an accessibility limitation disclosure notice prior to proceeding to Step 5.
❓ Unknown; Contact your academic liaison for assistance or next steps.
Step 5: Is your link text to the web content meaningful in indicating the link destination? (The link text is not meaningful if using generic terms like “click here” or “read more.”)
✅ Yes; Both linked web content and the link itself is compliant with ADA Title II; proceed to Step 6.
❌ No; Update link text for clarity and context, then proceed to Step 6.
Step 6: Is there a plan to monitor and maintain the link by re-checking, updating or removing outdated or inaccessible content, or keeping a log of accessibility checks?
✅ Yes; Both linked web content and the link itself is compliant with ADA Title II and a maintenance protocol is established. Proceed to Final Checks.
❌ No; Establish a maintenance protocol prior to proceeding to Final Checks.
Final Checks before publishing the link:
[ ] Is the destination web content accessible or, when required in its original form, paired with a CAV?
[ ] Is the link text descriptive and meaningful, providing descriptive text about the link destination?
[ ] Are any accessibility limitations disclosed with support channels made available?
✅ All are checked; The linked web content is ready to publish.
❌ One or more are not checked; For any unchecked items, resolve the associated issues and recheck.
Recommended contacts