About the research
Our higher education readiness survey—conducted in partnership with disability community leaders—captured insights from 300 public college and university administrators. The findings explore how institutions are managing the transition toward proactive digital inclusion under the ADA Title II Final Rule. As campuses embrace a mobile-first student experience, this research shines a light on why public institutions must look beyond their homepages to secure accessibility within the third-party apps and portals where academic life actually happens.
Growing reliance, growing risk: mobile platforms as vital academic portals
Mobile devices are now the primary way many students engage with campus life. Registration, financial aid, course materials, housing updates, and safety alerts increasingly live inside mobile apps and vendor-hosted portals.
As institutions prioritize “mobile-first” student portals, core academic workflows are moving into these environments. When accessibility gaps exist in mobile systems, the impact is immediate and disproportionate for students with disabilities.
A student relying on a screen reader may open a registration portal only to encounter unlabeled form fields or controls that cannot be navigated by keyboard, making it difficult or impossible to complete required steps independently.
Recent research indicates that approximately 72% of mobile user journeys contain significant accessibility barriers, particularly in navigation, forms, and time-sensitive transactions. When those journeys involve required academic processes, barriers are no longer minor usability issues — they directly affect participation and retention.
This creates elevated Title II risk precisely where students interact with campus services most.
In our survey of 300 public colleges and universities, fewer than half reported including mobile applications in their defined accessibility scope.
What ADA Title II mandates for digital services in higher ed
The DOJ’s 2024 Final Rule clarifies that ADA Title II applies to the digital systems public colleges and universities use to deliver programs and services — including websites, mobile apps, and third-party platforms.
If students must use a mobile app or vendor-controlled system to register for classes, access coursework, manage financial aid, or complete other required processes, that system falls within Title II’s scope.
Public institutions must ensure these systems conform to WCAG 2.1 Level AA by:
- April 24, 2026: large public institutions (serving 50,000+ people)
- April 26, 2027: smaller institutions must meet the standard
Accessibility responsibility remains with the institution, even when the technology is owned or operated by a vendor.
WCAG 2.1 Level AA addresses common digital barriers that prevent task completion, including:
- Missing text alternatives for images or icons
- Inaccessible or unlabeled form fields
- Controls that cannot be operated by keyboard
- Insufficient color contrast
- Dynamic content not announced to assistive technologies
Mobile apps and vendor platforms are especially prone to these issues because they rely on custom interface components and frequent updates.
Why mobile risk slips through the cracks
Mobile accessibility gaps rarely occur because institutions don’t care. They often happen because ownership of these systems is distributed. A university homepage often has a dedicated web team and established review cycle. Mobile apps and vendor platforms often do not.
In our survey of 300 public colleges and universities:
- 41% said accessibility responsibility is spread across multiple teams
- 38% said digital systems are created and managed across many platforms
When ownership is fragmented, gaps are easier to miss — especially as apps update and vendors push new releases.
Institutions may also assume vendor platforms are “built accessible.” In reality, accessibility depends on configuration, custom content, and ongoing maintenance. Vendor ownership does not remove institutional responsibility under Title II.
When barriers surface, institutions often fall back on workarounds — phone lines, email support, or in-person assistance. But when the primary pathway for registration, coursework, or financial aid is digital, those alternatives are not equal access under Title II.
Mobile risk doesn’t hide because institutions lack commitment. It hides because responsibility is shared.
How accessibility gaps become academic barriers
When accessibility fails inside campus apps or vendor platforms, the impact is immediate — at the moment students try to complete required academic tasks.
These are not edge cases. They are core workflows.
Required steps become blocked. Students may be unable to submit assignments, register for classes, or access financial aid.
Independence is lost. Everyday tasks like password resets or grade tracking require outside assistance.
Deadlines and safety updates are missed. Inaccessible alerts can prevent students from receiving critical academic or safety information.
Workarounds are not equal access. When the standard pathway is digital, phone lines and in-person support do not provide equivalent access under Title II.
Critical focus areas for higher education leaders
Under ADA Title II, the biggest risk isn’t inaction — it’s focusing on the wrong systems.
Many institutions have strengthened their primary websites. But Title II exposure increasingly concentrates in the systems students are required to use every day.
Leaders should focus on four priorities:
1. Start with required systems
Treat student portals, mobile apps, and vendor platforms used for coursework, registration, housing, or financial aid as core infrastructure. If it’s required, it should be reviewed first.
2. Know what you operate
Many institutions have strengthened their primary websites. But Title II exposure increasingly concentrates in the systems students are required to use every day.
3. Assign ownership
Accessibility spans IT, procurement, and academic departments. Without clear accountability, gaps persist. Ownership must extend from vendor selection through updates and renewals.
4. Fix the primary pathway
When the standard student experience is digital, workarounds are not a solution. Risk decreases when the primary system works — not when exceptions or workarounds are managed.
Where ADA Title II risk now concentrates in higher education
As campuses adopt mobile-first student experiences, ADA Title II risk increasingly concentrates in the systems where students complete academic tasks — mobile apps, learning management systems, and vendor-hosted portals.
While institutions may not control every layer of these platforms, they remain responsible for ensuring the digital services students rely on are accessible.
accessiBe works alongside higher education institutions to help strengthen accessibility oversight across the broader digital environment — supporting teams with monitoring, visibility into accessibility issues, and expert guidance as systems evolve.
Because digital environments change constantly, accessibility cannot be treated as a one-time effort. Institutions benefit from consistent oversight and structured progress across the systems connected to the student experience.
If your institution is preparing for the 2026 or 2027 Title II deadlines, our accessibility specialists can help you review your current approach and identify practical next steps.
Speak with a Title II accessibility expert one-on-one about your institution’s accessibility strategy.
Frequently asked questions about mobile and third-party accessibility in Higher Ed
Q1. What does ADA Title II require for university mobile apps?
A1. Under the 2024 Title II Final Rule, public colleges and universities must ensure that all mobile applications used to deliver their programs, services, and activities—including university-branded apps for registration, campus maps, and student life—are accessible to people with disabilities. These digital assets must conform to the technical standards of Web Content Accessibility Guidelines (WCAG) 2.1 Level AA.
Q2. When is the deadline for campuses to ensure their apps are compliant?
A2. Deadlines are based on the population size the institution serves. Large public entities (serving 50,000 or more people) must meet the standard by April 24, 2026. Smaller institutions (serving fewer than 50,000 people) and special district governments have until April 26, 2027, to ensure their digital services, including mobile apps, are conformant.
Q3. Is the university responsible for the accessibility of third-party platforms like Canvas or Blackboard?
A3. Yes. Under ADA Title II, your institution is responsible for the accessibility of any digital service it "provides or makes available," including those through contractual, licensing, or other arrangements. This means Learning Management Systems (LMS), student portals, and library databases must meet accessibility standards even if they are developed by an outside vendor.
Q4. Does Title II apply to apps that are only for internal student use?
A4. Yes. The rule applies broadly to all digital content used for programs and services, whether it is public-facing or restricted by a login for students and faculty. This includes internal portals for course registration, financial aid workflows, and emergency notification systems used exclusively by the campus community.
Q5. Can we provide a phone number as a workaround if a mobile app is inaccessible?
A5. No. Federal guidance emphasizes that public entities must proactively ensure digital services are "accessible by default" up front. Providing an "after-the-fact" accommodation, such as a phone workaround, is not a substitute for making the primary digital pathway accessible from the start.
Q6. What are common accessibility barriers in campus mobile apps?
A6. Frequent issues include buttons or icons without descriptive text labels (which prevents screen reader users from navigating), reliance on gesture-only interactions (like swiping or pinching) without alternatives, and inaccessible modals or pop-ups that are not adequately announced to assistive technology.
Q7. How should higher education leaders manage accessibility with third-party vendors?
A7. Institutions should require a Voluntary Product Accessibility Template (VPAT) or an Accessibility Conformance Report (ACR) during procurement to verify that vendor products conform to WCAG 2.1 Level AA. It is essential to include specific accessibility requirements and penalties for non-conformance in all future vendor contracts.
