Body
Introduction
The University of Oklahoma (“OU”) is committed to the goal of achieving equal access for individuals with disabilities. The University affirms that accessibility is a shared responsibility. This policy sets the minimum requirements for creating and making digital materials, including web content and mobile applications.
Digital Material and Information Technology Accessibility is a legal requirement as stated in the Americans with Disabilities Act (ADA) and Section 508 of the Rehabilitation Act of 1973.
This Policy sets the minimum requirements for creating and maintaining accessible digital content, resources, and technology ("digital materials"). These minimum requirements allow the University’s students, employees, and others to equitably access the University’s digital materials. These requirements comply with all relevant laws and University policies and are consistent with the University’s mission.
Web Address For This Policy
To Be Determined
Definitions
- Accessible: “Accessible” means a person with a disability is afforded the opportunity to acquire the same information, engage in the same interactions, and enjoy the same services as a person without a disability in an equally effective and equally integrated manner, with substantially equivalent ease of use. The person with a disability must be able to obtain the information as fully, equally and independently as a person without a disability. Although this might not result in identical ease of use compared to that of persons without disabilities, it still must ensure equal opportunity to the educational benefits and opportunities afforded by the technology and equal treatment in the use of such technology.
- Americans with Disabilities Act (ADA) and the Title II Update: Title II of the ADA requires state and local governments to make sure that their services, programs, and activities are accessible to people with disabilities. Title II applies to all services, programs, or activities of state and local governments. This includes the services, programs, and activities that state and local governments offer online and through mobile apps. On April 24, 2024, the Federal Register published the Department of Justice’s final rule updating its regulations for Title II of the ADA. The final rule has specific requirements about how to ensure that web content and mobile applications (apps) are accessible to people with disabilities. The Title II Update sets a specific technical standard (i.e., WCAG 2.1, AA) that state and local governments must follow to meet their existing obligations under Title II of the ADA for web and mobile app accessibility.
- Disability: With respect to an individual, means (A) a physical or mental impairment that substantially limits one or more major life activities of such individual; (B) a record of such an impairment; or (C) being regarded as having such an impairment.
- Digital Accessibility: Inclusive practice of removing digital barriers that prevent interaction with or access to web content, digital tools, and technologies by people with disabilities.
- Digital Materials (Digital Content, Resources, and/or Technology): Information, products, and services available for download or distribution electronically, or on a web page or computer application.
- Equally Effective Alternative: A way that communicates the same information and does the same things in a timely way.
- Existing Digital Material: Includes all Digital Materials developed or bought before the effective date of the policy.
- New Digital Material: Includes all Digital Materials developed or bought after the effective date of the policy.
- University Business: Work performed as part of an employee’s job responsibilities, or work performed on behalf of the University by faculty, staff, volunteers, students, other trainees, and other persons whose conduct, in the performance of work for the University, is under the direct control of the University, whether or not they are paid by the University. University business includes the use of a Portable Computing Device to access OU email, non-public University systems, networks, or data in the performance of work for the University.
- Web Content Accessibility Guidelines (WCAG): The World Wide Web Consortium (W3C) guidelines for creating accessible Web content.
See additional Information Technology and Security Definitions.
Scope
This policy applies to all OU digital material whether it faces the public, or requires a log-in, examples include:
- Websites;
- Video and audio content;
- Electronic documents;
- Desktop, mobile, and cloud-based software applications;
- Content and learning management systems;
- Tools and platforms;
- Email and calendars;
- Library resources;
- Social media;
- Products for digital research; and
- Digital materials used in a course.
This policy applies to all OU digital material, internal or external, regardless of how it’s made or used. This policy also applies to everyone who selects, acquires, maintains, creates, or shares digital material for OU.
All employees, including students and graduate students, are expected to comply with this policy.
Policy
Compliance Level
New Digital Material
- Beginning April 24, 2026, New Digital Material, provided by any OU unit, department, or office for University Business, must meet the minimum accessibility requirements.
Existing Digital Material
- All OU units, colleges, departments, and offices must identify and prioritize Existing Digital Material that is not accessible and create an action plan to make it accessible by April 24, 2026.
- Units, departments, and offices must prioritize requests for content that is not accessible. If the Existing Digital Material cannot be made accessible, OU must provide an Equally Effective Alternative.
Responsibility for Ongoing Digital Accessibility
- Units, departments, and offices have an ongoing responsibility to ensure accessibility of Digital Materials. This includes:
- Evaluating digital material to ensure it complies with this policy each semester;
- Assigning the appropriate resources for accessibility assessment and compliance;
- Bearing the cost of bringing digital materials they provide into compliance with the policy; and
- Checking links to external resources and making their best effort to ensure that the resources accessed are accessible.
- The university has an ongoing, targeted evaluation process for high-priority digital material:
- Marketing and Communications must participate in ongoing site scanning for their public-facing websites;
- IT must participate in ongoing site scanning for their learning management system;
- OU units must include any site or service as directed by the university; and
- OU units are encouraged to participate with their internal sites not available to the public.
Digital Accessibility Training
- OU is committed to ensuring that all digital materials and services are accessible to our diverse community. By completing digital accessibility training, employees contribute to creating a welcoming and inclusive environment for all students, employees, and visitors.
- To achieve this, OU will provide ongoing and comprehensive training on digital accessibility to all employees, including:
- Digital accessibility education and awareness; and
- Beginner, intermediate, and advanced digital accessibility skill-building.
- OU strongly recommends that employees and student workers participate in digital accessibility training if it is relevant to their role at the university.
- Supervisors are encouraged to support their teams in engaging in learning opportunities and training sessions on digital accessibility awareness and digital accessibility skill-building.
- Training resources will be communicated to the university via the OU Digital Accessibility website, emails from leadership, or other university communication channels.
- OU may recommend additional specialized training relevant to specific roles and responsibilities, and may require additional training for those working on large or high-priority sites, services, or projects.
- Employees whose job duties involve the creation, design, or publication of digital content—including but not limited to websites, documents, learning management system materials, videos, and social media—may be required to complete additional role-specific training.
Procurement of IT
- University employees who are responsible for making decisions about IT procurement must consider accessibility as one of the criteria for acquisition.
- Any contract, obligation, or agreement that requires the University to purchase, acquire, or otherwise accept a digital product or service shall contain a provision indicating that the vendor or provider of the product or service certifies its compliance with WCAG 2.1, AA within an Accessibility Compliance Report (ACR) and/or a Voluntary Product Accessibility Template (VPAT).
- All technology suppliers are expected to provide assurances that their product is either compliant with accessibility standards or is working toward compliance within a reasonable timeline.
- All technology suppliers must demonstrate, upon request, that the product provided to the university is accessible to all users with substantially equivalent ease of use.
- IT will provide support to university units regarding procuring accessible IT.
Exceptions
- Limited and Minimal use
- If a specific condition applies, an exception may be used to buy and use digital material that is not accessible according to the policy, if
- The material will be used by 5 or fewer identified individual(s) (such as a small office or a research lab), and
- The responsible unit confirms that the digital material is accessible to those people.
- The Digital Material is not subject to the evaluation or remediation requirements of this standard, and there is no requirement to provide an equally effective alternative.
- The exception would no longer apply if the characteristics of the group of people who use the digital material change in a way that would violate one of the above requirements.
- The exception does not apply:
- When digital material is intended for long-term use or by unknown future people
- If a person using the material has an approved accommodation.
- Once the exception no longer applies, the Digital Material is subject to all requirements of this Standard, including those related to identification and remediation of accessibility issues and to availability of an equally effective alternative.
Fundamental Alteration or Undue Burden
- If an Equally Effective Alternative cannot be provided because it would make a fundamental alteration or cause an undue burden, or if another requirement of this standard cannot be met, the University unit responsible for the digital material must use the following process to request an exception:
- Obtain approval from the applicable University unit head to submit the request.
- Submit an exception request to digitalaccessibility@ou.edu. The request must include detailed information about:
- How the unit has tried to make digital material accessible or to provide an Equally Effective Alternative.
- Include information about why it is not possible to make the digital material accessible and why providing an Equally Effective Alternative would impose a fundamental alteration or undue burden.
- Representatives from the Accessibility Compliance Taskforce will conduct reviews and provide notice to the unit about whether the exception is approved.
- If an exception is not approved, the Accessibility Compliance Taskforce may help the unit make a plan to ensure accessibility.
Title II Update Exceptions Alignment
- In accordance with the new federal regulations in the ADA Title II Update, OU will adhere to the exceptions identified in the regulation, which include:
- Archived web content;
- Preexisting conventional electronic documents;
- Content posted by a third party;
- Individualized documents that are password-protected; and
- Preexisting social media posts (i.e., posted prior to April 24, 2026)
- The federal government defines the criteria for each of these five exceptions, and they must be strictly adhered to.
- View the Americans with Disabilities Act website for detailed information on each exception.
Revision, Review, and Approval History
- November 2025: Baseline Created.