The Title II rule puts school district websites on a deadline. Web content must meet WCAG 2.1 AA by April 26, 2027, for districts serving areas of 50,000 people or more, and by April 26, 2028, for everyone else. A district uses its city’s or county’s population, or, for an independent district, the Census Bureau’s estimate for the district itself, according to the Justice Department’s guidance.
The first question most districts ask is about PDFs, because most district websites are mostly PDFs. The short answer is yes, they count. The rule covers the documents you post, not just your pages. But it has exceptions that matter for schools, and they turn on dates and use, not file type. Here is how they play out on a typical district site.
- This month’s board agenda: covered. Anything posted after your compliance date gets no exception.
- The 2021 kindergarten registration packet families still fill out: covered. An old document loses its exception if it’s currently used to apply for or take part in a program. The Justice Department’s own example is a years-old license application that’s still in use.
- The 2019 strategic plan on the About page: probably exempt, if it was posted before your compliance date and nobody needs it to use a service. Edit it after that date, and the exception is gone.
- The bus routes PDF you replace every August: covered. It’s updated after the deadline, and families use it to get their children to school.
- The lunch menu your food-service company posts: covered. The exception for third-party content applies only when the poster has no contract or other arrangement with the district, and a vendor under contract is posting on your behalf.
- Ten years of newsletters in a clearly labeled archive: exempt, if they were created before your compliance date, are kept only for reference, sit in a dedicated archive section, and haven’t been changed since.
- A student’s report card in the parent portal: exempt from the up-front requirement as an individualized, password-protected document. When a family asks for an accessible version, you still owe one.
That last point applies to every exception. The rule changes what has to be accessible before anyone asks. It doesn’t change a district’s duty to communicate effectively with a family when someone does ask.
The workable plan is three piles. Fix what families use now: forms, calendars, handbooks, and anything you update each year. Move what’s truly old into a labeled archive and leave it alone. And for the documents families read most, consider a web page instead of a PDF. A page is easier to make accessible, easier to read on a phone, and easier for search engines to read, and for any chatbot on your site, which is held to the same standard.
This isn’t legal advice, and your board attorney has the final word. But the inventory is worth starting now, because the PDFs families use most are almost never the old ones.
AskK12 is built to meet WCAG 2.1 AA, and its VPAT is on our accessibility page.