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Andrew Coban··2 min read

The Vendor Built It. The District Owns It.

Under the ADA Title II rule, the district is responsible for the accessibility of the vendor tools and apps it offers. Here’s how to hold vendors to it.

Here’s a question every district leader should be able to answer: if the district licenses an app or a website tool from a vendor, who is legally responsible for making it accessible? Many people assume it’s the company that built it.

Under the Justice Department’s ADA Title II rule, it’s the district. The regulation requires public entities, public school districts included, to make sure the web content and mobile apps they provide or make available, “directly or through contractual, licensing, or other arrangements,” (opens in a new tab) meet WCAG 2.1 Level AA. A learning app licensed for students, the chatbot on the homepage, the online registration form, the payment portal: if the district offers it, the obligation is the district’s, no matter who wrote the code. The deadlines are April 26, 2027, for districts in areas with 50,000 or more people and April 26, 2028, for smaller ones.

That doesn’t let vendors off the hook. It means the district has to hold them to the standard, and the contract is where that happens.

Start by knowing what you have. List every vendor tool on the district website and every app the district asks students or families to use. Most districts find more than they expected.

Then ask each vendor for evidence. A current Accessibility Conformance Report, often called a VPAT, should cover WCAG 2.1 Level AA and explain any criteria the product only partially supports. A vendor that answers with “we’re ADA compliant” and nothing else hasn’t answered the question. Our post on chatbots and the ADA walks through what to look for in that report.

Write the standard into new contracts and renewals: conformance to WCAG 2.1 Level AA, a timeline for fixing reported problems, and an updated report when the product changes. And test the tools families use most, such as registration, payments, and the parent portal, with a keyboard alone and a screen reader.

A district won’t fix every vendor product before its deadline. It can know which products it relies on, what each vendor has promised in writing, and which gaps to close first.

AskK12 publishes its accessibility report on our accessibility page, including the one area where the chat widget only partially supports the standard. Every vendor on your website should be able to show you the same.