Specific requirements regarding digital accessibility established in a 2024 rule by the U.S. Department of Health and Human Services (HHS) mandate that digital content and tools provided by the University must meet accessibility standards by May 11, 2026. Achieving that requirement will require action by faculty and staff members across campus, supported by guidance and resources from multiple units at Brown. These detailed FAQs help clarify the scope of these new requirements and the obligations for members of the Brown community.

Digital accessibility means ensuring that digital content and tools are accessible, allowing all individuals, regardless of physical or developmental ability, to participate in the University’s academic and administrative programs by removing barriers to information. Digital accessibility is the practice of designing and developing content so that it can be used by individuals with visual, auditory, motor or cognitive disabilities, as well as other challenges that may not be apparent. Such materials should be made available at the same time and with the same ease of use as for all community members. When digital materials are not created with these standards in mind, remediation is required. Remediation is the process of identifying and correcting accessibility issues in existing content to bring it into compliance with both University standards and federal regulations.

Achieving and maintaining digital accessibility is a shared responsibility that must be integrated into the daily work of every individual and department at Brown.

The Web Content Accessibility Guidelines, or WCAG, are a series of technical standards created to ensure that digital content is accessible to people with a wide range of disabilities. These guidelines cover everything from visual elements (e.g., color contrast and text size) to technical functionality (e.g., making sure a website can be used with only a keyboard for those unable to use a mouse, trackpad or other peripheral device). Federal regulations now require Brown and other universities to meet WCAG 2.1 Level AA across all digital content and platforms.

WCAG is developed by the World Wide Web Consortium (W3C), an international community where member organizations, full-time staff and the public work together to develop web standards. Because the W3C is the leading authority on how the web should function, the consortium’s accessibility standards are recognized by governments and organizations worldwide as the official standards for an accessible digital environment.

For the vast majority of faculty and staff, the answer is no. The official WCAG is technical and primarily intended for web developers and software engineers. Rather than reading the standards themselves, you should follow the specific training and how-to guides provided on this website, which translate the requirements into clear steps for common tasks. However, if you are in a technical role — such as a web developer, software engineer or system administrator — you will likely find it necessary to consult the technical documentation directly to ensure that custom code or complex integrations meet the required standards. The WCAG also has helpful tools to assess how to correct problems and also remediation choices to avoid. 

No, the standards extend beyond websites. While "Web" is in the name, these standards apply to nearly all digital materials used for University business and instruction. This includes PDFs, presentation slides (PowerPoint, Keynote, etc.), documents (Word, Google, etc.), mobile applications, social media posts and videos, and even the software and services we purchase from third-party vendors. Essentially, if a member of the Brown community or the public interacts with your content on a screen (including phones, computers, and even kiosks), it must meet these accessibility standards.

Integrating accessibility into your workflow is often simpler than it initially seems. While the underlying technical standards are complex, the day-to-day practices for digital accessibility are generally straightforward. Most modern platforms, such as Microsoft Office and Adobe Acrobat feature built-in accessibility tools and accessibility checkers that simplify the process by identifying potential issues for you. Ultimately, adopting these standards is less about technical expertise and more about building a consistent habit of checking your work before it is published or shared.

Because the core principles of accessibility are mostly universal, many of the same fundamental practices — such as using structural headings, providing alternative text for images and creating descriptive hyperlinks — apply across all digital formats. By incorporating these basic habits into your regular workflow, you can ensure that everything you create, whether it is a departmental report, a slide presentation, a social media post, or a University website, is inclusive and accessible for all users.

Digital accessibility has long been a priority for Brown, and Brown has had digital accessibility standards in place for several years. However, new federal regulations from the U.S. Department of Health and Human Services (HHS) have formalized the requirements. These rules establish a clear legal deadline and a specific technical standard (WCAG) that all institutions receiving federal funding must meet. Adhering to these standards ensures that Brown programs and research remain open to everyone and that we remain in compliance with federal law.

Inaccessible content creates barriers for individuals with disabilities, preventing them from fully participating in University programs, courses or services. Any lack of compliance puts University funding at risk and can lead to formal complaints, federal reviews, or litigation. By creating accessible materials from the outset, we ensure that our digital environment reflects Brown’s values of inclusion and excellence without the need for reactive, time-consuming remediation later. For faculty, thinking ahead on creating accessible content will likely make it easier if and when a student with a disability requiring accessibility registers for the course.

Digital remediation is the process of identifying and correcting barriers to access within existing content to ensure it is accessible to all users, including those with disabilities. Similar to updating a physical space to meet modern building codes, remediation involves modifying digital files, videos or platforms so they function correctly with assistive technologies. This process may include tasks such as adding structural headings to documents, providing alternative text for images or ensuring that navigation is logical and descriptive. The objective of remediation is to ensure that all members of the Brown community — and the public for activities with public participation — can access the same information and enjoy a comparable digital experience.

Because the creation and management of digital content is distributed across the University, there is no central team or tool that can ensure materials are accessible on behalf of others. Instead, each department and individual is responsible for ensuring the materials they produce and share meet the required standards.

These accessibility standards apply widely across all services, programs and activities of Brown University (including unit-level and individual activities that are part of education, research and operations). While the new regulations were issued by the U.S. Department of Health and Human Services (HHS), they apply to any institution that receives federal financial assistance from the department. Because Brown receives funding from HHS — including major research grants from the National Institutes of Health and other HHS agencies — these requirements apply to all digital materials and programs across the entire university.

Yes. The standards apply to both academic materials (such as syllabi, lecture slides, etc.) as well as administrative content (such as department websites, HR forms, financial forms and internal communications). If the material is used to conduct University business, deliver instruction, or share research, it must meet the required accessibility standards.

No. If a document is for your personal use only and is not shared, published or used to participate in University programs, it does not need to meet these technical standards. However, as soon as a document is shared with a colleague, posted to a course site, sent via email or used as part of a University activity, it becomes a piece of University digital content and must be made accessible.

The new standards apply to all digital content, whether it is public-facing or “internal” content behind a login (such as single sign-on). Content in internal Google Docs and PDFs, departmental Google sites and password-protected course sites must meet the same WCAG 2.1 Level AA standards as our public websites and digital platforms and applications. For internal content, the goal is to ensure that employees and students with disabilities have the same level of access to internal tools and information as their peers.

Yes, in specific contexts. If a student or student organization produces content for a brown.edu website or a University-controlled platform (such as Events@Brown, Brown Google Sites, brownbears.com, etc), these rules apply. Because these platforms host official institutional programs, students are considered University content creators and share the responsibility for digital inclusion. The expectation is that materials related to a Brown program, service, or activity should satisfy the University's digital accessibility standards. The University will release additional guidance specifically for students and student organizations in the coming weeks.

While digital accessibility can seem technical, there are several universal principles that apply whether you are creating a document, a website or a presentation:

Use Built-in Headings

One of the most straightforward things you can do is use built-in Headings (Heading 1, Heading 2, etc.) rather than bolding or enlarging text to create titles. When you use official styles in applications such as Word, Google Docs or Canvas, you are building a "map" that allows screen readers to navigate your content efficiently. Without these tags, a person using assistive technology may have to listen to the entire document to find a specific section. It takes only seconds to apply a heading style, but it significantly improves the experience for anyone using a screen reader. View OIT’s help guide on using headings and accessibility.

Ensure Sufficient Color Contrast

Maintaining sufficient color contrast between text and its background is essential for readability. You should avoid light or muted colors for text and instead use dark text on light backgrounds to assist readers with low vision or color blindness. Similarly, when using images on a website or a presentation, be careful of how text falls on the image as that might change contrast ratios. Proper contrast prevents text from disappearing into the background, which ensures that all users can process your written content without unnecessary visual strain. View OIT’s guide on color use and accessibility.

Add Descriptive Alt Text

Providing alternative text for images and charts allows individuals using assistive technology to understand visual content. By adding a concise description, you ensure that the core message of the graphic is conveyed to those who cannot see the screen. This small adjustment helps make visual elements into accessible information, ensuring that no reader is excluded from the data or context provided by your imagery. View OIT’s guide on image alt text and accessibility.

Create Meaningful Link Text 

When adding links to a document, avoid using generic phrases like “click here,” “read more,” “online here,” or “on this website.” Instead, use descriptive text that explains exactly where the link leads. Descriptive link text provides essential context for individuals using screen readers, who often navigate documents by skipping from link to link. By ensuring the text is informative out of context, you make it much easier for all users to understand the purpose of the link before selecting it. View OIT’s guide on accessible link text.

AI is not a standalone solution for digital accessibility; ensuring content is compliant still requires manual checks and human expertise. While generative AI can serve as a helpful assistant, it is not a substitute for human review. These tools lack the necessary context and judgment to understand the unique purpose of your materials or to determine which information is most relevant to your audience. For example, AI may be able to detect that an image is missing alternative text, but it cannot know if that image is meant to be purely decorative or if it contains a vital data point that is central to your message. 

AI models can also occasionally misinterpret or incorrectly reformat complex data, such as tables or charts, which can scramble the information for someone using a screen reader. Because effective accessibility requires making informed decisions about how information is prioritized, a human must review and verify AI-generated changes to ensure the content remains accurate, relevant and free of technical barriers.

Finally, in the specific context of digital documents, AI tools do not have the ability to consistently or correctly manipulate the content, structure and metadata of document files to properly detect and modify any necessary accessibility improvements.

Automated scanning tools and remediation software can certainly be useful for remediating content to ensure accessibility, but they often identify only a fraction of potential accessibility barriers. Relying solely on these "checkers" can create a false sense of security because automated systems are incapable of understanding the unique context or purpose of your digital content. Many critical requirements — such as ensuring a logical reading order, providing meaningful link text or verifying that a complex table is intuitive — require manual review by someone familiar with the material. By using automated tools as a starting point rather than the only step in the process, you ensure that important barriers are not overlooked, protecting both the University’s compliance and the user’s ability to access information.

Accessibility Tools to Use as a Starting Point:

• SensusAccess for Document Accessibility
• Guide to Microsoft Office Accessibility Checker
• Canvas guide to Pope Tech Accessibility Checker for documents in Canvas
• Adobe Acrobat Pro guide to PDF Accessibility Checker
• WAVE Webpage Accessibility Checker
• WebAIM Contrast Checker

A highly effective method for ensuring departmental compliance is the regular audit and removal of outdated/unused digital content. We recommend that faculty and staff review their digital content and decommission files, duplicate resources or outdated materials that are no longer necessary for current instruction or University operations. By proactively deleting non-essential content, you significantly reduce the volume of material requiring technical remediation and ensure that users are only interacting with current, accessible resources.

Creating an accessible course involves a few essential steps to ensure that all students can engage with your instructional materials. You should begin by following these practices:

1. Run Pope Tech, an accessibility checker in Canvas that scans course materials for accessibility issues and guides you through the remediation process.
2. Make use of the Course Accessibility Checklist, which provides detailed information about how to make course materials and media accessible.
3. Update your syllabus with the revised accessibility and accommodations statement and repost your syllabus to Courses@Brown using Coursetools so that students know how to report inaccessible content.

The Sheridan Center’s Digital Learning & Design team provides several resources, referenced on the accessible courses page, to help instructors create and maintain accessible course materials. We recommend that instructors:

• Review accessibility guides that address the most common digital accessibility errors.
• Schedule a digital accessibility consultation to get answers to questions about accessibility and using accessibility tools.
• Join a Sheridan event on digital accessibility best practices.

Ensuring that documents are adjusted to be accessible (a process often referred to as document remediation) requires discipline-specific expertise and judgment. This required knowledge and decision-making makes it impossible for someone other than the instructor to adequately remediate documents. A few examples include:

• Complex content, such as mathematical formulas, code snippets or specialized diagrams, requires deep subject knowledge to properly convert into accessible formats.
• Alternative text (alt-text) for images, charts and other visuals requires an understanding of the relevance to the course content that only the instructor truly knows.
• If someone else attempts to fix discipline-specific work, they risk misrepresenting the instructor’s course content. Proper, high-quality remediation requires intimate knowledge of the course, making the instructor the most qualified to ensure accuracy.

The most important thing is to make progress toward ensuring your materials are accessible. By maintaining a “progress over perfection” attitude, you can tackle accessibility in manageable steps rather than all at once. We advise following this approach:

• Take stock of your course materials. Identify materials that are directly tied to course objectives and remove those that are not.
• Leverage Library course reserves. If you put digital course materials on reserve through the library rather than linking them directly to the course site, library staff will assist you by verifying that materials meet the accessibility standards.
• Prioritize the materials that may be most used and most impactful.

If you miss something and a student encounters a barrier, they can report inaccessible materials using the Digital Accessibility Concern Reporting Form linked from both the Help option in the left navigation in Canvas and the revised accessibility and accommodations statement. Once a report is submitted, the Digital Learning & Design team will reach out to instructors to provide support in helping the faculty member create an accessible version of the reported content.

No. Digital accessibility does not have implications for what you teach or research; rather, it addresses how that information is delivered to ensure it does not exclude students or colleagues with disabilities. Providing materials in an accessible format is a matter of functional access, similar to ensuring a classroom is physically accessible. These standards are designed to ensure that all students, regardless of ability, have the same access to educational information and opportunities.

There are several tools integrated directly into the University’s digital environment to support you in this process:

Pope Tech

Pope Tech is an accessibility scanning and remediation tool that is integrated in Canvas. Pope Tech will guide you through remediating the most common accessibility errors.

For more information on how to use Pope Tech, please visit our Pope Tech guides.

Canvas Accessibility Checker

Canvas has a built-in accessibility checker that can find and address basic issues. When editing a page, there is an accessibility icon on the lower right-hand corner of the text editor that indicates the number of accessibility issues it detects. In most cases, we recommend using the Pope Tech accessibility guide for a more comprehensive scan.

SensusAccess for Document Conversion

To convert PDFs and other document types to alternative formats, including .docx for easy remediation with Microsoft’s accessibility tool, you can use Brown’s SensusAccess tool. To use the tool, visit the SensusAccess page and scroll to the Use SensusAccess section.

Any type of digital document falls under the federal mandate for accessibility, including PDFs, Google Docs, Microsoft Office Documents, presentations and more.

The process for ensuring documents are accessible will vary depending on the type of document. See the “Simple Ways to Get Started” section of these FAQs for general tips that apply to documents, such as using heading styles correctly, ensuring legible color contrast, adding Alt tags to images and using meaningful link text. For specific document formats, the following guidance applies (also consult our help guide for document accessibility):

• Microsoft Documents (Word, PowerPoint, Excel): In the Review tab, use the Accessibility tool to check and fix accessibility issues.
• Google Documents: Follow the general advice in the “Simple Ways to Get Started” section of this FAQ.
• PDFs: If possible, we recommend finding an alternate format to share information because PDFs are more work to remediate. Consider including text directly on your website instead of a PDF, and move PDF forms to Qualtrics or Google Forms. If you must use a PDF, the best way to create an accessible one is to run the accessibility checker on a Microsoft Office Document. If using a Google Doc to create your PDF, download it in Microsoft format first. After running the Microsoft Accessibility checker, choose Save As PDF (do not Print to PDF).

You are only required to ensure accessibility for documents that are actively shared or used for University business, instruction and research. Documents that you maintain for your own personal use and do not distribute to students, colleagues or the public do not need to be remediated.

Additionally, you do not need to proactively remediate archived content. If a document is no longer being updated and is kept solely for reference or research purposes, it is generally exempt from these requirements. For more specific details on what qualifies for this exception, please see the “Archived Material” section of these FAQs.

If you do not have the original source file for a PDF (such as a Word or PowerPoint document), you can still remediate the PDF directly using accessibility tools like Adobe Acrobat Pro. These tools allow you to add tags, define reading orders and include alternative text for images without needing the original file. Learn more about making PDFs accessible with Acrobat on the Adobe website.

To meet accessibility standards, all videos — including those on social media and internal platforms — must be accessible to viewers with hearing and vision disabilities. This requires two primary features:

• Captions: All speech and important sound effects must be captioned. While auto-captions are a helpful starting point, they must be reviewed and edited for 100% accuracy.
• Audio Descriptions: If a video contains essential visual information that is not mentioned in the dialogue (like text on a slide or a physical demonstration), that information must be described audibly. If all of the important information in the video track is already conveyed in the dialogue, no additional audio description is necessary.

Under the HHS regulations, any social media content used to conduct University business, programs or activities must be accessible. This includes official departmental, program and administrative accounts.

New Social Media Content

When posting new content on any social media platform, you are responsible for ensuring it is accessible at the time of publication. This involves providing descriptions for images, ensuring video content is captioned, and using formatting — such as specific hashtag styles — that allows screen readers to interpret the text correctly. The goal is to ensure that information is not restricted to users who can see or hear the content.

Existing Social Media Content

The new HHS regulations focus on content created or shared after the May 2026 compliance deadline, and you are not required to proactively remediate your entire social media archive. The exception to this is "active" content. If an older post is still being used to conduct current University business — such as a pinned post containing active resources, a link to a current application, or a video that serves as the primary instructions for a program — it must be made accessible. For the vast majority of historical posts that are maintained only for reference or as a chronological record, remediation is not required.

Yes. When a University office, department or individual shares or reposts content from an external source to provide information in their capacity as a member of the Brown community (this does not apply to personal social media accounts), we assume responsibility for the content’s accessibility. If you share a post that lacks image descriptions or captions, you should provide that missing information within your own caption or post to ensure you are not passing along a digital barrier to your followers.

To remain compliant with readability standards, hashtags should use "CamelCase" (capitalizing the first letter of each word) so assistive technology can distinguish individual words. Additionally, emojis should be used sparingly and placed at the end of posts rather than in the middle of sentences to avoid interrupting the flow for individuals using screen readers.

Yes. Any email used to conduct University business, programs or activities is subject to accessibility standards. This includes both public-facing newsletters sent to alumni or the public and internal emails sent to staff and students. Because these communications are official digital content, they must be designed to be compatible with assistive technologies like screen readers to ensure all recipients have equal access to the information.

Many of the same rules that apply to websites and digital documents also apply to email, including newsletters. To meet the required standards, you should focus on the following to ensure the accessibility of newsletters:

• Descriptive Links: Avoid vague phrases like "click here." Use unique, descriptive link text (e.g., "View the Faculty Resource Guide") so users know exactly where the link leads.
• Alt Text for Images: Provide descriptive alternative text for all meaningful images.
• No "Image-Only" Emails: For design purposes, departments sometimes embed one large image that contains all the text and information of the email. This is not permitted in any circumstance. Screen readers cannot read text flattened into an image, and if the image fails to load, the recipient will have no access to the information. All important text must be actual, selectable text within the body of the email.
• Structure and Headings: For HTML emails, use proper headings (e.g., Heading 1, Heading 2) just as you would on a webpage so screen reader users can navigate the content easily.

Generally, no. Newsletters sent before the compliance deadline (May 2026) that are no longer being updated and are kept exclusively for reference or record-keeping do not require proactive remediation.

These standards apply to all websites that are part of Brown’s web presence. This includes academic and administrative unit websites, research lab sites, conference sites and Google sites hosted by the University. In addition, if a platform is used to officially represent a Brown entity or to conduct University business, it also is included in these requirements, even if it is not hosted by Brown.

However, the accessibility standards do not apply to individual professional websites that are not University websites, are not supported by University funds, and are hosted on external platforms without the use of the University’s logo or visual identity. For example, if you maintain an independent site to highlight personal professional activities — such as promoting a book or sharing a speaker series you have participated in — and that site is not hosted within the University’s digital infrastructure, does not include the Brown logo, and does not include the Brown name other than to identify a professional affiliation with the University, it is outside the scope of this policy. While we still encourage the use of accessibility best practices for all digital content to ensure the broadest possible audience, these independent external sites are not subject to the specific requirements that apply to Brown’s digital materials.

Brown has a long-standing commitment to web accessibility and has maintained a formal Web Accessibility Policy since 2018. That policy established WCAG 2.1 Level AA as the official standard for all University websites, which aligns with the requirements now included in federal regulations. Because these standards have been part of University policy for several years, the work we are doing specifically to ensure the accessibility of our websites and web presence is a continuation of these established requirements. The federal requirements now extend many of the practices applied to websites to also include all digital materials and communications.

While the University’s centrally available templates and foundational code are built to be accessible, the ongoing compliance of a site depends on the daily actions of those who manage website content. Fortunately, many of the core principles of digital accessibility are universal. Many of the same practices required for document accessibility — such as using structural headings, providing alternative text for images and creating descriptive hyperlinks — apply directly to web content. Consistent application of these fundamental principles ensures that digital materials remain accessible across all mediums, from internal reports and presentations to University websites. To learn more about web accessibility, view Brown’s web accessibility training.

The federal regulations provide a narrow exclusion for archived material, meaning it does not have to be made accessible. This refers to content created prior to the effective date of the federal mandate, that is no longer being actively updated, and is no longer being used for active university courses, programs, or services, and is instead maintained exclusively for reference or research. While these materials do not need to be proactively remediated, any digital content that is currently being used, created or developed must be made accessible.

According to the HHS regulations, the exclusion for archived material is narrow. To qualify as archived, the content must meet all of the following criteria:

1. It was created before May 11, 2026.
2. It is retained exclusively for reference, research or record-keeping.
3. It is not currently being used for active University courses, programs or services.
4. It is not being updated or changed.
5. It is stored in a dedicated area clearly identified as being archived.

If you are still using a document for a current course, or if a website provides instructions for a current departmental process, it does not qualify as archived — even if it was created years ago. Such materials must be remediated to meet current standards.

Simply labeling a folder as an "archive" is not enough to meet the legal exception to ensure accessibility of active content. The content must actually serve an archival purpose (reference/research) and cannot be used for any ongoing university business or operations. Additionally, once a file is placed in this designated archive area, it cannot be edited. If you update or modify an archived file, it loses its exempt status and must be brought into full compliance with WCAG 2.1 AA standards.

Even if content legally qualifies for the archived exception, the University still has an obligation to provide "effective communication" under the Americans with Disabilities Act and Section 504 of the Rehabilitation Act of 1973. This means that if a person with a disability requests access to an archived item that is not accessible, the department responsible for that content must provide it in an accessible format or offer an equally effective alternative in a timely manner. This website provides a link where individuals can report accessibility issues with content they need to access.

Yes. There is a specific, separate exception for "pre-existing social media posts" that establish such posts as archived content that is exempt from the HHS accessibility standards. Posts made on University-affiliated social media accounts (such as Instagram, X, LinkedIn or Facebook, among other platforms) prior to the May 11, 2026, deadline do not need to be retroactively remediated.

The exception to this is "active" social media content. If an older post is still being used to conduct current University business — such as a pinned post containing active resources, a link to a current application or a video that serves as the primary instruction for a program — it must be made accessible. For the vast majority of historical posts that are maintained only for reference or as a chronological record, remediation is not required.