Short answer
Public school websites in the US are covered by a Department of Justice rule that adopts WCAG 2.1 Level AA as the technical standard, with compliance dates in April 2027 and April 2028 depending on population size. It is a deadline, not a recommendation.
Key takeaways
- 01The standard is WCAG 2.1 Level AA — the rule names a specific version and level.
- 02Deadlines are April 26, 2027 for populations of 50,000 or more; April 26, 2028 below that.
- 03Six failure types account for 96% of all detected accessibility errors.
- 04A student photograph is directory information under FERPA, with notice and opt-out rules.
There is now a standard and a date
For years the answer to "which accessibility standard applies to our school website?" was a lawyer's shrug. That changed. The Department of Justice's Title II rule adopts WCAG 2.1 Level AA as the technical standard for state and local government web content and mobile apps — which includes public schools, districts and libraries.
An interim final rule published in April 2026 pushed the original dates back by a year. The current deadlines:
| Entity | Deadline |
|---|---|
| Public entities serving 50,000 or more people | April 26, 2027 |
| Public entities serving fewer than 50,000 | April 26, 2028 |
| Special district governments | April 26, 2028 |
What actually fails is a short list
WebAIM tests one million home pages every year. In February 2026 it found detectable WCAG 2 A/AA failures on 95.9% of them — up from 94.8%, reversing six years of slow improvement — at an average of 56.1 errors per page.
The useful part is how concentrated those errors are. Six categories account for 96% of everything detected, and have done for seven consecutive years:
| Failure | Pages affected | Usual culprit on a school site |
|---|---|---|
| Low contrast text | 83.9% | Brand colours in headings and buttons |
| Missing image alt text | 53.1% | Event photos and scanned notices |
| Missing form labels | 51.0% | Search boxes and enquiry forms |
| Empty links | 46.3% | Icon-only social media links |
| Empty buttons | 30.6% | Menu toggles and carousel arrows |
| Missing document language | 13.5% | A template that never set it |
None of these needs a redesign. They need someone to fix them and then keep them fixed.
Student photographs are a privacy decision
School websites run on photographs of children, and FERPA treats a photograph as directory information — the same category as a student's name, address and dates of attendance.
Directory information may be disclosed, but only after the school has given public notice covering three things: the types of information designated as directory information, the right to refuse that designation, and the period within which a parent or eligible student must object in writing. If your site publishes photos, that notice is part of your publishing process, not a separate policy document.
Where to start if the deadline is close
- Run an automated scan first — it will not find everything, but it finds the six common failures cheaply
- Fix contrast in the design tokens rather than page by page, so it stays fixed
- Give every icon-only link and button a real accessible name
- Decide what happens to PDFs — board minutes and newsletters are usually the largest untested pile
- Write the opt-out process into how photos get published, not into a policy nobody reads
Most of this is maintenance discipline rather than a rebuild. If the site is old enough that fixing it costs more than replacing it, that is a genuine reason to look at web design — but check first, because the answer is often no. Talk it through at contact.
Frequently asked questions
Title II covers state and local government entities, so public schools and districts are directly in scope. Private schools are generally addressed under Title III, which has no equivalent dated regulation — but the ADA still applies and WCAG remains the reference standard in practice.
WCAG 2.1 Level AA. The rule names that version and level specifically, and the April 2026 interim rule changed the deadlines without changing the standard. Meeting WCAG 2.2 also satisfies it, since 2.2 builds on 2.1.
They are web content when you publish them, and they are usually the largest accessibility problem a school has. Scanned newsletters and board minutes are images of text with no structure. Where possible, publish as web pages instead of converting to PDF.
No. Overlays act on the rendered page and cannot fix underlying structure, and the failure categories that dominate real-world testing — contrast, alt text, labels, empty controls — need changes in the source. Treat overlays as unrelated to the deadline.
Under FERPA a photograph is directory information. The school must give public notice of what it designates as directory information, the right to refuse, and the window for objecting in writing. Build that opt-out list into whoever publishes the photos.
Sources
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