Why this matters
Two federal rules, one technical standard, one deadline that already moved once.
The DOJ's April 2024 final rule under Title II of the ADA [28 CFR Part 35, Subpart H] requires state and local government entities — including public universities — to make web content and mobile apps, video included, conform to WCAG 2.1 Level AA. An interim rule published in April 2026 pushed the original dates back by a year: public entities serving 50,000 or more people now have until 26 April 2027; smaller entities and special district governments until 26 April 2028.
HHS's Section 504 final rule reaches further than Title II does: it applies to any institution receiving HHS funding — private universities included — across the whole of its operations, not just federally funded programmes. It adopts the same WCAG 2.1 AA standard, with its own compliance date of 11 May 2027. Between the two, almost every degree-granting institution in the country is covered by one or the other.
"Our lecture archive is old — doesn't that get an exception?"
Not the way most people hope, and it's worth having the distinction on file before your ADA coordinator is asked.
28 CFR § 35.201 exempts archived web content — material kept only for reference or research, not altered since it was archived, and stored in an area clearly identified as an archive. A course video that a current cohort is still assigned, or that gets reused, updated, or re-linked into a live LMS page, does not meet that bar. It is active content, not an archive, whatever its upload date.
The practical read most institutions land on: anything a currently-enrolled student can be assigned needs to conform, regardless of when it was recorded. We prioritize by enrollment and term first for exactly that reason.
Clause by clause
Where each effect sits in the rule.
Every row below cites the actual regulation or WCAG success criterion, so your ADA coordinator can check it against the text rather than take our word for it.
| Regulation | What it requires | Where Lecture Studio applies |
|---|---|---|
| 28 CFR § 35.200–.201 | Web content and mobile apps of a state or local government entity — including a public university's course video — must conform to WCAG 2.1 AA, subject to narrow, named exceptions. | Full production pipeline |
| WCAG 1.2.2 · Level A | "Captions are provided for all prerecorded audio content in synchronized media." | Transcript and CaptionsPresenter Plus – Captions |
| WCAG 1.4.3 · Level AA | "Text... has a contrast ratio of at least 4.5:1" against its background — including burned-in captions and on-screen cards. | Title CardSpeaker CardPresenter Plus – Captions |
| WCAG 2.4.6 · Level AA | "Headings and labels describe topic or purpose" — each unit of video should be identifiable on its own. | Title CardLearning Objectives and Key Takeaways |
| HHS Section 504 final rule (2024) | Extends the same WCAG 2.1 AA conformance duty to any recipient of HHS funding, reaching private institutions Title II does not reach — compliance date 11 May 2027. | Full production pipeline |
One thing your compliance office should know about which rule applies
Three federal regimes get invoked in the same conversation, and they are not the same rule. Section 508 binds federal agencies themselves and still incorporates WCAG 2.0 AA — it has not been updated to 2.1 — so it mainly reaches a university indirectly, through a federal contract's flow-down clause. Title II binds the university itself if it is a public institution, at WCAG 2.1 AA, on the 2027/2028 schedule above. Section 504, via HHS's 2024 rule, binds any HHS-funded institution — public or private — also at WCAG 2.1 AA, on its own May 2027 date.
Most universities are actually caught by two of the three at once. In practice that changes nothing about the production work — WCAG 2.1 AA is WCAG 2.1 AA regardless of which rule is citing it — but it is worth knowing which one your own ADA coordinator will name in a board memo.
Lecture Studio addresses the technical conformance standard — WCAG 2.1 AA — for the video content it produces. Your institution's ADA coordinator remains responsible for the rest of your digital accessibility programme: PDFs, LMS templates, third-party tools, and the compliance filing itself. We'd recommend reviewing this mapping with that office before it goes on record.
Try it
Sixteen effects, one click each.
Click any effect on the left to play a real sample in the frame — the same clips referenced in the mapping above.
From the blog
Seven questions to ask before you sign.
We wrote the evaluation criteria we would want used on us. Some of these we answer well. One of them we answer badly, and it is named — the questions that separate a real capability from a good deck.
A buyer's guide for universities procuring lecture video production, wherever they are.
Bring your Title II or Section 504 video up to WCAG 2.1 AA.
Talk to us about a pilot on your next batch of lecture recordings.