Why ADA Title II Requires Accessible LMS Content: A Roadmap to Accessibility

Why ADA Title II Requires Accessible LMS Content—And What That Actually Means

If your organization is a state or local government entity, here's the plain truth: your Learning Management System (LMS) content must be accessible to individuals with disabilities. The new Americans with Disabilities Act (ADA) Title II rule makes it crystal clear that digital services aren’t optional when it comes to compliance. They’re part of your legal obligation.

LMS = A Covered Digital Service

Under ADA Title II, any digital service offered by a public entity must be accessible. This includes websites, mobile apps, and—yes—Learning Management Systems. If you're using an LMS to deliver:

• Online courses
  
• Professional development
  
• Job training
  
• Public information
  

…you’re legally responsible for making all that content accessible.

What’s the Standard?

The rule requires that all LMS content conform to WCAG 2.1 Level AA. That includes:

• Digital documents (PDFs, slides, Word docs)
  
• Videos and multimedia
  
• Interactive quizzes and assessments
  
• Discussion boards and forums
  

This is the baseline. It's not a nice-to-have; it's the law.

Pre-Existing Content? Still Needs to Be Accessible

Let’s talk about the common cop-out: “But we made that document before the rule went into effect!”

Doesn’t matter.

If the content is currently used to participate in your services—like a training module, required reading, or part of a certification—it must be accessible. The only exception is for outdated materials that are no longer in active use, and even then, there’s a strong case for retrofitting.

There Are No Workarounds—Only Action Steps

To comply with ADA Title II:

• Audit your LMS content against WCAG 2.1 AA standards.
  
• Train your staff on accessible content creation.
  
• Build accessibility into your course and content development workflow.
  
• Partner with vendors who prioritize digital accessibility.
  

This isn’t about checking a box. It’s about ensuring equal access to public services for all—regardless of ability.

Trusted Resources

Want to see it straight from the source? The Department of Justice’s Final Rule on Title II explains exactly how and why digital content must meet accessibility standards.

Bottom line? If your LMS isn’t accessible, it’s not compliant—and more importantly, you’re excluding learners who have every right to equal access. Now is the time to invest in getting it right.

Need help evaluating your LMS or training your team on accessible design? Reach out—let’s make learning accessible for everyone.