Minimum Digital Accessibility Technical Standard (Interim)


Document Control

Field

Details

Standard Owner

Accessible Technology Services (ATS), UW-IT

Approval Authority

I&TG Digital Accessibility Board
CIO for emergent standards

Date of Issue

11/12/2025

Last Reviewed

11/12/2025

Next Review Date

11/11/2026

Document Number

APS-9.0.STN-02.01

Related Policies

Purpose

This technical standard establishes the minimum accessibility requirements for digital content and applications to meet the University’s commitment to equal access to University services, programs, and activities, and ensure compliance with applicable laws and regulations.

Scope

This standard applies to all digital content and applications acquired, developed, distributed, used, purchased, or implemented by or for the University and used to provide University services, programs, or activities regardless of the source of funding.

Definitions

(Technical or unit / role definitions referred to in the standard document.)

Academic or Administrative Unit (Unit)

Academic or Administrative Units are divisions, campuses, or colleges headed by an executive who reports directly to the President or the Provost.

Applications

Applications means software-based tools and systems, regardless of platform or channel, designed to collect, process, store, and communicate information, enabling users from diverse backgrounds, abilities, and environments to perform tasks, solve problems, and enhance productivity across personal, educational, social, and professional contexts.

Conventional Electronic Documents

Conventional electronic documents mean web content or content in mobile apps that are in the following electronic file formats: portable document formats (“PDF”), word processor file formats, presentation file formats, and spreadsheet file formats.

Digital Accessibility

Digital accessibility means a person with a disability is afforded the opportunity to acquire the same information, engage in the same interactions, and enjoy the same services within the same time frame as a person without a disability in an equally effective and equally integrated manner, with substantially equivalent ease of use. A person with a disability must be able to obtain information as fully, equally, and independently as a person without a disability.

Digital Content

Digital content refers to all digital information and materials made available through University of Washington websites, web applications, or mobile applications. This includes, but is not limited to, webpages, documents (such as PDFs, Word, Excel, or PowerPoint files), multimedia (such as videos, audio recordings, and images), online course materials, electronic forms, mobile applications, and interactive tools or dashboards.

Fundamental Alteration

A fundamental alteration is something that would change the essential nature of a University service, program, or activity.

Procedure Owner

A procedure owner is the Unit responsible for publishing a procedure, ensuring it is regularly reviewed and updated to reflect evolving processes and technologies, and overseeing its implementation.

Social media platforms

Social media platforms mean websites or mobile apps of third parties whose primary purpose is to enable users to create and share content in order to participate in social networking ( i.e., the creation and maintenance of personal and business relationships online through websites and mobile apps like Facebook, Instagram, X (formerly Twitter), and LinkedIn).

Temporary Alternative Access

Temporary alternative access means a provisional solution to ensure continued access to a product while remediation is underway. Alternative access does not exempt products from compliance. Alternative formats must communicate the same information as quickly as the original. For interactive applications, alternative formats must allow users to accomplish tasks in a comparable time and with comparable effort.

Undue financial and administrative burden

Undue financial or administrative burden means something would be excessively costly, extensive, substantial, or disruptive, or result in a fundamental alteration of the nature or operation of the institution, program, service, activity, or course.

Unit Leader

A unit leader is an executive head reporting directly to the President or the Provost. [Future Link: Delegation of Authority currently in review by Rules Office.]

University services, programs, and activities

University programs, services, or activities include all operations of the university including but not limited to teaching, learning, advising, research, outreach, employment, advancement, entertainment, medical services, and other official functions of the university.

Standard Requirements

The University of Washington adopts an internationally recognized accessibility standard for web access, the Web Content Accessibility Guidelines (WCAG) 2.2 at conformance Level A/AA as the Minimum Technical Standard for Digital Accessibility.

Roles and Responsibilities

(Clearly assign responsibility for implementation, monitoring, and enforcement.)

Role Responsibility

Chief Information Officer (CIO)/Vice President of Information Technology

  • Grants exceptions to the standard in accordance with the published exception procedure
  • Delegates authority to designated roles or Unit Leaders to grant exceptions to the standard in accordance with the published exception procedure
Unit Leaders
  • Ensure adherence to the standard within their respective Units · Ensure that related procedures are followed within their respective Units
  • Ensure temporary alternative access is provided when exceptions are granted
Procedure Owners 
  • For each procedure under their responsibility, Procedure Owners must
    • Ensure the procedure undergoes appropriate stakeholder review and feedback
    • Publish the procedure in a location accessible to relevant stakeholders. 
    • Review and update the procedure at least annually to align with evolving processes and technologies.

 

Exemptions

In the following limited situations, digital content is not required to meet the Minimum Digital Accessibility Standard.

  1. Archived web content
    1. The content was created before April 24, 2026, or reproduces paper documents or the contents of other physical media that were created that date, AND
    2. The content is kept only for reference, research, or recordkeeping, AND
    3. The content is kept in a special area for archived content, AND
    4. The content has not been changed since it was archived.
  2. Preexisting conventional electronic documents
    1. The documents are word processing, presentation, PDF, or spreadsheet files; AND
    2. They were available on a UW website or mobile app before April 24, 2026; AND
    3. They are not currently being used to apply for, access, or participate in UW services, programs, or activities.
  3. Content posted by a third party where the third party is not posting due to contractual, licensing, or other arrangements with UW
  4. Individualized documents that are password-protected
    1. The documents are word processing, presentation, PDF, or spreadsheet files, AND
    2. The documents are about a specific person, property, or account, AND
    3. The documents are password-protected or otherwise secured.
  5. Preexisting social media posts
    1. Posted on social media platforms before April 24, 2026

Nonconformance

Units who have digital content or applications that cannot meet the Minimum Digital Accessibility Technical Standard due to technical or legal limitations—and that do not fall under one or more of the 5 listed exceptions—may pursue a conforming alternative version in accordance with published procedures.

Other exceptions to the Minimum Digital Accessibility Technical Standard are permitted only under the following conditions:

In these cases, the requesting individual or unit must document the justification and obtain the necessary approvals outlined in the Exception Procedure.

When an exception is granted, Units are responsible for ensuring that individuals with disabilities still receive the benefits or services to the maximum extent possible.

Failure to adhere to this standard in good faith may lead to required remediation plans, escalation to University leadership, and, if unaddressed, disciplinary or corrective action.

Implementation Timeline

Achieving comprehensive compliance with the Minimum Technical Standard for Digital Accessibility requires cultural, technical, and operational change. To support this effort, the University will use a phased implementation approach that allows units to build capacity while making consistent progress. Defined milestones will guide implementation, gradually increasing compliance expectations and supporting effective planning and prioritization.

If a unit’s web or mobile applications digital content does not fully meet the Minimum Technical Standard for Digital Accessibility, it may still be considered compliant if the issue has only a minimal effect on accessibility. In such cases, the issue must not prevent students, faculty, staff, patients, or visitors with disabilities from accessing the same information, completing the same tasks, or using University services, programs, or activities with equivalent timeliness, privacy, independence, and ease of use as others.

  1. Transition Period
    Departments and units will be provided with a reasonable period to achieve compliance with this standard and related procedures. Unless otherwise specified, the standard implementation period is twelve (12) months from the policy’s effective date.
  2. Unit Compliance
    Planning Each department or administrative unit must develop and implement a plan that identifies areas of non-compliance or accessibility gaps, outlines the actions needed to achieve compliance, and sets target completion dates within the approved transition period.
  3. Interim Risk Management
    During the transition period, departments must implement appropriate interim measures to reduce accessibility risks based on their current level of non-compliance. These measures must be documented in the unit’s plan.
  4. Extensions and Exceptions
    Requests for additional time or specific exceptions must be submitted to Compliance and Risk Services or its designee. Extensions or exceptions may be granted for good cause, including undue financial or administrative burden, technical or legal limitations, or when compliance would fundamentally alter the nature of a service, program, or activity.
  5. Monitoring and Reporting
    Compliance and Risk Services, or a delegated compliance office, will monitor progress toward compliance and may require periodic reports or attestations from departments throughout the transition period.

References

(Additional guidelines and contact information that may support compliance with the standard.)

Related Procedures

Owner Procedure
Compliance and Risk Services, Civil Rights Compliance
  • Compliance Monitoring and Reporting (Interim)
  • Evaluating Scope and Risk of acquired products (Interim)
Finance, Planning, and Budget
  • Acquisition Procedure for Procuring Accessible IT (Procurement Procedure 7.2.15)
  • Acquisition Procedure for Accessible Low-Cost IT (future)
Information Technology, Accessible Technology Services (IT-ATS)
  • Reporting Accessibility Issues in Web Content (Interim)
  • Creating and Publishing Accessible Web Content (Interim)
  • Exception to the Minimum Digital Accessibility Technical Standard (Interim)
Office of the Provost 
  • Storing Archived Course Content (Interim)
  • Creating and Publishing Accessible Courses Content (Interim)
  • Reporting Accessibility Issues in Course Content (Interim)
  • Exception to the Minimum Digital Accessibility Technical Standard – Course Content (Interim)
University Advancement, Marketing and\ Communications 
  • Storing Archived Web Content (Interim)
  • Creating and Publishing Accessible Social Media (Interim)
  • Creating and Publishing Accessible Mobile Applications (Interim)

Revision History

Date Description   Author/Editor