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Policy Number: VI-1.00(E)

University of Maryland Electronic Information, Communication and Technology Accessibility Policy

All Policies Section VI: General Administration

University of Maryland Electronic Information, Communication and Technology Accessibility Policy

(Approved by the President on an interim basis September 12, 2017, Amended April 5, 2018, Technical amendments September 21, 2021, Approved by the President on an interim basis, pending University Senate review July 25, 2025, Technical amendments December 9, 2025, Amended and approved by the President March 18, 2026)

I. POLICY

The University of Maryland (“University”) is committed to creating and maintaining a welcoming and inclusive educational and working environment for people of all abilities and to ensuring equal access to information and services for all its constituencies. Electronic Information, Communication and Technology (“EICT”) and services delivery are the primary means by which the campus community and its visitors communicate and conduct business.

This Policy sets minimum standards for the Accessibility of all University Web-based information used to conduct University business, to ensure compliance with applicable state and federal law and regulations, including but not limited to ADA Title II (28 C.F.R. Part 35), the 2024 DOJ Title II rule “Accessibility of Web Information and Services of State and Local Government Entities” (Subpart H), and Section 508 (36 C.F.R. Part 1194).

Scope
This policy applies to any University college, school, department, program or unit that makes available electronic information technology, including web-based information, mobile applications, and systems used to transact University business that impacts students, employees and the public as it relates to all aspects of the University mission of teaching, research, service, and administration. This includes course management systems, student information systems, human resource and finance systems, as well as individual faculty and staff who publish Web pages, distribute electronic documents (e.g., via email, Google Drive, ELMS-Canvas, etc.) and/or sign a contract with a vendor of electronic technology for the purpose of conducting University-related business and services.

II. DEFINITIONS

  1. “Accessibility” means the practices of ensuring that all people—regardless of ability—can interact with the information or services provided and are afforded the opportunity to acquire the same information, engage in the same interactions, and enjoy the same services in an equally effective and equally integrated manner, with substantially equivalent ease of use.
  2. EICT includes information technology and any equipment or interconnected system or subsystem of equipment used to create, convert, duplicate, or deliver data or information used to conduct University business.
  3. “Legacy Web-based information” means any Web-based information created, adopted, or modified before April 24, 2026.
  4. “Web-based information” refers to a broad range of EICTs for administrative, research, and academic applications, including but not limited to: web pages; websites; Web content; web-based applications; Mobile applications; online instructional content, services, and resources; and Conventional electronic documents. Any of these that the University (or any of its units) provides or makes available directly or through contractual, licensing, or other arrangements (for example through third-party vendors or open sources) are subject to this policy.
    1. “Conventional electronic documents” means Web content or content in Mobile applications that is in the following electronic file formats: portable document formats (‘‘PDF’’), word processor file formats, presentation file formats, and spreadsheet file formats.
    2. “Mobile applications” means software applications that are downloaded and designed to run on mobile devices, such as smartphones and tablets.
    3. “Web content” means the information and sensory experience to be communicated to the user by means of a user agent (meaning any software that retrieves and presents Web content for users), including code or markup that defines the content’s structure, presentation, and interactions. Examples of Web content include text, images, sounds, videos, controls, animations, and conventional electronic documents.

III. REQUIREMENTS

  1. All Web-based information (including both Legacy Web-based information and newly designed Web-based information) by any University administrative, academic, or programmatic unit must be in compliance with accessibility standards as required by law or otherwise by the University.
  2. Except as otherwise set forth in Section III.C below, effective April 24, 2026, all Web-based information (including both Legacy Web-based information and newly designed Web-based information) by any University administrative, academic, or programmatic unit must be in compliance with the W3C Web Content Accessibility Guidelines, version 2.1 (WCAG 2.1) Level A and Level AA success criteria and conformance requirements.
    1. The following types of Web-based information are not subject to this requirement:
      1. Archived web content: Web content that: (1) was created before, reproduces paper documents created before, or reproduces the contents of other physical media created before April 24, 2026; (2) is retained exclusively for reference, research, or recordkeeping; (3) is not altered or updated after the date of archiving; and (4) is organized and stored in a dedicated area or areas clearly identified as being archived;
      2. Preexisting conventional electronic documents: Conventional electronic documents that are available as part of the University’s web content or mobile app before the date of compliance, unless such documents are currently used to apply for, gain access to, or participate in the University’s services, programs, or activities;
      3. Third-party content: Content posted by a third party on the University’s web content or mobile app, unless the third party is posting due to contractual, licensing, or other arrangements with the University;
      4. Individualized documents: Conventional electronic documents that are: (1) about a specific individual, their property, or their account; and (2) password-protected or otherwise secured; or
      5. Preexisting social media posts: University social media that were posted before April 24, 2026.
    2. All Web-based information under an exception category must be made accessible and usable upon request.
  3. Web-based information that is internal to a University unit(s) and is only employee-facing (meaning it is neither student-facing nor public-facing), must be in compliance with any accessibility standards required by law or the University, as further set forth in the Digital Accessibility Standards and Guidelines referenced in Section VII.
  4. All University web pages (newly designed or legacy), including course content sites, must comply with the requirements outlined in the UMD “Web Accessibility Standard.” The unit that owns and controls the Web-based information is responsible for any remediation and for replacing or modifying the original content.
  5. The instructor or unit who owns and controls online instruction content in the University’s learning management system (“LMS”) or other outside platforms is responsible for any remediation and for replacing or modifying the original content.
  6. The unit that procures or manages the Web content or Mobile application is responsible for remediation and for replacing or modifying the original content.

IV. EXCEPTIONS

  1. Any University administrative, academic, or programmatic unit may request an exception to the requirements of this Policy to use “conforming alternate versions of Web Content”, as defined by WCAG 2.1, only where it is not possible to make Web-based information directly accessible due to technical or legal limitations.
  2. Any University administrative, academic, or programmatic unit may request an exception to the requirements of this Policy on the basis that noncompliance with the requirements would have such a minimal impact on access that it would not affect the ability of individuals with disabilities to do any of the following in a manner that provides substantially equivalent timeliness, privacy, independence, and ease of use: (a) access the same information as individuals without disabilities; (b) engage in the same interactions as individuals without disabilities; (c) conduct the same transactions as individuals without disabilities; and (d) otherwise participate in or benefit from the same services, programs, and activities as individuals without disabilities.
  3. Any University administrative, academic, or programmatic unit may request an exception to the requirements of this Policy on the basis that compliance with the requirements: (a) would result in a fundamental alteration in the nature of a University service, program or activity, or (b) would result in an undue financial or administrative burden. A decision that compliance would result in a fundamental alteration or undue burden must be made by the President or their designee after considering all resources available for use in the funding and operation of the service, program, or activity, and must be accompanied by a written statement of the reasons for reaching that conclusion. If compliance would result in a fundamental alteration or undue burden, compliance is required to the extent that it does not result in a fundamental alteration or undue burden, and the University shall take any other action that would not result in a fundamental alteration or undue burden but would nevertheless ensure that individuals with disabilities receive the benefits or services provided by the University to the maximum extent possible.

V. EXCEPTION REQUEST PROCESS

Units seeking an exception must submit an exception form, which may be found at https://it.umd.edu/accessibility, explaining in detail why the Policy exception is being sought and how, if the requested exception is granted, the unit will provide equally effective alternative access and ensure, to the maximum extent possible, that individuals with disabilities will receive the same benefits or services as their nondisabled peers.

VI. PURCHASING

University purchases of web-based deliverables must comply with applicable procurement policies, processes and standards, including any IT accessibility requirements and contract provisions. More information is available at https://purchase.umd.edu/

VII. STANDARDS AND GUIDELINES

This Policy is supplemented by Digital Accessibility Standards and Guidelines that are developed in coordination with appropriate stakeholders and the University IT Council and maintained by the DIT Senior IT Accessibility and UX Specialist. These Standards and Guidelines address the operationalization of the requirements herein.

The Vice President for Information Technology & Chief Information Officer (VPIT & CIO) or designee may issue, amend, or rescind such Digital Accessibility Standards and Guidelines as required to comply with legal obligations and University policy.

VIII. REVIEW

The University’s Americans with Disabilities Act (ADA) Coordinator will initiate a review and propose necessary revisions of this Policy and its associated standards as needed.

IX. CONTACTS