What the New ADA Standards Mean for Institutions With Dispersed L&D

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For over a year, learning and development (L&D) teams working for public schools and universities have been preparing for new ADA regulations, specifically the ADA Final Rule for Digital Accessibility. In short, this new mandate requires that all digital learning and development content meet the Web Content Accessibility Guidelines ( WCAG 2.1 AA ). To meet these new requirements, L&D professionals are reviewing courses, platforms, and materials. We are ensuring that all videos are properly captioned, all images include proper alt text descriptions, and all slide decks have high color contrast. Keyboard navigation is being looked at in relation to online learning courses. Content is specifically being tested for screen reader compatibility. All of this is to ensure that every learner can fully access and benefit from the learning assets we are producing for our institutions and clients.

For over a year, learning and development (L&D) teams working for public schools and universities have been preparing for new ADA regulations, specifically the ADA Final Rule for Digital Accessibility. In short, this new mandate requires that all digital learning and development content meet the Web Content Accessibility Guidelines (WCAG 2.1 AA). To meet these new requirements, L&D professionals are reviewing courses, platforms, and materials. We are ensuring that all videos are properly captioned, all images include proper alt text descriptions, and all slide decks have high color contrast. Keyboard navigation is being looked at in relation to online learning courses. Content is specifically being tested for screen reader compatibility. All of this is to ensure that every learner can fully access and benefit from the learning assets we are producing for our institutions and clients.

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And now, with the hard compliance deadline of April 24, 2026, fast approaching for large institutions, the timeline for auditing thousands of assets has shrunk to just months.

And now, with the hard compliance deadline of April 24, 2026, fast approaching for large institutions, the timeline for auditing thousands of assets has shrunk to just months.

What Is WCAG?

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Web Content Accessibility Guidelines (WCAG) aim to provide a single standard for web content accessibility. The goal of this work is to ensure that all individuals, organizations, and governments have equal access to web content, and in this context, to learning and development content.

Web Content Accessibility Guidelines (WCAG) aim to provide a single standard for web content accessibility. The goal of this work is to ensure that all individuals, organizations, and governments have equal access to web content, and in this context, to learning and development content.

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WCAG 2 is made up of 13 guidelines , organized under four principles:

WCAG 2 is made up of 13 guidelines, organized under four principles:

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Perceivable: Learners must be able to perceive the content being presented using at least one of their senses. The four guidelines that fall under this principle include:

Perceivable: Learners must be able to perceive the content being presented using at least one of their senses. The four guidelines that fall under this principle include:

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  Text Alternatives: You must provide text alternatives for any non-text learning content.

  Text Alternatives: You must provide text alternatives for any non-text learning content.

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  Time-based Media: You must provide alternatives for time-based media.

  Time-based Media: You must provide alternatives for time-based media.

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  Adaptable: You must create content that shares the same information in different ways.

  Adaptable: You must create content that shares the same information in different ways.

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  Distinguishable: You must make it easy for learners to see and hear the learning content, for example, the color contrast of foregrounds and backgrounds.

  Distinguishable: You must make it easy for learners to see and hear the learning content, for example, the color contrast of foregrounds and backgrounds.

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Operable: Learners must be able to successfully interact with the learning elements of your training, regardless of how they are accessing the training. The five guidelines that fall under this principle include:

Operable: Learners must be able to successfully interact with the learning elements of your training, regardless of how they are accessing the training. The five guidelines that fall under this principle include:

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  Keyboard Accessible: You must make interaction functionality available via the keyboard.

  Keyboard Accessible: You must make interaction functionality available via the keyboard.

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  Enough Time: You must provide users enough time to read and use the content.

  Enough Time: You must provide users enough time to read and use the content.

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  Seizures and Physical Reactions: You must avoid creating content in ways that are known to cause seizures or physical reactions.

  Seizures and Physical Reactions: You must avoid creating content in ways that are known to cause seizures or physical reactions.

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  Navigable: You must ensure learners can navigate the learning asset, find the content, and determine where they are in the learning asset.

  Navigable: You must ensure learners can navigate the learning asset, find the content, and determine where they are in the learning asset.

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  Input Modalities: You must make it easy for learners to operate any e-learning course through various inputs beyond just the keyboard.

  Input Modalities: You must make it easy for learners to operate any e-learning course through various inputs beyond just the keyboard.

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Understandable: Learners must be able to understand the learning content and how to use it. The three guidelines that fall under this principle include:

Understandable: Learners must be able to understand the learning content and how to use it. The three guidelines that fall under this principle include:

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  Readable: You must make content readable and understandable.

  Readable: You must make content readable and understandable.

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  Predictable: You must ensure that the learning assets appear and operate in predictable ways.

  Predictable: You must ensure that the learning assets appear and operate in predictable ways.

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  Input Assistance: You must create content that helps users avoid and/or correct mistakes.

  Input Assistance: You must create content that helps users avoid and/or correct mistakes.

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Robust: Learning must be designed in ways that can be accessed via a wide variety of devices and when using available assistive technology. The one guideline that falls under this principle is:

Robust: Learning must be designed in ways that can be accessed via a wide variety of devices and when using available assistive technology. The one guideline that falls under this principle is:

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  Compatible: You must maximize the compatibility of your learning assets with current and future agents, including assistive technology.

  Compatible: You must maximize the compatibility of your learning assets with current and future agents, including assistive technology.

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And for each guideline, there are testable success criteria falling into three levels: A (lowest), AA, and AAA (highest).

And for each guideline, there are testable success criteria falling into three levels: A (lowest), AA, and AAA (highest).

L&D’s Role in Accessibility

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If you are an L&D professional, I hope that you were not surprised as you read through the above list. For years, it has been our mission to democratize learning and development, empowering the masses with the power of learning. We have worked under the mantra that learning can and should be designed in ways that make it accessible to everyone. In a perfect learning world, no one would need to request an accommodation to benefit from the support we offer.

If you are an L&D professional, I hope that you were not surprised as you read through the above list. For years, it has been our mission to democratize learning and development, empowering the masses with the power of learning. We have worked under the mantra that learning can and should be designed in ways that make it accessible to everyone. In a perfect learning world, no one would need to request an accommodation to benefit from the support we offer.

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The spirit of L&D has always been to meet people where they are and provide the support they need to be successful. Each principle and guideline above is written to ensure that this happens. It’s part of standard adult learning theory and has been part of our work lives for years, long before these rules were codified into law. Yet as our environment and the structure of L&D within our institutions change, we may have cause to worry.

The spirit of L&D has always been to meet people where they are and provide the support they need to be successful. Each principle and guideline above is written to ensure that this happens. It’s part of standard adult learning theory and has been part of our work lives for years, long before these rules were codified into law. Yet as our environment and the structure of L&D within our institutions change, we may have cause to worry.

The Disconnect

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In his advisory and research work across global enterprises, Markus Bernhardt of Endeavor Intelligence has noted that the “Shadow Learning” economy is exploding, with some organizations even holding more than four times as many authoring tool licenses outside the L&D function as within it. Markus warns that this creates a dangerous “Governance Gap”: we have democratized the ability to create content, but we have failed to democratize the expertise required to make it compliant. When the tools are easier to use than the standards are to understand, accessibility is the first casualty.

In his advisory and research work across global enterprises, Markus Bernhardt of Endeavor Intelligence has noted that the “Shadow Learning” economy is exploding, with some organizations even holding more than four times as many authoring tool licenses outside the L&D function as within it. Markus warns that this creates a dangerous “Governance Gap”: we have democratized the ability to create content, but we have failed to democratize the expertise required to make it compliant. When the tools are easier to use than the standards are to understand, accessibility is the first casualty.

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During a recent conversation, Markus and I began pondering what this could mean for institutions and organizations whose work falls under these ADA regulations.

During a recent conversation, Markus and I began pondering what this could mean for institutions and organizations whose work falls under these ADA regulations.

Why This Matters

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Crucially, the new Title II rule destroys the distinction between “public” and “internal.” If a university requires staff to access a portal or take training as part of their employment, that internal content must meet the same WCAG 2.1 AA standards as the public homepage. Meaning that if your organization is producing learning assets, and those who are creating the content are not aware of the ADA rules, you could find yourself in a challenging position.

Crucially, the new Title II rule destroys the distinction between “public” and “internal.” If a university requires staff to access a portal or take training as part of their employment, that internal content must meet the same WCAG 2.1 AA standards as the public homepage. Meaning that if your organization is producing learning assets, and those who are creating the content are not aware of the ADA rules, you could find yourself in a challenging position.

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Well-meaning subject-matter experts (SMEs) may not be versed in these rules and could create learning assets that are not accessible to every member of your workforce. Years ago, that would have manifested as a quiet problem; someone is unable to progress in their career because they are not being given the proper development and training needed, and they might grow stagnant or leave the company. While still a terrible tragedy, and something that L&D professionals worry about each day, it probably wouldn’t cause more than a blip on the organizational workforce dashboard. Today, it could get you sued.

Well-meaning subject-matter experts (SMEs) may not be versed in these rules and could create learning assets that are not accessible to every member of your workforce. Years ago, that would have manifested as a quiet problem; someone is unable to progress in their career because they are not being given the proper development and training needed, and they might grow stagnant or leave the company. While still a terrible tragedy, and something that L&D professionals worry about each day, it probably wouldn’t cause more than a blip on the organizational workforce dashboard. Today, it could get you sued.

What Can You Do About It?

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1. Uncover Who Is Designing Learning Assets for Your Company. Some leaders might think that learning assets are designed only by the learning and development team. As I’ve highlighted here, that might not be the case. Additionally, the new rule explicitly holds institutions liable for third-party content procured through “contractual or licensing arrangements.” This means you cannot blame the vendor. If your SMEs use a non-compliant tool you licensed, the legal risk falls on you, not the software company. To ensure your institution isn’t putting itself at risk, I encourage you to inventory who is creating learning for your workforce. You might be surprised to see how dispersed your learning creation is.

1. Uncover Who Is Designing Learning Assets for Your Company. Some leaders might think that learning assets are designed only by the learning and development team. As I’ve highlighted here, that might not be the case. Additionally, the new rule explicitly holds institutions liable for third-party content procured through “contractual or licensing arrangements.” This means you cannot blame the vendor. If your SMEs use a non-compliant tool you licensed, the legal risk falls on you, not the software company. To ensure your institution isn’t putting itself at risk, I encourage you to inventory who is creating learning for your workforce. You might be surprised to see how dispersed your learning creation is.

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2. Create Policy, Practices, and Procedures. Regardless of the legal requirements, creating learning assets accessible to everyone who might ever need them should be our goal. Individuals should not have to ask for an accommodation to benefit from the learning available at our institutions. Create and share policies, practices, and procedures that highlight this; build them into your institution’s norms and hold people accountable for creating learning that can be accessed by anyone, at any time that it is needed.

2. Create Policy, Practices, and Procedures. Regardless of the legal requirements, creating learning assets accessible to everyone who might ever need them should be our goal. Individuals should not have to ask for an accommodation to benefit from the learning available at our institutions. Create and share policies, practices, and procedures that highlight this; build them into your institution’s norms and hold people accountable for creating learning that can be accessed by anyone, at any time that it is needed.

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3. Support Communities of Practice Focused on Creating Accessible Learning. Communities of Practice and other Employee Resource Groups (ERGs) are incredibly powerful when building, sharing, and sustaining practices and procedures that support accessible design. Odds are, there are people at your institution who are already paying close attention to these requirements and who would love the opportunity to bring others together to share what they know. Look for those individuals, support safe-space learning environments for group learning, and formally recognize the work of these groups in building an equitable and inviting learning environment at your institution.

3. Support Communities of Practice Focused on Creating Accessible Learning. Communities of Practice and other Employee Resource Groups (ERGs) are incredibly powerful when building, sharing, and sustaining practices and procedures that support accessible design. Odds are, there are people at your institution who are already paying close attention to these requirements and who would love the opportunity to bring others together to share what they know. Look for those individuals, support safe-space learning environments for group learning, and formally recognize the work of these groups in building an equitable and inviting learning environment at your institution.

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4. Talk About the Importance of Accessible Learning. In addition to the bottom-up strategy of supporting Communities of Practice, employ top-down strategies that include your most senior leaders talking about the importance of this work. Ensure you have proper funding in place to support the efforts, and provide the necessary talking points and senior leader educational moments to prepare your top leaders to share this message. For this work to be seen as important, make sure you are providing leaders with what they need so that they can model and champion the behaviors that you wish to see (and that the law now requires).

4. Talk About the Importance of Accessible Learning. In addition to the bottom-up strategy of supporting Communities of Practice, employ top-down strategies that include your most senior leaders talking about the importance of this work. Ensure you have proper funding in place to support the efforts, and provide the necessary talking points and senior leader educational moments to prepare your top leaders to share this message. For this work to be seen as important, make sure you are providing leaders with what they need so that they can model and champion the behaviors that you wish to see (and that the law now requires).

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5. Be An Organization Where Everyone Is Seen as a High-Potential Employee. As you work to build and fortify a culture of accessible learning at your institution, take a moment to ensure that you are also creating a workplace where everyone is seen as having the potential to succeed. When given the right support and placed in the right role, it’s my opinion that everyone can be successful. Create a learning and development culture within your institution that supports and rewards staff development and growth as visibly as it rewards any other career goal accomplishment.

5. Be An Organization Where Everyone Is Seen as a High-Potential Employee. As you work to build and fortify a culture of accessible learning at your institution, take a moment to ensure that you are also creating a workplace where everyone is seen as having the potential to succeed. When given the right support and placed in the right role, it’s my opinion that everyone can be successful. Create a learning and development culture within your institution that supports and rewards staff development and growth as visibly as it rewards any other career goal accomplishment.

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By employing these five actions, you can ensure that your institution is acting within the law and, more importantly, supporting the true spirit of a learning organization. Learning should not be available only to some; it should be readily accessible to every employee in your workforce ecosystem. By ensuring your learning assets are accessible, you will ensure no one is left out of your workforce readiness strategy.

By employing these five actions, you can ensure that your institution is acting within the law and, more importantly, supporting the true spirit of a learning organization. Learning should not be available only to some; it should be readily accessible to every employee in your workforce ecosystem. By ensuring your learning assets are accessible, you will ensure no one is left out of your workforce readiness strategy.

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Check out more accessibility resources below:

Check out more accessibility resources below:

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  Go Beyond a Checklist Mentality and Design for All Learners ( ATD Accidental Trainer

  Go Beyond a Checklist Mentality and Design for All Learners (ATD Accidental Trainer

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  podcast episode)

  podcast episode)

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  Designing for Inclusion: 6 Ways to Reach Everyone When You’re Presenting (Blog)

  Designing for Inclusion: 6 Ways to Reach Everyone When You’re Presenting (Blog)

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  Enhance Accessibility in Virtual Training Environments ( TD at Work guide; member benefit)

  Enhance Accessibility in Virtual Training Environments (TD at Work guide; member benefit)

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  Toolbox Tip: Check Accessibility in PowerPoint (video)

  Toolbox Tip: Check Accessibility in PowerPoint (video)

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  Toolbox Tip: Create Your Own Accessibility Checklist (video)

  Toolbox Tip: Create Your Own Accessibility Checklist (video)

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  Toolbox Tip: Test Keyboard Navigation (video)

  Toolbox Tip: Test Keyboard Navigation (video)

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