The Law Nobody Is Talking About: Will Your School Be at Legal Risk Come April?
In April, a federal accessibility rule begins to matter in a very real way for school districts. It does not arrive with a new test, a new funding formula, or a public announcement from state education agencies. Instead, it quietly changes what schools are expected to do every day online.
Many districts have not realized how broad this change is. Fewer still have planned for what happens if they fall short.
The rule affects how schools share documents, post assignments, communicate with families, and deliver instruction through digital systems. In practice, it touches nearly everything.
What Law Is Going Into Effect in April?
The ADA Title II Web Accessibility Rule
In March 2024, the U.S. Department of Justice finalized a rule under the Americans with Disabilities Act. It requires state and local governments, including public school districts, to ensure their digital content meets WCAG 2.1 AA accessibility standards.
This requirement applies to:
- Public school districts
- Charter schools operated by public entities
- State education agencies
- Any school system considered a state or local government entity
Private schools are generally not covered under Title II, though they may still have obligations under other parts of the ADA or state law.
This rule is not limited to district websites. It includes instructional materials, internal systems, and documents used to provide school services.
The full rule is available from the Department of Justice: DOJ Web Accessibility Rule – March 2024
For a broader explanation of how this rule fits into recent ADA updates, see the ADA compliance 2024 update.
When Do These Requirements Apply?
Why April Matters
The DOJ rule sets compliance timelines based on the size of the government entity. While exact deadlines vary, April marks the point when districts are expected to be actively addressing accessibility, not merely aware of the rule.
By April, districts should reasonably be able to show:
- That they understand which content is covered
- That they have identified accessibility gaps
- That they are taking steps to remediate issues
April is not about perfection. It is about preparedness.
Districts that cannot demonstrate progress face greater exposure if a complaint is filed.
More detail on timing is outlined in the WCAG compliance timeline for schools.
Why This Law Is Easy to Miss
It Did Not Come With a Checklist
Unlike many education regulations, this rule did not arrive with a single form or certification process. There is no checkbox that signals compliance.
Instead, it raises the baseline expectation for how schools operate digitally on an ongoing basis.
Common Assumptions That Are Incorrect
As a result, many districts assume:
- Accessibility only applies to public websites
- Internal systems are not covered
- Teacher-created materials are exempt
These assumptions are understandable. They are also incorrect. We explain why in WCAG exceptions for schools.
What Actually Creates Legal Risk for Schools
Accessibility Is Enforced Through Civil Rights Law
The ADA is a civil rights statute. Enforcement does not depend on intent or awareness. It depends on whether people with disabilities can access programs and services on equal terms.
If digital content is used to provide instruction, information, or school services, it is expected to be accessible.
The Content Most Districts Overlook
This includes:
- PDFs and handouts shared with students or families
- Google Docs and Slides used for instruction
- Learning management system content
- Forms, notices, and parent communications
In many districts, much of this content does not meet WCAG standards today. The downstream consequences are outlined in what happens if a school is not WCAG compliant.
What Happens When Districts Are Not Compliant
Complaints and Investigations
When accessibility issues arise, districts may face complaints filed with the Department of Justice or with the U.S. Department of Education's Office for Civil Rights.
These complaints can lead to formal investigations. Districts are often required to respond with documentation, timelines, and remediation plans.
Settlement Agreements and Consent Decrees
In some cases, investigations result in settlement agreements or consent decrees. These agreements typically require districts to:
- Remediate large volumes of digital content
- Meet strict timelines
- Report progress regularly
- Submit to ongoing monitoring
These requirements are often far more disruptive and expensive than proactive compliance.
Lawsuits Are Possible
While not every case leads to litigation, school districts can and do face lawsuits related to digital accessibility. Even when cases settle, districts often incur significant legal and operational costs.
Federal Funding Is Not Automatically Withheld, But Risk Increases
There is no automatic loss of federal funding for accessibility violations. However, unresolved civil rights findings can complicate compliance obligations and oversight relationships.
In practice, districts under investigation face heightened scrutiny and reduced flexibility.
A Common Misunderstanding About Complaints
Complaints Are Not the Trigger
Some districts assume risk begins only after a complaint is filed. In reality, the legal obligation exists regardless.
The practical difference is timing. Districts that act early retain control. Districts that act after a complaint often lose it.
Why Manual Fixes Fall Short
Training Alone Does Not Scale
A common response is to train staff or ask teachers to fix documents manually. This approach rarely works across an entire district.
Manual remediation is technical, inconsistent, and difficult to sustain when new content is created every day.
We examine this in detail in why manual accessibility remediation fails in school districts.
What Prepared Districts Are Doing Differently
Treating Accessibility as Infrastructure
Districts that reduce legal risk tend to:
- Handle accessibility at the district level
- Assume most instructional content is in scope
- Avoid asking teachers to interpret legal standards
- Put systems in place that address accessibility continuously
For districts just starting, Getting Started with WCAG offers a practical entry point.
Why This Is Not a Teaching Problem
Teachers Are Not Compliance Officers
Teachers create content quickly and constantly. Expecting them to manage technical accessibility standards introduces inconsistency and risk.
This challenge will intensify as expectations expand. We discuss this in new WCAG accessibility guidelines for teachers in 2026.
How ClearLinks Can Help
Reducing Risk Before It Becomes a Case
ClearLinks helps districts address accessibility before it becomes a legal issue. Our platform identifies and remediates accessibility issues across digital content, including documents and LMS materials, without placing the burden on teachers.
For document-level guidance, see document accessibility best practices.
Accessibility works best when it is routine and built into systems.
If you want to understand where your district stands before April, you can contact ClearLinks.