How to Use OCR Resolution Agreements in Accessibility Planning

Office for Civil Rights resolution agreements record commitments made to resolve particular investigations. They can help institutions think about coordination, audits, training and remediation, but the signed terms apply to the parties and circumstances described in each agreement.

Read the actual agreement

Use the Department of Education's resolution records to locate primary documents. Check the institution, docket, date, applicable statutes, technical standard, content scope, deadlines and reporting requirements. Read the agreement alongside its letter or findings where available.

Do not repeat a quotation or docket attribution until it has been checked against the signed source. This article does not establish a comprehensive review of all OCR agreements or reproduce unverified settlement language.

Separate three questions

• What obligation comes from the applicable law and regulation?
• What additional commitments appear in this specific agreement?
• What governance practice would help our institution address its own barriers?

A named coordinator, regular audits or a written action plan can be useful program choices. Their presence in one agreement does not make the exact same structure a universal statutory requirement. Nor does the absence of a scanner score mean substantive accessibility or technical standards no longer matter.

Turn relevant examples into operational work

Inventory the content and interactions students need. Assign owners, define evaluation methods, retain findings and record corrective actions. Include a timely route for students to report barriers and obtain support. Use qualified manual and assistive-technology checks where automated tools cannot establish the outcome.

For a vendor evaluation, ask which content it can assess, whether it changes the source or supplies an alternative, what saved outputs can be inspected, and what unresolved work remains. Request evidence exports appropriate to your records process. A dashboard or audit trail alone does not guarantee compliance or a successful response to a complaint.

The DOJ Title II rule sets WCAG 2.1 Level AA requirements for covered state and local government web content and mobile apps, subject to the rule's scope and exceptions. The April 2026 IFR extends the dates to April 26, 2027 for public entities with a population of 50,000 or more and April 26, 2028 for smaller public entities and special district governments. Determine the institution's cohort using DOJ's population rules; enrollment and federal funding alone do not determine it. Existing accessibility obligations continue before those dates.

The new dates concern the DOJ Title II rule. OCR's Section 504 responsibilities and a particular resolution agreement require their own assessment. Counsel should determine which obligations and case-specific terms apply; a marketing article cannot establish a regulator's exclusive evidentiary test.

Further reading

These links provide additional context; each source should be assessed for its own scope.

Resource 1: www2.ed.gov

AI-Assisted University Accessibility: Review, Evidence and Legal Scope

Resource 3: www.ed.gov

Resource 4: www.ed.gov

Resource 5: www.ed.gov

Resource 6: www.ed.gov

Resource 7: www.ed.gov

Accessibility Compliance After the Deadline: Ongoing Obligations for Universities