Advocating for Title II Compliance

Compliance with Title II by institutional repositories may require additional staffing, money, and changes to processes and workflows. This section provides framing and potential talking points to help you confidently communicate what meaningful accessibility compliance requires with stakeholders, particularly library administration. 

Why Title II Matters 

• Under ADA Title II, accessibility compliance for Institutional Repository (DSpace) is no longer optional. Institutions like ours are required to ensure our digital content is accessible to everyone. 

• While we may not be fully compliant by the April 2026 deadline, we should have a documented plan, assigned responsibility, and demonstrated good faith efforts to avoid litigation and reduce risk in a responsible way. 

Legal & Institutional Context

• DSpace repositories may not qualify as ‘archives’ under ADA exceptions. Please see Exceptions and Institutional Repositories for further details.

• Consult and follow the guidance of your institution’s general counsel.

  • Each institution’s risk profile is different.

  • Policies around remediation scope, prioritization, and timelines should align with your library, institution, and legal guidance.

Collaboration

• Everybody needs to be on board.

• Repository teams likely cannot fix accessibility alone.

• Success depends on shared responsibility across departments (libraries, grad schools, faculty/content creators, IT, administration, etc).

• Accessibility is an ongoing program that involves everyone at the library: both forward-looking and retrospective.

  • Forward-looking -> Prevention

    • Clear guidance and relevant education is provided to content creators.

    • New submissions meet accessibility standards at deposit.

    • Accessibility checks are added into library workflows.

  • Retrospective -> Remediation

    • Clear responsibility of staffing, funding, and capacity.

    • A prioritization strategy.

Staffing and Resources

• Accessibility work requires people and time, good intentions aren’t enough. This work cannot be classed as 'extra duties' indefinitely. 

  • Without staffing, compliance efforts are unsustainable.

  • Burnout and inconsistent workflow increase institutional risk.

• Accessibility remediation has real costs (e.g., staff time, specialized training, third party applications). 

  • Funding support is essential if: 

    • We expect repositories to accept content

    • We expect all content to be accessible.

    • We expect to remediate content.

    • We expect our staff to meet compliance expectations.

Outreach and Shared Responsibility

• Content creators (faculty/staff, students, and departments) must be part of the solution.

• Clear expectations and practical guidance are shared in public-facing webpages (e.g., library/institutional website, LibGuides, Wiki page, etc.).

• Early outreach reduces confusion and resistance: ‘Accessibility practice is for quality, inclusion, sustainability - not punishment!’

Engaging with Decision-makers

• Clear leadership direction helps set expectations. Questions to consider and answer:

  • What standards are we enforcing?

  • What tools are we using?

  • What content must meet the standards?

  • What happens when content doesn’t?

• Understand Decision-maker readiness

  • Their familiarity level with ADA Title II, how it applies to IR, the risks.

  • The accessibility compliance realistically entails (e.g., scope, time, cost, staffing, workflow)

  • Their priorities and concerns (short term v.s. long term).

  • Realistic expectations of existing staff and resources to address the large scope of the problem area.

• Ask for leadership support:

  • Help identify and connect the right stakeholders (General counsel/compliance, UIT, disability services, grad school/academic affairs, faculty/staff, students, etc.)

  • Support on transparent communication with stakeholders

  • Support cross-unit convening and align on communication expectations

  • Highlight accessibility is an institutional priority

  • Align repository policies with legal counsel guidance

  • Support and approval on staffing, funding, workflows, and third party services.

  • Willingness to advocate for necessary resources to address the large scope of the problem area.