Recommendations for Repository Content Accessibility

Title II of the Americans with Disabilities Act requires state and local governments, including public schools, community colleges, and public universities, to make sure that their services, programs, and activities are accessible to people with disabilities, including those offered online and through mobile apps. The original deadline for compliance for most public institutions of higher education was April 24, 2026; however, the Department of Justice delayed the implementation deadline by one year, to April 26, 2027.  

Libraries must take action to ensure that materials they publish in their TDL-hosted institutional repositories are fully accessible in order to comply with the law. However, as the American Library Association points out in its guidance on ADA Title II, these regulations “represent more than just legal compliance; they embody our profession’s commitment to ensuring everyone can access and benefit from our collections, services, and spaces.” 

Because many institutions have spent years building repository collections prior to the rule’s implementation, the scale of necessary remediation to ensure accessibility of legacy materials may be quite large. The recommendations below, drafted by the TDL Repository Content Accessibility Working Group, are intended to provide some realistic guidance in planning, prioritizing, and executing on this important work as we collectively strive to realize the promise of Open Access for all users. These recommendations are not legal guidance, and we strongly recommend that libraries and repository managers consult with their institution’s legal counsel and accessibility offices as they make plans to comply with the new rule.

#1 - Don’t go it alone.

• Consult your institutional accessibility office, Office of General Counsel, and others on campus who can guide library and repository policy. Follow your institution’s guidance.

• Rely on guidance from professional organizations such as the American Library Association’s New ADA Rules Explained to help understand how the rule applies to library content, and how the exceptions included in the rule may help you prioritize remediation work. 

• Take advantage of the Texas Digital Library community of repository managers and their experience. The TDL DSpace Users Group, through its Repository Content Accessibility Working Group has developed a Toolkit and Resource Library to help guide your efforts. The DUG also meets monthly and maintains a listserv where you can ask questions and learn about other institutions’ plans and ideas.

#2 - Document a policy and a plan.

• Develop an accessibility policy for your repository, including requirements for depositors. If you use TDL hosting, TDL can work with you to link this from your repository.

• Have a documented plan for achieving full accessibility for your repository. The plan should include the steps you will take to assess, prioritize, and execute on the goal of full accessibility of content, both in terms of new content deposited to the repository and existing files.  One common framework for accessibility prioritization is the “3Rs Framework,” which breaks actions into three categories and may be a useful way to structure your planning documentation: 

  • REMOVE. Remove or restrict content you do not need to share. 

  • REVISE. Revise any existing digital content that needs to be shared.

  • RIGHT FIRST. Create new content that is accessibility compliant.

• Consult the TDL Repository Accessibility Resource Library for some examples of policies and plans submitted by member institution libraries.

#3 - Prioritize compliance for newly deposited content.

• New content added to the repository on or after the Title II implementation deadline should meet accessibility guidelines, if it is to be made publicly available and does not fall under any of the exceptions of Title II.

  • Workflows going forward should include steps for assessing, rejecting, and/or remediating files before they are published in the repository.

  • Consider your own capacity and your institution’s risk tolerance when determining workflows. Some institutions have opted to move to fully mediated deposit (that is, no self-deposit) and introduce review workflows. (See Mediated Deposit: Phase 1 Policy & Communication for an example from Texas A&M Libraries.) 

    • For information about using review workflows in DSpace, see TDL’s Digital Repositories documentation.

  • Consider updating your default deposit license to require depositor affirmation that files meet accessibility guidelines. Users of TDL-hosted DSpace repositories may request changes to their default deposit license by contacting the TDL Helpdesk (support@tdl.org). Two examples of relevant deposit license language are below:

    • "You represent that your submission complies with [INSTITUTION] policy 10.102 Digital Publishing, with regard to accessibility of electronic information resources." 

    • “As the submitter of this item, I certify that it meets the minimum accessibility requirements required for submission to [REPOSITORY NAME]. I also certify that I may be required to remediate my item if it does not meet minimum accessibility requirements." 

  • If your institution deposits digitized content into your DSpace repository, ensure that the digitization workflows produce accessible documents by using techniques such as OCR, captioning, transcription, and/or detailed image descriptions. 

#4 - Assess and prioritize needs for remediation or restriction of existing content.

• Develop a plan for remediating or restricting existing content deposited (and last revised) prior to the implementation deadline. 

  • Inventory repository collections and determine necessary actions and priorities. Determine if any Collections meet exceptions under Title II (Please consult the ALA guidance and your campus general counsel and/or accessibility coordinator.) 

  • Some institutions have attempted to leverage the “archive” exception by restructuring repository collections to put old and static collections into Communities and/or Collections labeled as an “Archive.” 

  • Prioritize remaining collections for remediation based on usage and ease of remediation. Highly visible, highly downloaded items and Collections should be addressed early. Collections that can be remediated quickly (i.e. “low hanging fruit”) could also be prioritized.

  • Consider the following in your plan: 

    • Which collections are highest priority? 

    • Whose job is it to undertake the remediation? 

    • How much time can realistically be allocated to it? 

    • Which collections will require greater time and effort? Image-only PDFs, for example, may involve more detailed processing.

    • How can users request accommodation if needed in the meantime? 

    • What resources does the library have access to for this work? E.g., can the library procure licenses that students/faculty can use for remediation?

• Document workflows for providing alternate or individualized access to inaccessible materials. Note that Title II requires all materials to be immediately accessible; therefore this does not comply with the rule, but may be a reasonable interim step towards full compliance. Two options for soliciting requests for alternate access in a TDL-hosted DSpace repository are described below:

  • Add an accessibility statement to the HTML template of the Simple Item view of every item. The same statement would appear for every item across the repository.  For users of TDL DSpace hosting, contact the Helpdesk (support@tdl.org) to request this addition. An example is shown below. 

    Open

    

  • Alternatively, you may accomplish this by choosing a metadata field to include an accessibility statement for each item. You can achieve this through the DSpace admin interface by using an existing field, or creating the metadata field in the Metadata Registry, and then adding the values individually or via batch metadata editing. If you wish this field/value pair to appear on the Simple Item view, contact the TDL Helpdesk to make that request.

• Consult the TDL Repository Accessibility Toolkit for more resources on making PDFs and other file types accessible.

#5 - Communicate with stakeholders.

• Communication with repository stakeholders about accessibility requirements – as well as any changes to deposit workflows or new access restrictions – is crucial. New repository policies should be communicated to all stakeholder groups, including Community/Collection administrators across campus, library repository managers, and any depositors. Additionally, training materials, including those for student depositors, should be updated to include steps to ensure accessibility. 

• Collections of theses and dissertations are significant components of most institutional repositories. Communication with graduate colleges or directly with students about requirements for accessibility is an important component of any accessibility plan.

  • Some institutions have incorporated “Accessibility for ETDs” workshops into their instruction. See UH Thesis & Dissertation Information for an example.

  • For TDL members, ETDs may be published to DSpace via Vireo. The Vireo Users Group has developed a one-sheet to share with your graduate college about ADA requirements for accessibility.