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The University of New Mexico

ADA Title II Digital Accessibility compliance

Guidelines for Faculty and Staff, Department of Mathematics and Statistics, University of New Mexico.

Prepared by Title II Committee: Erica Dinkins (chair), Janet Vassilev, and Erik Erhardt.
Updated September 14, 2026

In April 2024, the Department of Justice issued a final rule under Title II of the Americans with Disabilities Act [1]. The rule sets an enforceable technical standard for the web content and mobile apps of public entities, and public universities are public entities. UNM holds the legal obligation, but faculty and staff create the content, so compliance happens in our documents, courses, and pages. This page cites the requirements, states what we must comply with, and gives strategies for meeting the standard. The appendix works through special cases that matter in a mathematics and statistics department.

1. What the rule requires, with citations

  1. Legal basis. DOJ final rule, Nondiscrimination on the Basis of Disability; Accessibility of Web Information and Services of State and Local Government Entities, 89 FR 31320 (April 24, 2024), codified at 28 CFR Part 35, Subpart H [1, 2].
  2. Technical standard. All web content and mobile apps that we provide or make available must conform to Web Content Accessibility Guidelines WCAG 2.1, Level AA (28 CFR 35.200(b)) [2, 4]. The current W3C recommendation is WCAG 2.2 (October 2023), which keeps the 2.1 success criteria, drops only the obsolete parsing criterion, and adds nine more; the rule still cites 2.1, so author new material to WCAG 2.2 AA and you meet the requirement with room to spare [12].
  3. Deadline. April 26, 2027 for UNM main campus. A DOJ interim final rule of April 20, 2026 extended the original April 24, 2026 date by one year (91 FR 20902). UNM branch campuses have until April 26, 2028 [3, 8].
  4. Scope. The rule covers public content and course content alike. This includes the department website, Canvas courses, syllabi, lecture notes, problem sets, electronically distributed exams, slides, recorded lectures, and content we post on outside platforms such as YouTube. Password protection does not exempt course materials. The only password-related exception covers individualized documents about a specific person, property, or account, such as a student bill (28 CFR 35.201) [1, 2].
  5. Exceptions, all narrow (28 CFR 35.201). Content archived in a designated archive area and left unmodified; conventional electronic documents (Word, PowerPoint, PDF, spreadsheet files) posted before the deadline, unless people currently use them to apply for, access, or participate in our services; third-party content we did not arrange by contract; and preexisting social media posts. An old PDF loses its exception the moment you assign it in a current course [1, 2].
  6. Continuing duties. Even for excepted content, we must provide effective communication and an accessible version on request (28 CFR 35.160). Claims of fundamental alteration or undue burden require a written determination by the head of the university, not by an instructor or a department (28 CFR 35.204) [1, 2].

2. What WCAG 2.1 AA means in daily work

  1. Use real heading styles rather than bold text.
  2. Give every meaningful image alt text.
  3. Write link text that describes the destination.
  4. Keep sufficient color contrast, and never use color as the only way to convey information.
  5. Use tables for data only, with header rows.
  6. Caption videos and provide transcripts for audio.
  7. Post searchable text, never scanned page images.
  8. Make sure pages and documents work with a keyboard and a screen reader.
  9. Typeset mathematics so it carries structure; a screen reader cannot read a picture of a formula, and alt text cannot convey mathematical structure, so math must reach the reader as MathML [5, 6].

These practices track the WCAG 2.1 AA success criteria [4], and UNM CTL publishes a short guide on each practice [8]. WCAG 2.2 adds six A and AA criteria that mostly affect interactive pages: a minimum size for click and touch targets, help in a consistent place, alternatives to dragging, accessible sign-in, keyboard focus that is not hidden behind other content, and not forcing people to retype information they already gave [12].

3. Strategies for faculty and staff

  1. Start with new material and active courses. Create everything accessible from now on. Then remediate documents in current use, since those enjoy no exception [1]. Move retired content into a proper archive.
  2. Prefer HTML over PDF where practical. The AMS identifies HTML as the best target for digital mathematics [5]. Canvas pages, PreTeXt, LaTeXML, Quarto, and pandoc all produce accessible HTML, and MathJax and the Canvas equation editor render math with an accessible MathML layer.
  3. Produce tagged PDFs from LaTeX. Switch the compiler to LuaLaTeX, use TeX Live 2025 or later, and turn on tagging [6]. Appendix item A4 (below) gives the code.
  4. Use the checkers built into Word and PowerPoint. Apply styles for headings and lists, run the Accessibility Checker before posting, and enter equations with the equation editor rather than pasting images [8].
  5. Remediate PDFs in Adobe Acrobat Pro, available through the UNM Software Store. Run its accessibility checker (found in tools below), add tags and alt text, and OCR any scanned text. Validate tagged PDFs with veraPDF or ngPDF [6].
  6. Correct your captions. Automatic captioning mangles mathematical speech, so edit captions on recorded lectures before publishing them [8].
  7. Use UNM support. CTL offers the self-paced course Charting a Path to Accessible Digital Content, plus a Deque University training pilot. Write ctl@unm.edu, read the CTL digital accessibility standards, and watch accessibility.unm.edu as it grows. A university digital accessibility policy is in development [8, 9].

Appendix A. Tools and Special cases with example solutions

Mathematics and statistics work creates accessibility problems that generic university guidance does not address. Each item below names a case and a possible solution.

A1. Handwritten and scanned material

  • Scanned handwritten notes and solution keys fail the standard, and OCR does not reliably handle mathematical notation. Retype the material in LaTeX, Quarto, or Word with the equation editor [5]. Treat scanning plus manual tagging in Acrobat as a last resort for text without math.

A2. Website checkers

A3. PDF checkers

  • Adobe Acrobat Pro help
    • Under: Tools (view more), Accessibility, Assess for Accessibility. Can ask failing results for an "explanation" with a right-click.

A4. LaTeX documents (notes, homework, exams)

  • Compile with LuaLaTeX under TeX Live 2025 or later.
  • You need to designate a title for the pdf, which can be done with the following code:
\usepackage{hyperref}
\hypersetup{
    pdflang={en-US},
    pdftitle={title},
    pdfauthor={author},
    pdfsubject={Mathematics},
    }
  • Add this block as the first lines of the file, before \documentclass. This produces a tagged PDF (PDF/UA-2) with MathML generated from your source.
\DocumentMetadata{tagging=on,
    tagging-setup={math/setup=mathml-SE},
    pdfstandard=ua-2,
    lang=en-US
    }
  • Expect new compilation errors the first time; most come from incompatible packages, so check the LaTeX Tagging Project compatibility list [7, LaTeX Tagging Project package compatibility status] and adjust your preamble once per course.
  • One common compilation issue is needing to add an extra line after environments such as after \end{enumerate}.
  • Load unicode-math (\usepackage{unicode-math} in the preamble) so symbols carry meaning rather than appearance.
  • Give every figure alt text, for example \includegraphics[alt={Histogram of residuals, symmetric around zero}]{fig1.pdf} [6].

A5. Beamer slides

  • Beamer does not yet support tagging. Until it does, also post an accessible companion, either the same source compiled in article mode (beamerarticle) with the tagging block above in A4, or typed notes in HTML. The ltx-talk class, built for tagging under TeX Live 2026, is the replacement to watch [6, 7].

A6. Quarto and R Markdown figures

  • Every figure needs alternative text, and the two systems use different syntax.
  • In Quarto, give fig-alt as a hash pipe option inside the chunk [10].
```{r}
#| fig-cap: "Fuel economy falls as vehicle weight rises."
#| fig-alt: "Scatterplot of 32 cars. MPG falls from 34 to 10 as
#|   weight rises. Cylinder groups differ by color and shape."
ggplot(mtcars, aes(wt, mpg, color = factor(cyl), shape = factor(cyl))) +
  geom_point(size = 3) + scale_color_viridis_d()
```
  • In R Markdown, fig.alt goes in the chunk header, which must stay on one line; when fig.alt is absent, knitr reuses fig.cap as the alt text in HTML output [11].
```{r mpg-plot, fig.cap = "Fuel economy falls as vehicle weight rises.", fig.alt = "Scatterplot of 32 cars; MPG falls as weight rises; cylinder groups differ by color and shape."}
ggplot(mtcars, aes(wt, mpg, color = factor(cyl), shape = factor(cyl))) +
  geom_point(size = 3) + scale_color_viridis_d()
```
  • Caption text and alt text serve different readers; the caption interprets, the alt text describes what the plot shows. Render to HTML where possible so mathematics becomes MathML through MathJax.

A7. Plots must not identify groups by color alone

  • Pair color with a second encoding, such as shape, linetype, or direct labels, as in the example in A6.
  • Use a colorblind safe palette, viridis (scale_color_viridis_d() in ggplot2) or Okabe Ito (palette.colors(palette = "Okabe-Ito") in base R).
  • Keep text in figures large enough to read and check contrast against the background [4].
  • Relatedly, the AMS published a notice for "Making Accessible Documents Using LaTeX".

A8. Recorded lectures with math

  • Automatic captions garble spoken mathematics, writing "x2" for "x squared". Edit captions before publishing, and post typed notes covering the board work alongside the recording [8].

A9. Publisher platforms and third-party tools

  • WebAssign, publisher homework systems, and similar tools we adopt by contract carry our compliance obligation; the third-party exception does not cover them [1, 2]. Before adopting a tool, request the vendor accessibility conformance report (an ACR, often called a VPAT) and prefer tools that output MathML.

Sources

  1. ADA.gov fact sheet on the web and mobile app accessibility rule (Department of Justice)
  2. 28 CFR Part 35, Subpart H, current codified text (eCFR). Final rule at 89 FR 31320.
  3. Interim final rule extending the compliance dates, 91 FR 20902 (Federal Register, April 20, 2026)
  4. WCAG 2.1 quick reference (W3C)
  5. AMS accessibility guidance for mathematicians (American Mathematical Society)
  6. Creating accessible PDFs in LaTeX (Overleaf documentation)
  7. LaTeX Tagging Project package compatibility status (LaTeX Project)
  8. UNM CTL digital accessibility standards and training (Center for Teaching and Learning)
  9. UNM departments work to support Title II compliance (UNM Newsroom)
  10. Quarto cell options for figures, including fig-alt (Quarto documentation)
  11. knitr chunk options, including fig.alt (knitr documentation)
  12. What's New in WCAG 2.2 (W3C)