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Preparing for WCAG 2.1 AA Compliance: Vendor Guide
We greatly value the products and services your company provides to the State University
of New York at Stony Brook. A key factor in maintaining our relationship is ensuring
that your offerings meet the WCAG 2.1 AA standards for digital accessibility by April 24, 2026.
Given the extensive use of your products within our environment, we need to determine which products will comply with this requirement or if alternative solutions must be explored well in advance of the deadline. We are committed to achieving compliance with digital accessibility standards and ask for your assistance in this process.
Compliance Context
In Spring 2023, the U.S. Department of Justice (DOJ) and the U.S. Department of Health and Human Services (HHS) introduced new digital accessibility rules:
Given the extensive use of your products within our environment, we need to determine which products will comply with this requirement or if alternative solutions must be explored well in advance of the deadline. We are committed to achieving compliance with digital accessibility standards and ask for your assistance in this process.
Compliance Context
In Spring 2023, the U.S. Department of Justice (DOJ) and the U.S. Department of Health and Human Services (HHS) introduced new digital accessibility rules:
- DOJ rules under Title II of the ADA: Apply to all state and local government entities, including public higher education institutions, with a compliance deadline of April 24, 2026.
- HHS rules under Section 504 of the Rehabilitation Act: Apply to recipients of HHS funding, including most higher education institutions, with a compliance deadline of May 11, 2026.
These rules require full compliance with WCAG 2.1 AA standards across all web content, mobile apps, and kiosks, including systems used
internally by employees or accessed via login. Like many of our peers, Stony Brook
University is subject to both sets of rules. While these requirements do not directly
mandate compliance from third-party vendors, we may not be able to continue to use
non-compliant third-party products and services, as we will be held accountable for
the accessibility of all licensed systems and services under the new regulations.
Action Requested
We hope your company will bring its products and services into full compliance with WCAG 2.1 AA standards before the April 2026 deadline, enabling us to continue our valued partnership. To assist in this effort, we recommend the following steps:
Action Requested
We hope your company will bring its products and services into full compliance with WCAG 2.1 AA standards before the April 2026 deadline, enabling us to continue our valued partnership. To assist in this effort, we recommend the following steps:
- Prepare a WCAG 2.1 AA or WCAG 2.2 AA Accessibility Conformance Report (ACR) in 2025 for all web, mobile, and kiosk systems we use. Using the latest VPAT format is preferred, and third-party ACRs are strongly encouraged.
- Address compliance gaps by prioritizing remediation efforts to align your systems with WCAG 2.1 AA standards by April 24, 2026.
- Develop a remediation plan for any outstanding WCAG 2.1 AA issues, with clear timelines for resolution before the compliance deadline.
- Prepare to provide the following documentation during upcoming contract renewals or upon request:
- Your latest Accessibility Conformance Report.
- Remediation plans addressing any WCAG 2.1 AA gaps.
- Responses to all HECVAT 3.06 accessibility questions (ITAC-01 to ITAC-09). - Consult resources such as the Big Ten Academic Alliance's Digital Accessibility Vendor Cookbook.
Next Steps
Upon renewal and/or any new procurement with our institution, we expect that the above-referenced steps will have been completed. This will help us determine our path forward and ensure compliance with federal requirements.
Thank you for your attention to this important matter.
Upon renewal and/or any new procurement with our institution, we expect that the above-referenced steps will have been completed. This will help us determine our path forward and ensure compliance with federal requirements.
Thank you for your attention to this important matter.