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ACA for education: requirements, priorities, and audit checklist

ACA compliance for education and edtech requires applying Accessible Canada Act to the specific failure points typical of the education industry — including inaccessible pdf readings and lecture slides, live lectures without real-time captions, proctoring software incompatible with assistive tech.

Kai Schmidt · IAAP CPACC · Document accessibility specialist (PDF/UA-1)3 min readPublished · Updated

Does ACA apply to education and edtech?

The Accessible Canada Act (ACA, 2019) requires federally regulated entities — federal government, banks, telecom, broadcasting, transportation — to identify, remove and prevent accessibility barriers, with the explicit goal of "a Canada without barriers by 2040" and detailed regulations layered on top including the ICT regulations referencing EN 301 549.

Education accessibility — the lay of the land

Universities, K-12 districts, and edtech vendors are subject to overlapping accessibility law: Section 504 (federal funding), ADA Title II (state institutions), DOJ April 2024 rule (state/local entities including public universities), and FERPA (which constrains certain accessibility solutions). The DOJ rule requires WCAG 2.1 AA conformance with compliance staggered through 2026–2027.

Where ACA bites hardest in education and edtech

• Inaccessible PDF readings and lecture slides

• Live lectures without real-time captions

• Proctoring software incompatible with assistive tech

• Math content as images rather than MathML

• Inaccessible assessment platforms

Remediation priorities

• LMS core (Canvas, Blackboard, Moodle)

• Lecture video (captions, transcripts)

• Assessment platforms and proctoring

• PDF documents and course readings

• Student services portals

How to comply with ACA on a Education site

1. Publish an accessibility plan: Every federally regulated entity must publish a multi-year accessibility plan, updated every three years.

2. Establish a feedback mechanism: Accept and respond to accessibility complaints.

3. File progress reports: Annual progress report between plans.

4. Meet technical ICT requirements: Reference EN 301 549 for digital products and services.

Sources

FAQ

Frequently asked questions

Cited answers. Sourced. Updated as standards and case law change.

  • Does ACA apply to education websites?

    The Accessible Canada Act (ACA, 2019) requires federally regulated entities — federal government, banks, telecom, broadcasting, transportation — to identify, remove and prevent accessibility barriers, with the explicit goal of "a Canada without barriers by 2040" and detailed regulations layered on top including the ICT regulations referencing EN 301 549.

  • What are the most common ACA failures in education and edtech?

    Inaccessible PDF readings and lecture slides Live lectures without real-time captions Proctoring software incompatible with assistive tech

  • What conformance level should a education site target?

    WCAG 2.2 Level AA is the consensus target for legal compliance and the level referenced by virtually every national accessibility law.

  • Does the DOJ April 2024 Title II rule apply to public universities?

    Yes. Public universities and community colleges are state or local government entities under Title II of the ADA. The April 2024 final rule requires WCAG 2.1 AA conformance, with compliance dates of April 2026 (large entities, >50K residents) or April 2027 (smaller).

  • Do private universities have the same accessibility obligations?

    Private universities are typically covered by ADA Title III (public accommodations) and Section 504 if they receive federal financial assistance — which nearly all do. The functional standard is the same: WCAG 2.1/2.2 AA conformance.

  • Are lecture captions required?

    Live audio captioning is required under WCAG 1.2.4 and reinforced by Section 504 and Title II. Auto-generated captions alone often fail to meet accuracy thresholds; institutions are increasingly investing in human-corrected or hybrid captioning.

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