Skip to main content
wcag21aa.org

Social media under the Title II web rule

Source-backed explanations and practical guidance. Educational information, not a legal determination.

By Sonoma Solutions Last reviewed: Published:

Public-entity posts and the date exception

The Americans with Disabilities Act (ADA) Title II web rule addresses a public entity’s social media content. Section 35.201(e) excepts its social media posts made before the applicable compliance date from § 35.200. New posts after that date do not qualify for this particular exception. DOJ explains the social media exception.

Separate posts, linked content, and public comments

Review text, images, audio, video, and linked destinations. An old post does not automatically exempt a newly published document linked from it. An unaffiliated person’s comment may require analysis under the separate third-party-posting exception; posting under an arrangement with the entity is treated differently. Review § 35.201(c).

Apply requirements to the actual media

Informative images need an appropriate text alternative. Prefer real text for announcements instead of putting all essential information in a flyer image; an image’s alternative must serve its purpose in context. W3C’s images tutorial explains informative, decorative, and complex-image cases.

For media, distinguish prerecorded/live and audio-only/video-only/synchronized content. Captions, descriptions, and transcripts serve different needs; one is not universally a substitute for another. W3C’s audio/video guidance helps select the applicable requirements.

A suggested publishing check

  1. Include essential announcement information as readable text.
  2. Check image alternatives and the accessibility of any linked destination.
  3. Review caption accuracy and the need for audio description or other media alternatives.
  4. Check text contrast and avoid relying on color alone.
  5. Test the published result with keyboard and assistive technology where relevant.

This is workflow guidance, not a complete WCAG checklist or an assurance that a particular platform conforms.

Platform limits do not create an automatic safe harbor

Record barriers, raise them with the provider, assess other delivery options, and maintain an effective way to get assistance. A good-faith effort, a transcript, or a link elsewhere does not automatically satisfy every requirement. Evaluate conforming alternate versions, equivalent facilitation, or other provisions on their actual terms.

Even for excepted older posts, DOJ says effective communication, reasonable modifications, and equal opportunity obligations continue. Read the continuing obligations.