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Social media content under ADA Title II

Social media is in scope. Content posted by the public entity is web content the entity makes available. Platform-level constraints affect how the entity complies, not whether.

By Levi Whitted Last reviewed: Published:

Why social media counts

Content a public entity posts on social media is content the entity makes available to the public. Under 28 CFR Part 35 Subpart H, that brings it within the scope of the rule on the same terms as other web content the entity provides (Source: 28 CFR Part 35, Subpart H ) .

CCCCO Memo ESS 26-17 makes this explicit for California community college districts by naming social media in the list of in-scope content alongside websites, LMS, email, and documents (Source: CCCCO Memo ESS 26-17, February 27, 2026 ) .

The fact that the platform is operated by a third party (Meta, X, LinkedIn, YouTube, TikTok) does not change the analysis. The entity is using the platform to make content available; the content remains the entity's responsibility.

What social media content is covered

Coverage attaches to content the entity posts, including:

  • Image posts: photos, graphics, infographics, flyers shared as images
  • Video posts: announcements, event recordings, public meeting streams, training videos
  • Text posts: announcements, notices, updates, threads
  • Linked content: documents, web pages, and other materials shared via post
  • Live content: live streams of meetings, events, or announcements (with retained recordings)
  • Story and ephemeral posts where retained or otherwise made persistent

Coverage does not attach to comments posted by the public. The entity is not responsible for accessibility of third-party speech in its replies and mentions. The entity is responsible for its own posts and for content it shares or amplifies.

Practical accessibility challenges

Several recurring issues come up when applying WCAG 2.1 AA criteria to social media:

Images of text

Social media culture favors graphic flyers and image-based announcements. A flyer image with the date, time, location, and topic of an event embedded in the graphic is unreadable to screen reader users. The fix is alt text that captures all of the embedded information, or a text version of the content in the post body.

Captions on video

Auto-generated captions on most platforms are inconsistent in quality and frequently wrong on names, technical terms, and proper nouns. Live streams especially: auto-captioning on a live board meeting often misidentifies speakers and produces unusable transcripts. Human-reviewed captions are the workable baseline.

Alt text

Most platforms support alt text on images, but the feature is often hidden in the posting workflow and is not used by default. Without an institutional practice, posts go out without alt text by default.

Color contrast in graphics

Social media graphics produced by marketing teams or contractors often have poor text contrast against background images, gradient overlays, or brand-color combinations that fail WCAG 2.1 AA's 4.5:1 ratio for normal text.

Threaded text

Long announcements broken into threaded posts can be hard to read sequentially on assistive technology. A web page link with the full announcement is typically more accessible than a long thread.

Posting practices public entities need

A defensible posting practice typically includes:

  1. Alt text on every image. A short institutional rule, applied to every post. Image-of-text flyers need alt text that includes the full text of the image.
  2. Human-reviewed captions on every video. Either captions produced by the authoring tool with human review, or third-party captioning service for substantial content.
  3. Text version of substantive content in the post body. When the post is a flyer, an infographic, or a graphic, the post text itself should contain the substance (date, location, what is happening). This protects against alt-text omissions and serves users who do not access the image.
  4. Plain-language post text. Avoid stylized text alternatives (decorative Unicode characters, all-caps marketing text) that assistive technology mishandles.
  5. Link to accessible source. When a post points users at a document or page, that destination needs to be accessible. Posting an inaccessible PDF is not made acceptable by posting it through social media.
  6. Hashtag formatting. Use CamelCase in multi-word hashtags (#OpenHouse2026, not #openhouse2026). Screen readers parse CamelCase as separate words.

Platform limits and residual risk

Some accessibility issues are platform-level and not reachable through entity practice. Examples:

  • A platform's player UI fails keyboard navigation
  • A platform does not surface alt text reliably to assistive technology
  • A platform's auto-generated captions cannot be replaced
  • A platform's interface itself has color contrast or screen reader navigation failures

These are vendor-side failures, not entity authoring choices. The entity cannot directly remediate them. The entity can:

  • Document the known limitations as part of the accessibility statement
  • Provide accessible alternatives (a link to a web page version of the post, a transcript of a video) where the platform falls short
  • Choose platforms that have better accessibility track records for new initiatives
  • Report accessibility issues to the platform as part of the entity's compliance posture