Guest Editorial

Preparing for the ADA Title II Clarification: A Call to Cultural Change in Virtual Reference

Thomas Gerrish and Katie Gibson*

In April 2026, the Department of Justice’s clarification of Title II of the Americans with Disabilities Act (ADA) will take effect, defining accessibility requirements for the web and mobile services of public institutions, including academic libraries (U.S. Department of Justice, 2024). These updates formalize expectations that library websites, chat services, and other digital platforms meet Web Content Accessibility Guidelines (WCAG) 2.1 AA standards (World Wide Web Consortium, 2025), which is a necessary threshold many academic libraries have yet to reach. As the deadline approaches, conversations among our colleagues have increasingly centered on the urgency of compliance. However, as librarians with expertise in accessibility, we contend that the pressing problem that comes with these requirements is not timelines or technical remediation—the deeper issue is cultural. We encourage libraries to move away from approaching accessibility as a reactive process by responding to audits, complaints, and deadlines; rather we encourage colleagues to embed it as a proactive, ongoing value in our work.

Accessibility is not a separate compliance task; it is a core component of service design, user experience, and digital stewardship. Drawing on our complementary experience in online reference and accessibility, we approach these changes with the goal of providing accessible reference services that meet the needs of all our users. Because virtual reference sits at the intersection of human interaction and technology, it is an ideal place to begin promoting a culture of accessibility in academic libraries. In our experience, waiting until issues arise requires more time and labor to remediate documents, provide accessible databases, etc., than it would if accessibility had been considered from the start. More importantly, it limits who can fully participate in academic life. We contend that a proactive culture requires intentional planning, distributed responsibility, and leadership that prioritizes inclusion and accessibility in every decision about library systems and services.

We argue that this moment offers libraries an opportunity to move beyond compliance by moving toward cultural transformation. The approaching deadline should not be seen just as a mandate to meet but as the impetus for reimagining how accessibility is integrated into daily practice within academic libraries. Building a proactive culture means that accessibility is not just the work of designated specialists or coordinators: it is everyone’s job. As one of the most visible digital touchpoints of the library, virtual reference can lead the way. By starting here, libraries can then work toward embedding accessibility into other design processes, training, and evaluation cycles to become more inclusive while also ensuring that our services reflect our values as library professionals.

What Is the ADA Title II Update?

In 2024, the U.S. Department of Justice issued an update to Title II of the ADA, extending accessibility requirements to all digital services offered by state and local governments, including public colleges and universities. The ruling mandates that online platforms—such as virtual reference tools, research databases, and instructional media—meet WCAG 2.1 AA standards by April 1, 2026, for institutions serving populations of 50,000 or more, and by 2027 for smaller entities (U.S. Department of Justice, Civil Rights Division, 2024). The populations are defined by broad census areas rather than just the university community. These requirements apply equally to third-party and licensed content, underscoring that accessibility is a shared institutional and social responsibility.

Why Virtual Reference Belongs in the Accessibility Conversation

Virtual reference is an access service. It extends the library’s expertise to users wherever they are—on campus, at home, or around the world. As our teaching and research environments have become increasingly hybrid, the virtual reference desk has become the “front door” of the library. However, that front door is not equally open to all.

Research continues to reveal barriers faced by users with disabilities when interacting with digital library services. Ferrara (2024) notes that inaccessible platforms perpetuate systemic inequities in academic life, affecting students’ ability to complete coursework or fully participate in their institutions. Studies of library websites show persistent accessibility failures. Liu et al. (2024) found that 80% of the top 100 U.S. university library websites contained WCAG 2.0 AA-level errors, while Yang et al. (2020) observed similar shortcomings among Ivy League institutions.

Barriers impact not only users with disabilities but all users. Chow and Croxton (2014) similarly linked patron satisfaction with virtual reference to the overall usability of the library’s website. Mulliken (2019) found that visually impaired patrons using screen readers required substantially more time to learn library interfaces, disrupting research workflows and diminishing the perceived usability of library services. Thus, accessibility is not an isolated concern but a dimension of user experience itself.

When accessibility is neglected, the impact is systemic as users with disabilities may be excluded outright and all users may experience friction. Conversely, when accessibility is integrated into virtual reference from the start, everyone wins. As Vesco (2024) observes, “when we design and provide accessible products, everyone benefits.” Users gain flexibility and choice, and libraries save time and resources by avoiding costly retrofits later.

From Reactive Compliance to Proactive Culture

Accessibility in libraries has often been treated as a technical or legal issue, separate from service design or user experience. The ADA Title II update should compel academic librarians to rethink that division. Accessibility and usability are not separate tracks; they are mutually reinforcing dimensions of inclusive design (Schmutz et al., 2017).

Creating accessible virtual reference services requires a shift from reactive remediation to proactive cultural integration. Accessibility cannot rest solely with the web developer nor the accessibility coordinator. It must be distributed across the organization into everyday decisions about platforms, content, staffing, and training. Thus, we propose four strategies for building sustainable accessibility in virtual reference services. We provide links to resources for more information in Appendix A. Additionally, based on these points, we also created an annual checklist/workflow in Appendix B.

Test Regularly and Routinely

Accessibility testing should not be a one-time compliance task. Libraries can begin with basic automated tools, such as WAVE or Axe, to identify common WCAG violations; however, automated reports are only a starting point. Full accessibility evaluation must include usability testing by people with disabilities, ideally drawn from the institution’s student and staff communities (Ghosh & Dubey, 2025; Øksnebjerg et al., 2019; Valencia et al., 2021).

Partnerships with campus accessibility or disability resource offices can make this feasible. Likewise, an in-house accessibility librarian also improves a library’s chances of success. If this is not an option, task an existing staff member, or a working group with these responsibilities. If full testing cycles are not possible each year, a rotating schedule can ensure coverage of key services. Testing should mirror real information-seeking behavior by asking participants to complete tasks that range from finding a database article to booking a reference appointment. Regular testing not only improves compliance but normalizes accessibility as part of the library’s operational rhythm, which shows that inclusion is ongoing work and not a project to be completed and forgotten.

Procurement with Accessibility in Mind

Many academic libraries rely on vendor-provided virtual reference software such as LibChat, LibraryH3lp, or third-party chatbots and widgets. Under the ADA clarification, these tools must also meet accessibility standards. Libraries should integrate accessibility criteria into procurement and licensing workflows. They should also obtain a current Voluntary Product Accessibility Template (VPAT) and conduct independent verification using the tools mentioned above when possible (Hines, 2012). The VPAT is a disclosure voluntarily filled out by the vendor and indicates to which level their product is accessible. Because they are completed by vendors or updated with every interface update, it’s important to check their accuracy.

The Library Accessibility Alliance, a partnership between the Big 10 Academic Alliance and other regional consortia, has led the way in sharing accessibility resources. They provide sample contract language and vendor accessibility evaluations to assist in this process. Oud (2011) cautions that technical compliance does not guarantee usability; even an “accessible” product may pose barriers in real contexts. Procurement policies should therefore include both compliance review and user testing to ensure that chosen platforms truly work for the library’s community. Proactive accessibility training for staff overseeing procurement can help identify accessibility problems before they become major issues.

Train and Empower Staff

Accessibility must be part of every staff member’s skill set, not confined to one department or a designated accessibility librarian. Many accessibility issues arise simply because staff are unaware of them (Oud, 2011). Training programs can begin with basic instruction in WCAG principles and progress to advanced workshops on accessible content creation. Training should cultivate empathy, foster accountability, and include the real-world impacts of design choices on disabled users. For virtual reference, this training could include best practices for interacting with patrons and providing online information. This could mean providing additional time for visually impaired students to interact with the database link you have sent them; using shorter, more easily understood sentences; or providing screenshots with alternative text or appropriate color contrast.

Ferrara (2024) emphasizes that staff skills and confidence improve when training is tiered and the training meets employees where they are. As staff knowledge grows, they become better equipped to identify barriers in their daily work, whether editing LibGuides, responding to chat inquiries, or designing search tutorials. Accessibility goals should be embedded into professional development plans and performance evaluations, reinforcing that they are everyone’s responsibility. Empowered staff not only catch accessibility issues early but also foster a culture in which inclusivity becomes a professional norm rather than a compliance burden.

Engage the Users: “Nothing for Us Without Us”

A core principle of the disability rights movement—“Nothing about us without us”—should guide library accessibility work. Libraries can only design accessible services by working in partnership with those who use them. Engaging with student disability organizations, faculty advocates, and campus accessibility offices brings critical lived experience into decision-making.

Hearing directly from users reveals barriers that automated audits or staff reviews might miss. Users may note that chat windows automatically take focus and disrupt screen-reader navigation, or that captioning lags in live-reference video sessions. These insights help libraries move beyond minimal compliance toward authentic inclusivity. Ongoing communication channels, such as accessible feedback forms, user advisory groups, or open office hours, can keep the conversation active and ensure that accessibility remains responsive to changing needs. Including the community in yearly accessibility testing can improve results while also building trust (Pionke 2017).

Sustaining the Work: Resources and Leadership

Sustained accessibility requires resources, including time, staffing, funding, and administrative will. As Ferrara (2024) reminds us, these investments are essential if accessibility work is to move beyond rhetoric. Creating “born accessible” content takes time, as does building relationships, conducting user testing, and training staff.

Leadership commitment is crucial. Administrators must recognize accessibility as core to the library’s mission and allocate corresponding support. Accessibility should appear in strategic plans, budget lines, and annual goals. Library administration should internalize that accessibility is a defining service standard. At the same time, libraries can understand that accessibility investments often result in efficiency and user satisfaction. Vesco (2024) notes that designing accessibly from the start saves time, cost, and effort later. The “extra” time spent now prevents far greater time lost to retrofitting, user frustration, or legal exposure later.

Building a Culture of Accessibility

Accessibility work does not end when a library meets the April 2026 deadline. Laws, technologies, and user expectations evolve and so must academic libraries. To sustain progress, accessibility must become part of institutional culture and a shared expectation that at the very least informs all decisions. This means embedding accessibility into the annual assessment cycle, just as libraries already schedule budget reviews or accreditation reporting. It also means treating accessibility as a form of professional ethics and upholding librarianship’s core value of equity.

Removing barriers to information is a natural area of growth for the academic library. As campus information leaders, libraries have both the power and the obligation to dismantle barriers for all patrons. A culture of accessibility grows through repetition and reinforcement: regular audits, continuous training, collaborative design, and leadership advocacy. Over time, these practices move accessibility to an active choice rather than an afterthought.

Conclusion: From Regulation to Transformation

The April 2026 ADA Title II update offers libraries a powerful opportunity. Meeting WCAG 2.1 AA standards for virtual reference and digital services is non-negotiable; failure to comply risks both legal and ethical consequences. However, compliance should not be our ultimate ambition.

The real opportunity here lies in transforming how libraries think about accessibility, from a reactive technical issue to a proactive cultural value. When accessibility becomes embedded in design, procurement, training, and user engagement, the benefits reach far beyond compliance. Benefits can include smoother user experiences, reduced barriers, improved equity, and a stronger institutional reputation. A truly accessible library fosters a culture of empathy, inclusion, and shared responsibility wherein accessibility is embraced not merely as a requirement but as a reflection of core institutional values.

As librarians, we hold equity as a defining principle. Ensuring that all members of our communities—students, faculty, staff, and the public—can seek and receive information equitably is not a new mandate. This is the heart of our profession. The 2026 deadline should therefore be understood not as an endpoint but as a milestone on a longer path. By committing to continual testing, staff empowerment, inclusive design, and community partnership, libraries can fulfill both the letter and the spirit of the ADA. More importantly, we can build the kind of culture where accessibility is no longer exceptional but expected.

References

Chow, A. S., & Croxton, R. A. (2014). A usability evaluation of academic virtual reference services. College & Research Libraries, 75(3), 309–361. https://doi.org/10.5860/crl13-408

Ferrara, L. (2024). Library staff’s understanding of attitudinal barriers experienced by individuals with disabilities in libraries. Reference Services Review, 52(1), 50–65. https://doi.org/10.1108/RSR-03-2023-0033

Ghosh, S. & Dubey, S. (2025). The field of usability and user experience (UX) design. In A. Correia (Ed.), Navigating Usability and User Experience in a Multi-Platform World (pp. 117–154). IGI Global Scientific Publishing. https://doi.org/10.4018/979-8-3693-2337-3.ch005

Hines, S. (2012). Reference services for distant students with disabilities. Internet Reference Services Quarterly, 17(1), 7–12. https://doi.org/10.1080/10875301.2012.652039

Liu, Y. Q., Bielefield, A., & Beckwith, J. (2024). ADA digital accessibility on academic library websites. College & Research Libraries, 85(2), 166–186. https://doi.org/10.5860/crl.85.2.166

Mulliken, A. (2019). Eighteen blind library users’ experiences with library websites and search tools in US academic libraries: A qualitative study. College & Research Libraries, 80(2), 152–158. https://doi.org/10.5860/crl.80.2.152

Øksnebjerg, L., Woods, B., & Waldemar, G. (2019). Designing the ReACT App to support self-management of people with dementia: An iterative user-involving process. Gerontology, 65(6), 673–685. https://doi.org/10.1159/000500445

Oud, J. (2011). Improving screencast accessibility for people with disabilities: Guidelines and techniques. Internet Reference Services Quarterly, 16(3), 129–144. https://doi.org/10.1080/10875301.2011.602304

Pionke, J. J. (2017). Toward holistic accessibility: Narratives from functionally diverse patrons. Reference and User Services Quarterly, 57(1), 48–56. https://www.jstor.org/stable/90014867

Schmutz, S., Sonderegger, A., & Sauer, J. (2017). Implementing recommendations from web accessibility guidelines: A comparative study of nondisabled users and users with visual impairments. Human Factors, 59(6), 956–972. https://doi.org/10.1177/0018720817708397

U.S. Department of Justice, Civil Rights Division. (2024, June 24). Americans with Disabilities Act: Title II regulations. ADA.gov. https://www.ada.gov/law-and-regs/regulations/title-ii-2010-regulations/

Valencia, K., Rusu, C., & Botella, F. (2021). User experience factors for people with autism spectrum disorder. Applied Sciences, 11(21). https://doi.org/10.3390/app112110469

Vesco, B. (2024, July 8). Public schools have 2-3 years to comply with ADA Title II. Government Technology. https://www.govtech.com/education/k-12/public-schools-have-2-3-years-to-comply-with-ada-title-ii

World Wide Web Consortium. (2025, May 6). Web Content Accessibility Guidelines (WCAG) 2.1. https://www.w3.org/TR/WCAG21/

Yang, W., Zhao, B., Liu, Y. Q., & Bielefield, A. (2020). Are Ivy League libraries’ websites ADA compliant? Information Technology and Libraries, 39(2). https://doi.org/10.6017/ital.v39i2.11577