Background

On April 24, 2024, the Department of Justice issued a new Americans with Disabilities Act (ADA) Title II ruling that impacts the accessibility of web content at public institutions. In this ruling, state and local governments have deadlines for conforming their public-facing web content to the Web Content Accessibility Guidelines (WCAG) 2.1 standard. This includes libraries that are part of local governments or state universities. In addition, a new final rule issued by the Department of Health and Human Services (HHS) will similarly require conformance to the WCAG 2.1 standard for entities receiving HHS funds, including Medicare and Medicaid funding, which includes many libraries that are part of hospitals or medical schools.

The Charge

Noting a lack of guidelines and standards relating to digital data accessibility, a group of data information professionals formed a working group in late 2024 through the Research Data Access and Preservation (RDAP) Association to produce a report on how the new U.S. ADA Title II rulings will impact data and data repositories, and summarize accessibility standards and best practices for datasets and repository platforms. The report, published in early 2026, is freely available and contains three subsections: how the new ADA Title II requirements apply to data and repositories; guidance for assessing and remediating accessibility of repository platforms; and recommendations for making data files accessible.

The Report

Drawing on a breadth of experience across academic research institutions, hospital systems, and both institutional and generalist data repositories from the US and Canada, the working group spent a year researching, convening, writing, and editing to create a report to support research data professionals in making data more accessible. After drafting an initial version of the report, the working group sent out the document for feedback from a selection of reviewers with expertise and lived experience in accessibility. A mostly-done draft version is now available, and after one more round of edits a final version will be released later in the spring.The working group hopes it will be of use to research data professionals interested in learning about the new rulings, the accessibility of research data repositories and research datasets, or, more broadly, to those interested in digital accessibility in general.

Key Takeaways

ADA Title II, HHS Section 504, and WCAG: What Research Data Professionals Need to Know

• These new rulings impact state and local government libraries as well as hospital and private university libraries.
• WCAG 2.1 is the standard that institutional website and mobile content will need to adhere to (minding certain exceptions).
• The new rulings likely apply to data and data repositories as it’s not clear that the stated exemptions apply, though it is best to seek the advice of your legal counsel for more specific guidance.
• Professionals and organizations will need to navigate a level of uncertainty in meeting the new WCAG 2.1 requirements.

Strategies and Considerations for Repository Accessibility

• Different considerations for data repository accessibility need to be taken depending on who hosts the repository the data resides in (e.g., developed in-house, institutionally hosted, vendor-hosted).
• Multiple templates and roadmaps exist for repository owners to begin developing accessibility policies.
• After an accessibility assessment, repositories can employ various remediation strategies as further described in the report.

Reviewing Accessibility Options for Research Data Files

• Basic guidance for making data accessible exists but further guidance needs to be developed, especially for non-standard and complex data.
• Researchers and data curators need to be trained in how to make data accessible so that data can be born-accessible or made accessible at the time of sharing.
• All datasets, including those that were structured to be more accessible, may need to be remediated in the future in response to specific access needs and requests.
• The accessibility of research data is an area of growth where engagement needs to increase at all levels, including: guidance development, robust education, researcher and curator implementation, and increased expectations for accessibility from institutions, journals, and funders.

Contributors

Chairs:

• Clara Llebot Lorente (Repositories)
• Rachel Woodbrook (ADA)
• Kristin Briney (Data)

List of members: Emily Blumenthal, Lena Bohman, Carrie Breton, Kristin Briney, Cameron Cook, Will Dean, Joseph Edgerton, Christine Nieman Hislop, Danielle Kirsch, Clara Llebot Lorente, Wendy Mann, Michal McCullough, Heather Charlotte Owen, Peyton Tvrdy, Sarah Weirich, and Rachel Woodbrook

Reviewers:

• Gail Betz
• Randy Colon
• Sagan Wallace

About RDAP

RDAP (Research Data Access & Preservation) supports an engaged community of information professionals committed to creating, maintaining, advancing, and teaching best practices for research data, access, and preservation.
The RDAP community brings together a variety of individuals, including data managers and curators, librarians, archivists, researchers, educators, students, technologists, and data scientists from academic institutions, data centers, funding agencies, and industry who represent a wide range of STEM disciplines, social sciences, and humanities.
https://rdapassociation.org/about 

Contact Us

For any questions or feedback about the report, please contact Kristin Briney (briney@caltech.edu), Clara Llebot Lorente (clara.llebot@oregonstate.edu), and/or Rachel Woodbrook (woodbr@umich.edu).