Title II’s 2026 Shift: Audio Descriptions Move from “Nice-to-Have” to Must-Have in the Learning Management System

Before 2026, Title II of the Americans with Disabilities Act (ADA) largely focused on “effective communication”—ensuring accessibility for individuals with disabilities. However, the standards for “effective communication” were not clearly defined.

The digital landscape for public institutions is changing dramatically with the U.S. Department of Justice’s new regulations. The new rule, effective April 2026, establishes a specific, non-negotiable standard: Web Content Accessibility Guidelines (WCAG) 2.1 Level AA.

The change replaces a flexible, case-by-case standard with a clear, measurable checklist for websites, apps, and–most importantly–content within your Learning Management System (LMS). The advantage is less debate and greater clarity around what “accessible enough” means. The challenge is the increased responsibility, especially in the LMS, where the majority of instructor and student videos are hosted.

For many institutions, the most significant impacts will be the new requirements for audio descriptions on all prerecorded videos and captioning for live streams. 

The New Standard: Audio Descriptions and Live Captions

While many schools are familiar with live captioning services for real-time sessions (like those on Zoom), the new requirement for audio descriptions is a considerable change. Audio descriptions are separate audio tracks that narrate what is happening visually on screen. The mandate applies to all videos—not just when an accommodation is requested—including everything from professionally produced content to instructor-created “talking-head” recordings, where presenters must also describe key visual elements such as gestures, on-screen text, or slides.

This presents a significant challenge, especially for content within the LMS. The three main areas of impact are:

• Instructor Videos: Although instructors can be trained to describe visual content, ensuring consistent compliance across campus is challenging, and this approach doesn’t address accessibility for existing video libraries.
• Third-Party Videos: Acquiring or creating descriptions for third-party content is often expensive and time-consuming.
• Student Videos: With more assessments using video to prevent AI-generated content, the need for quick turnaround times on audio descriptions for student work complicates compliance.

A Path Forward: Leveraging Technology

All this arrives in an AI era where more assessment strategies are turning to video to sidestep AI-written content—fortunately, it’s also a time when we can use that same AI to help handle workload.

From a cost and time perspective, companies use AI or a combination of human and AI services to create descriptions. Leading providers for AI-generated descriptions include 3Play Media and Echo Labs. Typical costs range from $4 to $8 per minute of video. Some video platforms such as YuJa are beginning to offer AI-driven audio-description packages, with early reports suggesting this may be a more affordable option, potentially less than the $4 per minute.

Although these platforms may cover instructor-created videos, forgetting student work presents additional challenges. When visual content in student presentations or videos isn’t clearly described, blind or low-vision learners are unable to fully participate—and the institution is still on the hook.

Harmonize is launching a new package designed to help manage both instructor and student video content, including a dedicated space for hosting lectures, at an estimated cost of $0.50 per minute. The same technology will also generate alt text for all images within the platform, supporting broader accessibility efforts. You’re welcome to pilot the platform for a semester to see whether we’re a viable part of your Title II and student-engagement/RSI plans.

The key takeaway for every institution is to start planning now. It is crucial to assess your content and talk to all your digital tool providers to understand their strategies for achieving compliance. By proactively addressing these new requirements, schools can ensure they meet the new ADA standards while continuing to foster an inclusive and accessible learning environment for all students.

If you are interested in learning more about leveraging the FoundationCCC’s agreement with Harmonize Learning, please contact cbcontracts@foundationccc.org.