RD746 - Report on Digital Accessibility Compliance § 2.2-3504 – November 1, 2026
Executive Summary: The Virginia Department of Education (VDOE) prepared this report pursuant to § 2.2-3504 of the Code of Virginia, as amended by HB2541 (2025), which requires executive branch agencies to identify information and communications technology (ICT) that does not meet federal and state accessibility standards and provide annual fiscal impact estimates for bringing those technologies into compliance. These mandates strengthen statewide digital accessibility expectations and expand the responsibilities of covered entities to ensure equitable access for individuals with disabilities. VDOE also completed an internal ICT audit to establish a baseline of accessibility across agency systems. The results show a varied ecosystem, with many tools falling into “Pending Review" or “WCAG Alignment Mostly Achieved" status. Several high-impact platforms—including Virtual Virginia, GovDelivery, and the VDOE website—demonstrate progress but require continued remediation. Systems maintained by external vendors frequently provide Accessibility Conformance Reports or VPATs, though coordinated validation remains necessary. Large internal SharePoint environments house substantial volumes of documents that will require long-term remediation planning. To understand the broader statewide landscape, VDOE administered a voluntary School Compliance Survey across all local school divisions. The survey revealed significant variation in readiness, fiscal capacity, tooling, and training. Many divisions reported difficulty quantifying noncompliant websites and documents due to decentralized content creation and the lack of accessible auditing tools. Cost estimates ranged widely, with smaller divisions citing modest expenses while larger divisions anticipate substantial remediation costs, including millions of dollars in staff time. Most divisions are in the early stages of training and compliance planning, and nearly all identified funding, statewide training, procurement guidance, auditing tools, and clearer expectations as critical needs. A recurring theme across divisions is that the scope and complexity of compliance represent a substantial unfunded mandate and meeting federal and state deadlines will require coordinated support. Collectively, these findings highlight both the progress made and the extensive work ahead. VDOE has established foundational governance structures, initiated systemic improvements, and gathered statewide readiness data. Continued progress will rely on sustained remediation, expanded training, vendor coordination, and statewide supports that recognize the scale of the effort required. As implementation continues, the agency remains committed to transparency, accessibility, and partnership with school divisions to fulfill the requirements of the Information Technology Access Act and ensure equitable digital access for all Virginians. |