CRIV CONNECTION

Author: Laurel Moran, Assistant Director, Legal Information Management, San Diego Law Library

Many libraries have prioritized accessibility of their third-party electronic resources for some time. With recent federal rulemaking published in the Federal Register, most public entities are expected to be in compliance with new American with Disabilities Act (ADA Title II) rules by April 24, 2026, when Department of Justice enforcement begins. The rules mandate that state and local government programs—including public libraries—ensure their web content and mobile applications meet WCAG 2.1 AA standards.[1] WCAG standards are web content accessibility guidelines prepared by the World Wide Web Consortium or “W3C.”[2] As suggested by the Association of Research Libraries, “Consult your institution’s disability law experts to determine whether your library is covered by Title II, and which compliance date might apply.”[3]

Digital assets linked to from third party vendors—such as research databases, e-books, and legal information platforms are included, with limited exclusions.[4] So how can libraries obtain the necessary accessibility compliance information for electronic resources? The topic has come up recently in Technical Service Special Interest Section posts. Here are some resources and strategies on working with vendors to get the information you need:

1. Request your vendor’s accessibility testing. These are known as Voluntary Product Accessibility Templates (VPATs). A completed VPAT may also be known as an Accessibility Conformance Report (ACR). These documents detail how a vendor’s product meets ADA requirements. Many are directly available from your vendor representative or on their websites.
2. The Library Accessibility Alliance provides an accessibility toolkit as well as model language for electronic resource licensing. This website also lists third party testing that has been completed for several online resources.
3. View the RAILS Voluntary Product Accessibility Template page. There are links here to Westlaw, HeinOnline, and EBSCO’s Legal Information Source accessibility statements or VPATs—an excellent place to being your search.
4. Repositories of accessibility information have been created by academic libraries already. Check out the guide page by SUNY Office of Library and Information Services; or the City University of New York VPAT repository at VPATs & Accessibility Statements – Accessibility Toolkit for Open Educational Resources (OER) – Library Guides at CUNY Office of Library Services. Many other academic libraries have prepared their own repositories of VPATs for their database holdings. Checking with your peer libraries may provide you with information you need.
5. If you are unable to obtain accessibility information you can submit a CRIV (Committee on Relations with Information Vendors) request for assistance.
6. Reach out to other libraries via your special interest sections at AALL. Other libraries may already have accessibility information on your resources, and they are often happy to share.
7. If you have the expertise, conduct your own testing of these resources. Guidance is available on the tools you need to conduct your own testing.[5]

This brief post is meant to offer initial preliminary guidance on how to obtain accessibility information from vendors. The Association of Research Libraries and the Library Accessibility Alliance have more detailed information on how they are using the accessibility information they gather to negotiate licensing terms for accessible content.

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[1] WCAG 2.1 AA standards by publication date are found at https://www.w3.org/standards/history/WCAG21/.

The rule requires conformance with the 2018 version. A permalink to that version is linked to in the Federal Register and may be found at https://perma.cc/UB8A-GG2F.

[2] Fact Sheet: New Rule on the Accessibility of Web Content and Mobile Apps Provided by State and Local Governments, April 8, 2024, at https://www.ada.gov/resources/2024-03-08-web-rule/.

[3] ADA Title II Regulations: Implications for Libraries at https://www.arl.org/wp-content/uploads/2024/10/ADA-Title-II-regulations_-implications-for-libraries.pdf.

[4] ADA Title II and Academic Libraries, Library Accessibility Alliance at https://libraryaccessibility.org/ada-title-ii.

[5] Trust, But Verify: Auditing Vendor-Supplied Accessibility Claims. Code {4}lib Journal, Issue 48, 2020-05-11 at https://journal.code4lib.org/articles/15122.