Guide · updated
AEM migration for universities and public sector
Public bodies and universities are bound by accessibility law in most countries, and a platform migration is when accessibility either improves or quietly regresses. Templates, components and editors all change. This guide summarises the rules that usually apply and what AEM as a Cloud Service does and does not do for you. It is not legal advice.
The standard behind the rules: WCAG
Most rules point to the W3C's Web Content Accessibility Guidelines. WCAG 2.1 became a W3C Recommendation in June 2018 and WCAG 2.2 in October 2023; W3C encourages using the latest version, and content that meets 2.2 also meets 2.1. WCAG 2.2 adds four level AA success criteria: Focus Not Obscured (Minimum), Dragging Movements, Target Size (Minimum) and Accessible Authentication (Minimum).
Rules by region
| Region | Rule | Standard and key duties |
|---|---|---|
| United States: state and local government, including public universities | ADA Title II web and mobile rule (published April 2024) | WCAG 2.1 AA. An interim final rule in April 2026 moved compliance dates to 26 April 2027 for entities serving 50,000 people or more, and 26 April 2028 for smaller entities and special districts. The Department of Justice has said it may revisit parts of the rule, so check ada.gov for changes. |
| United States: federal agencies | Section 508 (Revised 508 Standards) | WCAG 2.0 level A and AA, incorporated by reference. |
| European Union | Web Accessibility Directive (EU) 2016/2102 | Public sector bodies' websites and apps; harmonised standard EN 301 549; a detailed accessibility statement with a feedback mechanism and a link to the enforcement procedure. Universities are not in the optional exclusion for schools. |
| United Kingdom | Public Sector Bodies (Websites and Mobile Applications) (No. 2) Accessibility Regulations 2018 | GOV.UK guidance sets WCAG 2.2 AA; an accessibility statement following the model statement, kept under regular review. |
| India | Guidelines for Indian Government Websites and Apps (GIGW) 3.0, released 2023 | Conformity with WCAG 2.1 level AA; all government-owned websites and apps must comply; STQC offers Certified Quality Website certification. |
The European Accessibility Act (Directive (EU) 2019/882), applying since 28 June 2025, mainly covers products and consumer services from the private sector; public bodies' own websites remain under the Web Accessibility Directive.
What AEM gives you, and what it does not
- Adobe says authors can create content on AEM as a Cloud Service that meets WCAG 2.1 level A and AA success criteria, and that AEM provides the capabilities while authors must follow accessible techniques.
- Core Components are documented as complying with WCAG 2.1, with ARIA labels and keyboard support; Adobe links their known accessibility issues on GitHub. Custom and Foundation-based components carry no such statement, so they are where migrations usually find problems.
- AEM Sites Optimizer has an accessibility opportunity that reports issues against WCAG guidelines with the failing elements and suggested fixes.
- The authoring interface is a separate question. Adobe's accessibility conformance reports for AEM Sites (Cloud Service and 6.5, both September 2024) report partial support: for example, many drag-and-drop operations are not keyboard accessible, and most functions do not meet the 320-pixel reflow criterion. If your authors include people with disabilities, read the report for your version.
Make the migration an accessibility checkpoint
- Audit the current sites against your required standard before migrating, so the new site is measured against a known baseline.
- Replace Foundation and custom components with Core Components where you can, and test the custom ones that remain with keyboard and screen reader.
- Add automated accessibility checks to the customer UI tests, which run in Cloud Manager pipelines before production.
- Check templates for WCAG 2.2 additions such as target size and focus visibility, even if your rule still names WCAG 2.1: the newer rules point that way.
- Update the accessibility statement at go-live, as EU and UK rules require.
Questions
When must US public universities meet the ADA Title II web rule?
After the April 2026 interim final rule: 26 April 2027 for entities serving 50,000 people or more, 26 April 2028 for smaller ones. The standard is WCAG 2.1 AA. Check ada.gov, because the Department of Justice has signalled further rulemaking.
Does AEM as a Cloud Service make a site WCAG compliant?
No product does on its own. Adobe says AEM provides the capabilities to meet WCAG 2.1 A and AA, and that authors must use accessible techniques. Custom components and content need testing.
Which accessibility standard applies to Indian government websites?
GIGW 3.0 (2023), which conforms to WCAG 2.1 level AA. STQC offers Certified Quality Website certification for compliant sites.
Sources
- W3C: WCAG overview
- W3C: WCAG 2.2
- ADA.gov: Title II web rule first steps
- Federal Register: ADA Title II web rule (24 April 2024)
- Federal Register: Interim final rule extending compliance dates (20 April 2026)
- Section508.gov: Applicability and conformance
- EUR-Lex: Directive (EU) 2016/2102
- EUR-Lex: Directive (EU) 2019/882 (European Accessibility Act)
- Legislation.gov.uk: SI 2018/952
- GOV.UK: Accessibility requirements for public sector websites and apps
- GIGW: New features of GIGW 3.0
- GIGW: Scope and objective
- STQC: GIGW 3.0 transition plan (2023)
- Adobe: AEM as a Cloud Service and web accessibility guidelines
- Adobe: Core Components introduction
- Adobe: Sites Optimizer accessibility issues
- Adobe: Accessibility conformance report, AEM Sites Cloud Service (2024)
- Adobe: Accessibility conformance report, AEM 6.5 Sites (2024)