The Texas Education Agency requires publishers with digital instructional materials in IMRA Cycle 2026 to contract with a third party, at the publisher’s expense, to evaluate accessibility against WCAG 2.1 AA and Section 508, remediate all findings, and submit an accessibility compliance report with a required coversheet to TEA by March 22, 2027.
TEA’s Publisher Handbook describes this evaluation as an accessibility audit. Publishers who miss this requirement can lose their place in EMAT, the state ordering system, and their spot on the List of Approved Instructional Materials.
Everything below quotes TEA’s official documentation, primarily the IMRA Cycle 2026 Request for Instructional Materials (RFIM) and the IMRA Publisher Handbook: Process Overview.
| Key Point | What It Means for You |
|---|---|
| Standards | All digital student and teacher components must meet WCAG 2.1 AA and Section 508 technical standards. |
| Third-Party Evaluation | You must contract with a reputable third party, at your own expense, to evaluate accessibility. TEA’s handbook calls this an accessibility audit. |
| Deliverables | An accessibility compliance report plus TEA’s required coversheet, due to TEA by March 22, 2027, at 5:00 p.m. CDT. |
| Remediation | All findings of non-conformance must be remediated as a condition of SBOE approval. |
| Consequence | Unremediated findings result in removal from EMAT and possible removal from the List of Approved Instructional Materials. |
| Scope | Each grade level is a separate program. Every digital component in every program is subject to the requirement. |
What Exactly Does the RFIM Say About Digital Accessibility?
Section 3 of the RFIM, under the heading “Accessible Digital Materials,” contains the full requirement in three parts.
The Standard
“Any student or teacher components offered to local school systems in a digital format must comply with the Web Content Accessibility Guidelines (WCAG), version 2.1, level AA standards and the technical standards required by the Federal Rehabilitation Act, Section 508.”
The Third-Party Evaluation
“Publishers must, at their own expense, contract with a reputable third party to evaluate accessibility, produce an accessibility compliance report, and complete the required coversheet.”
Self-evaluation does not satisfy this requirement. The RFIM requires a third party.
The Consequence
“Any findings of non-compliance must be remedied as a condition of approval by the SBOE. Any findings of non-compliance that are not remedied prior to the state ordering system opening will result in the publisher’s program being removed from EMAT, the state’s instructional materials ordering system, and the program may be removed from the List of Approved Instructional Materials.”
Removal from EMAT means Texas school systems cannot purchase the program with instructional materials allotment funds. The evaluation is a revenue gate, not a paperwork exercise.
Is It Called an Evaluation or an Audit?
The RFIM uses “evaluate accessibility.” TEA’s IMRA Publisher Handbook, in Phase 5, Post-Approval Submissions, describes the same requirement with the word audit:
“Publishers must contract with a reputable third party to conduct an accessibility audit, produce an accessibility compliance report, and submit the required coversheet to TEA. All identified issues must be addressed before the materials will be added to EMAT and made available for purchase.”
Same obligation, two words for it. In practice, the third-party accessibility audit is the evaluation, and its output is the accessibility compliance report.
When Is the Accessibility Compliance Report Due?
The RFIM’s Anticipated Schedule of Events lists the deliverable under the March 22, 2027 milestone:
“The Accessibility Compliance Report, along with the cover sheet, is due to TEA.”
The deadline is March 22, 2027, at 5:00 p.m. CDT. This sits inside a tight post-approval window. Here is the sequence from the same schedule:
- November 16-20, 2026: The SBOE takes its final vote on materials.
- November 21, 2026: Publishers with approved materials begin making required changes.
- March 22, 2027: The Accessibility Compliance Report and coversheet are due to TEA, along with the complete post-approval program submission.
- April-August 2027: TEA conducts a confirmation of changes review.
- May 2027: Texas school systems begin submitting orders through EMAT.
That gives an approved publisher roughly four months to complete the third-party audit, remediate every finding, and file the report. Audits of full curriculum platforms take time. Remediation takes longer. Publishers who wait until after the November vote to start compress both into a very short window.
What Do Accessibility Auditors Test in Digital Materials?
A WCAG 2.1 AA evaluation of digital instructional materials examines every interface a student or teacher touches. Common areas include:
- Text alternatives for images, charts, and diagrams
- Keyboard access to lessons, assessments, and navigation
- Color contrast in text, buttons, and graphed content
- Labels and instructions on form fields and quiz inputs
- Reading order and heading structure for screen reader users
- Captions and transcripts for video and audio lessons
- Focus indicators and error identification in interactive activities
Why Manual Testing Matters
Automated scans catch only a fraction of WCAG issues. Screen reader testing and keyboard testing are necessary to evaluate the criteria that matter most for students who rely on assistive technology. Accessible.org audits are always 100% manually conducted, which is the level of rigor a state submission calls for.
A Simple Example
Auditors evaluate markup, not just appearance. An image of a fraction model that looks fine visually may communicate nothing to a screen reader:
<!-- Does Not Meet WCAG 2.1 AA (1.1.1 Non-text Content) -->
<img src="fraction-model.png">
<!-- Passes -->
<img src="fraction-model.png" alt="Circle divided into four equal parts with three parts shaded, showing three fourths">
Multiply one issue like this across every lesson, activity, and assessment in a grade-level program, and the value of starting early becomes obvious.
Tracking Findings Through Remediation
The report alone is not enough. Publishers need a way to track every issue from discovery through remediation and validation. An audit report identifies issues. Tracking systems confirm each issue was fixed and verified before the report goes to TEA. The Accessibility Tracker platform is built for exactly this post-audit workflow. It tracks remediation status issue by issue until validation is complete.
Does the Requirement Cover Every Grade Level?
Yes. The RFIM’s program terminology section defines a program as instructional materials “tailored to meet the TEKS and/or ELPS for a specific grade level and subject area or course,” and each grade-level program requires its own Form B submission. A K-5 math submission is six programs, and each program contains multiple components, such as a teacher guide and a student workbook. Every digital component within every program falls under the WCAG 2.1 AA and Section 508 requirement.
Publishers scoping audits should count components across all submitted grade levels, not just count titles. This is where audit scoping conversations usually reveal the true size of the work.
How Does ADA Title II Make This Bigger Than Texas?
TEA’s requirement is not an isolated state rule. The Department of Justice’s rule under Title II of the Americans with Disabilities Act (ADA) requires state and local government entities, including public school districts, to make their web content and mobile apps conform to WCAG 2.1 AA. The rule covers course content, including digital instructional materials that districts provide to students, even when a third-party publisher supplies those materials.
Compliance deadlines under the Title II rule arrive in April 2026 for larger public entities and April 2027 for smaller ones. Districts buying instructional materials are legally accountable for the accessibility of the digital content they deploy, so they will increasingly demand audit documentation before adopting digital materials. A publisher who completes a genuine third-party audit for IMRA has documentation that answers procurement questions in all fifty states.
What Should the Accessibility Compliance Report Contain?
TEA requires the report to document the third-party evaluation of your digital components. A required coversheet accompanies the report.
Accessibility Compliance Report vs. ACR
The terminology deserves a note. TEA calls the deliverable an “accessibility compliance report.” In the accessibility industry, the standard document is an Accessibility Conformance Report (ACR), produced using the VPAT template. An ACR based on the WCAG edition or the Section 508 edition of the VPAT documents conformance criterion by criterion. Since the RFIM requires both WCAG 2.1 AA and Section 508, publishers should confirm their audit provider evaluates and documents against both.
What About Print Materials?
Print carries a separate accessibility requirement under the RFIM’s “Accessible Print Materials” section. The digital evaluation and the print NIMAS workflow are two distinct obligations with two distinct deadlines.
NIMAS Files and the Accessible PDF Replica
Publishers must submit NIMAS files for all print student components, validated through the NIMAC Validation Wizard, plus what the RFIM describes as “a high-quality, color, accessible PDF (i.e., high-resolution, optimized PDF) that is an exact replica of their print student materials.” These go to designated braille, audio, and large-print producers, with the first deliverables due February 1, 2027.
The RFIM states the consequence plainly:
“A program will be removed from the List of Approved Instructional Materials and EMAT, the state’s instructional materials ordering system, if the requirements for NIMAS files are not met.”
MathML for Math Notation
For math publishers, the RFIM adds a format recommendation: “Mathematical Markup Language (MathML) Version 3.0, 2nd Edition, is the recommended way to represent mathematical notation in NIMAS.” MathML gives screen readers and braille producers the structure of an expression rather than a flat image of it:
<math xmlns="http://www.w3.org/1998/Math/MathML">
<mfrac>
<mn>3</mn>
<mn>4</mn>
</mfrac>
</math>
A screen reader announces this as “three fourths.” An image of the same fraction without markup announces nothing.
Frequently Asked Questions
Can we conduct the accessibility evaluation ourselves?
No. The RFIM states publishers “must, at their own expense, contract with a reputable third party to evaluate accessibility.” An internal evaluation does not meet the requirement.
What accessibility standard applies to IMRA digital materials?
WCAG 2.1 AA and the Section 508 technical standards. Both apply to any student or teacher components offered to Texas school systems in a digital format.
When is the accessibility compliance report due to TEA?
March 22, 2027, at 5:00 p.m. CDT, together with the required coversheet and the complete post-approval program submission.
What happens if our audit finds issues?
All findings must be remediated as a condition of SBOE approval. Issues left unremediated before EMAT opens result in removal from the ordering system. Publishers should track each issue through remediation and validation so nothing is outstanding at submission.
Does ADA Title II apply to instructional materials publishers?
Title II applies to public entities, including school districts, rather than to publishers directly. But because districts must provide WCAG 2.1 AA conformant digital course content under the DOJ rule, districts will require conformance from the publishers they buy from. IMRA formalizes in Texas what Title II is driving nationally.
Actionable Takeaways
- Start the third-party audit before the November 2026 SBOE vote if possible. The post-approval window is roughly four months, and remediation is the long pole.
- Scope the audit by counting every digital component across every grade-level program, since each grade level is a separate program under IMRA.
- Confirm your audit provider evaluates against both WCAG 2.1 AA and Section 508 and documents results in a report suitable for TEA submission.
- Track every finding from the audit through remediation and validation so the March 22, 2027 submission reflects zero open issues.
- For math programs, plan for MathML in NIMAS files so notation reaches braille and audio producers with structure intact.
- Treat the IMRA audit as national documentation. The same WCAG 2.1 AA conformance evidence answers ADA Title II driven procurement requirements from districts in every state.
If you have questions about scoping or scheduling an audit for IMRA, contact us.
