Standards for Social Media and the Title II Social Media Exception

Social Media Exception

The exception generally applies to:

  • Content created by members of the public.
  • Comments or replies posted by third parties.
  • User-generated content that the entity does not control.
  • Content created before the date of compliance (April 24, 2026).

Examples:

  • Public comments on a Facebook post.
  • Replies from users on X (Twitter).
  • Community responses on Instagram.
  • Comments on YouTube videos.

Public entities are not required to remediate user-generated comments made by others.

What the Social Media Exception Does NOT Cover

The exception does NOT apply to content created or controlled by the public entity.

You must ensure accessibility for:

  • Posts created by your organization
  • Posts created by a contractually authorized 3rd party
  • Images you upload
  • Videos you publish
  • Graphics you share
  • Livestreams you host
  • Stories or reels you create
  • Pinned posts
  • Profile information
  • Event announcements

If your organization posts it, you are responsible for accessibility.

Platform Limitations

Social media platforms may have accessibility limitations. However, platform limitations do not remove the obligation to provide accessible communication.

If a platform does not support a needed accessibility feature:

  • Provide the information on an accessible website.
  • Include a link to an accessible version.
  • Provide alternative communication upon request.

Live Social Media Events

If hosting live content:

  • Enable live captions when available.
  • Provide post-event captioned recordings.
  • Provide accessible alternatives for critical information.

Emergency or public safety communications must be accessible.

What Is Not an Exception

The following are not valid reasons to avoid accessibility on social media:

  • “It’s just social media.”
  • “The platform doesn’t make it easy.”
  • “We’re moving too fast.”
  • “It’s temporary.”
  • “It’s marketing content.”

If the post communicates information about programs, services, or activities, accessibility applies.

Responding to Accessibility Requests

If someone requests:

  • A transcript
  • An accessible version of a graphic
  • A captioned version of a video

The entity must:

  • Respond in a timely manner
  • Provide equal access
  • Offer accessible alternatives

The social media exception does not remove this responsibility.

Practical Decision Guide

Before posting, ask:

  • Does this communicate information about our services or programs?
  • Would someone miss important information if they could not see the image?
  • Would someone miss information if they could not hear the video?
  • Is the information available in accessible text somewhere else?

If yes then make it accessible before posting. 

Please refer to the Social Media and Text Accessibility guide for information regarding accessibility features and best practices when using social media.

Safe Operating Principle

If your organization creates or controls the social media content then it must be accessible. User comments and independent third-party posts are generally covered by the exception, but official content is not.