Your Complete Guide to Texas IMRA Accessibility Requirements
For vendors pursuing Texas IMRA 2026 adoption, accessibility is not a matter of interpretation; it is codified in law and enforced through audits. All instructional materials reviewed under this cycle must comply with the standards established by the Texas Administrative Code §206 and §213, Section 508 of the Rehabilitation Act, and the Web Content Accessibility Guidelines (WCAG) 2.1 Level AA published by W3C in May 2025.
The Texas Education Agency (TEA) outlines these obligations through its Accessibility Checklist, Accessibility Fundamentals, and Electronic Information Resources (EIR) Accessibility Policy, which together define the state’s minimum expectations for digital and print-accessible instructional materials.
Accessibility compliance applies to all Full-Subject, Tier-One and Partial-Subject, Tier-One materials, including Mathematics K–12, Advanced Mathematics 6–8, ELAR K–5, SLAR K–5, Fine Arts, Career and Technical Education (CTE Batch 1), and English and Spanish Phonics K–3, as well as Supplemental Materials in these subjects.
The Foundation: WCAG 2.1 AA and Texas EIR Policy
The WCAG 2.1 AA framework establishes four governing principles: Perceivable, Operable, Understandable, and Robust, which translate directly into measurable checkpoints adopted by TEA. Each principle is represented in the state’s Accessibility Checklist, which provides a consistent reference for publishers, developers, and evaluators conducting compliance reviews.
Core WCAG 2.1 AA Principles and TEA Alignment
| Principle | Definition | Representative TEA Checklist Focus |
|---|---|---|
| Perceivable | Information must be available to all senses (sight, hearing, touch). | Color contrast ≥ 4.5:1; alt text for non-text elements; captioned video/audio. |
| Operable | Navigation and interface controls must function via keyboard and assistive technology. | Tab navigation order, skip links, keyboard-accessible media players. |
| Understandable | Content structure and language must remain logical and predictable. | Proper heading nesting, descriptive links, and consistent navigation. |
| Robust | Content must remain compatible with current and future assistive technologies. | Tagged PDFs, valid HTML, machine-readable metadata. |
Understanding the Difference Between NIMAS and NIMAC
The National Instructional Materials Accessibility Standard (NIMAS) and the National Instructional Materials Access Center (NIMAC) are two components of the same federal accessibility framework, serving distinct purposes.
NIMAS defines the technical standard as an XML-based file format that publishers must use to create source files for accessible versions of K–12 instructional materials. These files include structural markup and metadata that allow conversion into specialized formats such as braille, large print, DAISY, or digital text. Under the Individuals with Disabilities Education Act (IDEA, 2004), all states, including Texas, are required to ensure that core instructional materials meet this standard before distributing them to eligible students.
NIMAC, by contrast, serves as the central repository for storing and distributing NIMAS-conformant files. Managed by the American Printing House for the Blind (APH), NIMAC receives certified NIMAS files from publishers and makes them available to authorized users, typically state-designated agencies or local education service centers, who convert the files into accessible formats for students with print disabilities.
In practical terms, NIMAS is the specification, and NIMAC is the delivery system. Compliance with both ensures that instructional materials adopted through IMRA 2026 can be converted efficiently and legally distributed to students who require alternate formats.
NIMAS and MathML: Technical Mandates for K–12 and STEM Materials
The National Instructional Materials Accessibility Standard (NIMAS) requires publishers to provide XML source files convertible to braille, large print, DAISY, and audio formats. Texas uses the National Instructional Materials Access Center (NIMAC) as the repository for these files. NIMAS applies to all core materials in Mathematics, ELAR, SLAR, and Phonics for K–3.
Mathematics and STEM content must also incorporate MathML (Mathematical Markup Language), which encodes formulas and equations so that they can be interpreted by screen readers and braille displays. MathML compliance is aligned with WCAG Success Criterion 1.3.1 (“Info and Relationships”) and 4.1.2 (“Name, Role, Value”). Together, NIMAS and MathML form the technical infrastructure that ensures STEM and literacy materials can be rendered and read through assistive technology without altering meaning or structure.
Verification and Audit: How Compliance is Measured
The TEA EIR Accessibility Policy requires publishers to maintain a current VPAT (Voluntary Product Accessibility Template) or an Accessibility Conformance Report (ACR) issued by a credible third-party auditor. Audits must verify conformance to the WCAG 2.1 AA and Section 508 standards. Internal manual reviews are also expected to confirm that materials comply with the TEA Accessibility Checklist categories listed below.
TEA Accessibility Checklist Requirements
| Category | Core Requirement | Purpose in Instructional Use |
|---|---|---|
| Color and Contrast | Do not use color alone to convey meaning; contrast ≥ 4.5:1. | Supports readability for students with low vision or color blindness. |
| Headings and Structure | Use Heading 1 for titles; nest subheads properly; use Styles or Layouts. | Enables navigation by screen readers. |
| Images and Graphs | Provide concise alt text; mark decorative elements as null (alt=""). | Ensures contextual understanding of visuals. |
| Media | Caption video and audio; include transcripts; ensure keyboard accessibility. | Meets WCAG 1.2 and 2.1 operability criteria. |
| Tables | Use for data only; assign headers; avoid merged cells. | Preserves logical reading order for data sets. |
| Text Formatting | Use Sans-serif fonts; left-align; maintain readable spacing. | Improves legibility and text flow. |
| Links | Use descriptive phrasing; avoid raw URLs. | Enhances contextual comprehension. |
| Document Properties | Set Title and Language metadata in PDF and Office files. | Enables accurate translation and screen-reader recognition. |
| 3rd-Party Audit (ACR/VPAT) | Provide a certified WCAG 2.1 AA report. | Demonstrates verifiable compliance for state review. |
IMRA 2026 Accessibility Focus Areas
Accessibility requirements apply to all program types but manifest differently by discipline.
| Subject Area | Specific Accessibility Expectations |
|---|---|
| Mathematics K–12 / Advanced Math 6–8 | MathML markup for equations; table headers for data; keyboard navigation for interactive tools. |
| ELAR K–5 / SLAR K–5 | NIMAS-formatted XML source files; captioned read-alouds; proper language tagging (lang="es" for Spanish content). |
| Fine Arts | Alt text for visual art; contrast analysis for design content; captioning for music or video samples. |
| Career and Technical Education (CTE Batch 1) | Accessible forms; logical tab order; error identification on data inputs per WCAG 3.3. |
| Phonics K–3 (English and Spanish) | Audio examples paired with transcripts; clear phoneme-grapheme markup; captioned video demonstrations. |
| Supplemental Materials | Same WCAG 2.1 AA conformance as core materials; include vendor audit documentation. |
Accessibility Compliance Verification
| Requirement | Standard Reference | Verification Method | Applies To |
|---|---|---|---|
| Alt Text for Images | WCAG 1.1.1 | Manual review + screen reader test | All visual subjects |
| Captioned Videos | WCAG 1.2.2 & 1.2.3 | Closed-caption accuracy check | All digital media |
| Contrast ≥ 4.5:1 | WCAG 1.4.3 & 1.4.11 | Automated contrast testing | All content |
| Keyboard Navigation | WCAG 2.1.1 | Manual keyboard-only navigation test | Interactive modules and assessments |
| Language Identification | WCAG 3.1.2 | Metadata review | SLAR and Spanish Phonics |
| NIMAS File Provision | NIMAS 2006 / NIMAC requirement | XML submission audit | Core K–12 materials |
| MathML Encoding | WCAG 1.3.1 / 4.1.2 | Math expression validation | Math and STEM |
| 3rd-Party VPAT Audit | Section 508 / WCAG 2.1 AA | Auditor report submission | All vendors submitting digital materials |
State Contact and Reference Resources
| Resource | Description | Contact/Link |
|---|---|---|
| TEA Accessibility Coordinator | Responds to vendor inquiries and audit questions. | webadmin1@tea.texas.gov |
| Official technical standard (W3C Recommendation, May 2025). | w3.org/TR/WCAG21 | |
| NIMAC Submission Portal | Repository for NIMAS files required for adoption. | https://nimac.us/ |
Accessibility under Texas IMRA 2026 is defined by law, not interpretation. WCAG 2.1 AA, NIMAS, and MathML standards provide the framework for equitable access and technical compliance across all content areas. Publishers who design and verify materials according to these requirements strengthen their eligibility for adoption and ensure instructional materials can be used by every Texas student.
