Yes. At Dalhousie, we have always said that it's a shared responsibility between faculty and administration, and while the university would be the named respondent if there was a court case, we have made it clear that that is a shared responsibility with faculty. Disciplinary proceedings are long and well-governed in a university, so it wouldn't by any means be grounds for dismissal but it would be an action with consequences.
We found that faculty are very interested in being in compliance and they ask instead of just going and putting something up. We did an audit of our learning management system before we left the Access Copyright licence with our university auditor leading it, and it was a clean audit. So people do want to comply.