Quick Answer:
The ADA Coordinator should oversee Title II compliance, but they should not be expected to handle all the digital accessibility work alone. Content, IT, Legal, and Accessibility teams should each own the parts that fall within their responsibilities.When Is a Public Entity Required to Designate an ADA Coordinator?
A public entity must designate an ADA Coordinator when it has 50 or more employees. Under 28 CFR §35.107, the designated employee coordinates the entity’s Title II compliance efforts, handles accessibility complaints, and helps maintain the required grievance process and public contact information.
A few parts of this requirement are worth keeping in mind:
- The 50-employee threshold: Full-time and part-time employees across departments and sub-units count toward the threshold. Independent contractors do not.
- Someone must be designated: This person serves as the ADA Coordinator and helps coordinate the public entity’s Title II compliance efforts.
- The public needs their contact information: The ADA Coordinator’s name, office address, and telephone number must be made available to the public.
- A grievance procedure is required: The public entity must establish and publish a process for handling complaints related to Title II.
- The role is broader than website accessibility: The ADA Coordinator helps coordinate the organization’s overall Title II responsibilities. That does not automatically make them responsible for fixing website code, remediating PDFs, or testing mobile apps.
That last point is important.
The ADA Coordinator has a legal and compliance coordination role, not necessarily a technical one. They may be responsible for making sure the organization is addressing accessibility, but that does not mean they need to personally fix a website, remediate a PDF, or test a mobile application.
Why Isn't the ADA Coordinator Enough to Ensure Digital Accessibility?
The ADA Coordinator cannot realistically handle digital accessibility alone. Their role is to coordinate broader Title II compliance, respond to accessibility complaints, and manage the required grievance process. Digital accessibility, however, involves hands-on work across the organization, from fixing website code and testing applications to remediating PDFs and reviewing content before it is published.
The 2024 Title II rule makes this distinction especially important. Covered web content and mobile apps must meet WCAG 2.1 Level AA, subject to the rule’s limited exceptions. Meeting that standard requires people with different types of expertise.
For example:
- IT deals with websites, applications, code, testing, and technical fixes. The team can also review accessibility when evaluating technology vendors, including VPATs and ACRs.
- Marketing and Content are responsible for the material they publish, including web pages, PDFs, public notices, reports, and videos. This can include checking captions, transcripts, audio description, and alternative text.
- Accessibility specialists can provide regular testing, remediation guidance, and training where the organization has a dedicated accessibility function.
- Legal and the ADA Coordinator focus on the broader compliance picture, including complaints, grievance procedures, the public point of contact, and compliance risks.
The ADA Coordinator remains an important part of the process. The issue is that coordinating compliance and carrying out technical accessibility work are two different jobs.
How Should Digital Accessibility Responsibilities Be Divided?
Once the roles are separated, each part of the organization can take responsibility for the work it is best equipped to handle. The ADA Coordinator can keep the overall Title II effort connected, while the teams doing the actual digital work handle their respective areas.
| Function | What They Should Own |
|---|---|
| Legal / ADA Coordinator | Coordinates the broader Title II compliance effort, handles accessibility complaints and grievance procedures, maintains the public point of contact, and helps leadership understand compliance risks. |
| IT | Handles technical accessibility across websites and applications, including WCAG 2.1 Level AA requirements, development testing, technical remediation, and accessibility reviews of technology vendors. |
| Marketing / Content | Makes sure published material is accessible before it goes live. This includes web content, PDFs, public notices, reports, videos, captions, transcripts, audio descriptions, and other communications. |
| Accessibility team or specialist | Where one exists, handles regular testing, remediation guidance, training, and accessibility support across departments. This role can also help IT and Content teams interpret accessibility requirements. |
| Governance committee | Brings the different functions together, sets organization-wide policies, reviews legitimate exceptions, allocates resources, and keeps departments working toward the same standard. |
| Executive sponsor | Provides senior-level authority when there are disagreements or resource gaps and gives leadership a clear view of accessibility progress. |
The exact setup will depend on the size and structure of the public entity. A smaller organization may have one person covering several of these responsibilities. A larger organization may have separate teams for Legal, IT, Content, and Accessibility.
What matters is that the responsibilities are clear. Someone should know who checks a new PDF, who reviews a technology vendor, who handles an accessibility issue found during testing, and who steps in when a department cannot resolve a problem on its own.
That clarity is what turns accessibility from a general organizational goal into something teams can actually manage.
What Does a Title II-Specific Governance Framework Actually Look Like?
A Title II-specific governance framework for digital accessibility is the system a public entity uses to keep its accessibility work organized. It brings together the policies, people, standards, testing processes, and reporting needed to keep websites, mobile apps, documents, and other covered digital content aligned with WCAG 2.1 Level AA as the applicable compliance deadlines approach.
The framework does not need to be complicated. It needs to make three things clear: what standard the organization follows, who is responsible for each part of the work, and how accessibility issues are found and fixed.
The Core Components of Title II
- A clear policy and standard
Start by formally identifying ADA Title II and WCAG 2.1 Level AA in the organization’s accessibility policy. The policy should make it clear which digital content falls within the organization’s accessibility program and who is responsible for maintaining the standard.
- Know what you actually have
Before an organization can fix accessibility problems, it needs to know where those problems might exist. Keep an up-to-date inventory of websites, mobile apps, PDFs, third-party tools, and other digital properties that the public entity manages or publishes.
- Review vendors before buying
Accessibility should be considered when selecting new software, platforms, and digital services. Procurement teams can request accessibility documentation such as a VPAT or Accessibility Conformance Report and include accessibility requirements in vendor reviews.
- Give people clear responsibilities
Accessibility should not sit with one person while everyone else assumes someone else is handling it. Content creators, developers, IT, procurement, Legal, and Accessibility teams should each know what they are expected to review and maintain.
- Build testing into normal workflows
Accessibility checks should happen while content and technology are being created, not only after something has already gone live. Depending on the material, this can include automated checks, keyboard testing, screen reader testing, and manual review.
- Train the people doing the work
Staff who create or publish digital content need to understand the accessibility requirements that apply to their work. Regular training can help prevent the same problems from appearing in new documents, web pages, and other content.
- Make it easy to report problems
The public should have a clear and accessible way to report an accessibility barrier. Those reports should feed into the organization’s existing complaint and remediation process rather than being handled separately.
How Can Continual Engine Help Your Organization Meet ADA Title II Requirements?
Defining who owns accessibility is only the first step. The teams responsible for it still need to find inaccessible content, remediate it, test their work, and keep checking new material as it is published.
This is where Continual Engine’s PREP platform can help. It gives IT, Accessibility, and Content teams practical tools for handling document accessibility at scale, without having to build the entire process in-house.
- Find and fix document backlogs: PREP’s Accessibility Checker and Audit APIs can identify and evaluate PDFs already hosted across an organization’s website. Its AI-powered remediation tools can then help transform legacy PDFs and other conventional electronic documents into more accessible, WCAG-conformant formats.
- Reduce manual remediation work: PREP can automatically structure documents, add tags, and generate alternative text aligned with WCAG and PDF/UA standards. This can make it easier for Content teams to work through large collections of documents such as public notices, meeting minutes, budget reports, and forms.
- Test documents before publishing: PREP’s screen reader simulation lets staff preview how documents may be experienced when using screen reader software and catch accessibility issues before the material goes public. These practices are useful for people with visual impairments, individuals with visual and cognitive impairments, and anyone using screen reader software.
- Use HTML when it makes more sense: PREP’s PDF-to-HTML conversion can turn static PDFs into responsive, accessible HTML, giving public entities another option while longer-term document remediation is underway.
- Keep checking after remediation: Accessibility is ongoing. New documents are published, and existing files are updated. PREP’s checking, auditing, and reporting capabilities can help organizations continue monitoring accessibility rather than treating compliance as a one-time project.
- Choose how the work gets done: Organizations can use PREP as a self-service platform for internal teams or work with Continual Engine’s accessibility experts for outsourced remediation. Cloud, on-premise, and hybrid deployment options are available.
Ready to Tackle Your Accessibility Backlog?
See how Continual Engine can help your team identify, remediate, and manage accessible government documents at scale. [ Explore Continual Engine’s Accessible Municipality Solutions ]
Closing Thoughts
ADA Title II digital accessibility is not really a one-person job. The ADA Coordinator has an important role in coordinating broader compliance, but IT, Content, Accessibility, Legal, and leadership all have different parts to play. Defining those responsibilities now can make the path to the 2027 and 2028 deadlines much more manageable and prevent accessibility work from becoming a last-minute scramble.
Frequently Asked Questions ( FAQs)
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Does every government entity need an ADA Coordinator?
No. Under 28 CFR §35.107, public entities with 50 or more employees must designate at least one responsible employee to coordinate Title II compliance. Smaller public entities still have accessibility responsibilities under Title II, even though the specific ADA Coordinator requirement does not apply in the same way.
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Is the ADA Coordinator responsible for website accessibility specifically?
Not by themselves. The ADA Coordinator has a broader Title II compliance role. Website and mobile accessibility also requires technical work from IT and development teams, along with accessible content from Marketing and Content teams.
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What happens if we miss the 2027/2028 compliance deadline?
Missing the applicable deadline can create legal and compliance risks and leave accessibility barriers unresolved. It can also make the remediation process much more difficult if an organization waits until the deadline is close before addressing a large backlog.
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Can IT and Legal share ownership, or does the regulation require a single person?
They can share operational responsibility. The requirement to designate a responsible employee for Title II coordination does not mean that one person has to perform every accessibility task. IT, Legal, Content, Accessibility, and leadership can each have defined responsibilities.
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What technical standard applies, WCAG 2.1 or WCAG 2.2?
The 2024 Title II rule identifies WCAG 2.1 Level AA as the technical standard for covered web content and mobile applications. Organizations may also consider newer accessibility standards as part of their broader accessibility work, but WCAG 2.1 Level AA is the standard specified by the Title II rule.
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How does Title II governance differ from Title III private-sector accessibility obligations?
Title II applies to state and local government entities, while Title III applies to places of public accommodation operated by private entities. The two have different legal frameworks and requirements, so public entities should build their accessibility governance around their specific Title II obligations rather than simply adopting a private-sector model.
