Understanding the ADA Title II rule is one thing. Being operationally prepared for it is another.
If you are a state or local government entity, use this checklist to evaluate whether your digital systems are ready before the compliance deadlines.
For a broader overview of ADA requirements across sectors, read our ADA Compliance Checklist.
ADA Title II Digital Accessibility Compliance Checklist
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Governance & Accountability
Accessibility compliance starts with clear ownership and accountability across your organization.
- ☐ Appoint a designated Digital Accessibility Coordinator
- ☐ Establish a written accessibility policy aligned with WCAG 2.1 Level AA
- ☐ Define responsibilities across IT, content, design, and procurement teams
- ☐ Set a remediation roadmap ahead of the April 2026 / April 2027 deadlines
- ☐ Create a documented process for handling accessibility complaints
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Website WCAG 2.1 Level AA Compliance
Your public website must meet WCAG 2.1 Level AA standards under the updated DOJ rule.
- ☐ All meaningful images include descriptive alt text
- ☐ Proper heading hierarchy (H1–H6) is used consistently
- ☐ Color contrast meets required accessibility ratios
- ☐ Full keyboard navigation works across pages
- ☐ Forms include accessible labels and clear error messages
- ☐ Videos include accurate captions
- ☐ Visible focus indicators appear for interactive elements
- ☐ No inaccessible auto-playing media
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Mobile App Accessibility
If your agency provides a mobile app, it must also meet accessibility standards.
- ☐ Screen reader compatibility (VoiceOver, TalkBack)
- ☐ Proper labeling of buttons and navigation elements
- ☐ No gesture-only functionality
- ☐ Content reflows correctly when zoomed
- ☐ Error messages are programmatically announced
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PDF & Digital Document Accessibility
Digital documents are one of the most common compliance gaps under ADA Title II.
- ☐ PDFs are properly tagged
- ☐ Logical reading order is defined
- ☐ Tables include structured headers
- ☐ Images contain descriptive alt text
- ☐ Forms within PDFs are labeled and keyboard accessible
- ☐ Scanned documents are OCR-processed and remediated
If you manage large volumes of legacy documents, prioritize high-traffic public service documents first (applications, payment forms, voter information, healthcare guides, etc.).
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Third-Party & Vendor Compliance
Public entities remain responsible for accessibility, even when vendors build or host digital systems.
- ☐ Vendor contracts require WCAG 2.1 Level AA compliance
- ☐ VPATs are reviewed during procurement
- ☐ Payment portals, LMS platforms, and service systems meet accessibility standards
- ☐ Ongoing vendor accessibility monitoring is documented
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Exception Validation
The DOJ rule includes limited exceptions, but they must strictly qualify under defined conditions.
- ☐ Archived content meets all DOJ exemption requirements
- ☐ Pre-deadline documents are verified as eligible
- ☐ Password-protected personal documents meet exemption criteria
- ☐ No active public-facing service content is incorrectly classified as exempt
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Testing & Ongoing Monitoring
Accessibility compliance requires continuous monitoring, not a one-time fix.
- ☐ Automated accessibility audit completed
- ☐ Manual accessibility testing performed
- ☐ Screen reader testing conducted
- ☐ Issues prioritized based on public impact
- ☐ Ongoing monitoring plan established (quarterly reviews recommended)
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Accessibility Statement & Public Feedback
Publishing an accessibility statement improves transparency and reduces legal risk.
- ☐ Accessibility statement published on the website
- ☐ Clear method provided for reporting accessibility barriers
- ☐ Defined response timeline for complaints
- ☐ Documented remediation workflow in place
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Deadline Readiness Check
- ☐ Large public entities (serving 50,000+ population): Ready before April 24, 2026
- ☐ Smaller entities and special districts: Ready before April 26, 2027
- ☐ High-risk systems (benefits portals, payments, elections, healthcare platforms) remediated first
Quick Self-Assessment
If your organization cannot confidently check most of the items above, you likely need a structured accessibility remediation plan before the compliance deadline.
Taking action early helps reduce legal risk, operational disruption, and rushed remediation costs.
For detailed information on deadlines, scope, and legal updates, refer to our ADA Title II Requirements & Changes blog.
As the digital landscape continues to evolve, ensuring equal access to online content has become more important than ever. In this article, we present an insightful checklist that highlights the key principles and practical steps to make your website accessible to all users in accordance with the Americans with Disabilities Act (ADA). We will explore the realm of inclusive design and empower you to create an inclusive digital space that embraces diversity and eliminates barriers by adhering to an ADA compliance checklist.
Need Support with Large-Scale Digital Remediation?
Public entities often manage thousands of PDFs, legacy systems, and third-party platforms. A structured accessibility workflow, supported by AI-assisted remediation and expert quality checks, can significantly accelerate compliance efforts before the deadline.
