New federal accessibility requirements under Title II of the Americans with Disabilities Act (ADA) establish a clear technical standard for websites and mobile applications provided by state and local governments.
Under the rule, web content and mobile applications must generally conform to the Web Content Accessibility Guidelines (WCAG) 2.1, Level AA. These standards are intended to ensure that people with disabilities can access online government information, programs, and services.
Compliance Deadlines
The U.S. Department of Justice has extended the compliance deadlines:
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April 26, 2027: Public entities serving a population of 50,000 or more
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April 26, 2028: Public entities serving fewer than 50,000 people and special district governments
What the Standards Cover
The requirements apply broadly to web content and mobile applications that a local government provides or makes available, including content managed by employees, contractors, or vendors. This may include:
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Municipal websites and webpages
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Online forms, applications, and payment systems
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Meeting agendas, minutes, notices, and other documents
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PDFs and Microsoft Office documents
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Images, graphics, audio, and video
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Mobile applications
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Third-party portals and services used to provide municipal programs
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Social media content
The rule contains limited exceptions for certain archived materials, preexisting conventional electronic documents, third-party posts, and individualized password-protected documents. Municipalities should review these exceptions carefully rather than assuming older or third-party content is automatically excluded.
What WCAG 2.1 Level AA means
WCAG organizes accessibility around four principles. Digital content must be:
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Perceivable: Information must be available in ways users can perceive, such as alternative text for meaningful images, captions for videos, readable color contrast, and content that works with screen readers.
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Operable: People must be able to navigate and use the content with a keyboard or assistive technology, without encountering keyboard traps or inaccessible controls.
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Understandable: Pages, instructions, links, navigation, and error messages must be clear and consistent.
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Robust: Content must be structured so that it works reliably with current and future browsers and assistive technologies.
Steps municipalities should take now
Municipalities do not need to fix everything at once, but they should begin developing a documented and sustainable accessibility program. Recommended first steps include:
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Identify who will lead the work. Designate an employee or team to coordinate digital accessibility efforts across departments.
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Inventory digital content and services. Identify websites, documents, forms, videos, mobile applications, social media accounts, and third-party platforms used by the municipality.
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Evaluate the current website. Use automated accessibility tools as an initial check, followed by manual keyboard and assistive-technology testing. Automated tools alone cannot identify every accessibility barrier.
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Prioritize essential services. Begin with frequently visited pages and services that affect public safety, utility payments, permits, employment, elections, meetings, and access to municipal programs.
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Remediate inaccessible content. Common improvements include adding alternative text, correcting heading structures, improving color contrast, labeling form fields, adding captions, making documents accessible, and ensuring keyboard navigation.
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Review vendor-provided services. Ask website, payment, permitting, agenda-management, and other technology vendors how their products conform to WCAG 2.1 Level AA. Include accessibility requirements in future contracts and procurement documents.
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Train employees who create content. Anyone who updates webpages, posts documents, creates forms, publishes videos, or manages social media should understand basic accessibility practices.
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Adopt an accessibility policy and process. Establish standards for creating, reviewing, publishing, and periodically testing digital content. Consider publishing an accessibility statement that explains how residents can report a problem or request assistance.
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Document your progress. Maintain records of inventories, evaluations, remediation work, training, vendor communications, and accessibility-related policies.
Accessibility should be treated as an ongoing responsibility, not simply a one-time website redesign. New webpages, documents, applications, and online services should be created accessibly from the beginning and reviewed regularly.
The League has compiled the following resources to help members understand the requirements and begin preparing:
Because each municipality’s website, services, and technology arrangements are different, members should consult their legal counsel and qualified accessibility professionals regarding specific compliance questions.