1. Understanding ADA Title II and Digital Accessibility
ADA Title II has long required state and local governments to provide equal access to programs, services, and activities. Recent regulatory updates have clarified how these obligations apply in digital environments, including the technologies used to deliver public services online. The updated ADA Title II regulation explicitly includes services, activities and programs provided through:
- Websites
- Mobile applications
- Digital documents
Title II requires public entities to ensure that people with disabilities have equal access to services, programs, and activities. The recent rule update provides clarity about the technical requirements for websites, mobile apps, and documents—namely, conformance with Web Content Accessibility Guidelines (WCAG) 2.1 Level AA, which must be maintained over time. Title II’s overall focus on equal access and nondiscrimination means that digital accessibility efforts must extend beyond technical compliance to deliver long-term, usable access for people with disabilities.
2. What Compliance Means Under ADA Title II
A practical path toward compliance under Title II should focus on functional access, not immediate perfection. The means organizations need an accessibility strategy that includes key expectations:
- Meet Web Content Accessibility Guideline (WCAG) 2.1 Level AA for all covered websites, mobile apps, and digital documents
- Prioritize access to essential services and high-impact user flows
- Provide equivalent access when full conformance is not feasible
- Evaluate vendor-supplied solutions for technical compliance and work with vendors to improve accessibility, or consider alternative options
There are two key deadlines approaching:
- April 24, 2026: Public entities serving 50,000+ people
- April 26, 2027: Smaller entities and special district governments
3. Getting Started: The ADA Title II Checklist
If your organization provides programs, services, or activities through websites, mobile applications, or digital content, you play a role in ensuring those experiences are accessible under ADA Title II. This checklist offers a practical, scannable guide to the core requirements and the foundational practices that support sustainable digital accessibility.
Organizational & Process Foundations
A strong accessibility program starts with a strong foundation. These steps help organizations build sustainable, repeatable processes that support long-term ADA Title II conformance.
- Make digital accessibility an executive priority
- Secure leadership support, accountability, and cross-functional ownership for Title II compliance efforts.
- Become familiar with the Title II digital accessibility requirements
- Ensure there is a shared understanding of what digital resources are covered by Title II, what is exempted, and what the requirements are.
- Create an inventory of digital resources covered by Title II
- Inventory all websites, mobile apps, and public documents to identify those that are subject to the Title II digital accessibility requirements.
- Prioritize digital assets based on impact and use
- Focus remediation efforts on assets that support critical services, receive high levels of use, or lack accessible alternatives.
- Assess current accessibility conformance
- Evaluate each resource against WCAG 2.1 A/AA standards using a combination of automated tools and expert manual review.
- Remediate resources
- Based on the assessment, remediate each resource to the greatest extent possible to bring it into conformance.
- Integrate accessibility into procurement
- Review and update procurement policies and processes to manage accessibility risk with third party technology purchases.
- Train teams with role-specific guidance
- Accessibility is most effective when it’s baked into processes early, and teams are well-trained. Designers, developers, content authors, product management, and QA teams all play a role.
- Establish ongoing monitoring and governance
- Implement a monitoring program to minimize accessibility regression as digital services continue to evolve.
Core ADA Title II Technical Requirements
These technical practices address the most common barriers that prevent people with disabilities from using public digital services. While not exhaustive, these requirements reflect the most common accessibility barriers and align with WCAG 2.1 Level A and AA success criteria.
- Provide text alternatives for meaningful images and icons
- Non-text content must include appropriate text alternatives, so screen reader users can understand the purpose or information.
- Caption videos and provide audio descriptions
- Captions and transcripts must provide an accurate text representation of all critical audio content and audio descriptions should provide a spoken description of visual events.
- Avoid flickering or flashing content and use animation with care
- Avoid any flickering or flashing content that may trigger seizures. Provide a way to pause, stop, or hide animated content.
- Use proper structure for headings, lists, and tables
- Semantic structure should identify headings, lists, and table markup to help users understand content hierarchy and relationships and to navigate efficiently.
- Use sufficient color contrast for text and interactive elements
- Text, icons, and interactive controls must have enough contrast so users with low vision can read and identify them without strain.
- Ensure keyboard navigation functionality
- All interactive elements, including menus, buttons, forms, dialogs, and custom components, must be operable using a keyboard alone.
- Use clear, descriptive page titles and link text
- Page titles should clearly describe the purpose of the page. Buttons and links should communicate what action it performs or where it directs users to.
- Maintain visible focus indicators for keyboard users
- Keyboard users must be able to see where focus is at all times through a clear focus indicator; focus order through interactive elements must be logical.
- Clearly label form fields and provide actionable error messages
- Form fields must have persistent labels that identify their purpose. Users should receive clear error messages that explain what went wrong and how to correct it.
- Do not rely on color alone to convey meaning
- Information, status, or instructions should never be communicated using color alone.
- Ensure custom components expose name, role, state and value to assistive technologies
- Custom user interface components must communicate their name, role, state, and value programmatically so assistive technologies can interpret and interact with them accurately.
4. Testing Your Digital Experiences for Real-World Accessibility
Under ADA Title II, accessibility is measured by whether people with disabilities can effectively access and use digital services, not whether individual pages meet technical requirements. Testing should focus on how real users experience your websites, applications, and digital workflows. Effective testing combines automation, assistive technology validation, and task-based evaluation to identify barriers that may prevent equal access to public services.
Start with automated scans
Automated tools can find many accessibility issues such as missing alt text, low color contrast, mislabeled form elements, and structural markup errors. While these tools can’t catch every error, they quickly provide accessibility data at scale. However, automation provides an incomplete picture of accessibility and cannot determine whether your digital services are usable by people with disabilities. Automated scanning tools should serve as a starting point for evaluating and monitoring accessibility and be paired with human-led evaluations.
Validate with assistive technology
Assistive technology-led testing, using industry-standard tools like JAWS®, ZoomText®, and Fusion®, help organizations understand accessibility from the user’s point of view. Testing with these tools goes beyond automation, uncovering usability errors such as confusing reading order, missing context, or illogical keyboard navigation.
Test user flows, not just individual pages
Accessibility isn’t experienced one page at a time. Users move through tasks—logging in, searching, submitting information, completing transactions. Testing entire workflows helps identify barriers that may not be obvious in isolation. Focus on whether users can:
- Understand where they are
- Navigate efficiently
- Complete actions without confusion
- Recover from errors
This approach aligns accessibility testing with the real-world use of public services.
When to consider an accessibility partner
Digital services evolve. Content changes, features are added, and platforms are updated. Under ADA Title II, organizations are responsible for monitoring accessibility and addressing issues as they arise to prevent regression and service disruption for users with disabilities.
5. Need more help?
Vispero’s Accessibility Managed Services provides government organizations with the support they need to achieve ADA Title II compliance with confidence. Our services go beyond automation, leveraging ARC—our centralized system for issue tracking, prioritization, and remediation—alongside our in-house digital accessibility expertise. The result is sustainable accessibility practices, streamlined workflows, and improvements that ensure residents maintain access to the essential services they need If you’re looking for a quick first step to assess your ADA Title II readiness, you can sign up for a free website accessibility scan, which will identify machine-detectable WCAG conformance issues on your website. It’s the easiest way to see how your content meets WCAG standards. If you are unsure of how to bring your digital assets into conformance with ADA Title II standards or how to interpret the individual requirements:
