ADA compliance checklist: Americans with Disabilities Act requirements for websites

The requirements of the Americans with Disabilities Act (ADA) apply to the digital world, not just physical spaces. Businesses of all sizes may face legal action under ADA Title III if their websites are inaccessible to people with disabilities. Additionally, a new rule under ADA Title II mandates WCAG 2.1 AA conformance for state and local government websites and mobile apps. 

Many organizations don’t realize that ADA requirements extend to websites until they face a complaint or lawsuit.

If your organization falls under Title II or Title III of the ADA, prioritizing digital accessibility is essential to avoiding legal, financial, and reputational risks. But what exactly does the ADA require when it comes to websites–and how can you meet your obligations?

In this blog, we’ll explore what the ADA says about digital accessibility, and provide a quick checklist you can use to start working toward compliance and providing a barrier-free web experience.

Key insights

• The ADA requires that a wide range of organizations–including businesses and state and local governments–provide services to people with disabilities on an equal basis with the general public.
• Title III of the ADA, which applies to “public accommodations,” has been interpreted by courts to include the websites of private businesses open to the public.
• The best way to demonstrate ADA compliance for websites is to conform to the Web Content Accessibility Guidelines (WCAG) 2.1 AA (at minimum). WCAG 2.1 Level AA is the benchmark for Title III compliance referenced by many courts.
• Under a 2024 DOJ rule, state and local governments serving populations of 50,000 or more must ensure their web and mobile content conforms with WCAG 2.1 AA by April 24, 2026.
• Plaintiffs filed 3,117 federal website accessibility lawsuits in 2025, up 27% from 2024.

The history of the ADA and digital accessibility

The ADA was enacted in 1990 as a civil rights law, prohibiting discrimination based on disability. Because the ADA was passed when the internet was still in its infancy, the original text of the law is primarily focused on accessibility in the physical world. However, the U.S. Department of Justice (DOJ) has taken the position that the ADA’s protections extend to websites and other digital services, and many federal and state courts have interpreted the law to apply to at least some digital spaces, although the case law is not fully uniform.

Specifically, the DOJ has issued official guidance that Title III of the ADA, which applies to places of public accommodation–like businesses open to the public–applies to websites, not just physical stores. Courts have widely upheld this interpretation.

In April 2024, the DOJ further clarified the ADA’s application to digital accessibility when it published a final rule under Title II, which applies to state and local governments. The rule requires all state and local government websites and mobile applications to conform to WCAG 2.1 Level AA. This covers public-facing websites, mobile apps, and other digital content used to deliver government services.

How does WCAG relate to ADA compliance?

The best way to demonstrate ADA compliance for websites is to conform with the Web Content Accessibility Guidelines (WCAG), the global standard for evaluating and creating accessible digital content. These guidelines provide specific technical accessibility criteria organized across four principles: Perceivable, Operable, Understandable, and Robust (POUR).

There are multiple versions of WCAG: 2.0, 2.1, and, most recently, 2.2. There are also multiple levels of conformance: Level A is the most basic level, Level AA is the intermediate level (targeted by most organizations), and Level AAA is the most advanced.

The DOJ’s 2024 Title II rule explicitly requires WCAG 2.1 Level AA conformance for the websites of state and local governments. For private businesses, courts have also referenced WCAG 2.1 as the de facto standard for Title III compliance in enforcement actions. Past DOJ cases show that WCAG is the dominant factor in rulings. In summary: For public entities, WCAG 2.1 AA is now legally required. For private businesses, it is the compliance benchmark agreed upon by many courts.

While WCAG 2.1 Level AA provides baseline compliance confidence, WCAG 2.2 AA is the recommended target for future-proofing. Compared to WCAG 2.1, this latest version adds nine new success criteria, including focus appearance requirements, minimum touch target sizes of 24×24 CSS pixels, accessible authentication, and drag-movement alternatives. In October 2025, WCAG 2.2 became ISO/IEC 40500:2025, the current global standard. Any website that conforms with WCAG 2.2 automatically satisfies WCAG 2.1.

The April 2026 compliance deadlines

The DOJ’s Title II rule establishes a two-tier deadline for state and local governments. Public entities serving populations of 50,000 or more (based on the 2020 Census) must achieve WCAG 2.1 AA compliance by April 24, 2027. Local governments serving fewer than 50,000 people, special district governments, and independent school districts have until April 26, 2028. The parent government determines the population count, so a small library in a county of 70,000 residents falls under the 2027 deadline.

The Department of Health and Human Services (HHS) imposes a similar deadline. Healthcare organizations that receive HHS funding and have 15 or more employees, including hospitals and clinics that accept Medicare or Medicaid, must meet WCAG 2.1 AA standards by May 11, 2026. Those with fewer than 15 employees have until May 10, 2027.

Beyond the ADA: Section 508 and state laws

The ADA is not the only piece of legislation that relates to online accessibility needs. Updates to Section 508 of the Rehabilitation Act in 1998 include information and communication technology, requiring U.S. federal government agencies to make all digital communications accessible. This is why all government agencies must provide accessible PDF documents upon request.

While Section 508 does not apply to commercial businesses, it shapes interactions between federal vendors and contractors and governmental agencies. Specifically, businesses selling digital products to the federal government will likely need to provide documented proof of digital accessibility–typically in the form of the Voluntary Product Accessibility Template (VPAT)–to meet government buyers’ procurement requirements.

Additionally, several states enforce additional ADA standards beyond federal requirements. California’s Unruh Civil Rights Act provides $4,000 in statutory damages per violation. New York requires state agency websites to conform to the most current version of WCAG. And Colorado mandates accessible digital communications for state and local governments with fines of $3,500 per violation per individual.

Is my business at risk of being sued if my website isn’t ADA compliant?

Complying with ADA regulations is essential to avoid legal exposure. Per Seyfarth Shaw, plaintiffs filed 3,117 website accessibility federal lawsuits in 2025, a 27% increase from 2024. Website cases now represent 36% of all ADA Title III federal filings.

No organization is immune. Plaintiffs sued Beyoncé’s Parkwood Entertainment because its website did not offer image alt text. Large research universities have faced lawsuits because their sites did not provide captions for video content.

If a lawsuit arises, businesses typically cover the plaintiff’s attorney fees, pay their own legal fees, and agree to specific website changes. The National Center on Disability and Access to Education found that one educational institution could have saved close to $600,000 had it made accessibility accommodations before being sued.

5 tips to start working toward ADA website compliance

The following five steps can help your organization start bringing your website into alignment with current ADA standards.

1. Obtain an accessibility audit: Engage an expert to audit your site for conformance with accessibility standards, like WCAG 2.0 AA, WCAG 2.1 AA, and WCAG 2.2. A thorough, reliable audit should include manual evaluation by an accessibility professional along with automated scans and testing by users with disabilities.
2. Fix issues in order of priority: Start by addressing issues in high-traffic locations, like your home page, and those with the most critical impact on users.
3. Gather feedback from users with disabilities: Ensure that your website includes a mechanism for users with disabilities to provide feedback about any issues that they encounter.
4. Continually monitor your site for new issues: Use monitoring tools to scan your site for issues at regular intervals, so that you can stay on top of potential issues as your website evolves.
5. Design and build new content with accessibility in mind: Prevent new issues from emerging by incorporating accessibility into your process for new content creation. Training designers, developers, and content creators about accessibility best practices can help everyone play their part in keeping your site compliant.

ADA compliance checklist: Quick tips for websites

As you create new digital content, use the following quick tips to avoid common WCAG violations that may expose you to risk.

1. Use sufficient color contrast: Provide strong color contrast between foreground content and background colors.
2. Ensure buttons have accessible names: Use accessible naming conventions for all website buttons, including ARIA labels where appropriate.
3. Use alt text: Provide clear, detailed descriptions for all non-decorative graphical website elements.
4. Offer accessible PDF files: Provide accessible PDF web files for users who rely on assistive technology. This is a requirement for compliance with both Section 508 and the ADA for applicable organizations.
5. Provide video captions and transcripts: Provide synchronized captions for all video content on your site, narrated and non-narrated, and include transcripts where possible.
6. Offer audio descriptions: Include audio descriptions for video content to provide an equitable experience for users who are blind or have low vision.
7. Simplify online forms: Online forms must be clearly labeled, simple to follow, and accessible via keyboard.
8. Choose accessible fonts: Use website fonts that are readable for all users, including those with dyslexia.
9. Avoid flashing imagery: Flashing images can cause adverse reactions, such as seizures, in some users.
10. Enable content zooming: Provide browser functionality that allows users to zoom to enlarge text and all site content.
11. Add skip navigation: Provide skip navigation links for website visitors who use screen readers and keyboard navigation, enabling them to reach primary content quickly.
12. Highlight important content: Use clear headlines and subheadings to delineate page content and convey its structure to all users.
13. Create descriptive links: Ensure all outbound links in your web content are easy to click and readable for site visitors and search engines.
14. Support keyboard navigation: Ensure all site elements can be navigated using a keyboard.

UserWay: Jump-start your journey to ADA compliance

Not ready to commit to an accessibility audit? UserWay offers one lightweight option for making immediate accessibility improvements. Our AI-Powered Accessibility Widget automatically remediates common WCAG violations while providing additional accessibility controls for end users. It supports all leading CMS platforms and plain HTML /CSS / JavaScript sites.

Automated tools like UserWay work best as part of a broader compliance program that includes manual audits, code-level remediation, and the proactive integration of accessibility into the software development life cycle. Automation alone does not satisfy ADA requirements.

Frequently asked questions

What does an ADA audit entail?

A qualified third party evaluates your website against WCAG requirements, identifies violations, and produces a written remediation plan. Audits should combine automated scanning with manual review, since automated tools cannot catch all WCAG failures.

Can accessibility consultants help with ADA compliance?

Yes. Accessibility consultants evaluate your website against ADA standards, identify compliance gaps, and provide practical remediation plans tailored to your organization.

Can a website achieve complete ADA compliance?

Achieving full ADA compliance is an ongoing process because websites change and requirements evolve. The right combination of tools, audits, and continuous monitoring keeps your site meeting WCAG 2.1 AA standards over time.

What is the deadline for ADA website compliance in 2027?

State and local governments serving populations of 50,000 or more must comply with WCAG 2.1 AA by April 24, 2027; smaller entities have until April 26, 2028.

What is the difference between WCAG 2.0, 2.1, and 2.2?

WCAG 2.1 AA is the standard required by the DOJ’s Title II rule and the one courts apply in private enforcement actions; WCAG 2.2 adds nine more criteria and is the recommended target for future-proofing. Compliance with WCAG 2.2 automatically satisfies WCAG 2.1.

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