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The ADA Title II Compliance Checklist

Every step your public entity needs to reach WCAG 2.1 AA compliance before the DOJ deadline. Check items off as you go - your progress saves automatically on this device. Switch modes to match your role.

April 26, 2027Entities serving 50,000+ people

April 26, 2028Smaller entities & special districts

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1. Know Your Deadline & Scope

Determine which deadline applies to you

Count the population your entity serves. 50,000 or more people means your deadline is April 26, 2027. Under 50,000, or a special district like a water or school district, means April 26, 2028.

Population is based on the most recent decennial Census for general-purpose governments; special district governments use the 2028 deadline regardless of size. Document the determination and the data source in your compliance file (28 CFR Part 35, as amended by the April 2026 Interim Final Rule).

Identify everything the rule covers

The rule covers your websites AND mobile apps, plus content you provide through third parties, like an online payment portal or recreation signup system run by a vendor.

Scope includes all web content and mobile apps the entity provides or makes available, including via contractual, licensing, or other arrangements. Vendor-hosted services (payment processors, agenda platforms, LMS, transit apps) are in scope. Map each property to an owner and a vendor contract.

Learn the limited exceptions

A few things are excepted, like old archived documents and content posted by outside parties, but the exceptions are narrow. Do not assume something is exempt without checking.

Exceptions: archived web content (meets all four regulatory criteria), preexisting conventional electronic documents not currently used to apply for or access services, third-party content not under contract, individualized password-protected documents, and preexisting social media posts. Each has qualifying conditions; document any exception you rely on.

Name an accessibility coordinator

Put one person in charge of this effort with the authority to get it done. Compliance projects without an owner stall.

Designate a program lead (entities with 50+ employees already require an ADA coordinator under 28 CFR 35.107). Give them budget authority, a reporting line to leadership, and a charter covering web, documents, and procurement.

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2. Inventory Your Digital Presence

List every website and subdomain

Write down every site your entity runs: the main site, the library, parks, courts, utilities. Departments often launch sites nobody tracks.

Enumerate domains and subdomains via DNS records, certificate transparency logs, and analytics properties. Include staging sites that are publicly reachable. Record CMS, hosting, and owner for each.

List mobile apps

Any app your entity offers to the public counts, including ones a vendor built and runs for you.

Inventory iOS/Android apps published under the entity's accounts and vendor apps provided on the entity's behalf. Note framework (native, React Native, web view) since it drives the testing approach.

Inventory documents the public uses

PDFs, forms, and spreadsheets people need to apply for or use your services must be accessible. Old archived ones may be excepted, but anything in active use is covered.

Crawl for PDF/DOCX/XLSX/PPTX assets; classify each as in-scope (used to apply for, access, or participate in services) or candidate for the preexisting-document exception. Prioritize forms, notices, and frequently downloaded files by traffic.

List third-party tools and embeds

Payment portals, meeting video platforms, calendars, chat widgets, maps. If you provide it to the public, you are responsible for it being accessible.

Catalog embedded and linked vendor services with contract references. Request a current ACR/VPAT (WCAG 2.1 AA) from each vendor and log gaps for remediation or contract action.

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3. Audit Against WCAG 2.1 AA

Run automated scans on every property

Automated scanners find common problems fast, like missing image descriptions and poor color contrast. They catch roughly a third of issues, so this is the start, not the finish.

Scan with axe-core or equivalent across representative templates and high-traffic URLs. Track issues by WCAG success criterion and severity. Automated coverage is roughly 30 to 40 percent of criteria; plan manual testing for the rest.

Test with a keyboard only

Unplug the mouse and try to use your site: navigate menus, fill forms, pay a bill. If you get stuck, so does anyone who cannot use a mouse.

Verify 2.1.1 (keyboard), 2.1.2 (no traps), 2.4.3 (focus order), 2.4.7 (focus visible). Pay attention to custom widgets, modals, and date pickers; confirm ARIA patterns follow the APG.

Test with a screen reader

Have someone use your key pages with a screen reader, the software blind users rely on. Critical journeys like paying a utility bill should be testable start to finish.

Test top user journeys with NVDA+Chrome and VoiceOver+Safari at minimum. Verify landmark structure, heading hierarchy, form labels and error association (3.3.1, 3.3.2), and live-region behavior.

Check multimedia

Videos need accurate captions. Recorded meetings, PSAs, and training videos all count.

Prerecorded video requires captions (1.2.2) and audio description (1.2.5); live video requires captions (1.2.4). Auto-captions must be corrected to be accurate.

Audit your priority documents

Check that your most-used PDFs and forms work with assistive technology, or replace them with accessible web forms, which is often easier.

Validate tagging, reading order, form field labels, and language settings (PDF/UA where feasible). Where remediation cost is high, convert documents to native HTML forms instead.

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4. Plan & Execute Remediation

Prioritize by impact

Fix the things people need most first: paying bills, applying for services, emergency information, meeting agendas. Perfection everywhere later; critical journeys now.

Rank by user impact × traffic × WCAG severity. Blockers on transactional flows outrank cosmetic issues site-wide. Maintain the backlog in your existing tracker with WCAG criterion tags.

Fix templates before pages

Most websites reuse the same header, menus, and layouts everywhere. Fixing those shared pieces fixes hundreds of pages at once.

Remediate shared components (nav, footer, form controls, modals) in the design system or theme first; component fixes propagate. Then sweep page-level content issues.

Set a realistic timeline with milestones

Work backward from your deadline and leave slack. A credible plan with dates is also your best evidence of good faith if anyone asks.

Define milestones: audit complete, critical journeys conformant, template conformance, document remediation, full WCAG 2.1 AA. Schedule re-testing after each milestone and before the deadline.

Verify fixes, do not assume them

After something is fixed, test it again the same way you found it. A surprising number of fixes do not actually fix the problem.

Close issues only on re-test (automated + manual for the affected criterion). Add regression checks to CI where possible, e.g. axe-core in the pipeline with a no-new-violations gate.

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5. Policies, Procurement & Vendors

Adopt a written accessibility policy

Put it in writing: your entity commits to WCAG 2.1 AA, who is responsible, and how the public can report problems.

Policy should reference the technical standard (WCAG 2.1 AA), assign roles, define content-publishing requirements, and establish a feedback and remediation SLA. Have counsel review against 28 CFR Part 35.

Bake accessibility into purchasing

Every new website, app, or software purchase should require accessibility before signing. It is far cheaper to demand it up front than to retrofit later.

Add WCAG 2.1 AA conformance language, ACR/VPAT submission, and remediation obligations to RFPs and contracts. Include acceptance testing with accessibility criteria before final payment.

Hold current vendors accountable

Ask your existing vendors for their accessibility status in writing and get fix commitments with dates. Their product, your legal responsibility.

Issue VPAT requests to all in-scope vendors; track responses, gaps, and committed remediation dates. Where a vendor cannot conform, document the equivalent facilitation or replacement plan.

Publish an accessibility statement with a contact path

A public page that says what you are doing and gives people an easy way to report barriers and request help. Respond when they do.

Statement should cite the standard, known limitations, and a monitored contact channel. Log and triage reports; barrier reports are both a legal-risk signal and a free audit.

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6. Train Your Team

Train content publishers

Everyone who posts to your site needs the basics: descriptive link text, image descriptions, proper headings, accessible documents. Otherwise new content recreates old problems.

Role-based training for CMS authors: alt text, heading semantics, link purpose, table markup, accessible document export. Enforce with CMS-level checks where the platform supports them.

Train developers and designers

Your technical staff or web vendor should know how to build accessibly from the start, not patch afterward.

Cover semantic HTML, ARIA only where needed, focus management, color contrast tokens, and testing tools. Add accessibility acceptance criteria to the definition of done.

Make it recurring, not one-time

Staff turn over and standards evolve. Put refresher training on the calendar annually and include accessibility in onboarding.

Annual refreshers plus onboarding modules; track completion. Update materials when standards or platforms change.

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7. Document, Monitor & Maintain

Keep a compliance file

Save your audits, plans, fix records, training logs, and vendor letters in one place. If a complaint ever comes, this file is your defense.

Maintain dated records: audit reports, remediation tickets and re-test evidence, policies, training completion, vendor ACRs, and exception determinations. Version everything.

Monitor continuously

Websites change weekly, so compliance is not a one-time project. Set up regular scans and periodic manual checks so new problems get caught early.

Schedule automated scans (weekly or per-deploy) with alerting on regressions, plus periodic manual audits of critical journeys, at least annually and after major releases.

Re-verify before your deadline

A few months before your date, do a full top-to-bottom check so there is time to fix whatever surfaces.

Run a full conformance evaluation (e.g. WCAG-EM methodology) 3 to 6 months pre-deadline; remediate findings and retain the final report as your conformance baseline.

Plan for what comes after

Budget for accessibility as an ongoing operating cost, like security. The deadline is the start of compliance, not the end.

Line-item ongoing monitoring, training, and remediation capacity in the annual budget. Reassess scope when launching new sites, apps, or vendor services.

Your readiness score

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Check items off above to track where your entity stands. Your progress saves on this device, so you can come back anytime.

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This checklist is educational and not legal advice. Deadlines reflect the DOJ Interim Final Rule published April 2026. Provided free by AX4E · Access for Everyone.