Government & Public Entities
ADA Title II
Title II of the Americans with Disabilities Act covers state and local governments - cities, counties, courts, public schools, universities, libraries, and transit. In April 2024 the U.S. Department of Justice published a final rule setting a specific technical standard for web and mobile accessibility: WCAG 2.1 Level AA.
On April 20, 2026, DOJ published an Interim Final Rule that extended the compliance deadlines by one year:
Population ≥ 50,000
April 26, 2027
Larger cities, counties, and public entities
Population < 50,000 & special districts
April 26, 2028
Smaller entities and special district governments
- Applies to web content and mobile apps the entity provides, uses, or contracts for
- Entities with 50+ employees must designate a responsible ADA coordinator
- Free deadline tracker and resources at TitleII.org
Business & Private Sector
ADA Title III
Title III covers private businesses that are "places of public accommodation" - retailers, restaurants, hotels, banks, healthcare providers, and more. Courts have widely held that their websites must be accessible too. Unlike Title II, there is no single dated deadline; the obligation is ongoing and enforced largely through litigation.
- Over 4,600 ADA web accessibility lawsuits are filed in the U.S. each year
- WCAG 2.1 AA is the de facto benchmark courts and plaintiffs use
- A documented program - widget deployed, audit complete, statement published - is your strongest defense
The Technical Standard
WCAG 2.2
The Web Content Accessibility Guidelines (WCAG), published by the W3C, are the global standard for digital accessibility. They're organized around four principles - content must be Perceivable, Operable, Understandable, and Robust - with three conformance levels (A, AA, AAA). Level AA is the target nearly all laws reference.
WCAG 2.2 (October 2023) is the current version, adding criteria for focus appearance, dragging alternatives, and accessible authentication. ADA Title II currently references WCAG 2.1 AA; meeting 2.2 AA satisfies it and future-proofs your site.
- Perceivable: text alternatives, captions, contrast, reflow
- Operable: keyboard access, enough time, no seizure risks, navigation
- Understandable: readable, predictable, input assistance
- Robust: compatible with assistive technologies (valid ARIA)
U.S. Federal
Section 508
Section 508 of the Rehabilitation Act requires U.S. federal agencies - and many organizations that sell to or receive funding from them - to make their electronic and information technology accessible. The 2017 Revised 508 Standards adopt WCAG 2.0 Level AA as the baseline.
- Applies to federal agencies and many federal contractors and grantees
- Procurement often requires a VPAT (Voluntary Product Accessibility Template)
- AX4E generates VPAT and conformance documentation as part of consulting