This page guide provides an educational overview of the United States Department of Justice’s (DOJ) final rule on web and mobile accessibility for state and local government entities under Title II of the Americans with Disabilities Act (ADA). This rule establishes clear, enforceable standards to ensure individuals with disabilities can equally access public services, programs, and activities delivered online.
1. Applicability of the DOJ Rule
The rule applies to all state and local government entities, as well as organizations that provide digital services on behalf of these public entities through contractual, licensing, or other arrangements.
Entities Covered
- State agencies
- Counties, cities, townships, and municipalities
- Independent school districts
- Special district governments
- Any contractors or vendors providing public‑facing digital services (e.g., third‑party payment portals, scheduling apps)
Compliance Timeline
- April 24, 2026 — Entities with 50,000+ population must comply.
- April 26, 2027 — Entities with <50,000 population and special districts must comply.
These dates refer to when covered entities must ensure their digital content meets the required accessibility standards.
2. What the Rule Requires
The DOJ mandates that covered entities ensure all web content and mobile applications they provide or make available are accessible to individuals with disabilities.
Core Standard: WCAG 2.1 Level AA
The rule incorporates the Web Content Accessibility Guidelines (WCAG) 2.1, Level AA as the minimum technical standard. WCAG 2.1 addresses barriers experienced by people with:
- Vision disabilities (low vision, blindness)
- Hearing disabilities
- Cognitive or learning disabilities
- Mobility or manual dexterity impairments
Examples of required accessibility features
- Text alternatives for images
- Captioning and audio descriptions for video
- Keyboard navigation support
- Sufficient color contrast
- Logical heading and content structure
- Resize‑friendly text and responsive layouts
- Adjustable time limits (where applicable)
- Avoiding reliance on motion‑based device inputs
Mobile app requirements
Mobile applications must also follow WCAG 2.1 AA, including:
- Operability without device motion (e.g., shaking)
- Orientation flexibility (landscape/portrait)
- Adequate touch target size and spacing
3. Exceptions Under the Rule
Some content is exempt unless it is actively used for current services, as below:
- Archived web content created before compliance dates
- Pre‑existing conventional electronic documents (PDFs, Word files, presentations) not used for active transactions or applications
- Content posted by third parties, unless posted under contract or arrangement
- Password‑protected, individualized documents (e.g., account statements)
- Pre‑existing social media posts
Even when exceptions apply, entities must still provide accessible alternatives upon request.
4. How Organizations Can Comply
To prepare for compliance, organizations should:
A. Conduct accessibility audits
- Review websites, apps, and digital documents for WCAG 2.1 AA conformance
- Prioritize high‑impact public‑facing content
B. Implement accessibility governance
- Adopt digital accessibility policies
- Build accessibility checks into procurement processes
- Require vendors to meet WCAG 2.1 AA and include compliance language in contracts
C. Remediate and monitor
- Use automated and manual testing
- Involve assistive‑technology users when possible
- Maintain continuous monitoring for new content
D. Train staff
- Provide training for web teams, content creators, and leadership
- Establish an accessibility help desk or escalation channel
5. Additional State Resources
Several states offer publicly accessible guidance and tools to support digital accessibility best practices. Consider consulting the following resources to help identify efficiencies and methods to meet accessibility:
Colorado Office of Information Technology
Colorado provides extensive accessibility standards, tools, and training resources: Accessibility Program Home
Minnesota Office of Accessibility (Minnesota IT Services – MNIT)
Minnesota is a national leader in state digital accessibility standards: Accessibility Resources & Standards
Web Accessibility Standards & Evaluation Tools
These state programs and W3C resources offer practical checklists, testing tools, policy templates, and guidance that organizations can adapt for their own compliance efforts.
6. Compliance Checklist for DOJ Web Accessibility Rule
Below is a quick-reference checklist organizations can use to assess readiness:
A. Determine applicability
- Confirm whether your organization is a state/local government entity or contractor providing digital services for one
- Identify population size to determine your compliance deadline
B. Assess current digital assets
- Inventory all websites, subdomains, microsites, and portals
- Inventory all mobile applications
- Identify third‑party systems that deliver public‑facing services
C. Evaluate against WCAG 2.1 AA
- Conduct automated scans for accessibility errors
- Perform manual testing, including screen‑reader compatibility
- Verify compliance across key areas: text alternatives, captions, contrast, keyboard navigation, orientation flexibility, motion actuation controls, and form accessibility
D. Address exceptions
- Identify archived content and move it to clearly marked archive areas
- Determine whether any pre‑existing conventional electronic documents qualify for exceptions
- Confirm whether third‑party content is covered based on contractual arrangements
E. Implement governance & remediation
- Create and adopt a digital accessibility policy
- Integrate WCAG 2.1 AA requirements into procurement and vendor agreements
- Develop remediation timelines prioritizing high‑impact content
- Establish processes for ongoing monitoring and periodic audits
F. Train personnel
- Train content authors, designers, developers, and project managers
- Ensure staff understands accessibility basics and testing tools
G. Provide feedback channels
- Publish an accessibility statement
- Provide a mechanism for users to report accessibility issues
H. State resources for reference
